Environmental Impact Assessment Scoping Report

Environmental Impact Assessment Scoping Report Stadium for Bath July 2019

Contents 1.

Introduction

2.

Approach to EIA

13

3.

Description of Site and Surrounding Area

23

4.

Description of the Proposed Scheme

26

5.

Landscape and Visual Amenity (including Arboricultural considerations)

27

6.

Built Heritage

31

7.

Archaeology

40

8.

Ecology and Nature Conservation

45

9.

Hydrology, Flood Risk and Surface Water Drainage

48

10.

Hydrogeology and Hot Springs

52

11.

Traffic and Access

54

12.

Socio-economics and human health

59

13.

Air Quality

65

14.

Noise and Vibration

68

15.

Ground Conditions, Soils and Contaminates Land

69

16.

Lighting and Light Pollution

72

17.

Waste

74

18.

Climate Change

75

19.

Methodology for Assessment of Cumulative Effects

81

20.

Conclusion

85

Tim Burden tim.burden@turley.co.uk Client Arena 1865 Limited Our reference ARER3004 July 2019

4

Appendices Appendix 1: EIA study boundary Appendix 2: Previous BANES Scoping response dated 25th October 2013 Appendix 3: Proposed Landscape and Visual Impact Assessment Representative Viewpoints (May 2019) Appendix 4: LVIA Baseline Summary Appendix 5: Heritage Asset Plan Appendix 6: Zones of Theoretical Visibility (ZTV) Appendix 7: Potential sensitive designated heritage assets

Tim Burden tim.burden@turley.co.uk Client Arena 1865 Limited Our reference ARER3004 July 2019

1. Introduction 1.1

Arena 1865 (‘the applicant’) is preparing proposals to redevelop its existing stadium at the Bath Recreation Ground (‘the Rec’) and the intention is to submit a formal planning application (including application for planning permission for relevant demolition in a conservation area and a listed building consent application relating to works to North Parade Bridge) later in 2019 for the ‘Stadium for Bath’ project. The Stadium for Bath project group comprises the three founding members who will deliver the project: Bath Rugby, Bath Rugby Foundation and Arena 1865.

1.2

The existing Bath Rugby ground lies within the wider Bath Recreation Ground, adjacent to the River Avon and Bath city centre, within the City of Bath World Heritage Site. The location of the site, hereafter referred to as the ‘Site’, is shown in the EIA Scoping Study Area plan found at Appendix 1.

1.3

A planning application is being prepared which will propose that the existing rugby stadium, which currently has a capacity of approximately 14,500 attendees (comprising in part of a variety of temporary facilities), is turned into a modern ‘world class’ arena including a range of complementary uses. This is in order to sustain Bath Rugby at its historic home ground in Bath city centre, whilst also providing a City-wide facility for other sporting, community, leisure and cultural activities, and realising the Council’s ambitions for this area.

Planning Policy Summary 1.4

The adopted Development Plan facilitates the provision of a new stadium at the Rec. The Core Strategy (adopted July 2014) at Policy B1(b) (Bath Spatial Strategy) states that: “b At the Rec, and subject to the resolution of any unique legal issues and constraints, enable the development of a sporting, cultural and leisure stadium.”

1.5

In July 2017, the Council subsequently adopted the Placemaking Plan (the ‘PMP’).

Policy SB2 (Central Riverside and Rec) sets out a Vision for the Rec and the surrounding area (as identified on extracted Diagram 5 below) and notes that there are a number of interrelated projects that have enormous potential to re-energise and re-define the important role and function that this area can play as a recreational heart to the city.

1.6

The Placemaking Plan sets out a Vision for this area that can comprise of: •

"A 21st century re-interpretation of the historic ‘pleasure garden’ of Harrison’s Walks (now Parade Gardens);

•

An inspirational setting for the development of a new sporting, cultural and leisure stadium that safeguards the valued assets and attributes of the World Heritage Site, including key views;

•

The provision of an enhanced green infrastructure throughout the area, including improvements to the important biodiversity role of the river and the riverside;

4

•

Potentially, an enhanced role as a point of access into the central area. As part of this, it identifies that there are significant opportunities to transform the visual and physical connectivity of this area to its surroundings and these will be strongly encouraged provided they protect and enhance the Outstanding Universal Value of the World Heritage Site. Specific measures include: ‒

Improving the connections from the streets and spaces of Terrace Walk, Orange Grove and Grand Parade, including the Colonnades into Parade Gardens and to the riverside;

‒

Transforming the existing links from Pulteney Bridge and North Parade Bridge to a remodelled riverside path on the east side. Policy SB2 splits this area into sub-areas and identifies specific policy requirements under an area entitled “Riverside East (The Rec, including Bath Rugby Club, Bath Sports and Leisure Centre, the Pavilion, and other associated areas)”.

Proposed Scheme 1.7

The project team have developed a description of the ‘Proposed Scheme’ (referred to as ‘Stadium for Bath’), which is outlined in full within Chapter 4 of this EIA Scoping Report.

Whilst the Proposed Scheme continues to be refined and the development principles agreed, this description aims to provide factual and sufficient information to inform the EIA Scoping process and the preparation of this EIA Scoping Report.

1.8

The Proposed Scheme, in summary, is for the demolition / removal of a number of existing structures / buildings at the site, and the erection of a multi-purpose sporting and cultural recreational facility with a capacity of approximately 18,000 spectators. The proposals will also include improvements to, and additional, public realm, including hard and soft landscaping works and tree planting. An under-pitch car park with approximately 680 spaces, including accessible spaces, cycle and motorcycle parking will also be provided.

5

1.9

Retail, conference, restaurant and related uses are proposed within the west stand on the riverside promenade, as well as public WC, baby change, and ‘changing places’ facilities.

1.10

The east stand is to include facilities including stadium offices, changing rooms and match day boxes. The boxes are also to be multi-use community spaces, for use as community, charity and classroom spaces.

1.11

The proposals include the creation of a new vehicular and pedestrian access from the proposed car park onto North Parade Road, which includes the demolition and reinstatement of the eastern elevation of Bath Pavilion. A new pedestrian bridge from North Parade Bridge to the riverside is proposed. The works relating to the new bridge will likely require their own Listed Building Consent application as they involve works to a listed structure.

1.12

The proposals also include the removal of the existing radial gate and platform structure, and its replacement with a three tier stage weir, comprising of a linear weir situated perpendicularly across the channel and the construction of a new eel pass alongside the weir if required. For clarity, the radial gate proposals may take the form of a separate full planning application, or be incorporated within the same application as the stadium proposals. However, the Environmental Statement will assess the radial gate proposals alongside the stadium proposals (and other works), in order to enable the assessment of those proposals holistically.

1.13

This Environmental Impact Assessment (‘EIA’) Scoping Report is therefore based on the EIA Scoping Study Area Boundary, found at Appendix 1 which identifies the extent of the site. At this stage the boundary is considered to be the maximum extent of all temporary and permanent works required as part of the Proposed Scheme.

1.14

In accordance with Regulation 15 of the Town and Country Planning (Environmental Impact Assessment) EIA Regulations, 2017, (hereafter referred to as the ‘EIA Regulations’), Turley request a Scoping Opinion from Bath and North East Somerset Council (‘the Council’), informed by this EIA Scoping Report.

1.15

The planning application will be submitted to the Council pursuant to the requirements of the Town and Country Planning Act 1990 (“TCPA 1990”).

Definition of EIA 1.16

The term ‘EIA’ describes a procedure that must be followed for certain types of project before they can be given 'development consent'. The procedure is a means of drawing together, in a systematic way, an assessment of a project's likely significant environmental effects. This helps to ensure that the importance of the predicted effects and the scope for reducing them are properly understood by the public and the relevant local planning authority before it makes its decision. The aim of EIA is to: ‘protect the environment by ensuring that a local planning authority when deciding to grant planning permission for a project, which is likely to have significant effects on the environment, does so in the full knowledge of the likely significant effects, and takes this into account in the decision making process…. The aim is also to

6

ensure that the public are given early and effective opportunities to participate in the decision making procedures’.1

Requirement for EIA 1.17

When EIA is required for a project, the EIA process requires that an Environmental Statement (‘ES’) is prepared and submitted to accompany any planning application, there is public consultation on the ES, and that the local planning authority must take account of the ES and any representations on it when making their decision on approval of the planning application. The ES must include sufficient information on the development proposals, the main alternatives that have been considered, the likely main or significant environmental effects of the proposals, the measures proposed to mitigate significant effects, and a non-technical summary.

1.18

The Proposed Scheme is of a type listed in Schedule 2 to the EIA Regulations (under part 10b of Schedule 2 ‘Infrastructure Projects - Urban Development Project’ which include sports stadia) and the site is located within the City of Bath World Heritage Site, a ‘sensitive area’ in the EIA Regulations, where exclusive thresholds (below which EIA cannot be required), do not apply.

1.19

Given previous correspondence with the Council as Local Planning Authority regarding an earlier proposed scheme (which was not taken forward), including the issuing of a previous Screening and Scoping Opinion dated 25th October 2013 (enclosed at Appendix 2), it is not considered that there is a requirement for an EIA Screening Opinion under Regulation 5 of the EIA Regulations, as it is considered that an ES will be required for the proposals.

1.20

Due to the nature, size, location and the likelihood of the Proposed Scheme giving rise to some significant effects on the environment, the Applicant has elected to voluntarily undertake an Environmental Impact Assessment (“EIA”). Accordingly a screening request has not been submitted to the Council and instead the scheme has proceeded to the scoping stage.

1.21

The results of the EIA will be reported in an Environmental Statement (“ES”) which will be submitted as part of the planning application.

1.22

This document comprises a request for the Council to adopt an Environmental Statement Scoping Opinion (“ESSO”) as to information to be provided within the ES. This request is made pursuant to the provisions of Section 15 of the EIA Regulations 2017. It is accompanied by: (a)

A plan sufficient to identify the land;

(b)

A brief description of the nature and purpose of the development, including its location and technical capacity;

1

https://www.gov.uk/guidance/environmental-impact-assessment#the-purpose-ofenvironmental-impact-assessment

7

1.23

(c)

An explanation of the likely significant effects of the development on the environment; and

(d)

Such other information or representations as the person making the request may wish to provide or make.

An important part of the EIA process is deciding on the scope of the work for the EIA and ES – the ‘EIA scoping’ process. This includes: •

how the proposed development will be described;

•

the scope of the alternatives considered and the reasons for their rejection;

•

the range of potential environmental impacts to be studied;

•

the extent to which each potential impact is investigated;

•

how potential impacts will be assessed and reported; and

•

how measures to avoid, reduce or remedy (mitigate) potentially significant effects will be considered.

1.24

The EIA Regulations allow applicants to request a ‘Scoping Opinion’ from local planning authorities under Regulation 15. A Scoping Opinion is the local planning authority’s opinion on the necessary scope of the EIA, and is subject to consultation with statutory bodies with environmental responsibilities (including the Environment Agency, Natural England, Historic England and in some cases others).

1.25

This Scoping Report addresses the above issues and should enable the Council to consult on and issue its Scoping Opinion.

8

Structure of EIA Scoping Report 1.26

The EIA Scoping Report will be structured as outlined in Table 1.1 below.

Table 1.1: Chapt.

No.

Structure of EIA Scoping Report

Topic

Description

1

Introduction

Outlines the context in which Turley request a Scoping Opinion, provides an overview of the Proposed Scheme and details on the structure of the EIA Scoping Report along with the definition and requirement for EIA

2

Approach to EIA

Establishes the approach undertaken to date and the forthcoming actions in order to align with the EIA Regulations. Outlines the environmental topics which we consider are insignificant at this stage and will not form part of the EIA and

3

Description of the Site and Surrounding Area

Provides a description of the Site and the surrounding environment, which represents the baseline conditions

4

Description of the Proposed Scheme

5 - 19 Environmental Topics

20

Outlines the high level specification of the Proposed Scheme based on the information available and considered sufficient to inform this EIA Scoping Report The environmental topics which we consider are potentially significant at this stage, albeit we have identified a number of insignificant effects within these environmental topics

Impact Interactions and Outlines the proposed methodology for the Cumulative Effects assessment of cumulative, comprising both effect interactions and in-combination effects

21

1.27

Residual Impacts and Conclusions

Provides a tabular summary of the insignificant and likely significant effects at this stage

Chapters 5-19 generally follow the structure set out below: •

Introduction

•

Scope and Methodology ‒

•

Including section on Legislation and Planning Policy Framework

Baseline Conditions

9

•

Impact Assessment ‒

Identification of potential effects

‒

Impacts during construction phase

‒

Impacts during rugby season, including on match days and on non-match days

‒

Impacts outside rugby season, and including on non-match days

‒

Significance of impacts

•

Mitigation Measures

•

Summary

Stakeholder Engagement 1.28

Consultation is an important part of the EIA process and the ‘Exploring the Opportunity’2 (November 2017) document notes the wide ranging consultation that occurred with stakeholders throughout 2017. Subsequently, in April 2018 a draft Development Brief3 was published for consultation. The final version of this document will be submitted to the Council imminently, taking into account comments received.

1.29

In order to inform the public of the proposals for the site, public exhibitions were held at the site in July 2018 and December 2018, with a further event envisaged (dates to be confirmed). The public and other stakeholders were able to comment on the emerging plans and members of the project team were on hand to answer questions and provide further clarification on the information provided. Feedback from these events will be used in the EIA process to inform the environmental impact studies being undertaken.

1.30

Discussions with a range of stakeholder continued throughout 2018 and into 2019, and will continue as the project is refined. Additional technical consultations are underway for the project as a whole and for the purposes of the EIA, and will be reported in the ES.

1.31

A Statement of Community Engagement will be prepared and submitted with the planning application, to set out the results of consultation with the community and how comments have been taken account in the proposals.

1.32

On receipt of this Scoping Report, the Council will consult with statutory consultees, their own internal officers and potentially a number of other organisations, on this Scoping Report in order to provide a robust Scoping Opinion.

1.33

The following are considered statutory consultees for the purposes of EIA:

2

https://www.stadiumforbath.com/stadium-for-bath-opportunity-for-redevelopment-revealed-2/

3

https://www.stadiumforbath.com/draft-development-brief/

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1.34

•

the Environment Agency;

•

Natural England;

•

Sport England; and

•

Historic England.

A number of other consultees will also be consulted by the Council on the Scoping Report, and by the applicants/report authors. The organisations to be consulted directly on the Scoping Report will be identified in consultation with the Council, and may include: •

International Council on Monuments and Sites (ICOMOS) / ICOMOS-UK

•

Bath Recreation Limited

•

Federation of Bath Residents Associations

•

Pulteney Estates Residents Association

•

Bath Preservation Trust

•

Bath Heritage Watchdog

•

The River Regeneration Trust

•

Avon Wildlife Trust

•

Canal and River Trust

•

Bristol Avon Rivers Trust

•

Georgian Society

•

National Trust

1.35

The Scoping Opinion and comments received from Council officers and consultees will be taken into account in the EIA and in preparing the ES. The ES will summarise the comments received and describe how the feedback influenced the scope of the EIA and ES. When submitted, the ES will be publicised by the Council and subject to consultation with the above organisations, other notified parties, and the public.

1.36

Due to the likely high level of interest in the Stadium for Bath proposals and their potential environmental effects, as well as the Applicant's desire to ensure that this document is widely available for comments, this Scoping Report will also be circulated to other organisations (to be identified in consultation with the Council) and made available for public comment. It will be published on the stadiumforbath.com website.

1.37

In accordance with the EIA Regulations, the Council have a 5 week period to consider this report and adopt a formal Scoping Opinion.

11

EIA Team 1.38

This EIA Scoping Report has been prepared by Turley (IEMA EIA Quality Mark Registrants), on behalf of the Applicant with the assistance and contributions from the following team: •

J4 Projects (Project Managers);

•

Grimshaw (Lead architects);

•

Gross Max (Landscape Architect);

•

IMA Transport Planning (transport and access);

•

Turley (Planning, EIA, Built Heritage, retail and socio-economic);

•

Kim Watkins and Wessex Archaeology (Archaeology);

•

Nicholas Pearson Associates (Landscape and Visual Amenity);

•

AW Water Engineering (Flood Risk);

•

Arup (Engineers, Air Quality, Hydrology, Hydrogeology and Hot Springs, Ground Conditions, Soils and Contaminated Land and Surface Water);

•

Blackdown Environmental (Arboricultural, Ecology and Nature Conservation);

•

Carbon Consult (Waste);

•

Vanguardia (Air quality);

•

Entran (Noise and vibration);

•

WYG (Lighting and light pollution); and

•

Carbon Consult/3Adapt/LUC (Climate change).

Decommissioning 1.39

This development is proposed to be operational in excess of 100 years and thereafter will comprise developed land in perpetuity; therefore, we do not propose that the ES will address decommissioning.

12

2. Approach to EIA 2.1

This section outlines the objectives of the EIA Scoping Report; the boundaries and time periods for data collection; approaches to iterative Scoping and alternatives; the information which will inform and the structure of the Environmental Statement (‘ES’) (including its interaction with other documents to be submitted with the planning application); assurance of technical quality; and competence and application of best practice.

EIA Scoping Report Objectives 2.2

This EIA Scoping Report supports a formal request for a Scoping Opinion from the Council as to the scope and methodology for assessment to be adopted in the ES. It aims to ensure that there is a clear and agreed scope for the EIA including all of the relevant baseline studies that will be required to ensure a robust assessment of likely significant effects.

2.3

In accordance with Regulation 15(2) of the EIA Regulations, this report contains the following: •

A plan sufficient to identify the land (Appendix 1 - EIA Scoping Study Area);

•

A description of the Proposed Scheme, including its nature, purpose, location and technical capacity (Chapter 4 – The Proposed Scheme). This includes an overview of the site preparations; development principles; any primary mitigation and timescales;

•

An explanation of the likely significant effects of the development on the environment (Chapters 5-19); and

•

Such other information or representations as the person making the request may wish to provide or make.

Adopting Best Practice 2.4

Schedule 4, Part 7 of the EIA Regulations states that an ES should include: ‘a description of the measures envisaged to avoid, prevent, reduce or, if possible, offset any identified significant adverse effects on the environment and, where appropriate, of any proposed monitoring arrangements (for example the preparation of a post-project analysis). That description should explain the extent, to which significant adverse effects on the environment are avoided, prevented, reduced or offset, and should cover both the construction and operational phases’.

2.5

IEMA has issued guidance on the interaction of design and EIA as part of ‘Shaping Quality Development’ which was published in November, 2015. The principles of this document have been adopted for the project.

13

2.6

As we progress through the EIA process, there will be different types of mitigation developed and these are worth defining at the outset: •

Primary mitigation – modifications to the location or design of the Proposed Scheme made during the pre-application phase that are an inherent part of the project;

•

Secondary mitigation – actions that will require further activity in order to achieve the anticipated outcome. These would be included within the ES and secured by condition; and

•

Tertiary mitigation – actions that would occur with or without input from the EIA feeding into the design process. These include actions that will be undertaken to meet other existing legislative requirements, or actions that are considered to be standard practices used to manage commonly occurring environmental effects.

2.7

The design process will be informed by baseline surveys and desktop reviews so that effects are well understood and primary and tertiary mitigation developed.

2.8

Examples of primary mitigation measures may include proposed ground levels, hedgerow retention, agreed landscape design / planting, surface water management strategy or biodiversity enhancements. Examples of tertiary mitigation measures may include an Environmental Management Plan (‘EMP’) or adherence to the Considerate Contractors Scheme.

2.9

In the context of this project, we would aim to identify all primary and tertiary mitigation as part of the design process and in advance of the assessments within the ES as this will ensure the ES remains proportionate.

2.10

The assessment of effects of the Proposed Scheme will be based on the information contained within a ‘Description of the Proposed Scheme’ or referred to as a ‘development specification’.

2.11

Following the conclusion of the effects based on the Proposed Scheme, any further mitigation (secondary) will further reduce a negative effect or enhance a positive one.

Study Boundaries for Data Collection 2.12

The boundary upon which the data is collected is as Appendix 1 – EIA Scoping Study Area. This is not necessarily the boundary upon which the EIA will be based but is considered the maximum extent of the Site including all permanent and temporary works (including primary mitigation) as outlined in Schedule 4 of the EIA Regulations.

2.13

Should this boundary extend there may be insufficient information upon which to base the EIA. Therefore, it is important to set the maximum extent at this stage.

2.14

It is unknown at this stage whether any specific off-site improvements/mitigation will be required. These types of improvements/mitigation will be considered as secondary mitigation and appropriately assessed within the residual effects assessments within the EIA. It is considered appropriate that secondary mitigation does not need to be 14

within the boundary because any impact will be assessed and controlled as part of the approval process for these works.

Interaction between Design and EIA 2.15

A range of technical surveys and desk studies have been undertaken and supplementary/new surveys and desk studies are planned or/underway, as outlined in Chapters 5-19.

2.16

The EIA process will demonstrate how technical surveys, desk studies and design advice have influenced the design parameters upon which the EIA will be based.

2.17

By following this process, and where possible, the EIA will demonstrate the resolution and minimisation of environmental effects during design. This should ensure the ES focuses only on likely significant environmental effects and complies with the need to provide ‘a description of the measures envisaged to prevent, reduce and where possible offset any significant adverse effects on the environment’.

Consideration of Climate Change 2.18

The EIA Regulations set out a requirement to assess the likely significant climate change effects on, and as a result of, the Proposed Scheme. This EIA Scoping Report sets out the current high level description of the Proposed Scheme. As the design of the Proposed Scheme continues, the ES will consider the impact of the Proposed Scheme on climate (for example the nature and magnitude of Greenhouse Gas emissions) (‘GHG Assessment’) and the vulnerability of the Proposed Scheme to climate change (‘Climate Change Adaptation’). The scope is considered within Chapter 18 – Climate Change.

An Iterative Approach to Scoping 2.19

Whilst this EIA Scoping Report seeks to establish the overall framework for the EIA in relation to the environmental topics and associated likely significant effects, iterative re-scoping will continue as the design and strategy is refined, and the parameter plans, design principles and development specification evolve.

2.20

This iterative ‘re-scoping’ process will continue up until the point when the assessments within the ES are in their first draft, although this will be well in advance of planning application submission.

2.21

Any deviation between the scope of effects considered within the EIA Scoping Report and the ES will be clearly communicated with the Council and there may be a requirement for further, subsequent responses from the Council

2.22

It is the Council Scoping Opinion and subsequent responses which collectively are considered the Scoping Opinion upon which the ES will be based. This will ensure that the specific requirements of the EIA Regulations are met.

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Approach to Alternatives 2.23

Paragraph 2, Schedule 4, of the EIA Regulations states that an ES should include: ‘a description of the reasonable alternatives (for example in terms of development design, technology, location, size and scale) studied by the developer, which are relevant to the proposed project and its specific characteristics, and an indication of the main reasons for selecting the chosen option, including a comparison of the environmental effects’.

2.24

The EIA process provides an opportunity to influence the design evaluation of a development taking potential environmental constraints and opportunities into consideration before a final decision is taken on design. Early consideration of potential alternatives to the Proposed Scheme will ensure minimisation of risks and could also help to avoid likely environmental effects.

2.25

On this basis, a detailed assessment of the need for the proposal and consideration of alternative sites is not considered necessary for the scope of this EIA, given that the site is allocated for a new stadium in both the Core Strategy (2014) and Placemaking Plan (2017). The Site has also been the home of Bath Rugby for many years and it is considered by the Applicant to be the most appropriate site for a new stadium, allowing Bath Rugby to remain in the heart of its community. Indeed, it is allocated for such a proposal within the up to date development plan. Alternatives that will be considered within the EIA include a ‘Do nothing’ option and ‘Alternative designs’ scenario, which will summarise the evolution of the current design proposal.

2.26

The ES will therefore consider the main alternatives studied, with a focus on alterative scheme options and scheme design iterations. These will be aided by the process in place which logs decision making during the design.

2.27

Component uses of the scheme will be subject to their own town centre uses assessment, the scope of which has been agreed separately with the Council.

The Baseline Scenario for Use in the EIA 2.28

Likely significant effects as a result of the Proposed Scheme will be described in the ES in relation to the deviation from the baseline environment within the Site or/and relevant technical study areas. The baseline environment will comprise the existing environmental characteristics and conditions, based upon surveys undertaken and information available at the time of the assessment.

2.29

The baseline conditions for the purpose of the ES will vary depending upon the timing of the survey or the date when data sources will have been accessed. We anticipate that all baseline conditions will be based upon data accessed or surveys completed between 2016 and summer 2019.

2.30

Some data obtained from third parties may be older; however, this is largely associated with below ground data which is not anticipated to have significantly changed and therefore still remains relevant to the baseline scenario. The origin of all third party data, the dates of surveys and the dates when data sources have been accessed will be 16

clearly outlined within the relevant Technical Chapters of the ES alongside any limitations and assumptions.

2.31

No construction activities within the Study Area have occurred or are anticipated to occur from other sources prior to Summer 2019. We can therefore conclude that baseline conditions will have remained constant during the process of desktop reviews and baseline surveys.

2.32

In terms of the Baseline Conditions at the site, this will include a description of the environment as it is currently (2019) and as it is expected to change given the project were not to proceed (i.e. ‘do-nothing’ scenario).

2.33

The site (as shown in Appendix 1: EIA Scoping Study Area) comprises a range of permanent and temporary buildings and structures. The planning history of the site establishes the current quantum of development at the site, albeit some elements of the existing built form are in the form of temporary permissions.

2.34

However, the most recent temporary planning permissions (and others) granted at the site (for example, permission 15/05237/FUL) were in part allowed in order to facilitate the long term aspiration of the Applicant and the Council to secure a permanent stadium at this site, in accordance with Policy B1(8) of the Council's adopted Core Strategy and Policy SB2 of the Council's adopted Placemaking Plan. See for example the Committee Report for permission 15/05237/FUL which noted that: "Policy SB2 in the draft Placemaking Plan includes Development Requirements and Design Principles that will apply to the consideration of long term development proposals within this area. There have been repeated applications for temporary stands on the site over the years and an incremental growth in spectator capacity whilst discussions on a long term solution have progressed then stalled. Some of the issues preventing progress are coming to a conclusion and it is considered that the retention of the stands for a further four years will allow time to resolve the future of the Club at the Recreation Ground. The Council would not support the Stands being retained on a permanent basis however in the interim, as temporary structures they are considered to be acceptable."

2.35

Bath Rugby has played at this site for nearly 150 years. It is therefore considered justified and reasonable to treat the current site conditions, with the benefit of live planning permissions, as the baseline scenario for considering the Proposed Scheme.

2.36

Indeed, were this scheme to be refused planning permission (or should determination of the planning application be delayed beyond the expiry date of the current temporary planning permissions), the Applicant would seek to extend the lifetime of the current temporary planning permissions through the submission of a new application(s), in order to provide additional time for the Applicant to work with the Council to secure a permanent solution for the site which safeguards Bath Rugby's presence in the city for years to come. The granting of further temporary planning permissions would clearly be justified given the unique circumstances of the site and the Proposed Scheme.

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2.37

It is considered that adopting a baseline scenario which assumes that the temporary stadium infrastructure has been removed would create a situation in which the ES assesses an unrealistic and purely hypothetical scenario, which will not enable a reasonable and proper consideration of the likely significant environmental effects of the Proposed Scheme, as required by the EIA Regulations. If the temporary structures are required to be excluded from the baseline, the baseline conditions would need to assume that Bath Rugby is no longer playing at the site, on the basis that a Premiership rugby club could not play at a stadium that only include the permanently consented structures. This would almost certainly result in unjustifiable and misleading exaggeration of the environmental effects of the Proposed Scheme, both negative (e.g. noise, traffic, etc.) and positive (e.g. socio-economic). This would clearly run counter to the EIA Regulations and associated planning policy and guidance.

2.38

It would also be challenging to robustly assess (whether qualitatively or quantitatively) baseline conditions that do not actually reflect the situation that has existed on the ground for many years.

2.39

Baseline data will be collected in such a way that the importance of the particular subject area to be affected can be placed in its context and surroundings so that the effects of the proposed changes can be predicted.

Significance Criteria 2.40

The EIA will report on the likely significant effects for the construction and operational phases of the Proposed Scheme.

2.41

The following criteria will be taken into account when determining significance:

2.42

•

Relevant legislation;

•

International, national, regional and local standards/guidance;

•

Probability/likelihood of occurrence of likely effect;

•

Geographical extent of likely effect;

•

Magnitude and complexity of likely effect;

•

Sensitivity/value/importance of the receptor/receiving environment;

•

Duration (short – up to 1 year, medium – 1 to 10 years, or long-term – over 10 years) of effect;

•

Frequency and reversibility of effect (temporary/permanent); and

•

Inter-relationship between effects (both cumulatively and in terms of potential effect interactions).

The method for assessing significance of effects varies between environmental topics but in principle will be based on the environmental sensitivity (or value/importance) of a receptor and the magnitude of change from the baseline conditions. The magnitude

18

of change will be assessed on a scale of large, medium, small and negligible and sensitivity (or value / importance) will be assessed on a scale of high, medium, low and negligible.

2.43

The assignment of significance will be based on professional judgement and the matrix below is only a tool to assist with the process. Whilst the matrix provides ranges, this is to guide the competent expert and a definitive assessment of significance will be provided for each effect. A conclusion will also be provided as to the threshold of a significant effect, again based on professional judgement.

Table 2.1:

Matrix to Support Determining Significance

2.44

For some specific topic assessments, guidance or the nature of the effect requires that differing criteria or scales for determining significance are to be used, however, wherever possible there will be consistency of terminology and conclusions will tie in with the above matrix. This is to ensure that the conclusions of the different effects can be compared during the decision making process and be robustly considered cumulatively.

2.45

Summary of effect tables that summarise the likely significant effects associated with each of the environmental topics will be provided at the end of each Chapter. These tables will outline sensitive receptors, mitigation measures and residual effects. A distinction will be made between direct and indirect; short, medium and long-term; permanent and temporary; and positive and negative effects. Cumulative effects will be considered as a single coordinated assessment as outlined in Chapter 19 – Methodology for Assessment of Cumulative Effects.

Insignificant effects 2.46

As part of the EIA process and based on the information available to date, there are a number of topics for which it is considered an assessment as part of the EIA is not justified and topics will not be considered within the ES. We request the Council’s agreement to the exclusion of these topics from the ES.

2.47

Further to the previous Scoping Opinion received from BANES, the topic areas for which no likely significant environmental effects have been identified are:

19

2.48

•

Risk of Major Accidents and/or Disasters; and

•

Microclimate

The topic areas outlined within this EIA Scoping Report also identify effects which are likely to be insignificant.

Competent Expertise 2.49

The EIA will be led by Turley. The Institute of Environmental Management and Assessment (IEMA) has awarded Turley the EIA Quality Mark in recognition of our technical quality and commitment to improvement in practice.

2.50

In line with the EIA Regulations, all contributors to the EIA are competent experts in EIA and this will be demonstrated in the ES with an overview of each key expert’s qualifications, professional accreditations and experience.

Format of Environmental Statement (‘ES’) 2.51

2.52

The ES will comprise of three volumes: •

Volume 1 - Main Text and Figures;

•

Volume 2 - Technical Appendices; and

•

Volume 3 - Non-Technical Summary.

It is envisaged that the structure of the ES and responsibility for production of individual chapters is identified below: Chapter

Author

1. Introduction

Turley

2. Site and Surrounding Area

Turley

3. Scope, EIA Methodology and Consultation

Turley

4. Alternatives and Design Evolution

Turley / Grimshaw

5. The Proposed Scheme

Turley / Grimshaw

6. Legislation and Planning Policy Context

Turley

7. Landscape and Visual Amenity (including Arboricultural Reports)

Nicholas Pearson Associates Blackdown

8. Built Heritage

Turley Heritage

9. Archaeology (including desk top archaeology report)

Wessex Archaeology and Kim Watkins

20

10. Ecology and Nature Conservation (including survey work)

Blackdown

11. Hydrology, Flood Risk and Surface Water Drainage

AW Water Engineering (Flood) ARUP (Hydrology and Surface water)

12. Hydrogeology and Hot Springs

ARUP

13. Traffic and Access (incorporating public rights of way issues if relevant and Travel Plan and Transport Assessment)

IMA Transport Planning

14. Socio-Economic Effects (incorporating playing pitch assessment / Sport England response; Retail Assessment; Health Impact Assessment and Economic Impact Assessment)

Turley Economics / Turley Retail / Torkildsen Barclay

15. Air Quality

Vanguardia

16. Noise and Vibration

Entran

17. Ground Conditions, Soils and Contaminates Land

ARUP

18. Lighting and Light Pollution

WYG

19. Waste

Carbon Consult

20. Climate Change

Carbon Consult/3Adapt/LUC

21. Impact Interactions and Cumulative Effects Turley / all 22. Residual Impacts and Conclusions

Turley / all

Interaction of ES with Other Planning Application Documents 2.53

The planning application and ES will be accompanied by a number of supporting documents. All documents which technically inform the ES will be based on the same level of information as outlined above under ‘Information to inform the Final Assessment within the ES’. The ES will be supported by a range of technical appendices.

2.54

There are also a number of documents which should be read in conjunction with the ES, but do not inform it, and they will be submitted as standalone planning application documents in their own right. These other application documents will provide a greater level of detail on how the Proposed Scheme is likely to come forward or how the Proposed Scheme complies with policy. These are outlined below: •

Design and Access Statement

•

Planning Statement;

21

•

Statement of Community Involvement;

•

Framework Travel Plan;

•

Foul Sewage and Utilities Statement;

•

Sustainability Strategy; and

•

S106 Heads of Terms.

22

3. Description of Site and Surrounding Area 3.1

The application site (as shown in Appendix 1) comprises part of the Recreation Ground incorporating Bath Rugby’s current stadium at ‘the Rec’, adjoining green open space to the east and riverside land to the west of the Rec, as well as the radial gate land and land adjoining the Bath Pavilion and Leisure Centre.

3.2

The site currently comprises the permanent stand (the South Stand), a temporary uncovered, seated stand (the East Stand), a temporary covered, seated stand (the West Stand), and a temporary uncovered terrace stand (the North Stand), with a separate permanent clubhouse building comprising bar and changing rooms. Vehicular access is served principally via William Street.

3.3

There are four listed buildings within the Site: •

Sports Pavilion4 at the Bath Recreation Ground (grade II listed building);

•

Entrance Kiosks and Gates to Recreation Ground (grade II listed building);

•

Lime Kiln/ President’s Lounge, Bath Rugby Club (grade II listed building) referred to as the ‘Presidents Lounge’); and

•

Viaduct leading to North Parade Bridge with associated Lodges (grade II listed building).

3.4

The Site is within the City of Bath World Heritage Site (WHS) and forms part of Bath Conservation Area. There are 14 scheduled monuments, two registered parks and gardens (RP&G) and over 600 listed buildings within 500m of the Site. Bath is situated in a hollow, surrounded by hills from which there are views down to the city centre including designed inter-visibility between the City and designated heritage assets at a greater distance from the Site including Prior Park (grade I Registered Park & Garden), Prior Park College: The Mansion with Link Arcades (grade I listed building) and Sham Castle (grade II* listed building).

3.5

In addition, Bath is one of eleven spa towns across Europe which comprise the ‘Great Spas of Europe;’ a tentative designation which will be evaluated for inclusion on the World Heritage List for consideration at the 2020 meeting of the World Heritage Committee.

3.6

Being located in a central area of Bath, the Rec is in an extremely accessible location for access by sustainable travel modes, including on foot or by cycle from much of the city. It is also within 600m of the city’s main railway and bus stations, an easy walking distance with many other bus stops being located in the surrounding area, including those for the buses serving Bath’s Park and Ride sites.

4

Otherwise referred to as the ‘Cricket Pavilion’ 23

3.7

In the Council’s Strategic Flood Assessment the application site is identified as falling within Flood Risk Zone 3a (as also agreed with the Environment Agency).

3.8

The Recreation Ground (the "Rec") is an open space in the centre of Bath, used for recreational purposes by Bath residents and the general public. The Rec is owned and operated by the Bath Recreation Limited (see http://www.bathrec.co.uk/). The Charitable Company's objects are: “The provision, with or without charge, of property in or near Bath (including, but not limited to, the Bath Recreation Ground) for use as outdoor recreation facilities for the benefit of the public.”

3.9

Rugby has been played at the Rec since 1894. About a quarter of the Rec is leased to Bath Rugby as a sports ground now capable of holding approximately 14,500 people.

During the off-season, the rugby ground's temporary East Stand is currently removed.

3.10

The adjacent riverside path (Riverside Walk, a public right of way footpath) comprises a 3m wide tarmac path, which for part of the length includes a paved slope/ bank down to a narrow river edge with boat mooring posts and railing. A number of timber benches/ picnic tables are located at the back of the path. The path edge includes a metal handrailing, which has recently been extended to cover the whole rear of the West Stand, with access steps to the river. The existing West Stand of rugby facilities backs onto the riverside.

3.11

Existing car parking at the Rec comprises 130 spaces adjacent to the cricket pavilion and 60 spaces at Bath Sports Centre (under an agreement with the Council), which are used by VIP spectators on match days.

Surroundings 3.12

Parts of the eastern area of the Rec are used by Bath Croquet Club, Bath Drama Club and some tennis courts. Pitches are available by prior booking for amateur sports.

There is a timber pavilion at the William Street entrance to the ground. The Bath Sports and Leisure Centre is located on the southern edge of the Rec, accessed via North Parade.

3.13

The local section of the river and riverside path, with lighting columns, semimature/maturing trees, and benches, continues north to Pulteney Bridge and south to North Parade Bridge. To the north of the Site is located the ‘Beazer Maze’. This is an open space of grass, accessed from the riverside, with a ‘paving maze’, well enclosed by walls and vegetation. Other notable elements include Pulteney Weir and the ‘radial gate’. The latter is a structure (managed by the Environment Agency) which was installed in the early 1970s to assist with flood management, but no longer fulfils that role. The riverside area next to the weir opens out into a wider space with a range of trees.

3.14

To the north of the Site lies Johnstone Street, which includes grade I listed buildings, with the gable ends, and associated garden spaces, of the terraces bounding the site, with Laura Place and Great Pulteney Street beyond. To the west of the river lies the eastern edge of the city centre, which includes a number of elements and features of 24

importance and high value including Bath Abbey (a grade I listed building), Orange Grove, Grand Parade, Terrace Walk, North Parade and Parade Gardens (a grade II Registered Park and Garden).

3.15

Parade Gardens is a park situated at river level, Bath’s most centrally situated and popular pleasure grounds, which attract tourists (for a small entrance fee) and Council residents (who have free entry). Overlooking the River Avon, Parade Gardens includes flower bed displays, floral features, concerts at the bandstand during summer months, deck chairs for hire, space for picnics, and a cafÊ with outdoor seating.

25

4. Description of the Proposed Scheme 4.1

All temporary and permanent works will take place within the EIA Scoping Study Area Boundary (Appendix 1 – EIA Scoping Study Area), albeit this includes some temporary activities, significant green and blue infrastructure and land where no activity will take place.

4.2

The proposed description of development is as follows: “Full planning application (and accompanying Listed Building Consent application) for: Demolition of existing Clubhouse, south and west stands and ancillary structures; removal of all existing temporary structures; and removal of trees fronting River Avon; 

      4.3

Construction of new sporting, cultural and leisure stadium, sports pitch and ancillary structures incorporating retail (Class A1/A3), conference / function / banqueting / hospitality rooms (Class D1), assembly and leisure uses (Class D2) and flexible multi-use areas for community / charity / education uses (Classes B1/D2) and ancillary uses; Construction of under-pitch car park; Creation of a new vehicular and pedestrian access to/from the car park onto North Parade Road and a new pedestrian bridge from North Parade Bridge to the riverside; Public realm works including hard and soft landscaping; Demolition and reinstatement of eastern elevation of Bath Pavilion building; Removal of existing radial gate and platform structure and replacement with new weir and public realm; and Associated works.”

As noted above, the radial gate works may potentially form the subject of a separate planning application. However, the works will be assessed as part of the ES for the Proposed Scheme in order to ensure that a holistic assessment of the environmental effects is undertaken.

Timescales 4.4

It is envisaged that the site preparation associated with the Proposed Scheme and subsequent building construction will commence in May 2020 and will be completed

by Summer 2022.

26

5. Landscape and Visual Amenity (including Arboricultural considerations) Introduction 5.1

The Site is within a sensitive position located within the City of Bath World Heritage Site (WHS) and Bath Conservation Area. It is located approximately 400m from the Cotswolds Area of Outstanding Natural Beauty (AONB). The Site is visible from recognised important locations within the city centre (e.g. Grand Parade and Orange Grove), the riverside, and from key elevated viewpoints (e.g. Bathwick and Widcombe Hill, Bath Skyline Walk), including those within the defined WHS Setting. There are also a number of mature trees along the riverside, which are afforded protection on the basis of their location within the Conservation Area.

5.2

Key issues will relate to the physical and visual relationships between the Proposed Scheme and identified receptors, particularly those stated above.

Methodology 5.3

A Landscape and Visual Impact Assessment (LVIA) will be undertaken with reference to the Institute of Environmental Assessment and Landscape Institute (LI/IEMA) guidelines, ‘Guidelines for Landscape and Visual Impact Assessment’ (3rd edition 2013).

Reference will also be made to the city of Bath World Heritage Site Setting Supplementary Planning Document (SPD; August 2013) which includes in Appendix 9, ‘Grading Categories for Assessing Impacts on the World Heritage Site’.

5.4

Agreement will be sought with the Council’s Landscape Officer on the study area including key representative viewpoints (see Appendix 3). With regard to the latter, given the cite centre location, it is considered appropriate to identify broad areas/ types of view, together with specific representative viewpoints from these areas. Both daytime and night-time views will be considered.

5.5

The assessment will also draw on a Tree Survey, Tree Constraints Plan and Arboricultural Impact Appraisal, which will be prepared and submitted with the planning application and as an Appendix to the ES.

5.6

The preparation of the LVIA will be coordinated with the Built Heritage chapter.

Baseline Conditions 5.7

These will be established through desk study and site appraisal. Receptors, both in terms of landscape character and visual amenity, will be identified, together with their condition and sensitivity to the proposed change. Reference will be made to the Bath City Character Assessment, Bath Conservation Area Appraisal, as well as the WHS Setting SPD noted above.

5.8

The existing night time conditions will be set out.

27

5.9

A summary baseline is provided as Appendix 4 to this document

Impact Assessment 5.10

This will assess the magnitude of the impacts both directly and indirectly to the receptors and set out the considered level of effect based upon a combination of sensitivity of the receptor and the magnitude of change. A judgement will be made as to whether the effect is significant.

5.11

The assessment will be based upon design information provided by the design team and the preparation of verified visual montages (‘VVM’)/ accurate visual representations (AVR).

5.12

Effects during the construction phase will be assessed.

5.13

Consideration will be given to night time effects as a result of: •

Changes to baseline associated with floodlights during staging of events/ matches

•

Changes to baseline associated with operational conditions during non-event/ non-match occasions.

Mitigation 5.14

Where possible and practical, mitigation of adverse effects will be an intrinsic part of the iterative design process – ‘primary mitigation’. No ‘secondary mitigation’ is currently proposed.

5.15

Overall the design proposals will need to: •

Demonstrate the highest quality design;

•

Demonstrate integration with respect to adjoining areas;

•

Demonstrate that visual impacts have been considered through the design process;

•

Provide a high quality public realm which is well integrated into the landscape setting of the Rec and the riverside and accommodates functional requirements with respect to flooding, access and circulation;

•

Set out a tree retention/ removal/ replacement strategy;

•

Consider existing site boundaries and enclosures, including existing stone walls, together with information on the design of new site boundary fencing/ structures; and

•

Provide information on materials which are appropriate to the context and are robust and durable.

28

Likely Effects - Summary 5.16

5.17

5.18

The likely landscape effects of the proposals, based upon current project information, at this stage of the project are: •

Temporary impacts associated with the construction phase including demolitions;

•

Permanent change (direct impact) to the physical character of the Rec with increased scale of built form, with demolitions of existing buildings and a new arrangement of spectator stands, noting that the nature of use will be retained;

•

Permanent change (direct, permanent impact) to the physical character of the local riverside corridor as a result of new building positions, and rearrangement and improvement of the public realm with tree removals and replacement;

•

Permanent change (indirect impacts) to the landscape settings of adjoining character areas around the site; and

•

Change to the night time lighting effect along the riverside and within the Rec during event/ non-event days.

The likely visual effects of the proposals, based upon current project information, at the stage of the project are; •

Temporary impacts associated with the construction phase including demolitions;

•

Effects to views from the city centre across the site to the eastern and southern hillsides;

•

Effects to views along the river corridor;

•

Effects to views from within the Rec; and

•

Effects to views looking across the site from elevated locations around the city.

The effects are likely to include a range of beneficial and adverse landscape and visual impacts.

Arboricultural 5.19

An arboricultural assessment comprising Tree Schedule and initial Impact Assessment and accompanying tree constraints plans was produced by Blackdown Environmental in July 2018 and updated in March 2019 to include the radial gate land.

5.20

The Arboricultural survey will follow a four staged specification.

29

Stage 1: Feasibility, Planning & Design (RIBA Work Stages 0 & 1) 5.21

Undertake to survey the trees within the curtilage of the site as indicated on the site plan by the red line, and any offsite trees likely to be affected by development in accordance with BS 5837:2012 Trees in relation to design, demolition and construction.

The trees will be categorized as per Table 1 of BS5837 [Clause 4.5] and scheduled in a tabular format.

5.22

Prepare a Scope for the Proposed Scheme to show root protection areas, accurate crown spreads and potential shade implications where applicable.

5.23

Prepare a preliminary Feasibility & Tree Constraints Assessment.

5.24

Prepare a schedule of the trees surveyed as per the above.

Stage 2: Design Development (RIBA Work Stage 3 & 4).

5.25

Provide advice as required to inform the design development and likely tree constraints to inform the technical design.

Stage 3: Technical Design, Arboricultural Impact Assessment, Tree Protection Plan & Method Statements (RIBA Work Stages 4) 5.26

Prepare a Tree Protection Plan drawing to show trees for retention and removal, location of the tree protection fencing, ground protection measures and other mitigation

5.27

Prepare an Arboricultural Implication Assessment to support the tree protection plan

5.28

Prepare Arboricultural Method Statements to submit with the planning application.

Stage 4: Implementation, Site Monitoring & Close Out (RIBA Work Stages 5, 6 & 7) 5.29

Carry out periodic site visits to monitor compliance with the tree protection details and problem solve where issues arise.

5.30

To record the site visits and inspections along with: the reasons for such visits; the findings and any necessary actions; all variations or departures from the approved details and any resultant remedial action or mitigation measures.

5.31

On completion of the development, sign off the completed site monitoring log and prepare a certificate of practical completion for submission to the Council for approval and final discharge of the condition.

30

6. Built Heritage Introduction 6.1

A 500m Study Area has been defined (Appendix 5) following a site visit and inspection of relevant heritage assets, undertaken by a suitably qualified heritage professionals (MRTPI and IHBC), a review of the Zones of Theoretical Visibility (ZTV) (Appendix 6) and the information in Section 4 taking into account: •

The nature and scope of the Proposed Scheme;

•

The proximity of heritage assets to the Proposed Scheme;

•

The degree of inter-visibility between the heritage assets and the Site taking into consideration, for instance, changes in topography as well as interposing townscape and landscape features; and

•

The significance of the relevant heritage assets and the contribution made by their setting including any historic or functional relationships.

6.2

The potential impact of the Proposed Scheme was considered in relation to all designated heritage assets within the 500m Study Area and additional designated assets outside the Study Area where the ZTV indicated potential intervisibility between the Site and the asset and where there are known relevant historic or functional associations. A preliminary list of potential sensitive designated heritage assets (receptors) was identified (Appendix 7) for further consideration and the identification of likely insignificant and significant environmental effects arising from the Proposed Scheme.

6.3

The iterative re-scoping will continue as the assessment is developed and the parameter plans, design principles and development specification evolve. This will include the identification of likely insignificant and significant environment impacts in relation to non-designated heritage assets.

Insignificant Effects 6.4

The following effects have been identified as insignificant in ES terms and will not be considered further within the EIA or reported in the ES. A factual evidence base has been provided below to support this.

Change in the setting of designated heritage assets outside the 500m Study Area with the exception of the following assets: •

Sham Castle (grade II* listed building, HAP ref 83);

•

Prior Park College: The Mansion with Link Arcades (grade I listed building, HAP ref 84); and

•

Prior Park (grade I RP&G, HAP ref 3)

31

6.5

Heritage assets with views towards the Study Area but located outside its boundary are unlikely to experience significant effects as a result of the intervening built form, distance, vegetation and/or topography. Where visible, the Proposed Scheme will be experienced as part of the wider city centre context and there are no known functional or historic connections between these assets and the Site. As such, there will not be significant environmental effects on these assets and they will not be considered further within the ES. Change in the setting of designated heritage assets within the 500m Study Area

6.6

A number of heritage assets located within the Study Area are also unlikely to experience significant effects arising from the Proposed Scheme due to: •

the nature and extent of their significance;

•

the limited contribution made by setting to the significance of the assets; and/or

•

the limited degree of intervisibility that will be experienced between the assets and the Proposed Scheme.

Identification of Sensitive Receptors and Likely Significant Effects 6.7

The following sensitive receptors identified in Table 6.1 below will be considered within the EIA: Table 6.1:

5

Sensitive Designated Heritage Assets:

Asset Type

Name5

Grade

HAP ref

World Heritage Site(WHS)

The City of Bath WHS

N/A

N/A

Conservation Area

Bath Conservation Area

N/A

N/A

Registered Park and Parade Gardens, Garden (RP&G) Bath

II

1

Registered Park and Prior Park Garden (RP&G)

I

3

Listed Building

Lime Kiln/The President’s Lounge

II

85

Listed Building

Sports Pavilion at II the Bath Recreation Ground

86

Listed Building

Entrance Kiosks and II Gates to Recreation Ground

87

Listed Buildings contained within the Listed Building Groups are listed at Appendix 7.

32

Listed Building

Viaduct leading to II North Parade Bridge with associated Lodges

88

Listed Building

Newmarket Row

II

1

Listed Building

The Empire Hotel

II

4

Listed Building

Victoria Art Gallery and Library

II*

5

Listed Building

The Abbey Church of St Peter and St Paul

I

8

Listed Building

Nos. 1-7 Orange Grove

II

9

Listed Building

Obelisk

II*

10

Listed Building

Roman Catholic Church of St John

II*

11

Listed Building

24 – 29 Pulteney Road

II

13

Listed Building

Church of St Mary

II*

14

Listed Building

1-4 Bathwick Terrace

II

15

Listed Building (group)

Listed Building Group 1 - Great Pulteney Street Terraces

II/I

16-31

Listed Building (group)

Listed Building Group 2 - Edward Street Terraces

II/II*

32-37

Listed Building (group)

Listed Building Group 3 - Pulteney Mews

II

38-39

Listed Building (group)

Listed Building Group 4 – Johnstone Street Terraces

I

40-44

Listed Building (group)

Listed Building Group 5 – Argyle Street

II/II*

45-48

Listed Building (group)

Listed Building Group 6 – Pulteney Bridge

I

49-51

33

Listed Building (group)

Listed Building Group 7 – Parade Gardens

II

52-54

Listed Building (group)

Listed Building II/II* Group 8 -Terrace Walk/ North Parade

55-67

Listed Building (group)

Listed Building I Group 9 – North Parade/Duke Street

68-73

Listed Building (group)

Listed Building Group 0 – Raby Place

II/II*

74-75

Listed Building (group)

Listed Building Group 11 – Darlington Place

II

76-82

6.8

It should be noted that the Great Spas of Europe (including Bath) has been nominated for World Heritage Site status. It has been validated on the UK World Heritage Site Tentative List and, if successful, will be inscribed during mid- 2020. Assessment of the impact of the Proposed Scheme on the nominated Great Spas of Europe World Heritage Site will be assessed in a separate Heritage Impact Assessment, prepared in accordance with the ICOMOS Guidance on Heritage Impact Assessments. However, in recognition of the draft status of the designation and the limited weight that should be given to it as part of the planning process, this does not form part of the ES.

6.9

The following effects shown in Table 6.2 have been identified and will be assessed within the EIA and reported in the ES. Table 6.2:

Likely Significant Effects and Receptors

Effect

Receptor

Direct change to designated heritage assets

At this stage, the following designated heritage assets are considered likely to experience significant effects: •

The City of Bath World Heritage Site

•

The Bath Conservation Area

•

Lime Kiln/ President’s Lounge, Bath Rugby Club

34

Applicable Development Phase (Construction or/and Operational) C/O

(grade II listed building, HAP ref 85) •

Change within the setting of designated heritage assets

Viaduct leading to North Parade Bridge with associated Lodges (grade II listed building, HAP 88).

At this stage, the designated heritage assets identified in Table 6.1 above are considered likely to experience significant effects arising from change within their setting.

C/O

C – Construction / O – Operational

Assessment Methodology of Likely Significant Effects 6.10

In the absence of specific prescribed criteria for the assessment of impacts on built heritage the methodology for establishing the relative value or importance of heritage assets; the magnitude of impact; and the significance of effect is drawn from Design Manual for Roads and Bridges (DMRB).6 The detail of the methodology is to be agreed with Historic England and the Council7.

6.11

The Built Heritage ES Chapter will take into account the findings of the Townscape and Visual Impact and Archaeology Chapters to ensure integration of approach and assessment.

6.12

Determining Sensitivity of Receptor The heritage significance (value or importance) of the heritage assets (receptors) is defined on the basis of Table 6.3 below, which has been informed by the DMRB, the ICOMOS ‘Guidance on Heritage Impact Assessments for Cultural World Heritage Properties’ (January 2011) (the ‘ICOMOS Guidance’)8 and a clear understanding and appreciation of the heritage significance of each of the assets and the contribution of setting to their heritage significance. This has been undertaken in accordance with Historic England’s more recent guidance9 and been informed by documented evidence, site surveys, archival research and professional opinion.

6

Highways England (2008) Design Manual for Roads and Bridges (DMRB) Volume 11, Part 5.

There is no agreed methodology for assessing the impact on heritage assets for an ES – Historic England, for example, has not provided any guidance. This approach is an accepted methodology and, although the guidance relates to roads and bridges, the principles in relation to assessing impacts of development on heritage assets applies for other types of development. We have also drawn on the ICOMOS guidance.

8 ICOMOS (2011) ICOMOS ‘Guidance on Heritage Impact Assessments for Cultural World Heritage Properties’ 9 Historic England (2015) Historic Environment Good Practice Advice in Planning Note 2. Managing Significance in Decision Taking in the Historic Environment.

Historic England (2017) Historic Environment Good Practice Advice in Planning Note 3. The Setting of Heritage Assets (2nd edition).

7

35

6.13

The Heritage Assessment and ICOMOS HIA are most relevant here to establish the heritage baseline and heritage significance of the heritage assets.

Table 6.3:

Determining the Sensitivity of the Receptor

Sensitivity

Asset type

Very High

Standing buildings inscribed as of universal importance as World Heritage Sites Other buildings of recognised international importance

High

Scheduled monuments with standing remains Registered Battlefields Grade I and II* listed buildings Other listed buildings that can be shown to have exceptional qualities in their fabric or historical association not adequately reflected in the listing grade Grade I and II* registered parks and gardens Conservation areas containing very important buildings

Medium

Grade II listed buildings Historic (unlisted) buildings that can be shown to have exceptional qualities in their fabric or historical association Grade II registered parks and gardens Conservation areas containing important buildings Historic townscape or built-up areas with historic integrity in their buildings, or built settings (e.g. including street furniture and other structures)

Low

'Locally listed' buildings and landscapes Historic (unlisted) buildings of modest quality in their fabric or historical association Historic townscape or built-up areas of limited historic integrity in their buildings, or built settings (e.g. including street furniture and other structures)

Negligible

6.14

Assets of no architectural or historic note; buildings of an intrusive character

Determining the Magnitude of Change The magnitude of change to heritage assets is assessed as outlined in the criteria in Table 6.4.

The terminology used in Table 6.4 (major, moderate, minor or negligible) is in accordance with the guidance within the DMRB and the ICOMOS Guidance. An equivalence exists with the terminology used elsewhere in the ES (major/ large, moderate/medium, minor/ small, negligible/negligible).

36

Table 6.4:

6.15

6.16

The Magnitude of Change to Heritage Assets

Magnitude of Change

Definition

Major

Change to key historic building elements, such that the asset is totally altered and much of its heritage significance is lost. Substantial change within the setting of an historic building leading to considerable loss of heritage significance of the asset

Moderate

Change to many key historic building elements, such that the asset is clearly modified and there is some loss of heritage significance. Change within the setting of an historic building leading to some loss of heritage significance of the asset

Minor

Changes to key historic building elements, such that the asset is slightly altered and there is some loss of heritage significance. Change within the setting of an historic building leading to a slight loss of heritage significance of the asset

Negligible

Slight changes to historic building elements or within its setting that hardly affect the heritage significance of the asset

Determining the Level of Effect The level attributed to each effect has been assessed based on the magnitude of change due to the Proposed Scheme and the sensitivity of the affected receptor, as well as a number of other factors that are outlined in more detail in Chapter 2: Approach to EIA. The magnitude of the impact against value on the heritage assets is assessed as outlined in the criteria in Table 6.5, again utilised from a table within the DMRB. Table 6.5:

Matrix to Support Determining the Level of Effect

Value/Importance (sensitivity)

Scale (magnitude) of Change

6.17

Negligible

Minor

Moderate

Major

Very High

Negligible

Moderate to Minor

Major to Moderate

Major

High

Negligible

Minor to Moderate

Moderate to Major

Major

Medium

Negligible

Minor

Moderate

Moderate to Major

Low

Negligible

Negligible to Minor

Minor

Minor to Moderate

Negligible

Negligible

Negligible

Negligible

Negligible

Whilst the matrix provides ranges, the level of effect is confirmed as a single level and not a range, informed by professional judgement. A statement is also made as to 37

whether the level of effect is ‘Significant’ or ‘Insignificant,’ again based on professional judgement.

6.18

The level of effect to heritage assets is quantified based upon the particular heritage significance and setting of the asset and the nature of the effect on that significance. A detailed discussion will be set out within the accompanying Heritage Assessment. The assessor has therefore exercised professional and reasoned judgment in determining which of the levels of effect is more appropriate and should be read in conjunction with the accompanying Heritage Assessment.

6.19

The following terms have been used to define the significance of the effects identified and these can be ‘beneficial’ or ‘adverse’: •

Major effect: where the Proposed Scheme is likely to cause a considerable change from the baseline conditions and the receptor has limited adaptability, tolerance or recoverability or is of the highest sensitivity. This effect is considered to be ‘Significant’;

•

Moderate effect: where the Proposed Scheme is likely to cause either a considerable change from the baseline conditions at a receptor which has a degree of adaptability, tolerance or recoverability or a less than considerable change at a receptor that has limited adaptability, tolerance or recoverability.

This effect is considered more likely to be ‘Significant’ but will be subject to professional judgement;

•

Minor effect: where the Proposed Scheme is likely to cause a small, but noticeable change from the baseline conditions on a receptor which has limited adaptability, tolerance or recoverability or is of the highest sensitivity or a considerable change from the baseline conditions at a receptor which can adapt, is tolerant of the change or/and can recover from the change. This effect is considered less likely to be ‘Significant’ but will be subject to professional judgement;

•

Negligible: where the Proposed Scheme is unlikely to cause a noticeable change at a receptor, despite its level of sensitivity or there is a considerable change at a receptor which is not considered sensitive to a change. This effect is ‘Insignificant’; and

•

Neutral: the Proposed Scheme will result in no change.

Background Studies to Inform Assessment 6.20

The following studies are proposed and will be used to inform the EIA: •

Heritage Assessment – A detailed Heritage Assessment will be carried out in light of the statutory duties of The Planning (Listed Buildings and Conservation Areas) Act 1990, relevant policies of the National Planning Policy Framework (NPPF) and national Planning Practice Guidance for the historic environment. It will identify the significance and setting of the relevant heritage assets and assess the impact of the Proposed Scheme upon that significance. It will be

38

appended to and inform the EIA. Consideration will also be given to the relevant guidance documents prepared by Historic England including:

•

‒

Good Practice Advice in Planning Note 2, Managing Significance in Decision Taking in the Historic Environment (March 2015)

‒

Good Practice Advice Note 3, The Settings of Heritage Assets (2nd Edition December 2017)

Heritage Impact Assessment (HIA): The City of Bath WHS - a HIA will be prepared to specifically assess the impact of the Proposed Scheme on the Outstanding Universal Value (OUV) of The City of Bath WHS in accordance with the ICOMOS Guidance. The structure and content of the HIA will be informed the ICOMOS Guidance, in particular Appendix 4 of the ICOMOS Guidance entitled ‘Heritage Impact Report Contents,’ with adjustments to the format to recognise that the inscription of The City of Bath WHS covers the entire settlement. It will be appended to the ES.

Limitations and Assumptions 6.21

To ensure transparency within the EIA process, the following limitations and assumptions have been identified: •

The assessment relies on available data, and best endeavours have been made to ensure that the data is accurate and up to date. It is assumed that information obtained from, Historic England, the HER database and other sources is accurate.

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7. Archaeology Introduction 7.1

The ‘archaeology’ chapter will include an assessment of the potential effect of the Proposed Scheme on archaeological remains within the Site. For the purposes of this chapter, ‘archaeology’ is considered to comprise below ground archaeological remains only. Matters related to the built heritage resource (the effect of the Proposed Scheme on the Bath WHS, Conservation Area, identified listed buildings, the setting of relevant above ground heritage assets and any other built heritage assets identified during the assessment process) will be covered by the Built Heritage chapter.

7.2

Known and currently unknown below ground archaeological features within the Site should be understood to be ‘undesignated heritage assets’ in the context of the NPPF.

Relevant national planning policy and guidance 7.3

The assessment will be undertaken with reference to national planning policy as set out in the National Planning Policy Framework (NPPF) and specifically Section 16 Conserving and Enhancing the Historic Environment. Local planning policies will be referenced if applicable.

7.4

All assessment work would be undertaken in accordance with relevant standards and guidance published by the Chartered Institute for Archaeologists and Historic England.

Baseline Conditions 7.5

For the purposes of the Report and subsequent ES, the ‘Site’ comprises the area enclosed by the intended ‘red line’ planning application boundary.

7.6

The assessment will be informed by a review of existing phases of assessment undertaken following pre-application discussions.

7.7

To date, the Site has been subject to a phased programme of archaeological assessment comprising: •

Archaeological Desk-based Assessment (based on a 200m Study Area radius)

•

Magnetometer Survey Report (October 2018)

7.8

The results of these assessments are summarised below.

7.9

There are no Scheduled Monuments within the Site.

7.10

A Desk-based Assessment (July 2018) identified no recorded evidence for human activity within the Site dating from the Mesolithic to Medieval periods.

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7.11

A modest archaeological evaluation was undertaken in advance of a new South Stand in 1993. This exercise comprised a single 5x2m trench. No archaeological features were observed.

7.12

Prior to 1790, much of the present Recreation Ground area formed part of a large meadow known as West Mead. Pleasure grounds known as The Spring Gardens occupied part of the north western corner of the Site from the 1730s, notably illustrated on historic mapping from 1735. Some of the archaeological anomalies detected by the Magnetometer Survey Report (October 2018) were interpreted as remains of the Spring Gardens, potentially including the remains of beds, paths and boundaries.

7.13

The Spring Gardens closed in 1798 and the area was subdivided for use as kitchen gardens, a timber and stone yard and an iron and brass works.

7.14

The Recreation Ground has been in use since 1894, following groundworks to enable the site to be used for sports including rugby and cricket. The Cricket Pavilion dates from 1895. This phase of landscaping has potential to have both truncated archaeological deposits and buried and potentially sealed other archaeological deposits in areas where the ground surface was raised.

7.15

Borehole data reviewed as part of the Desk-based Assessment identified deposits of topsoil and made ground overlying fine-grained alluvial deposits to depths of between 2m to 3.9m below the present ground surface. These deposits in turn overlay courser alluvial deposits of sand, gravel and flint extending to between 3.8 – 5.8m below the present ground surface.

7.16

The Desk-based Assessment noted that the present President’s Lounge building is listed (Grade II) as a lime kiln but considers this interpretation to be incorrect.

7.17

The geophysical survey included the area of the present Site (‘the rugby pitch’) and the wider Recreation Ground area. The area of the present rugby pitch was surveyed as a discrete area and equates approximately to the area of the present Site. A concentration of irregularly and curvilinear probable cut (ditch) features were recorded towards the north of the Site. These features may relate to remains of the former Spring Gardens. Larger linear features running roughly NE-SW (and continuing across the Recreation Ground to the east) and corresponding perpendicular features were provisionally interpreted as evidence of historic boundaries.

7.18

A number of unidentified anomalies of potential archaeological interest were also recorded. Rectilinear anomalies recorded in the north-west corner of the site may indicate episodes of intense burning and as such may be associated with the former ironworks. A smaller 3-4m rectangular anomaly near the centre of the present pitch may relate to a former structure, perhaps associated with an earlier pavilion. Other anomalies may relate to post-medieval drainage or kitchen garden features.

Wider archaeological background 7.19

Known archaeological features and deposits in the area surrounding the Site include evidence of human activity spanning the prehistoric (Mesolithic) to Medieval periods.

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7.20

Selected examples include evidence of Mesolithic activity at Cheap Street (c210m west of the Site) and evidence of prehistoric activity in the area of the Roman Baths some 2010 – 280m west of the Site. Concentrations of lithics recorded at Southgate c250m southwest of the Site provide evidence of Mesolithic activity focussed on river terraces in the locality.

7.21

The Roman settlement at Bath was focussed around the present Walcot Street, extending into the area of the modern city centre and area of the Roman baths and temple precinct. There is currently no evidence to suggest that Roman settlement extended into the Site. The nearest recorded features of Romano-British date relates to the Romano-British cemetery at Bathwick, c.250 m north east of the Site.

7.22

Archaeological evidence from the Saxon period is comparatively limited, perhaps in part due to truncation in later periods. A convent is recorded from 675AD. Excavations at Bath Abbey suggests that the modern Abbey stands on or near to the site of a Saxon monastic site. There is no evidence for Saxon occupation of the Site.

7.23

The Medieval settlement of Bath developed within a walled area potentially established during the later Saxon period. The Norman Abbey was constructed in the 12th century, some 200m west of the Site. Land associated with the Abbey extended to the west bank of the Avon opposite the Site. Evidence of a fulling mill on the west bank of the river survives within Parade Gardens, c.50m west of the Site.

7.24

The Medieval city wall followed a course broadly parallel to the river, with the surviving East Gate located c. 100m west of the Site. The closest record of Medieval activity to the Site relates to successive phases of building at Bathwick Mill north of the Site. The earliest mill on the site is thought to date from the Medieval period with the latest being of 17th of 18th century date. There is no recorded evidence of Medieval settlement extending onto the eastern side of the Avon i.e. to the location of the Site.

7.25

The area of Bathwick remained otherwise undeveloped until at least the 18th century, most, or all, of the present Site falling within the meadow or pasture known as West Mead.

Potential impacts 7.26

Potential impacts to the archaeological resource associated with the Proposed Scheme will include: 

Damage or destruction to known archaeological features or deposits (in this case untested anomalies of potential archaeological origin identified via geophysical survey)



Damage or destruction of unknown archaeological features or deposits



Impacts may arise via the process of site clearance, demolition of existing structures, construction of new buildings, temporary or enabling works, service connections, hard and soft landscaping, tree planting, improvements to the playing surface, any other intrusive groundworks, including temporary works.

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Archaeological potential, further assessment and consultation 7.27

The Archaeological Desk-based Assessment identified a high potential for postMedieval archaeological remains to occur in the north-west corner of the Recreation Ground. However, it considered the significance of such remains, if present, was likely to be low.

7.28

Overall, the Desk-based Assessment considered the potential for the development to impact significant archaeological remains to be low. However, it cautioned that, notwithstanding the modest archaeological intervention at the South Stand, the Site has not yet been subject to a detailed archaeological assessment.

7.29

The Desk-based Assessment advised that a programme of geophysical survey could be undertaken across undertaken across the site and that this might inform the location of targeted evaluation trenches, if required. However, it noted that alluvial deposits may mask deeper features or deposits within the Site, potentially including features of Roman or Prehistoric date.

7.30

The geophysical survey subsequently identified a number of anomalies of potential archaeological origin (summarised above), most of which are provisionally interpreted as being of post-medieval date. The results of the geophysical survey have not been tested.

Further consultation 7.31

It is anticipated that the need for further archaeological assessment, if necessary, and the scope of the archaeology chapter will be finalised via discussion with the LPA and their archaeological advisor.

7.32

Potential additional strands of archaeological assessment might include, for example:

Updated Archaeological Desk-based Assessment 7.33

The Archaeological Desk-based Assessment was completed in July 2018. An updated Historic Environment Record search will be undertaken to ensure any additional relevant data added to the HER since July 2018 is taken into account. The assessment will be reviewed and updated if necessary to reflect the present red line boundary and any additional requirements identified by the LPA or their archaeological advisor.

A programme of targeted archaeological evaluation trenching / testing 7.34

This exercise would test anomalies identified via the geophysical survey to confirm their presence / absence, character, extent and significance. The exercise would also test the veracity of the geophysical data by testing ‘apparently blank’ areas within the survey data.

Geoarchaeological assessment 7.35

This exercise would, in the first instance, utilise existing geotechnical borehole data to generate a predictive deposit model. This would inform an assessment of the potential

43

for significant archaeological deposits (potentially including waterlogged deposits preserving organic remains, artefacts and ecofacts) to occur at depths which could not be tested via geophysical survey and conventional evaluation trenching. Existing geotechnical data could be supplemented by additional boreholes undertaken under archaeological supervision, if necessary

Mitigation within the Submitted Design 7.36

The Proposed Scheme has potential to impact or destroy archaeological features and deposits within the development footprint.

7.37

The scheme design is an iterative process and therefore a mitigation strategy has yet to be finalised. However, as part of the evolving design process Wessex Archaeology will provide both construction and operational design mitigation.

7.38

It is anticipated that targeted field evaluation be undertaken, the scope of which will be agreed with the LPA and their archaeological advisor. The results of this work will inform the detail of a final design and mitigation programme. This might include, for example, the use of an intelligent foundation design in combination with programmes of archaeological monitoring and / or targeted excavation in advance of construction.

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8. Ecology and Nature Conservation Introduction 8.1

The site is located in a largely urban area of Bath and comprises predominantly of buildings and amenity grassland associated with the Bath Rugby playing surface and adjacent Recreation Ground. There are also a number of mature trees adjacent to the river Avon along the western boundary of the site and a number of mature, semimature and dead trees on the island to the west of the radial gate.

8.2

There are no statutory designated sites of importance for nature conservation within or immediately adjacent to the site. Statutory sites within 4km radius of the Bath Rugby site which could be affected by the Proposed Scheme include two constituent Sites of Special Scientific Interest (SSSI) of the Bath and Bradford on Avon Special Area of Conservation (SAC); Combe Down and Bathampton Mines and Brown’s Folly. These constituent sites comprise extensive networks of caves, mines and man-made tunnels which are used by bats for hibernation, mating and as a staging post prior to dispersal.

Annex II bat species which are the primary reason for designation includes greater horseshoe Rhinolophus ferrumequinum and Bechstein’s Myotis bechsteinii bats. Annex II bat species present (but not a primary reason for designation) includes lesser horseshoe bats Rhinolophus hipposideros.

8.3

In order to maintain the integrity and functionality of the bat roosts within the SAC, core roosts have been identified which support over 50+ breeding or hibernating greater horseshoe bats. The landscapes which surround these core roosts which are used regularly for foraging and committing bats have been identified as ‘core areas’ and this includes the stretch of the river Avon immediately adjacent to the western boundary of the site.

8.4

Additionally the River Avon is listed as a non-statutory Site of Nature Conservation Importance (SNCI) and a Strategic Nature Area (SNA).

Existing Survey Work 8.5

Ecological survey works were initially undertaken in 2013 and comprised a data search obtained from Bristol Regional Environmental Records Centre (BRERC) and additional search for statutory designated sites was undertaken using the MAGIC Map website (www.magic.defra.gov.uk). An Extended Phase 1 Habitat Survey of the site and a Preliminary Roost Inspection of the buildings within the rugby grounds was undertaken.

8.6

Following discussions with the LPA Ecologist and Natural England, Phase 2 surveys were undertaken in August and September 2013 comprising bat activity and automated static detector surveys of the site and boundaries and dusk emergence surveys of the clubhouse building. Commuting and foraging bat activity was recorded within and adjacent to the site with at least six species recorded including soprano pipistrelle, common pipistrelle, Myotis species, noctule, long-eared and lesser horseshoe bat. No bats were recorded as emerging from the clubhouse building.

45

8.7

Additional ecological survey work was undertaken during 2015 in relation to the development of the West Stand. A data search was obtained from BRERC. Bat activity and automated static detector surveys of the West stand and the boundaries were conducted during the period August and September 2015. Bat activity was recorded within the site however no bats were recorded emerging from the building.

Further Survey Work 8.8

An updated Preliminary Ecological Appraisal (PEA) was undertaken of the rugby ground and associated buildings on the 6th June 2019 which included a Phase 1 habitat survey of the revised site, preliminary bat roost assessment of all structures proposed to be impacted and a biological records search from BRERC. The PEA identified that the habitats within the stadium, are primarily of low ecological value comprising well managed grass and species poor hedgerows. Scattered bat droppings were identified on the west stand. Nesting house martins and feral pigeons were noted within the west stand and there are records of peregrine falcons in close proximity to the site The mature trees throughout the site provide habitats with the greatest ecological value both in terms of roosting and nesting bats and birds as well as foraging for bats and invertebrates and shade over the river allowing horseshoe bats from the SAC to forage within the city centre. It is understood that several trees will require removal and there consideration must be made to how this will affect roosting and foraging bats in particular.

8.9

Updated bat emergence and pre-dawn re-entry surveys were undertaken of the south stand, west stand, Novia stand, club house, members bar, presidents lounge and premier lounge in July and August 2018 which were assessed with low-moderate potential to support roosting bats. No bats were recorded emerging/re-entering from any of the buildings surveyed although regular, predominantly common and soprano pipistrelle passes were recorded particularly over the pitch and adjacent to the river.

8.10

New guidance ’Protecting bats in waterside development’ produced by the Council in 2018 states that it is not necessary to undertake bat activity surveys providing that the design is compliant with the principles of the guidance i.e. controlling light spill to a specific lux level, avoiding development immediately adjacent to the river and retaining vegetation such as trees within zones extending from the river.

8.11

A separate PEA was also undertaken of the radial gate and associated island on the 15th March 2019 and a draft report has been produced. Nesting birds were recorded on the island and radial gate and there is potential for the trees on the island to support roosting bats as well as providing a sheltered route for horseshoe bats to travel up and down stream. Commuting otters are likely to use the river and may feed on higher ground adjacent to the island. It is understood that there is likely to be a requirement to remove dead/dying trees from the island and a climbing inspection/dusk emergence and dawn re-entry surveys have been recommended.

8.12

A PEA of the Bath Pavilion was undertaken on 20th May 2019, no evidence of roosting bats was noted within the building however there were numerous areas that bats could get into the building and which could not be checked by the ecologist, such as the space between the roof covering and the sarking. The building was assessed with

46

moderate potential to support roosting bats and two emergence/dawn re-entry surveys have been commissioned. One of these was undertaken on 24th June 2019, despite suitable weather conditions no bats were recorded emerging. A further dawn re-entry survey will be undertaken on 23rd July 2019.

Scope and Methodology 8.13

The PEA process was undertaken following the guidance outlined in Chartered Institute of Ecology and Environmental Management’s (CIEEM) Guidelines for preliminary ecological appraisal 2nd edition (CIEEM,2017).

8.14

The 2013 and 2015 Preliminary Roost Inspection and bat activity surveys were undertaken in line with guidance document Bat Surveys - Good Practice Guidelines published by Hundt (2012). The guidance had been updated prior to the 2018 surveys and these were undertaken in line with the guidelines published within the updated Bat Surveys - Good Practice Guidelines (Collins, 2016).

8.15

The ecological value of the site and impacts associated with the Proposed Scheme will be assessed by undertaking an Ecological Impact Assessment (EcIA) following guidance outlined in the Guidelines for Ecological Impact Assessments in the UK and Ireland.

Terrestrial Freshwater, Coastal and Marine. (CIEEM 2018).

Impact Assessment 8.16

The ecological impact assessment will determine whether the stated impacts of the development are likely to give rise to a significant impact, defined as an impact on the integrity of the site or its receptors and/or the conservation status of habitats or species within a given geographical area. Consideration for cumulative impacts will also be given.

8.17

Impacts will also be defined in terms of the impacts on legally protected species and habitats and whether impacts may result in an offence under relevant wildlife legislation (e.g. Wildlife and Countryside Act 1981 (as amended) or the Conservation of Habitats and Species Regulations 2010 (as amended)).

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9. Hydrology, Flood Risk and Surface Water Drainage Introduction 9.1

The site is bordered by the River Avon on its western boundary, flowing from North to South. The principal source of flood risk to the Stadium for Bath site is from fluvial flooding from the River Avon. The site lies within Flood Zone 3a, as agreed by all parties, which is considered to be at a high risk of flooding from the river with an annual probability greater than 1%. The site is liable to flooding from a present day 5% annual probability flood event.

9.2

The River Avon falls within the Severn River Basin District, and the associated River Basin Management Plan (‘RBMP’) sets a number of actions to meet the requirements of the EU Water Framework Directive (‘WFD’). With regards to the WFD classification system, the reach of the River Avon adjacent to the site (described as Bristol Avon (By Brook to Netham Weir)) is classified as a heavily modified water body and is currently designated as Moderate with regards to Ecological Quality, but Good for Chemical Quality.

9.3

The Proposed Scheme includes for the removal of the radial gate. The ES will consider the current requirement for the radial gate and the likely impacts if this radial gate is removed.

9.4

During construction the possible significant effects that will need to be considered include: •

A flood event occurring during construction and resulting impact on construction workers and plant, and potential for material to enter the River Avon; and

•

Run-off from the site leading to deterioration of the quality of downstream water bodies, either due to reduced quality of run-off from construction activities or accidental leaks and spillages of materials.

•

During operation the possible significant effects that will need to be considered include:

•

Flood risk to all future site users;

•

An increase in flood risk to third parties as a consequence of altered flooding mechanisms in the area;

•

Pollutants and silts contained within flood water and surface water run-off; and

•

Increased surface water run-off in conjunction with no attenuation or restriction from the site, as a mechanism of mitigating flood risk.

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9.5

The site is not considered to drain to the Kennet and Avon canal approximately 350m east of the site, based on existing topography and drainage networks. For this reason, it has been excluded as a receptor for the development.

9.6

The site and surrounding area are currently serviced by a combination of combined and surface water sewers, with both combined and dedicated surface water outfalls to the River Avon from the site. The combined sewer discharges directly to the River Avon from an overflow weir in times of intense storm.

9.7

No attenuation or flow restriction will be provided on site, with the understanding that attenuating flows within the site could result in discharge from the site coinciding with the peak river flow, which is considered to present a greater flood risk to site users and third parties.

9.8

The drainage strategy will consider the existing and future drainage networks for the site, in the context of the foul water network capacity, existing combine water discharge, and flood risk mitigation measures.

9.9

The water supply for the site will be developed in collaboration with the Water Resource Management Plan by Wessex Water. The EA classify the region to be in low water stress and water supply is not considered to be under stress into the next 25 years. It is therefore understood that the magnitude of increase to the water demand for the site, without demand management in the scheme design, will be of little significance.

Methodology 9.10

A Flood Risk Assessment (FRA) will be prepared for the Proposed Scheme to support the planning application and will form an appendix to the ES. The conclusions and findings of the FRA will be summarised within the ES chapter. There will be consultation with the Council and Environment Agency (EA) throughout the application process. The FRA will be developed in accordance with the guidance set out in the National Planning Policy Framework (NPPF) and other relevant local and national guidance.

9.11

The FRA will need to demonstrate that the development is appropriate based on the flood risk in the area, will be safe over its lifetime, and will not increase flood risk to third parties. Further to this the FRA should seek to identify opportunities to reduce flood risk, and to provide improvements to the river corridor.

9.12

The FRA will need to demonstrate that people can either be evacuated safely from the site before, or during a flood event. This will be based on the different uses of the site, and the level of flood risk to those uses. A Flood Evacuation Plan will be required to be submitted as part of the application.

9.13

The FRA will also need to consider potential future works alongside the river and ensure that the development does not affect the ability for others to deliver these works in the future. The FRA will need to consider the need for the EA to access Pulteney Radial Gate and the proposed Fixed Weir intended to replace the gate.

49

9.14

The ES will assess potential impacts from the construction and operational phases of the Proposed Scheme on the surrounding surface water environment. This assessment will consider surface water drainage, foul water drainage and potable water supply.

The methodology will involve the following: •

Review of international, national and local legislation, policies and guidelines in relation to water resources, water quality and flood risk;

•

Establishment of baseline conditions on and around the site through literature review and existing data obtained from the Environment Agency and Envirocheck Report;

•

Identification of sensitive receptors through desk study, Envirocheck Report and consultations with the EA as reported within the FRA for the development;

•

Identification of risks to water quality, water resources and flooding from the development and hence the likely effects, magnitude of change and significance of environmental effects during both the construction and operational phases;

•

Development of mitigation strategies through consultation with the design team;

•

Identification of opportunities for enhancement of surface water quality and surface water management through design and mitigation; and

•

Identification of residual effects and identification of cumulative effects.

Baseline Conditions 9.15

Relevant baseline data will be reviewed, covering the site and immediate area. Baseline data will be obtained through a desk study, a site visit and consultation with the relevant authorities. Baseline flood level data will be obtained from the latest hydraulic modelling used by the EA.

9.16

Relevant baseline data will include assessing the current quality of any existing surface and ground water features in line with the requirements of the EU Water Framework Directive requirements and, where relevant, EU Habitats Directive. There will be a review of existing permitted discharges, surface and ground water abstractions, the existing surface water runoff regime, and a review of any existing flood risk issues through the FRA which will draw on information obtained from the EA and the Council.

A review and summary of relevant international, national and local legislation relating to the water environment will also be undertaken.

Impact Assessment 9.17

The FRA will consider the flood risk to the development and to others for all forms of flooding set out in the NPPF. These will include fluvial, surface water and ground water flooding. The FRA will demonstrate how these flood risks will be managed both now and in the future, taking climate change into account as defined in the February 2016 guidance note produced by the EA.

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9.18

Changes to flood risk on the River Avon will be assessed using a hydraulic model against the baseline condition. Effects will be assessed for both the construction and operational phases of development.

9.19

Potential changes will be assessed against baseline conditions, through a qualitativebased approach and professional judgement for both construction and operation stages. The significance of the effects will be based on the effect magnitude and the sensitivity of the receptors. Potential effects include:

9.20



Potential pollution to the River Avon;



Potential changes in the surface water runoff, which will be quantified and outlined in the Drainage Strategy;



Potential changes to the foul water drainage network; and



Potential changes in water supply.

Potential changes in the surface water runoff and drainage networks will be quantified and outlined in the Drainage Strategy that will accompany the FRA.

Mitigation 9.21

Where possible and practical, mitigation of adverse effects will be an intrinsic part of the iterative design process. The FRA will identify mitigation measures for managing the flood risk to and from the development. This will include measures such as setting ground and internal floor levels at an appropriate level based on the latest flood level information, and the various proposed uses. Potential climate change effects will be taken into account so as to protect the site now and in the future. Flood warning and management will be considered, as will the potential emergency access/egress routes, as part of the potential mitigation measures. Residual risks will also be considered within the assessment.

9.22

The contractor will develop a Construction Environmental Management Plan (‘CEMP’) that will include mitigation measures to protect the water environment. This will set out how construction activities will be undertaken in accordance with the Pollution Prevention Guidelines (PPG) published by the EA, particularly ‘PPG1 General guide to the prevention of water pollution’, ‘PPG2 Above ground oil storage tanks’, ‘PPG 5 Works in, near or liable to affect watercourses’, and ‘PPG 6 Working at construction and demolition sites’, and other good construction guidance such as CIRIA ‘Guidance C532 control of water pollution from construction sites’.

9.23

The Drainage Strategy will identify mitigation measures for managing the potential changes to the surface water environment, the foul drainage network and to water quality in run-off from the site.

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10. Hydrogeology and Hot Springs 10.1

This Chapter of the ES will assess the potential impacts that the construction of the Proposed Scheme may have on the existing hydrogeological conditions, including the Bath Hot Springs.

10.2

The springs have been under the care of the Civic Authority (now the Council) since 1590. The Bath springs (the King’s Spring, the Hot Spring and the Cross Bath Spring) are situated within a meander of the present course of the River Avon and continue to be central to economic, social and cultural developments in the City. Protection of the springs continues to be of paramount importance locally and nationally and the Hot Springs are of significant importance to the City of Bath and its status as a World Heritage site.

Methodology 10.3

A hydrogeological conceptual mode of the site will be developed for the site and an assessment of potential effects will be undertaken based on a qualitative appraisal of the interaction between the Proposed Scheme and the baseline hydrogeological conceptual site model. For the construction phase, the assessment will focus on ground opening construction activities e.g. exploratory holes or piling. For the operational phase, the presence of underground structures will be considered.

Baseline Conditions 10.4

Baseline conditions will be established using published reports, documents, regulatory data, and available and relevant survey records. This will result in creation of a baseline hydrogeological conceptual site model.

Impact Assessment 10.5

The methodology for effect prediction is based on assessing both the magnitude of the changes expected and the sensitivity of the receptors. Criteria for assessing the significance of effects on hydrogeology and the hot springs have been based on a qualitative assessment of the magnitude of the effect, or how far the effect deviates from the baseline condition, and the receptor sensitivity.

10.6

The criteria for assessing the significance of the impact takes account of the following factors: 

The value of the resource (international, national, regional and local level importance).



The magnitude of the impact.



The duration involved.



The reversibility of the effect.

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 10.7

The number and sensitivity of receptors.

The level of significance that merits further consideration / mitigation will be determined following the procedures set out in Chapter 2 of this document. In terms of the EIA Regulations, significant effects are generally those where the significance of the effect is 'moderate' or greater

Mitigation 10.8

Mitigation measures will be identified in the context of the Proposed Scheme and the identified impacts. It is likely that a major factor for the mitigation for protection of the hot springs will involve undertaking the proposed works in accordance with the County of Avon Act 1982. However further scheme specific mitigation measures will be developed where required based on the results of the chapter assessment.

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11. Traffic and Access Introduction 11.1

The transport impacts of the development will be assessed comprehensively within a Transport Assessment and the Transport Section of the Environmental Impact Assessment.

11.2

The assessment will consider the impacts of the 2 main trip attracting/generating elements of the development, namely: •

The proposed publicly available car park

•

The proposed stadium which will increase crowd capacity, and hence the number of trips made to the Stadium on match days

11.3

The assessment will include consideration of the impact of the development on all modes of travel, and will consider measures needed to both accommodate the development and mitigate its impact.

11.4

The assessment will consider transport policies relevant to the Proposed Scheme, and the extent to which the development conforms with those policies. This will include consideration of the proposed Clean Air Zone for Bath, which the Site lies within.

11.5

It will provide an assessment of the existing transport baseline position, and any committed developments likely to affect the baseline position. The assessment will consider the nature and severity of transport impacts, set out mitigation measures, and then considered the nature and severity of any residual impacts.

11.6

The cumulative impacts of the Proposed Scheme with other development proposal will be considered.

11.7

The extent of the highway network assessed will be appropriate to the impact of the various elements of the development, and at this stage is proposed to be as follows: Publicly available car parking

Proposed Stadium

Ancillary elements

11.8

The A36 from the A4 London Road/Cleveland Place junction through to the Churchill Bridge gyratory, with junction assessments being provided as necessary. The assessment of the highway will include pedestrian movements to and from the proposed stadium Link assessments for all main roads into Bath, with more detailed impacts being assessed as considered necessary.

Junctions local to the site where traffic flow changes are considered to be material

It is proposed to use surveyed traffic and pedestrian flows to carry out assessments, and give consideration to the use of Tempro growth to project traffic flows forward to

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a design year, but this will need to take into account historic data which tends to show limited peak hour growth in Bath.

11.9

A draft Travel Plan and Parking Management Plan will be provided setting out the proposed method and control and charging for the proposed car park, and which the assessment of the impacts of parking will be based.

11.10 The transport effects of the proposed publicly available car park and the increased capacity of the proposed stadium will be fed into the Air Quality assessment element of the EIA.

Methodology 11.11 The information used in compiling this section of the will be derived from the Transport Assessment [TA] prepared in support of this application.

11.12 The assessment will firstly establish the baseline transport conditions as they exist and then assess predicted conditions with the Proposed Scheme.

11.13 The highway network will be tested for the baseline position using the relevant industry standard assessment packages.

11.14 The implications of the Proposed Scheme will be considered for two scenarios, firstly in relation to the provision of a new car park and secondly in relation to the increased travel demand associated with the Proposed Scheme.

11.15 The impacts of the development on the transport network will be assessed and impacts identified. Measures considered necessary to mitigate that impact will be described, the impacts re-assessed and any residual impacts identified.

11.16 The process will then be repeated considering the cumulative impacts of the Proposed Scheme with other planned developments.

Significance criteria 11.17 Consideration is given to whether the effects are adverse (negative), beneficial (positive) or negligible, with any effects being categorised as minor, moderate or substantial.

11.18 For junction capacities, typically the ratio of flow to capacity (RFC) for each arm of a junction is used as a measure of operation, this being the ratio of the flow wanting to enter the arm, divided by the capacity of the arm.

11.19 This can either be expressed as a ratio (e.g. 0.8) or as a percentage (e.g. 80%), the latter generally being referred to as a degree of saturation. Typically, an arm is said to be below capacity when the RFC is below 0.9, at capacity when the RFC is between 0.9 and 1.0, and over capacity when the RFC is above 1.0.

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Table 11.1:

Significance criteria

Significance criteria

Description of criteria

Substantial beneficial

Substantial beneficial effects are likely to be highly noticeable and would lead to material improvement of conditions. A decrease in RFC value to below 1.0 at a junction operating over capacity would be classed as a major beneficial effect

Moderate beneficial

Moderate beneficial effects would result in a material, noticeable improvement of conditions. A decrease in RFC value to below 0.9 at a junction operating at capacity would be classed as a moderate beneficial effect.

Minor beneficial

Minor beneficial effects would improve conditions, but not materially so, and the improvement would be difficult to notice “on the ground”.

A decrease in RFC value at a junction already operating under capacity would be classed as a minor beneficial effect.

Negligible

Negligible effects would have an imperceptible effect on existing highway conditions.

Minor adverse

Minor adverse effects would worsen conditions, but not materially so, and the worsening would be difficult to notice “on the ground”. On junctions operating within capacity an increase in RFC which did not increase the value to over 0.9 would be classed as minor,

Moderate adverse

Moderate adverse effects would result in a material, noticeable worsening of conditions. On junctions operating within capacity an increase in RFC which increases the value to over 0.9 but below 1.0 would be classed as moderate. For junctions operating at capacity an increase which did not increase the RFC value over 1.0 would be classed as a moderate effect.

Substantial adverse

Substantial adverse effects are likely to be highly noticeable, material and result in a position that would be unacceptable. Any increase which increases the value to over 1.0 would be classed as a substantial effect as would any increases in RFC at junctions already operating over capacity.

Baseline Conditions 11.20 The methodology to establish the baseline conditions of the existing transport network is dependent on the mode of travel. The following modes will be considered: •

Walking and Cycling;

•

Public Transport

•

Traffic Flows; and

•

Car Parking 56

Transport Network 11.21 The existing transport network relevant to the development proposal will be described.

11.22 Background traffic survey information has been obtained to supplement previous information used in considering the approved enlargement of the West Stand between the 2015/16 and 2016/17 seasons.

11.23 A desk study of existing highway network conditions based on typical traffic speed data in Google Maps has been supplemented by timed and videoed car journeys through centre of Bath.

11.24 Road Collision data will be obtained for the assessment network.

11.25 First Group (buses) and First Great Western (rail) have been consulted, as the major public transport operators, to ascertain current transport conditions.

11.26 A desk study of the existing public transport services will be provided to the determine the routes and frequencies of existing public transport in the vicinity of the development.

11.27 Any proposals that will result in changes to the transport network that would be relevant to the development proposal will be described.

Car Parking 11.28 The TA will consider parking stock within the city and at the city’s Park and Ride [P&R] sites. Registration plate surveys have been undertaken to establish existing parking conditions at the main car parks within the city and these have been supplemented by desk top observations of parking conditions using the website http://www.bathcarparks.co.uk/ which provides up to date information on the availability of parking spaces within city centre car parks and the city’s P&R sites.

11.29 The transport implications of the provision of a new public car park will be assessed by considering the predicted change in traffic flows within the city, which has been based on the surveyed existing distribution of car park trips and assumptions regarding the transfer of existing car park trips to the new car park.

Stadium 11.30 Information on existing mode split will be obtained from an on-line supporter travel survey undertaken in 2018.

11.31 Baseline pedestrian conditions will be based on video surveys undertaken before and after matches for the North Parade and Pulteney Bridge areas. Output from Bath Rugby’s ticketing system will also be used to determine the arrival profile of supporters at the Rec. On-site measurements of the width at existing pinch points on the key pedestrian routes to the stadium will be provided. Consideration will given to the existing cycle routes to the stadium.

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Impact Assessment Car Park 11.32 The assessment will include consideration of the effect of the proposed car parking on the distribution of traffic around Bath based on data collected in relation to the main car parks, and the extent to which the proposed car park will be likely to attract new car trips into Bath.

11.33 The effects of the provision of the car park on the highway network on Bath will be assessed.

Stadium 11.34 An assessment of the level and mode trips generated by the proposed enlargement of the stadium, including the distribution of where the additional supporters are likely to travel will be made, based on historical data and the 2018 Travel Survey data, which is the most up to date information currently available.

11.35 The impact of the increase in trips on the transport network will be considered.

Construction Traffic 11.36 The impact of construction traffic on the transport network will be considered.

Mitigation and Residual Impacts 11.37 Mitigation required to support the development will be described, and an assessment made of any residual impacts.

Assessment of Cumulative Impacts 11.38 At present it is considered that the cumulative assessment will consider the Avon Quays North application (18/00058/EREG03) which was approved on 2nd April 2019, the Bath Cricket Club development (17/04338/FUL) which was approved on 12th October 2018, and the proposed extension to the Charlotte Street car park (18/04757/REG03) which was validated on 26th October 2018 and has yet to be determined.

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12. Socio-economics and human health Input to Description of EIA Scoping Study Area and Surroundings 12.1

The Site is located in Abbey ward and is located adjacent to the defined city centre (as defined in the PMP) where many of the city’s social and cultural features are located.

Business and residential uses are also located nearby.

12.2

There are approximately 4,400 working age (16-64) people living in Abbey ward, which accounts for 3.6% of the working aged population residing in the District10. A lower than average proportion of residents in Abbey ward is economically active (71.0%) as compared to the Council average (75.6%). For context, the England and Wales average is slightly higher, at 76.8%. Unemployment rates are slightly higher in Abbey ward (6.4%) compared to the BANES average (5.6%), but both are below the England and Wales average of 7.6%11.

12.3

At this time there are no Council residents in receipt of Job Seekers Allowance and seeking construction-related roles, but there are c. 150 people residing in the South West region looking for this type of work12. It is expected that jobs created by construction activity at the Development Site would draw in people from the wider South West region. There are higher numbers of residents in the District and the South West region seeking roles in customer service / retail and administrative roles (c. 100 and c. 6,000 respectively), which may provide a source of labour for jobs created by the operational phase of the Development Site.

12.4

A higher than average proportion of residents are economically inactive in Abbey ward (29.0%) compared to residents in the District (24.4%)13. This in part reflects the concentration of students in the area (16.4% compared to 4.7% average across the District) due to the presence of the City’s two Universities: University of Bath and Bath Spa University. In comparison, the student population across England and Wales makes up 6.6% of the population.

12.5

There are approximately 20,000 jobs in Abbey ward, with almost a quarter (22.5%) in the Retail industry and 20.0% in Accommodation and food services, both reflecting jobs typical of city centre uses and the role of tourism in the City. Tourism is a key driver of local economic development, with Bath being granted World Heritage Status in 1987. In 2016, Bath saw a total of 4.7 day visits, with a total visitor spend of approximately £430.5 million14.

12.6

A further 10.0% of jobs are in Professional, scientific and technical roles and another 11.2% in Information and Communication, reflecting business clusters in the centre of Bath (ONS, 2015, BRES). This is a similar profile to the District average, though across

10

ONS (2018) 2017 Population Estimates ONS (2011) 2011 Census 12 ONS (2019) Job Seekers Allowance data 13 ONS (2011) 2011 Census 14 Visit Bath (2016) Value of Tourism in Bath and North East Somerset – Key facts 11

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the District there are higher proportions of employment in Education (14.3%) and Health (16.5%) than the England and Wales averages (8.7% and 12.6%, respectively).

12.7

The rate of deprivation is comparatively higher in Abbey ward as compared to its surrounding wards in the District. The neighbourhood area15 within Abbey ward in which the Development Site is located is ranked among the 30% most deprived neighbourhoods in the country. The ward is, however, surrounded by areas of very low deprivation, for instance Bathwick ward which is adjacent to Abbey ward, is among the 10% least deprived the country16

12.8

Public Health England’s latest (2018) Local Authority Health Profile for the District explains that on average, the health profile of the local population in the District is positive and generally better than the England average. Life expectancy for BANES residents is higher than the England average. However, there is significant variation within BANES and rates of cancer and diabetes are high among some segments of the population. In the 2011 Census, 16.0% of Council residents reported that their day to day activities were limited through a long term illness or disability and 10% of the population stated that they spent a substantial portion of their time caring for a friend or relative17. The Office for National Statistics (ONS) project that the population residing in the District will increase to 199,100 by 2037, representing an increase of 12% from 201218. The most significant increases expected are in older people, in particular the 85+ population (equivalent to a 124% increase from 5,000 to 11,200 people).

Insignificant Effects 12.9

The impact of the Proposed Scheme on Socio-Economics and Human Health is guided by the Healthy Urban Development Unit (HUDU) framework19. In addition to the HUDU framework, the impact of the Proposed Scheme is assessed by economic indicators, namely jobs and GVA uplift. Of the topics outlined above, it can be concluded that the Proposed Scheme will have an insignificant effect on the following:

Housing 12.10 Housing demand: The Proposed Scheme is not expected to have a significant impact on the demand for housing either in the local impact area of the District or the wider impact area of the South West region. While the PDS is expected to generate an increase in the provision of job opportunities, it is expected that the majority of these will be taken up by those residing in the local area. As such, the PDS is not expected to impact housing demand and this topic will not be taken forward in the ES.

15

The Office for National Statistics describes these areas as Lower Layer Super Output Area (LSOA).

DCLG (2015), Indices of Multiple Deprivation 17 ONS (2011) 2011 Census 18 ONS (2017), 2016 Population Projections 19 Health Urban Development Unit (June 2015), Rapid Health Impact Assessment Tool. The 11 topics are: Housing quality and design; Access to healthcare services and other social infrastructure; Access to open space and nature; Air quality, noise and neighbourhood amenity; Accessibility and active travel; Crime reduction and community safety; Access to healthy food; Access to work and training; Social cohesion and lifetime neighbourhoods; Minimising the use of resources and Climate change.

16

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Social Infrastructure 12.11 Education provision: As the PDS is not expected to have a significant effect on the demand for housing; subsequently, the PDS is not expected to significantly increase demand for education provision. Therefore, the impact will not be significant and will not be considered further in the ES. 12.12 Health care provision: The PDS is not expected to generate significant levels of additional demand on local healthcare services, such as GPs, dentists and emergency services. The need to increase health care provision is more closely tied to the impact of housing development rather than commercial development. Therefore the impact on health infrastructure will not be considered further in the ES. 12.13 Crime reduction and community safety: The PDS, in both the construction and the operational phases, is likely to be secure and include primary mitigation measures such as the employment of security staff and the use of CCTV cameras. Therefore, the Proposed Scheme is not likely to generate opportunities to commit crime. Therefore the Proposed Scheme will have a negligible impact on crime and safety, and as such will not be considered further in the ES.

Identification of Sensitive Receptors 12.14 The following sensitive receptors have been identified and will be considered within the EIA: •

The economy of the local impact area (the administrative area of the Council) and the wider impact area (the South West region);

•

Construction workforce in the local and wider impact areas;

•

The workforce in the local and wider impact areas, across all industries;

•

The workforce in the local and wider impact areas, across all industries and with lower-level skills;

•

Local residents, all demographic profiles; and

•

Local population of poor health.

Likely Significant Effects 12.15 The following likely significant effects are shown in Table 12.1 have been identified and will be assessed within the ES.

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Table 12.1:

Likely Significant Effects

Effect

Receptor

Applicable Development Phase (Construction or/and Operational)

Creation of short-term direct, indirect and induced employment during construction phase

Construction workforce in the local and wider impact areas

C

Generation of long-term direct indirect, and induced employment opportunities during operation

The workforce in the local and wider impact areas, across all industries

O

Jobs and economic activity

The economy of the local and wider impact area The workforce in the local and wider impact areas, across all industries and with lower-level skills

Increased training opportunities

The workforce in the local and wider impact areas, across all industries and with lower-level skills

C &O

Economic productivity uplift

The economy of the local and wider impact areas

C&O

The economy of the local and wider impact areas

O

Local residents, all demographic profiles

O

Visitor economy Increased number of visitors to Bath; uplift in visitor expenditure Active travel Pedestrian visitors to the waterfront

Local population of poor health Social cohesion Increased opportunities for volunteering

Local residents, all demographic profiles

O

Local residents, all demographic profiles

O

Access to healthy food The PDS includes new food outlets which can be accessed by the local community as well as Bath Rugby Club visitors

Local population of poor health

C - Construction / O - Operational

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Background Studies to Inform Assessment 12.16 The Socio-Economics chapter of the ES is a desk-based study and as such does not require surveys or studies to be undertaken. Turley Economics has undertaken an Stadium for Bath: An Economic and Social Value Study of the Proposed Scheme, of which some of the findings will be used to inform the Socio-Economics ES Chapter.

Turley Economics will also require input from the Transport and Access consultants in the assessment of the impact on open space.

Assessment Methodology of Likely Significant Effects 12.17 In the absence of guidance or policy available to inform the definition of appropriate study areas, it is reasonable to define study areas based on an understanding of relevant local and wider economic geographies, and the extent to which SocioEconomic and Human Health effects are likely to be contained within these geographies.

•

A local impact area based on the administrative area of the District. The 2011 Census indicates that 59.8%20, of people working in the District also lived in this area, indicating a need to allow for a level of leakage from this area.

•

A wider impact area defined to cover the South West region. The 2011 Census found that the majority (94.9%) of people working in the South West region also lived within this area21, suggesting a reasonable level of socio-economic containment within this geography. It is considered, therefore, that the majority of socio-economic effects would be concentrated within the wider impact area.

12.18 There is no overarching guidance which sets out the preferred methodology for the preparation of assessments of the likely effects of development proposals in terms of Socio-Economic impact. Several established methodological guides have been published which cover key elements of the assessment. These will be drawn upon as appropriate within the assessment, with the HCA Additionally Guide (2014) and the HCA Employment Densities Guide (2015) being of particular relevance.

12.19 The economic impacts of the Proposed Scheme will be presented as net additional; discounting for leakage and displacement as well as accounting for multipliers to present indirect and induced impacts.

12.20 In terms of Human Health, the HUDU Rapid Health Impact Assessment Tool22 offers a framework for categorising characteristics of the built environment which can affect human health. The HUDU tool outlines eleven topics (or ‘determinants of health’) which are the social, economic and environmental conditions which influence health and wellbeing.

12.21 The assessment of potentially significant effects on socio-economic and human health receptors will consider the sensitivity of the receptor and the magnitude of change to 20

ONS (2011) Census – location of usual residence and place of work ONS (2011) Census – location of usual residence and place of work 22 HUDU (2017) Rapid Health Impact Assessment Tool 21

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determine significance, on a scale of very high, high, medium, low or very low (for sensitivity) and high, moderate, low or negligible for magnitude.

12.22 The sensitivity of receptors is determined through comparison with wider regional and national trends. Through observation of a receptors capacity for change relative to wider comparator areas and/or national standards, the sensitivity of receptors locally can be observed. Consideration is also given to the priority placed on specific receptors in strategy and policy terms, particularly in the case of more qualitatively based receptors and those where there may be a shortage of quantitative evidence. The assessment is based on professional judgement.

12.23 Once the sensitivity of the population group has been identified, the absolute impact attributable to the Proposed Scheme is benchmarked against the average annual rate of change in the corresponding social, economic or health characteristics or baseline.

This enables a relative assessment of the magnitude that is attributable to the Proposed Scheme to be undertaken.

12.24 Significance will be concluded as negligible, minor, moderate or major, with effects of moderate significance or above considered to be significant.

Limitations and Assumptions 12.25 The assessment will be based on a desk study and is therefore reliant on data and information obtained from a variety of sources. Where necessary, professional and realistic assumptions will be made and applied.

Consultation 12.26 Consultation will be carried out with the Council where appropriate. Key contact persons relevant to four themes considered in this chapter of the ES (economic growth, open space, social cohesion, healthy food provision), will be identified as necessary.

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13. Air Quality Introduction 13.1

The Council has declared five Air Quality Management Area’s, (AQMA’s) due to exceedances of national air quality objectives for nitrogen dioxide (NO2). The Site is not located within an AQMA, but the Bath AQMA is located approximately 100m to the west of the site.

13.2

The Proposed Scheme will have potential impacts upon local air quality concentrations during the construction and operational phases.

13.3

For the construction phase the following receptors will be considered: •

•

13.4

13.5

‒

350m of the Site boundary; or

‒

50m of the route(s) used by construction vehicles on the public highway, up to 500m from the site entrance(s).

An ‘ecological’ receptor within: ‒

50m of the Site boundary; or

‒

50m of the route(s) used by construction vehicles on the public highway, up to 500m from the site entrance(s).

For the operational phase the following receptors will be considered when the adjacent highway has the following changes in daily traffic flows due to the Proposed Scheme: •

A change in light vehicle flows of more than 100 AADT within or adjacent to an AQMA or more than 500 AADT elsewhere; or

•

A change in heavy vehicle flows of more than 25 AADT within or adjacent to an AQMA or more than 100 AADT elsewhere.

For the operational phase the following receptors will be considered when the adjacent highway has the following changes in daily traffic flows: 

13.6

A ‘human’ receptor within:

A change of 1,000 AADT’s or 200 heavy good vehicles within 200m of roads experiencing a change in traffic flows due to the Proposed Scheme.

The Proposed Scheme will have the potential to generate dust and particulate matter (PM10 and PM2.5) emissions during the demolition and construction phase. Whereas, during the operational phase the associated vehicular traffic are likely to give rise to nitrogen dioxide (NO2) and Particulate Matter (PM10 and PM2.5) emissions.

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13.7

The full methodology and assessment criteria have been agreed with the Environmental Health Officer at the Council.

Baseline Conditions 13.8

Baseline air quality data will be gathered from the following sources: •

The Council’s air quality review and assessment reports and monitoring data;

•

The National Atmospheric Emission Inventory;

•

Bath Clean Air Zone documentation; and

•

DEFRA air quality background maps.

Impact Assessment 13.9

A qualitative assessment in line with the Institute of Air Quality Management (IAQM) (2014)23 dust guidance will be undertaken for the potential ‘risks’ associated with the following processes: •

Demolition;

•

Earthworks;

•

Construction; and

•

Trackout (of construction vehicles)

13.10 Based upon the potential level of risk mitigation measures will be proposed for the construction phase to reduce potential adverse impacts associated with dust soiling and human / ecological health.

13.11 A quantitative assessment of the operational traffic-related will be undertaken using a suitable next-generation model, as approved in Local Air Quality Management Technical Guidance24, (e.g. ADMS-Roads).

13.12 The assessment will consider traffic-related pollutants (NO2, PM10 and PM2.5).

Concentrations of these pollutants will be predicted at specified receptors for the following traffic scenarios: •

Existing Baseline;

•

Do Nothing: future baseline without the development; and

•

Do Something: future baseline operation with the development.

23 Institute of Air Quality Management (2014) Guidance on the Assessment of Dust from Demolition and Construction.

24 Department for Environment, Food and Rural Affairs (2016) Local Air Quality Management Technical Guidance LAQM, TG (16).DEFRA. London

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13.13 The results from the modelling process will be compared to the air quality objectives and the IAQM & Environmental Protection UK (EPUK) Planning for Air Quality guidance25.

Mitigation 13.14 Appropriate mitigation measures will be proposed based upon the outcome of the construction and operational impact assessments.

25 Environmental Protection UK & Institute of Air Quality Management (EPUK & IAQM) (2017) Land-Use Planning & Development Control: Planning for Air Quality, EPUK & IAQM, London

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14. Noise and Vibration Operational Impacts and Effects Noise 14.1

We have already held a telephone consultation with the Environmental Health Department of BANES, to ascertain their primary concerns with regard to the proposed development and to steer the assessment method. In summary, their concerns relate primarily to the use of the on-site PA system, and playing of amplified music, particularly at half-time. This system is being designed and specified by Arup and will be designed in order to achieve the required noise limit. The noise limit will be specified and agreed with the Environmental Health Department as part of the ES.

14.2

We have already undertaken a series of attended and unattended noise measurements at the site, to determine the ambient/background levels during non-operational periods and the current acoustic impacts of operations associated with match day activities, which include crowd noise and PA usage.

14.3

On the basis of this assessment and a modelling exercise, the anticipated changes in crowd noise will be predicted at the closest residential and amenity receptors to the stadium, to consider the potential 3,500 uplift in crowd capacity and changes to the level of acoustic containment afforded by the new stadium design. This will be considered in terms of the general acoustic principles relating to relative change in noise level exposure.

14.4

We will consider the effects of any noise generating commercial elements, such as cafes and other uses anticipated for the riverfront area, on sensitive receptors. It is anticipated that there will be insufficient information to accurately predict impacts, so appropriate limits for such sources of noise will be set in accordance with BS 4142: 2014.

14.5

We will predict and assess the impact of demolition and construction noise and vibration associated with the Proposed Scheme at noise-sensitive receptors in the vicinity, in accordance with BS 5228: 2009+A: 2014: Code of practice for noise and vibration control on construction and open sites, using methods agreed with the LPA; anticipated to either comprise fixed limits or the ABC method.

14.6

We will predict and assess the impact of any changes in road traffic flows at sensitive receptors in the vicinity, in accordance with CRTN and the relative change method set out in DMRB.

14.7

Mitigation measures will be recommended where necessary, to comply with the stipulated requirements of the Local Authority and relevant British Standards and Planning Guidance.

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15. Ground Conditions, Soils and Contaminates Land Ground Conditions, Soils and Land Contamination Introduction 15.1

This chapter will address issues relating to existing ground conditions at the Site, with the aim of ensuring that suitable and safe conditions are achieved in the redevelopment of the site. The assessment will take full consideration of the Site’s conceptual model (the potential sources of contamination, the receptors that could be affected and the pathways that could link these sources to the receptors). For the purposes of this chapter, ground conditions include issues associated with the geological, hydrogeological (excluding hot springs) and hydrological regimes, including the soil gases and vapours, chemicals within site soils, within the surface water bodies on and adjacent to the site and within groundwater beneath the site.

15.2

A range of impacts associated with the design, construction and operation of the Proposed Scheme will be considered, including potential ground contamination.

Methodology 15.3

A conceptual model of the site will be developed that describes the environmental features of the site together with the expected interaction of potential contamination sources with the environment. This will be done by undertaking a Source – Pathway – Receptor analysis of the site: •

Sources: potential or known contaminant sources, e.g. historic site land uses;

•

Pathways: mechanisms/ systems thorough which exposure to a contaminant could occur e.g. direct contact or migration through air, over land or via permeable ground, etc.; and

•

Receptors: sensitive environmental receptors that could be adversely affected by a contaminant, e.g. site occupiers, groundwater resources, ecological resources.

15.4

Where a source, relevant pathway and receptor are present a ‘contaminant linkage’ is created whereby there is a circumstance through which some level of environmental harm could occur, which has to be assessed and mitigation identified as appropriate.

15.5

The assessment shall be carried out with reference to the relevant sections of the NPPF and local planning guidance, relevant British Standards and other relevant good practice guidance.

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Baseline Conditions 15.6

Baseline conditions will be established through a desktop review of the available geological maps, historic maps and regulatory data commercially available. A site walkover will be undertaken to identify any current potentially contaminating usages and identify any sensitive receptors.

Impact Assessment 15.7

The methodology for effect prediction is based on assessing both the magnitude of the changes expected and the sensitivity of the receptors. Criteria for assessing the significance of potential human and environmental effects have been based on a qualitative assessment of the magnitude of the effect, or how far the effect deviates from the baseline condition, and the receptor sensitivity.

15.8

For example, a large magnitude of effect would be: a short term (acute) or long term (chronic) adverse effect on human health equivalent to ‘significant harm’ as defined by the Environmental Protection Act 1990); a persistent and extensive pollution of water resource or ecosystem equivalent to Category 1 pollution incident (major pollution release); or catastrophic damage to crops/building/infrastructure.

15.9

Receptors are considered to have varying degrees of sensitivity to contamination potentially present beneath the site based on potential effects and the integrity of any site specific exposure pathways. The significance of ground conditions effects are influenced by this receptor sensitivity.

15.10 For example, receptors of high sensitivity are; people (on site or on neighbouring sites) occupying residential land with gardens, or using allotments, children’s play areas etc.; construction workers engaged in extensive earthworks; a major aquifer of regional importance that is used for potable water supply, a highly ecologically sensitive watercourse or water bodies, a nationally or internationally designated ecological site, or a buildings of high historic or local importance.

Likely Environmental Effects 15.11 The assessment of effect magnitude and sensitivity of the receptor are thus used to qualitatively assess the effect significance of the Proposed Scheme. Effects have the potential to be either adverse or beneficial. For example, the development may remove a source of contamination or it may break a pathway that currently links a source to a receptor; ground contamination relies on a source, pathway and receptor to be present. The significance of the effect depends upon the sensitivity of the receptor and the ways in which the project can provide a pathway to the receptor. The significance of an effect also takes account of the timescales involved, i.e. short-term (less than three years duration), medium-term (between three and 10 years duration) or long term (in excess of 10 years duration) and the extent of the area affected.

Significant effects for the assessment are deemed to be those that are moderate and major.

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15.12 At this stage, it is considered unlikely that there will be any significant effects with respect of ground conditions given previous uses at the site, and the impact of the Proposed Scheme.

Mitigation 15.13 Mitigation measures will be identified in the context of the Proposed Scheme and the identified impacts. Mitigation will be in line with best practice guidance and will ensure that any relevant source – pathway – receptor linkages are broken.

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16. Lighting and Light Pollution Introduction 16.1

This chapter provides the lighting scoping assessment and discusses the potential for the development to significantly affect this aspect of the environment. Residential receptors are located adjacent to the Site boundary with further residential receptors located at greater distances from the Site adjacent to the local road network. In addition to residential receptors, ecological receptors are expected to be present along the adjacent River Avon. Such receptors are of high sensitivity.

Baseline Conditions 16.2

The baseline environment has been established by measuring existing pre-curfew and post-curfew lighting conditions during a televised game and training game as well as baseline without a game. Both existing residential receptors as well as ecological receptors will be considered. Full details of the light survey will be presented as an appendix of the ES.

Methodology 16.3

Lighting from the Proposed Scheme including flood lighting, external lighting (e.g. car parking) and advertisements will be modelled to assess potential impacts to both existing and proposed residential units as well as any potentially sensitive ecological receptors as well as conservation and heritage sites within the city centre.

16.4

A 3D representation of the proposed development and surrounding area will be produced within a DIALux light model, based on the proposed Mast Proposed Scheme and the specifications of proposed light sources.

16.5

Light trespass will be predicted at the proposed sensitive receptor locations and compared with the guideline values stipulated within the ILP document, ‘Guidance Notes for the Reduction of Obtrusive Light’ in order to provide an indication of the potential impacts of existing light sources at proposed property façades. Where light trespass at proposed receptors is deemed to be significant, mitigation options will be presented.

Mitigation within the Submitted Design 16.6

The lighting of the Proposed Scheme will be designed in accordance with relevant standards.

16.7

During the construction phase, the CEMP will include good practice measures to be implemented across the Site. These measures to be implemented include: •

specified working hours, uses of lighting, locations of floodlights;

•

lighting to be switched off unless specifically needed; and

72

• 16.8

barriers to be erected to shield adjacent receptors where appropriate.

During the operational phase a high-quality lighting strategy and scheme will be proposed to provide an enhanced night-time experience for the development, whilst avoiding harmful light spillage onto the sensitive residential and ecological receptors surrounding the site.

Potential Environmental Effects of the Scheme Construction Phase 16.9

The onsite temporary light fittings, construction compounds and on Site security lighting associated with preparation and construction have the potential to result in sky glow and light trespass or ‘spill’ impacting sensitive local and ecological receptors.

16.10 The level of light will be dependent on the location of the construction activities on a daily basis and the equipment being used, with light levels being attenuated as the distance between the source and receptor increases. Any impacts would be temporary.

16.11 Through the implementation of a CEMP, the potential impact of construction lighting is deemed to be negligible.

Operational Impacts and Effects 16.12 Lighting associated with the operational phase of the Proposed Scheme due to the high level of lighting required for a televised rugby game has the potential to affect receptors of residential and ecological sensitivity within the vicinity of the site.

Scoping Assessment Summary 16.13 There is potential that the development will produce a significant negative lighting effect. It is therefore concluded that a separate Lighting chapter within the proposed EIA should be provided and therefore it has been scoped in. A technical lighting assessment will also be completed as part of the planning application.

73

17. Waste Introduction 17.1

In the redevelopment of the Site, there is the potential to generate significant amounts of construction and demolition waste during construction works. Additionally, as the facilities are set to expand and include support facilities, increasing visitor numbers will raise operational waste generation rates. The increases in waste streams have the potential to impact on localised and regional waste management infrastructure.

Methodology 17.2

No guidelines exist for the measurement and assessment of impacts on waste generation from developments. As such it is proposed that construction and operation waste generation rates will be estimated and the ability of local infrastructure to treat this will be assessed. Where impacts are deemed significant, mitigation methods deployed will be indicated.

Baseline Conditions 17.3

A desk study will be carried out to assess local waste management systems and their constraints and capabilities. This can be achieved by reviewing local policy documentation and in some cases nationally published data and documents on waste generation.

Impact Assessment 17.4

Waste generation rates for the development will be calculated based on published generation rates, existing data from the site and also from experience in the development of other sites. These rates will be compared to the local waste treatment capabilities and impacts assessed based on percentage increases in waste generation across the District.

Mitigation 17.5

There are many forms of mitigation to reduce the impacts of increased waste generation, and support the city and region in meeting sustainable waste management targets. These include, Site Waste Management Plans, Operational Waste Plans and other measures which seek to reduce, reuse and recycle waste. Suitable mitigation measures for the Proposed Scheme will be identified and proposed in the ES.

74

18. Climate Change Introduction 18.1

The purpose of this chapter will be to assess the effects of the Proposed Scheme in relation to climate change, in line with the 2017 EIA Regulations, which require: “A description of the likely significant effects of the development on the environment resulting from, inter alia: (f) the impact of the project on climate (for example the nature and magnitude of greenhouse gas emissions) and the vulnerability of the project to climate change”.

18.2

This chapter will consider the following: •

Climate change mitigation: the potential effects of the scheme on climate change, with measures included in the project to reduce the emissions of greenhouse gases (GHGs); and

•

Climate change adaptation: both the vulnerability of the scheme to climate change, including measures included in the project to ensure resilience to climate change, and also any implications of climate change for the predicted impacts of the project, as assessed by the other topic specialists (for example, identifying environmental receptors that may be particularly sensitive to climate change, which could lead to a higher magnitude of their predicted impact).

18.3

The climate change mitigation elements of this assessment will draw from the work that will be undertaken in the preparation of a number of documents supporting the planning application including the Sustainability Statement, and other technical chapters in the Environmental Statement (ES) which is likely to include the air quality assessment and transport assessment work.

18.4

The climate change adaptation elements of this chapter will collate information from the other technical chapters within the ES and other supporting documents supporting the planning application such as the Sustainability Statement.

18.5

This chapter will be prepared by LUC in association with 3ADAPT; a team competent in climate change assessment and carbon management.

Legislative and Policy Framework 18.6

This chapter will be informed by: •

International Agreements including the Paris Agreement;

•

UK legislation including the National Adaptation Programme and the Third Strategy for Climate Adaptation Reporting (2018) and the Climate Change Act 2008;

75

•

The Building Regulations Approved Document Part L, Current Requirements: Part L 2013 Incorporating 2016 Amendments;

•

National planning policy including the revised and updated National Planning Policy Framework (2019) and the National Planning Policy Guidance;

•

Local Policy including the Core Strategy (which is currently under review), The West of England Joint Spatial Plan (currently under examination) and the Placemaking Plan (adopted July 2017);

•

The Environmental Impact Assessment Guide to Assessing Greenhouse Gas Emissions and Evaluating their Significance (IEMA, 2017); and,

•

The Environmental Impact Assessment Guide to Climate Change Resilience and Adaptation (IEMA, 2015).

Consultation 18.7

This Scoping Report will form a stage of consultation where the Council as the decision-making authority, will formally respond with a Scoping Opinion which will include comments and recommendations on this climate change chapter. Where appropriate, recommendations given by the pre-app advice will also inform this chapter.

18.8

This chapter will also consider previous listening workshops such as the Pre-Design Listening Workshop at the pre-design stage which revealed that stakeholders were concerned about the riverside and congestion – both of these are of relevance to the Climate Change Chapter.

Study Area 18.9

This assessment will consider the effects of the scheme in the context of global climate, with specific reference to the climate changes expected in the UK. These will be defined using the UK’s climate change projections (UKCP18), which allow climate changes to be projected at the regional level; in this case, southwest England.

Proposed Approach 18.10 The relevant climate change projections will inform the future climate change scenarios; IEMA guidance (IEMA 2015) recommends the use of the UK Climate Projections Website (Met Office, 2019). ‘Probabilistic’ projections are provided for a range of variables including temperature, precipitation and sea level rise. Wind speed and storm frequency/intensity are considered separately as global modelling information is currently more limited.

18.11 The UKCP18 projections for temperature and precipitation are presented for the UK as a whole and also on a regional basis. The UK projections consider three variables: •

Timeframe: the projections are presented for four overlapping time periods (2020s, 2040s, 2060s and 2080s);

76

•

Probability: The projections are provided as probability distributions rather than single values, with figures provided for 5, 10, 50, 90 and 95% probability.

•

Representative Concentration Pathways (RCP): Four pathways have been adopted; RCP2.6, RCP4.5, RCP6.0 and RCP8.5. These pathways describe different GHG and air pollutant emissions as well as their atmospheric concentrations and land use26 with each one resulting in a different range of global mean temperature increases over the 21st century27. RCP2.6 represents a scenario which aims to keep global warming likely below 2°C compared to pre-industrial temperatures. RCP4.5 and RCP6.0 represent intermediate scenarios while RCP8.5 describes a very high GHG emission scenario. All scenarios are considered to be equally plausible.

18.12 This assessment will use projections for the 2080s and RCP6.0 will be used. As the most far-reaching projection, the 2080 scenario is considered to be appropriate for the design life of the project. RCP6.0 is selected as a precautionary approach on the basis that it is an intermediate pathway that can be reached without additional efforts to constrain emissions (‘baseline scenarios’). This RCP will be used to indicate the temperature, precipitation, wind speed and storms in the southwest of England.

Climate Change Mitigation Assessment 18.13 The Proposed Scheme will contribute to climate change due to the following: •

Direct CO2, nitrogen oxides (NOx) and aerosol emissions from vehicles and plant during construction, operation and decommissioning;

•

Indirect CO2 emissions arising from the demand for energy produced using fossil fuels (e.g. electricity for heating, cooling, lighting and charging electric vehicles) during the operational phase; and

•

Embodied carbon arising from the materials and systems which form the temporary and permanent structures and is a result of extraction and manufacture of materials, fabrication, transport to site, waste and the future demolition and potential for re-use.

18.14 In terms of the direct emissions, this chapter is likely to draw on Air Quality ES Chapter assessments and the Sustainability Statement. Indirect emissions and embodied carbon will be considered in the Sustainability Statement. As the Sustainability Statement will have a different structure to the ES, the significance of the effects of the Proposed Scheme in EIA terms will be interpreted within this chapter only.

18.15 With respect to climate change mitigation and impact significance, as yet, there are no established thresholds for assessing the significance of an individual project’s

26

Intergovernmental Panel on Climate Change, 2014, Climate Change Synthesis Report: Fifth Assessment Report 27 Met Office, 2018, UKCP18 Guidance: Representative Concentration Pathways

77

contribution to climate change. However, the IEMA EIA Guide to Assessing Greenhouse Gas Emissions states the following: “When evaluating significance, all new GHG emissions contribute to a significant negative environmental effect; however; some projects will replace existing developments that have higher GHG profiles. The significance of a project’s emissions should therefore be based on its net impact, which may be positive or negative.”

18.16 The IEMA guidance requires a proportionate approach to the assessment of climate change effects and suggests alternative means for assessing these effects: either in relation to defined GHG thresholds, or by comparing performance against benchmark, for example an unmitigated ‘standard’ development.

Table 18.1:

Effect Significance

Table 1: Criteria Used to Assess the Significance of Climate Change Mitigation Effects Description of Criteria Direct

Indirect

Emissions from road traffic (CO 2 , NO x , PM) and on-site plant emissions (NO x )

Emissions (CO 2 ) from on-site plant

Offsite emissions (CO 2 )

Negligible

Emissions are equal to the emissions predicated in the baseline.

Exceeds minimum legal/policy requirements.

Exceeds minimum legal/policy requirements.

Minor

An increase in emissions predicated in the baseline but there is a commitment to reasonable and deliverable measures to seek to reduce these emissions in accordance with relevant policy and guidance (e.g. the provision of electric charging points/ reserved parking for electric vehicles).

Compliance with legal/policy minimum e.g. Building Regulations Part L and Council policy.

Compliance with legal/policy minimum e.g. Building Regulations Part L and Council policy.

78

Effect Significance

Description of Criteria Direct

Moderate

Major

Indirect

Emissions from road traffic (CO 2 , NO x , PM) and on-site plant emissions (NO x )

Emissions (CO 2 ) from on-site plant

Offsite emissions (CO 2 )

An increase in emissions predicated in the baseline, without a commitment to reasonable and deliverable measures to seek to reduce these emissions, in accordance with relevant policy and guidance.

N/A

Falls short of policy minimum but is considered acceptable in policy terms e.g. the Council agrees that development can fall short on renewables target if other standards are met.

Falls short of policy minimum but is considered acceptable in policy terms e.g. the Council agrees that development can fall short on renewables target if other standards are met.

Falls short of legal minimum.

Falls short of legal minimum.

18.17 Major and Moderate effects are defined as ‘significant’ in EIA terms.

Climate Change Adaptation Assessment 18.18 This chapter will collate information from other technical ES chapters. Where effects relating to climate change adaptation are identified in other chapters, they will be presented in this section, taking account of the methodology used to define effect significance within those assessments.

18.19 Section 6.2.5 of IEMA’s Environmental Impact Assessment Guide to Climate Change Resilience and Adaptation explains that when determining significance, account should be taken of the susceptibility or resilience of a receptor to climate change as well as the value of the receptor. A high value receptor that has very little resilience to changes in climatic conditions will be considered more likely to be significantly affected than a high value receptor that is very resilient to changes in climatic conditions. If there is uncertainty about how a receptor will adapt to a changing climate, then a precautionary approach will be adopted.

18.20 Section five of this IEMA document recommends that project designers consider resilience within the scheme design. Project resilience within this chapter will therefore be considered through liaison with the project design team. Discussions will identify appropriate adaptive measures, including design features, construction material and variations to maintenance regimes.

79

Baseline Climate Change Mitigation 18.21 The baseline for direct and indirect CO2 emissions is to be based on the current site use. If available, the baseline for direct emissions associated with transportation will be based on the existing use of the Site. This will be assessed in terms of emissions generated by vehicular traffic using the Site and how the emissions may vary over the equivalent lifetime to the Proposed Scheme.

Climate Change Adaptation 18.22 Using the Met Office which provides data on the UK climate, averaged for the period 1971-2000, this section will summarise how other ES technical chapters have considered how the projected climate changes would alter the assessed baseline.

Scoping Decision 18.23 In light of the potential for climate change to impact upon the receptors considered in the ES, and the potential implications of the development for climate change adaptation and mitigation, it is considered appropriate to scope this issue into the ES.

80

19. Methodology for Assessment of Cumulative Effects Introduction 19.1

The Cumulative Effects Chapter of the EIA will assess the likelihood for significant cumulative environmental effects as a result of the Proposed Scheme.

To accord with the EIA Regulations and best practice guidance, the following types of cumulative effects will be considered within the EIA:

19.2

•

Effect interactions: the interaction and combination of environmental effects of the Proposed Scheme affecting the same receptor either within the Site or in the local area; and

•

In-combination interactions: the interaction and combination of environmental effects of the Proposed Scheme with a committed project (or projects) affecting the same receptor.

It is anticipated that a qualitative cumulative effects assessment will be undertaken for the majority of environmental topics considered. However, partially quantitative assessments may be undertaken for traffic-related effects in relation to pedestrian amenity, vehicle delay, congestion and changes in air quality and noise from traffic.

Assessment Methodology 19.3

At present, there is no widely accepted methodology or best practice for the assessment of cumulative effects although there are a number of guidance documents available. The following approach that will be adopted is based on previous experience at Turley, the types of receptors being assessed and the nature of the proposed schemes being considered.

19.4

The assessment will be a qualitative assessment based on the available information.

Where information is not available, assumptions will be made based on professional judgement and clearly stated alongside any uncertainty as part of the assessment.

Effect Interactions 19.5

The approach to the assessment of effect interactions will consider the changes in baseline conditions at common sensitive receptors, which will be clearly mapped. The common sensitive receptors considered within this Chapter are those within two or more of the technical Chapters presented in the EIA Scoping Report.

19.6

A matrix of residual effect interactions will be formulated in the ES corresponding to the construction and operational phase of the Proposed Scheme.

81

Impact Interactions and Cumulative Effects 19.7

The ES will review, identify and assess potential interactions between impacts of the development on different aspects of the environment (that are dealt with in each topic chapter) that may be of significance.

19.8

Consideration will also be given throughout the ES to any potential cumulative effects that the Proposed Scheme may have with other known developments in the vicinity of the development site, i.e. where the effects of the Proposed Scheme on the environment could be increased, decreased or otherwise changed through interactions with the effects of other developments that are proposed by other parties.

19.9

The assessment, and related timescales, assumes that those development proposals allocated within the Core Strategy (2014) and Placemaking Plan (2017) within Bath City Centre will be completed within the timescales set in that document. Given the nature of Bath, and the recently adopted Development Plan, it is considered that there are limited additional development schemes which would cumulatively need to be assessed.

19.10 However, at present it is considered that the cumulative assessment will consider the Avon Quays North application (18/00058/EREG03) which was approved on 2nd April 2019, the Bath Cricket Club development (17/04338/FUL) which was approved on 12th October 2018, and the proposed extension to the Charlotte Street car park (18/04757/REG03) which was validated on 26th October 2018 and has yet to be determined.

19.11 It is considered that it is however unnecessary to adopt a blanket approach to cumulative assessment where the cumulative impact of those schemes is assessed in detail for every single environmental topic. The sites identified above may have a particular cumulative effect on some topic areas (such as transport) but may not on others. The individual chapters of the ES will therefore consider whether there are likely to be any cumulative effects on their topic areas and assess accordingly.

19.12 BANES Council officers and stakeholders are requested to identify development projects that the Stadium for Bath redevelopment may have cumulative effects with.

Cumulative effects will be addressed as far as is relevant to the Proposed Scheme, throughout each relevant section of the ES. 19.13 An overall qualitative assessment of the cumulative effect on the common sensitive receptors identified will be made using professional judgement and informed by the technical information provided in the ES and supporting appendices.

In-Combination Effects 19.14 Assessment of potential in-combination effects will be undertaken using the methodology outlined below.

82

Step 1: Identification of Projects for Consideration 19.15 In order to inform potential committed developments, a high level review of planning applications submitted to the Council (and other sources as required) in the last 5 years will be undertaken in order to identify potential projects that could give rise to incombination interactions with the Proposed Scheme.

19.16 Applicable projects for consideration of in-combination effects will be determined using the following criterion: •

Projects that are under construction;

•

Permitted application(s) not yet implemented;

•

Submitted applications(s) not yet determined but have the potential to be determined prior to the determination of the Proposed Scheme; and

•

All refusals subject to appeal procedures not yet determined.

19.17 This will produce a ‘long list’ of projects for further evaluation.

Step 2: Evaluation of Projects for Assessment 19.18 Each of the projects identified will then be evaluated to determine whether the following criterion is met: •

A concurrent construction or operational phase with the Proposed Scheme (2019 – 2027);

•

A relevant scale - other projects which in their own right have been subjected to EIA as a result of ‘likely significant effects’; and

•

A relevant geographical boundary and common sensitive receptors to the Proposed Scheme.

19.19 This will produce a ‘short list’ of projects for assessment. Any assessment will depend on available documentation in support of the projects.

Step 3: Assessment of In-combination Effects 19.20 Once the receptors for assessment haves been defined, consideration, where possible will be given to their tolerance to effects.

19.21 The sources of construction or and operational activities in-combination with the Proposed Scheme will then be assessed. In order for there to be a potential incombination effect, there needs to be a potential effect on the same receptor for a similar duration within the overall programme. There may be effects at the project level which require due consideration and management but these effects will not be reconsidered as part of the assessment.

19.22 The qualitative evaluation at the receptor level will consider the following: 83

•

Combined magnitude of change;

•

Sensitivity/value/importance of the receptor/receiving environment to change; or/and

•

Duration and reversibility of effect.

19.23 Through a combination of the qualitative evaluation and mitigation presented in the EIA, conclusions will be drawn as to the likelihood for significant in-combination environmental effects.

84

20. Conclusion 20.1

This report has outlined the emerging proposals for development and the alternatives that have been considered. It has identified the environmental issues considered by the future applicants and their team to be likely to be affected by the Proposed Scheme, and how the environmental impacts will be assessed in the preparation of the Environmental Statement which will accompany the planning application.

20.2

The Council is requested to consider this report, consult with officers and the identified consultees, and provide a Scoping Opinion within the required timescale.

20.3

Consultees are also requested to copy comments directly to Turley: c/o Tim Burden Turley The Pinnacle 20 Tudor Road Reading RG1 1NH Email: tim.burden@turley.co.uk Tel: 0118 9022836

85

Appendix 1: EIA study boundary

C:\temp\17165-GAL-ZZ-XX-M2-A-Documentation_bcurtis.rvt 02/07/2019 12:44:54

INTELLECTUAL PROPERTY Stadium Planning Application Boundary BANES Masterplan Boundary

GRIMSHAWArchitects Telephone Address

+44 (0)207 291 4141

57 Clerkenwell Road London EC1M 5NG UK

www.grimshaw.global

© COPYRIGHT GRIMSHAW ARCHITECTS. UNLESS OTHERWISE AGREED IN WRITING; ALL RIGHTS TO USE THIS DOCUMENT ARE SUBJECT TO PAYMENT IN FULL OF ALL GRIMSHAW CHARGES; THIS DOCUMENT MAY ONLY BE USED FOR THE EXPRESS PURPOSE AND PROJECT FOR WHICH IT HAS BEEN CREATED AND DELIVERED, AS NOTIFIED IN WRITING BY GRIMSHAW; AND THIS DOCUMENT MAY NOT BE OTHERWISE USED, OR COPIED. ANY UNAUTHORISED USE OF THIS DOCUMENT IS AT THE USER’S SOLE RISK AND WITHOUT LIMITING GRIMSHAWS RIGHTS THE USER RELEASES AND INDEMNIFIES GRIMSHAW FROM AND AGAINST ALL LOSS SO ARISING

REV 1 2

DESCRIPTION

DATE

Pre App 2 Pre App 2 Update

04/06/19 02/07/19

CLIENT

CONSULTANTS

Project Manager

DRAWING KEY

PROJECT

NORTH

Existing Plan with Red Line Boundary

J4 Projects

QS

MottMacDonald

Interiors Architect

Kay Elliott

Structural Engineers

ARUP

MEP Engineers

ARUP

Planning Consultant

Turley

Landscape Architects Grossmax

DRAWING

ADDRESS

The Recreation Ground Spring Gardens Bath BA2 4DS

SCALE

1 : 1000 @A1

DRAWN

CHECKED

AUTHORISED

IP

JP

PS

GRIMSHAW PROJECT NO.

STATUS

DRAWING NUMBER

SFB

FOR INFORMATION

SFB - GAL - XX - RF - DR - A - 05001

REVISION

2

Appendix 2:

Previous BANES Scoping response dated 23rd October 2013

Appendix 3:

Proposed Landscape and Visual Impact Assessment Representative Viewpoints (May 2019)

Stadium for Bath Proposed Landscape and Visual Impact Assessment Representative Viewpoints |

May 2019 |

NPA 11002 |

Contents Figures Figure 1: Representative viewpoint locations in local area

Figure 18: Viewpoint 16

Figure 2: Representative viewpoint locations in wider area

Figure 19: Viewpoint 17

Figure 3: Viewpoint 1

Figure 20: Viewpoint 18

Figure 4: Viewpoint 2

Figure 21: Viewpoint 19

Figure 5: Viewpoint 3

Figure 22: Viewpoint 20

Figure 6: Viewpoint 4

Figure 23: Viewpoint 21

Figure 7: Viewpoint 5

Figure 24: Viewpoint 22

Figure 8: Viewpoint 6

Figure 25: Viewpoint 23

Figure 9: Viewpoint 7

Figure 26: Viewpoint 24

Figure 10: Viewpoint 8

Figure 27: Viewpoint 25

Figure 11: Viewpoint 9

Figure 28: Viewpoint 26

Figure 12: Viewpoint 10

Figure 29: Viewpoint 27

Figure 13: Viewpoint 11

Figure 30: Viewpoint 28

Figure 14: Viewpoint 12

Figure 31: Viewpoint 29

Figure 15: Viewpoint 13

Figure 32: Viewpoint 30

Figure 16: Viewpoint 14 Figure 17: Viewpoint 15

PROPOSED STADIUM FOR BATH

PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

| May 2019 | 11002 ARENA

Contents STADIUM FOR BATH Proposed representative viewpoints for assessment within LVIA – for EIA Scoping Nicholas Pearson Associates – May 2019.

Proposed viewpoints to be for day time assessment used for preparation of visually verifiable montages (VVM)/ accurate visual representations (AVR) are indicated, with asterisk indicating VVM/ AVR to be prepared for night time views on non event occasions.

This comprises a list of representive viewpoints, to be used within Landscape and Visual Impact Assessment. It was subject to consultation/ agreement with B&NES in April Comprehensive/ integrated approach to establishing the visual baseline and identifying 2018. List of viewpoints as shown on following figures 1 and 2, followed by the viewpoint Representative view selection has considered; photographs. The viewpoint selection is based upon: • The different areas from which the development may be visible – closer to and - GLVIA requirement to provide a proportionate number of viewpoints from both more distant from the site and from different locations around the city. local and more distant locations from around the site which allow assessment on the visual effect of the development.

• The different groups of people who may experience the views -

Previous consultations with B&NES and other stakeholders on the views to be included within LVIA.

•

Designations (eg. WHS, WHS Setting, AONB, listed buildings) and noted viewpoints/ key location

-

Review of WHS SPD document – which identifies key Bath/ WHS views.

•

Visual setting of Listed buildings/ structures and key heritage issues.

-

Consideration of key heritage assets and values.

-

The proposed planning application boundary.

-

Consideration given to views of The Recreation Ground overall.

The list of proposed viewpoints include reason(s) for inclusion noting that all viewpoints will variously have reference to the City of Bath World Heritage Site designation, as whole, and/ or WHS setting (as per SPD) and Bath Conservation Area with associated values.

PROPOSED STADIUM FOR BATH

PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

| May 2019 | 11002 ARENA

View Location no.

1 Grand Parade looking east

2

3

4

Distance from site <100m

Orange Grove (eastern edge) <100m

Terrace Walk looking east

<100m

150m

5

East end of Abbey/ Orange Grove Parade Gardens

6

North Parade/ Duke Street

150m

7

North Parade bridge

<100m

8

Riverside footpath (north of North Parade bridge)

<100m

Riverside footpath, Spring Gardens Road Riverside footpath adjacent to Beazer Gardens Riverside footpath adjacent to existing NW gate into Rec Riverside footpath adjacent to existing west stand Riverside footpath, rear of Hilton Hotel Johnstone Street (looking S)

150m

9 10 11 12 13 14

<100m

Visual settings of Listed Buildings

0m

Visual settings of Listed Buildings Sequential riverside view Visual settings of Listed Buildings Sequential riverside view Visual settings of Listed Buildings

0m 200m 5m

Johnstone Street (looking SE) 5m

16

Recreation Ground (NE part) 0m

PROPOSED STADIUM FOR BATH

| May 2019 | 11002 ARENA

VVM/ AVR Yes *

View to hillsides/ AONB Visual settings of Listed Buildings Noted sequential view View to hillsides/ AONB Yes Visual settings of Listed Buildings Noted sequential view View to hillsides/ AONB Yes Visual settings of Listed Buildings Noted sequential view View to hillsides/ AONB Visual settings of Listed Buildings Reg. Park & Garden View of river Visual settings of Listed Buildings View to hillsides/ AONB Visual settings of Listed Buildings Noted heritage context View to Pulteney Bridge Yes * Visual settings of Listed Buildings View to Pulteney Bridge/ Grand Parade Visual settings of Listed Buildings Sequential riverside view Sequential riverside view

20m

15

PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

Key reference & other

View to hillside Visual settings of Listed Buildings View to hillside Visual settings of Listed Buildings View to hillside View of Abbey Visual settings of Listed Buildings

View Location no.

17 Great Pulteney Street/ William Street 18 Vane Street, near Pulteney Road 19 St Maryâ&#x20AC;&#x2122;s Church, Bathwick

Distance from site 30m

250m

20 21

Pulteney Road Camden Crescent

200m 750m

22

North Road

850m

23

Sham Castle

1200m

24

Bathwick Fields

750m

25

Smallcombe Vale/ Widcombe Hill

1000m

26

Alexandra Park, Beechen Cliff 750m

27

Prior Park

1750m

28

1750m

29

Rainbow Woods, Claverton Down, Twerton Round Hill

30

Little Solsbury Hill

3000m

<100m

Yes

Yes Yes

* Night time visualisation

3250m

Key reference & other View to hillside Visual settings of Listed Buildings View to hills Visual settings of Listed Buildings View to hillside View of Abbey Visual settings of Listed Buildings Local view from east of site View from landmark View to hillside Visual settings of Listed Buildings View to hillside Visual settings of Listed Buildings View from landmark AONB View to/ from hillside Visual settings of Listed Buildings View from hillside AONB Visual settings of Listed Buildings View from hillside AONB Visual settings of Listed Buildings Landmark view View from hillside Visual settings of Listed Buildings Landmark view/ Reg. Park & Garden View from hillside Visual settings of Listed Buildings View from hillside Visual settings of Listed Buildings Landmark view Landmark view View from hillside AONB

VVM/ AVR Yes

Yes

Yes *

Yes

Yes *

Yes

Yes *

17 13

15

4

2

16

14

10 11

1

18

19

20

12

5

8

3

7

6

9

Site location Local representative viewpoint locations Wider representative Viewpoint locations

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

01

DATE:

May 2019

PROJECT:

PROJECT STADIUM FOR BATH

TITLE:

ISSUE STATUS:

EIA SCOPING

Proposed local representative viewpoint locations

30

21

22 23 24

25

26

29

28 27

Site location Wider representative Viewpoint locations

0

0.5

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

02

DATE:

May 2019

PROJECT:

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Site location plan, wider representative viewpoint locations

1km

Viewpoint 1: Grand Parade looking east.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

03

DATE:

May 2019

PROJECT:

Viewpoint 1

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 2: Orange Grove (eastern edge).

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

04

DATE:

May 2019

PROJECT:

Viewpoint 2

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 3: Terrace Walk looking east.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

05

DATE:

May 2019

PROJECT:

Viewpoints 3

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 4: East end of Abbey/ Orange Grove.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

06

DATE:

May 2019

PROJECT:

Viewpoint 4

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 5: Parade Gardens.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

07

DATE:

May 2019

PROJECT:

Viewpoint 5

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 6: North Parade/ Duke Street.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

08

DATE:

May 2019

PROJECT:

Viewpoint 6

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 7: North Parade bridge.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

09

DATE:

May 2019

PROJECT:

Viewpoint 7

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 8: Riverside footpath (north of North Parade bridge).

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

10

DATE:

May 2019

PROJECT:

Viewpoint 8

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 9: Riverside footpath, Spring Gardens Road.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

11

DATE:

May 2019

PROJECT:

Viewpoint 9

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 10: Riverside footpath adjacent to Beazer Gardens.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

12

DATE:

May 2019

PROJECT:

Viewpoint 10

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 11: Riverside footpath adjacent to existing NW gate into Rec. PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

13

DATE:

May 2019

PROJECT:

Viewpoint 11

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 12: Riverside footpath adjacent to existing west stand.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

14

DATE:

May 2019

PROJECT:

Viewpoint 12

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 13: Riverside footpath, rear of Hilton Hotel.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

15

DATE:

May 2019

PROJECT:

Viewpoint 13

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 14: Johnstone Street (looking S).

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

16

DATE:

May 2019

PROJECT:

Viewpoint 14

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 15: Johnstone Street (looking SE).

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

17

DATE:

May 2019

PROJECT:

Viewpoint 15

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 16: Recreation Ground (NE part).

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

18

DATE:

May 2019

PROJECT:

Viewpoint 16

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 17: Great Pulteney Street/ William Street.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

19

DATE:

May 2019

PROJECT:

Viewpoint 17

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 18:Vane Street, near Pulteney Road.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

20

DATE:

May 2019

PROJECT:

Viewpoint 18

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 19: St Maryâ&#x20AC;&#x2122;s Church, Bathwick.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

21

DATE:

May 2019

PROJECT:

Viewpoint 19

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 20 Pulteney Road.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

22

DATE:

May 2019

PROJECT:

Viewpoint 20

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 21: Camden Crescent.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

23

DATE:

May 2019

PROJECT:

Viewpoint 21

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 22: North Road.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

24

DATE:

May 2019

PROJECT:

Viewpoint 22

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 23: Sham Castle.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

25

DATE:

May 2019

PROJECT:

Viewpoint 23

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 24: Bathwick Fields.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

26

DATE:

May 2019

PROJECT:

Viewpoint 24

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 25: Smallcombe Vale/ Widcombe Hill.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

27

DATE:

May 2019

PROJECT:

Viewpoint 25

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 26: Alexandra Park, Beechen Cliff.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

28

DATE:

May 2019

PROJECT:

Viewpoint 26

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 27: Prior Park.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

29

DATE:

May 2019

PROJECT:

Viewpoint 27

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 28: Rainbow Woods, Claverton Down.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

30

DATE:

May 2019

PROJECT:

Viewpoint 28

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 29: Twerton Round Hill.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

31

DATE:

May 2019

PROJECT:

Viewpoint 29

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Viewpoint 30: Little Solsbury Hill.

PROJECT NO:

11002

CLIENT:

ARENA 1865

FIGURE NO:

32

DATE:

May 2019

PROJECT:

Viewpoint 30

ISSUE STATUS:

EIA SCOPING

STADIUM FOR BATH PROPOSED LVIA REPRESENTATIVE VIEWPOINTS

TITLE:

Appendix 4:

LVIA Baseline

Copyright of Turley This drawing is for illustra ve purposes only and should not be used for any construc on or es ma on purposes. To be scaled for planning applica on purposes only. No liability or responsibility is accepted arising from reliance upon the informa on contained within this drawing.

n

Plans reproduced by permission of Ordnance Survey on behalf of The Controller of Her Majesty’s Sta onery Office. © Crown Copyright and database right [2018]. All rights reserved. Ordnance Survey Licence number [100020449]

x

Application Site Study Area (500m) The City of Bath World Heritage Site The Bath Conservation Area Registered Parks and Gardens Scheduled Monument

Listed Buildings Individual listed buildings within the 500m Study Area Listed Building Group 1 Great Pulteney Street Terraces Listed Building Group 2 Edward Street Terraces Listed Building Group 3 Pulteney Mews Listed Building Group 4 Johnstone Street Terraces Listed Building Group 5 Argyle Street Listed Building Group 6 Pulteney Bridge Listed Building Group 7 Parade Gardens Listed Building Group 8 Terrace walk / north parade Listed Building Group 9 North Parade / Duke Street Listed Building Group 10 Raby Place Listed Building Group 11 Darlington Place Within the Site Boundary Listed Buildings outside the 500m Study Area

Ref 1 2 3

Registered Park and Garden PARADE GARDENS, BATH SYDNEY GARDENS PRIOR PARK

Grade II II I

CLIENT:

Arena 1865 Limited

PROJECT:

Stadium for Bath Ref Scheduled Monuments 1 The Eastgate, Bath DRAWING:

Heritage Asset Plan

PROJECT NUMBER:

AREH3002 DRAWING NUMBER:

CHECKED BY:

GIS_100

KL

REVISION:

STATUS:

1.4

Dra

DATE:

SCALE:

July 2019

@ A3

Ref 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

Within the 500m Study Area NEWMARKET ROW GUILDHALL MARKET EAST GATE EMPIRE HOTEL VICTORIA ART GALLERY AND LIBRARY THE OLD POLICE STATION GUILDHALL ABBEY CHURCH OF ST PETER AND ST PAUL 1-7, ORANGE GROVE OBELISK ROMAN CATHOLIC CHURCH OF ST JOHN NORTH PARADE BRIDGE 24-29, PULTENEY ROAD CHURCH OF ST MARY 1-4, BATHWICK TERRACE

Grade II II II* II II* II I I II II* II* II II II* II

Ref Group 3 OFFICE ADJOINING ST JOHN'S AMBULANCE 38 HEADQUARTERS 39 ST JOHN'S AMBULANCE HEADQUARTERS

Grade

Ref

Group 1 1-7, GREAT PULTENEY STREET (See details for further address informa on) 8-20, GREAT PULTENEY STREET NOS. 21-27 (CONSEC) AND ATTACHED RAILINGS AND GATES NOS. 28-31 (CONSEC) AND ATTACHED RAILINGS AND GATES NOS. 32-34 (CONSEC) AND ATTACHED RAILINGS AND GATES NOS. 35-39 (CONSEC) AND ATTACHED RAILINGS AND GATES 40, GREAT PULTENEY STREET 41A, GREAT PULTENEY STREET 42-52, GREAT PULTENEY STREET 53-65 Great Pulteney Street and a ached lamp standards to No. 59 66-77, GREAT PULTENEY STREET NOS. 7, 8 AND 9 NOS. 10, 11, AND 12 NOS. 1, 2 AND 3 1, HENRIETTA STREET FOUNTAIN

Grade

Ref 40 41 42 43 44

Group 4 1-8, JOHNSTONE STREET 2-5, HENRIETTA STREET 9-15, JOHNSTONE STREET 6-19, HENRIETTA STREET 20-35, HENRIETTA STREET

Grade I I I I I

Ref 45 46 47 48

Group 5 1-5, ARGYLE STREET 6, ARGYLE STREET 7, ARGYLE STREET 8-17, ARGYLE STREET

Grade II II II II*

Ref 49 50 51

Group 6 PULTENEY BRIDGE SHOPS NOS 1 TO 8 (CONSEC) SHOPS NOS 9 TO 17 (CONSEC)

Grade I I I

16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

Ref Group 2 32 1, EDWARD STREET 33 2-5, EDWARD STREET NOS. 6-10 (CONSEC) AND ATTACHED RAILINGS, 34 GATES AND OVERTHROWS NOS. 12-17 (CONSEC) AND ATTACHED RAILINGS, 35 GATES AND OVERTHROW KIRKNESS HOUSE AND ATTACHED PIERS, RAILINGS 36 AND LAMP STANDARDS 37 1-5, VANE STREET

I I I

II II

I I I I I I I I I I I I II

Grade II II II II II* II

Ref Group 7 COLONNADES, BALUSTRADING, STEPS AND KIOSK AT 52 PARADE GARDENS 53 EDWARD VII MEMORIAL IN PARADE GARDENS RETAINING WALL WITH BALUSTRADE TO PARADE 54 GARDENS, AND THE VAULTS BENEATH

Grade

Ref 55 56 57 58 59 60 61 62 63 64 65 66 67

Group 8 9, TERRACE WALK 7 AND 8, TERRACE WALK 6, TERRACE WALK 4 AND 5, TERRACE WALK THE ALE HOUSE BRIDGWATER HOUSE THE HUNTSMAN PUBLIC HOUSE COMPASS ABBEY HOTEL (PART) COMPASS ABBEY HOTEL (PART) 4, NORTH PARADE 5, NORTH PARADE 6, NORTH PARADE FOUNTAIN

Grade II II II II II II II* II* II* II* II* II* II

Ref 68 69 70 71 72 73

Group 9 7-12, NORTH PARADE NORTH PARADE HOUSE GEORGIAN HOUSE AND ATTACHED RAILINGS 14, NORTH PARADE DELIA'S GROTTO IN GARDEN OF NO. 14 NOS. 6-11(CONSEC) AND ATTACHED RAILINGS

Grade I I I I I I

Ref Group 10 74 1-17, RABY PLACE 75 18, RABY PLACE

II II II

Grade II* II

Ref 76 77 78 79 80 81 82

Group 11 1-8, DARLINGTON PLACE 9 AND 10, DARLINGTON PLACE 11, 12 AND 13, DARLINGTON PLACE 14 AND 15, DARLINGTON PLACE 16, DARLINGTON PLACE 17 AND 18, DARLINGTON PLACE 19 AND 20, DARLINGTON PLACE

Grade II II II II II II II

Ref Listed Buildings outside the 500m Study Area 83 SHAM CASTLE PRIOR PARK COLLEGE: THE MANSION WITH LINK 84 ARCADES

Grade II*

Ref Within site boundary 85 President's Lounge, Bath Rugby Club 86 Sports Pavilion at the Bath Recrea on Ground ENTRANCE KIOSKS AND GATES TO RECREATION 87 GROUND VIADUCT LEADING TO NORTH PARADE BRIDGE, 88 WITH ASSOCIATED LODGES

Grade II II

I

II II

Copyright of Turley

n

This drawing is for illustra ve purposes only and should not be used for any construc on or es ma on purposes. To be scaled for planning applica on purposes only. No liability or responsibility is accepted arising from reliance upon the informa on contained within this drawing.

Plans reproduced by permission of Ordnance Survey on behalf of The Controller of Her Majesty’s Sta onery Office. © Crown Copyright and database right [2018]. All rights reserved. Ordnance Survey Licence number [100020449]

Application Site Study Area (500m) The City of Bath World Heritage Site The Bath Conservation Area Registered Parks and Gardens Scheduled Monument Listed Buildings Individual listed buildings within the 500m Study Area Listed Building Group 1 Great Pulteney Street Terraces Listed Building Group 2 Edward Street Terraces Listed Building Group 3 Pulteney Mews Listed Building Group 4 Johnstone Street Terraces Listed Building Group 5 Argyle Street Listed Building Group 6 Pulteney Bridge Listed Building Group 7 Parade Gardens Listed Building Group 8 Terrace walk / north parade Listed Building Group 9 North Parade / Duke Street Listed Building Group 10 Raby Place Listed Building Group 11 Darlington Place Within the Site Boundary

Appendix 5:

Heritage Asset Plan

Bath Rugby Stadium for Bath

LVIA Baseline Summary

Landscape and Visual Impact Assessment (LVIA) The LVIA will form a technical chapter of the Environmental Statement and will identify the landscape character and visual context and amenity, in terms of receptors, of the Site at The Recreation Ground, Bath and assesses the impacts of the proposed upon the same. These issues have been identified as sensitive, and impacts potentially significant, due to the site location in the centre of Bath, within the Bath World Heritage Site, the Bath Conservation Area and approximately 400m from the Cotswolds Area of Outstanding Natural Beauty (AONB), with associated actual and potential visibility from a wide area around the city and environs.

The assessment will reference the methodology set out in 'Guidelines for Landscape and Visual Assessment (3rd Ed, Landscape Institute and IEMA, 2013) which provides the most up to date guidance for LVIA. It also draws upon the Bath World Heritage Site (WHS) Setting Study Supplementary Planning Document (SPD) since this document provides useful background on the WHS context and key viewpoints. Reference will also be made to relevant Historic England guidance.

The LVIA will be prepared in close collaboration with the Heritage Impact Assessment, and will consider daytime and night time effects.

Baseline summary Landscape Assessment Key background documents; 

National Planning Policy Framework (NPPF)



Planning Practice Guidance – Natural Environment; Landscape



Core Strategy (B&NES)



Place Making Plan (B&NES)



City of Bath World Heritage Site (WHS) Management Plan (B&NES)



City of Bath WHS Setting Study (B&NES)



Bath Conservation Area Character Appraisals (B&NES)

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 1

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary



City Wide Character Appraisal (B&NES Adopted SPD, 2005)



Cotswold Area of Outstanding Natural Beauty (AONB); Landscape Character Assessment and Management Plan



Bath Building Heights Strategy (B&NES 2010)



Bath Public Realm and Movement Strategy (B&NES SPD)

Receptors: 

Overall city - WHS and Bath Conservation Area; OUVs - Georgian town planning Georgian architecture; the green setting of the City in a hollow in the hills



Open landscape south east/ east of city - Cotswold AONB (including National Trust land)



The Recreation Ground



The local river corridor, including riverside path



Eastern edge of city centre (Grand Parade, Orange Grove, North Parade), west of river; local character area



Parade Gardens



East of city centre and eastern suburbs (Bathwick, Pulteney); local landscape character area



The Recreation Ground

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 2

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

(tables referenced relate to those in Bath WHS Setting SPD document appendix 9) Ref

Receptor

Site contribution

Value of Receptor (Asset table 2)

Susceptibility to proposed change

Sensitivity to proposed change

A

Overall city

Small element of open landscape east of city centre, with some built form

High

Low

Moderate

WHS Conservation Area Overall urban form

Existing facility Scale of development as proportion of city

High

Negligible/ low

Cotswold AONB National Trust land WHS Setting & part of OUV

Distance from site

High

Moderate

WHS/ Conservation Area Open space in city Trees

Existing facility Some poor existing built form

High

Low/ Moderate

WHS/ Conservation Area A defining element of city Setting of/ for key built form

Some poor existing built form

High

Moderate

WHS/ Conservation Area Some defining elements of city

Relationship between/ with site

B

C

D

E

Open landscape south east/ east of city

The Recreation Ground

Local river corridor

Eastern edge of city centre

ARENA/NPA/11002 LVIA baseline summary - April 2018

Small element of AONB setting as part of the city

Site forms substantial part of receptor

Western edge of site, distinctive element of local character; riverside trees

Landscape some detracting elements â&#x20AC;&#x201C; built form

Page - 3

Low/ moderate

Moderate/ high

Moderate

Moderate

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

Ref

Receptor

F

Parade Gardens

G

East of city centre and eastern suburbs

LVIA Baseline Summary

Site contribution

Value of Receptor (Asset table 2) Setting of/ for key built form Public realm

Susceptibility to proposed change Local setting

Sensitivity to proposed change

High

Moderate

Moderate

WHS/ Conservation Area Registered Park and Garden Open space in city Setting of/ for key built form Public realm

Relationship between/ with site Local setting

High

Moderate

WHS/ Conservation Area Built form

Relationship between/ with site Local setting

Moderate

Night time The Rec is normally unlit, except for very limited external/ emergency lighting. There is some influence from adjacent street and residential lighting. The site overall presents a relatively low lit area of the city.

For evening and winter afternoon rugby matches, and a time before and after matches, the floodlights, and other ancillary lights are switched on, and hence during this period the Rec is a highly lit area.

River corridor - the riverside path has a number of â&#x20AC;&#x2DC;streetâ&#x20AC;&#x2122; lights which provide local lighting. Some architectural feature lighting is present on Pulteney Bridge and along the colonnades. There is some general light spill from the adjacent city centre. It is a low lit area.

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 4

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

City centre – this includes a range of street lights, architectural lighting (Abbey) and light spill from buildings. It is a highly lit area.

Other urban areas - these include a range of street lights, and light spill from buildings. It is a low/ moderately lit area.

Open landscape east of city centre – these areas have very limited lighting, that existing relating to occasional street lights and that associated with residential dwellings. The lighting of the University at Claverton has both a local and wider influence on the character. It is dark/ very low lit area.

Overall city – the varied lighting associated with street lights, architectural lighting and that from buildings presents a highly lit area, with areas of relative darkness associated with parks and open spaces.

Overall site sensitivity to new lighting – moderate/ high; this balances the existing ‘normal’ dark site conditions with the the urban location, with the overall extent of lighting; reducing to negligible/ low during temporary match time lighting.

Visual Baseline Integrated approach to establishing the visual baseline and identifying Representative views considering; 

The areas from which the development may be visible – including use of Zone of Theoretical Visibility.



The different groups of people who may experience the views.



The viewpoints where they will be affected.



WHS Setting study – identified views.



Visual setting of Listed buildings/ structures.

Due to the urban location it is not considered relevant this instance to establish approximate or relative numbers of different groups of people affected.

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 5

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

Visual context identifying zones of visibility Zone/ area

Specific locations within zone

Receptors

Values

Nature of view

Proposed representative viewpoints

Grand Parade Orange Grove High Street/ Cheap Street Terrace Walk North Parade Parade Gardens

Pedestrians; cyclists, drivers; Residential Restaurants Places of work Hotels

WHS criteria - views to hillsides.

Generally transient and/ or sequential.

Static from residential.

Views of river corridor Views from/ setting of Listed buildings

Low level, panoramic

1. Grand Parade looking east 2.Orange Grove 3.Terrace Walk looking east 4. East end of Abbey 5. Parade Gardens 6. North Parade/ Duke Street 7. North Parade Bridge

Relationship with site City centre Site/ western boundary in foreground

Conservation Area

Easterly and south easterly aspect Urban location with views toward eastern suburbs hillside of Claverton Down / Rainbow Woods

Key tourist/ city location Great Pulteney Street and environs Site in foreground

Gt Pulteney St Laura Place Argyle St Johnstone Street William Street

Pedestrians; cyclists, drivers; Residential Places of work Hotels

WHS criteria - views to hillsides.

Generally transient and/ or sequential.

Static from residential.

Views from/ setting of Listed buildings

Low level, enclosed, some panoramic Generally southerly aspect

14. Johnstone Street, looking south 15. Johnstone Street looking SE 17. Gt Pulteney St/ William St

Conservation Area Key tourist/ city location

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 6

Urban location with views across site toward hillside of Rainbow Woods/ Prior Park/ Beechen Cliff

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

Zone/ area

LVIA Baseline Summary

Specific locations within zone

Receptors

Values

Nature of view

Proposed representative viewpoints

The â&#x20AC;&#x2DC;Recâ&#x20AC;&#x2122; facility Sports/ Leisure facilities Pathway

Sport participants Pedestrians Users of facilities

WHS Conservation Area

Transient and/ or sequential.

16.Recreation Ground, looking west

Relationship with site The Recreation Ground Site in foreground

Riverside path and river Site/ western boundary in foreground/ edge of view

Low level, panoramic setting of Listed buildings

Section between Pulteney Bridge and Spring Gardens Road

Pedestrians Cyclists Boat users

WHS Conservation Area Historic views along river setting of Listed buildings

Generally westerly and southerly aspect Urban open space location with views across site toward city centre, Rainbow Woods/ Prior Park/ Beechen Cliff Transient and/ or sequential.

Enclosed/ framed views.

Generally northerly or southerly aspect Urban open space location with views of city centre, Beechen Cliff to south, Camden/ Beacon Hill to north

8.Riverside footpath (north of North Parade bridge) looking north 9.Riverside footpath, Spring Gardens Road, (south of North Parade bridge) looking north 10.Riverside footpath adjacent to Beazer Gardens and radial gate, looking south 11. Riverside footpath adjacent to existing gate into Recreation Ground, looking south/ south east

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 7

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

Zone/ area

LVIA Baseline Summary

Specific locations within zone

Receptors

Values

Nature of view

Relationship with site

Proposed representative viewpoints

12. Riverside footpath adjacent to existing west stand looking south toward North Parade 13. Riverside footpath, rear of Hilton Hotel, Walcot Street, looking south Bathwick – lower elevations (at or below K&A canal) Site in mid distance – city centre as backdrop

ARENA/NPA/11002 LVIA baseline summary - April 2018

Pulteney Road Vane Street Bathwick Hill (near roundabout) Canal towpath

Pedestrians; cyclists, drivers; Residential Restaurants Places of work Hotel guests Place of worship (St Mary’s Church)

WHS Conservation Area Views to/ from/ setting of Listed buildings Views towards Abbey

Generally transient and/ or sequential.

Static from residential.

Low level, varied, some panoramic Generally westerly aspect

18. Vane Street, near Pulteney Road looking south west 19. St Mary’s Church, Bathwick 20. Pulteney Road

Urban/ suburban location with views toward city centre/ Beechen Cliff

Page - 8

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

Zone/ area

LVIA Baseline Summary

Specific locations within zone

Receptors

Values

Nature of view

Proposed representative viewpoints

Camden Crescent Camden Road Beacon Hill Mt Beacon

Pedestrians; cyclists, drivers; Residential

WHS Conservation Area Views to/ from Listed buildings Historic views over city

Transient and/ or sequential.

Static from residential

21. Camden Crescent, looking south

Relationship with site Camden/ Beacon Hill environs Site set down - seen as part of city – in mid distance

Elevated positions, panoramic Generally southerly aspect Urban/ suburban location with views toward/ across city centre to Beechen Cliff/ Prior Park

Bathwick – higher elevations Site set down - seen as part of city – in mid distance – city centre as backdrop

Widcombe Hill environs

ARENA/NPA/11002 LVIA baseline summary - April 2018

North Road Bathwick Fields (National Trust land/ Bath Skyline Walk) Bathwick Hill Sydney Buildings St Anne’s Way and adjoining streets

Pedestrians; cyclists, drivers; Residential

Widcombe Hill Smallcombe Vale (National Trust land/ Bath Skyline Walk)

Pedestrians; cyclists, drivers; Residential

WHS Conservation Area Views to/ from Listed buildings Historic views over city

Transient and/ or sequential.

Static from residential

22. North Road, Bathwick, looking west

Elevated positions, panoramic

24. Bathwick Fields, looking west

Generally westerly aspect Suburban/ city edge/ open space locations with views toward/ across city centre Beechen Cliff/ western parts of city

WHS Conservation Area Views to/ from Listed buildings Page - 9

Transient and/ or sequential.

Static from residential

25. Smallcombe Vale/ Widcombe Hill, looking north west

Elevated positions, panoramic NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

Zone/ area Relationship with site Site set down - seen as part of city – in mid distance – city centre as backdrop

LVIA Baseline Summary

Specific locations within zone

Receptors

Macauley Buildings

Values

Nature of view

Historic views over city Skyline walk AONB

Generally westerly and north westerly aspect

Proposed representative viewpoints

Suburban/ urban edge/open space locations with views toward/ across city centre Beechen Cliff/ Lansdown Claverton Down

Sham Castle Bath Skyline Walk

Pedestrians

Site set down - seen as part of city – in mid distance – city centre as backdrop

Prior Park and environs Site set down - seen as part of city – in mid/ far distance

ARENA/NPA/11002 LVIA baseline summary - April 2018

Prior Park College Prior Park Garden (National Trust) Public footpath (Rainbow Woods)

Pedestrians School

WHS Views to/ from Listed buildings Historic views over city Skyline walk AONB

WHS Registered Park and Garden Views to/ from Listed buildings Historic views over city Registered Park and Garden

Page - 10

Transient and/ or sequential.

23. Sham Castle, looking west

Elevated positions, panoramic Generally westerly aspect Urban edge/rural/ open space locations with views toward/ across city centre to Beechen Cliff/ Lansdown Transient and/ or sequential.

Elevated positions, framed and panoramic Generally northerly aspect

27. Prior Park, looking north 28. Rainbow Woods, Claverton Down, north of The Priory

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

Zone/ area

LVIA Baseline Summary

Specific locations within zone

Receptors

Values

Nature of view

Relationship with site

Proposed representative viewpoints

Urban edge/rural/ open space locations with views toward/ across city centre / western parts of city/ Lansdown Beechen Cliff and environs Site set down - seen as part of city â&#x20AC;&#x201C; in mid/ far distance

Alexandra Park Alexandra Road Shelley Road

Pedestrians Residential

WHS Conservation Area Views to Listed buildings Historic views over city Key tourist/ city location

Transient and/ or sequential.

Static from residential

26. Alexandra Park, Beechen Cliff looking north

Elevated positions, framed and panoramic Generally north/ NE aspect Urban open space locations with views toward/ across city centre Beechen Cliff/ western parts of city/ Lansdown

Western city elevated views

Twerton Round Hill Kelston View Kelston Round Hill

Pedestrians; cyclists, drivers; Residential

WHS Historic views over city

Site set down - seen as part of city â&#x20AC;&#x201C; in far distance

ARENA/NPA/11002 LVIA baseline summary - April 2018

Elevated positions, panoramic

29. Twerton Round Hill looking east

Generally north and easterly aspect Urban edge/ suburban open space locations with views toward/ across city centre Beechen Cliff/ eastern parts of city/ Lansdown/ Claverton Down / Bathampton Down

Page - 11

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

Zone/ area

LVIA Baseline Summary

Specific locations within zone

Receptors

Values

Nature of view

Proposed representative viewpoints

Little Solsbury Hill

Pedestrians

Historic Landmark Views across city

Elevated positions, panoramic

30. Little Solsbury Hill looking south west

Relationship with site Little Solsbury Hill Site set down - seen as part of city – in far distance

Southerly/ westerly aspect Rural location with views toward/ across city and surrounding hillsides; Beechen Cliff/ Lansdown/ Claverton Down / Bathampton Down

Night time views Views from city centre – highly lit location and context with views across unlit (normal condition) site or highly lit (temporary condition) Views along riverside – low lit location with context of highly lit city centre, with site either unlit (normal condition) site or highly lit (temporary condition) Views from other urban areas – low/ moderately lit location with views across/ to the highly lit city centre with the site either unlit (normal condition) site or highly lit (temporary condition) Views from open landscape beyond the city – very low lit context with views across moderately/ highly lit city with the site either unlit (normal condition) site or highly lit (temporary condition) Overall sensitivity to change to lighting condition is influenced by the distance from the site and whether views are transient or permanent (residential) and in relation to normal unit or temporary lit condition.

High sensitivity – local residential views of the unlit site

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 12

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

Low/ moderate sensitivity – views from wider city/ open landscapes of unlit site Low sensitivity – all views of temporary floodlit site conditions

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 13

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

Representative viewpoints – baseline summary table (tables referenced relate to those in Bath WHS Setting SPD document appendix 9) 

Receptor and view values relate to varied designations and noted landmarks



Receptor susceptibility influenced variously by extant built form and land use within an urban location, together with relative scale and of development and distance of viewpoint from site.

View No.

Location

Distance from site

Receptors

Key references

Value of view (table 2)

Receptor susceptibility to proposed change

Sensitivity

Duration/ type of view

Context of site in view

1

Grand Parade looking east

100m

All

View to wooded hillsides/ AONB View of river Visual settings of Listed Buildings

High

Moderate

Mod/ High

Transient/ static/ sequential

Near/ mid distance – part of open landscape

2

Orange Grove (eastern edge)

<100m

Pedestrians/ cyclists tourists, drivers

View to wooded hillsides/ AONB View of river Visual settings of Listed Buildings

High

Moderate

Mod/ High

Transient/ sequential

Near/ mid distance – part of open landscape

3

Terrace Walk looking east

100m

Pedestrians/ cyclists/ tourists, drivers

View to wooded hillsides/ AONB Visual settings of Listed Buildings

High

Moderate

Mod/ High

Transient/ sequential

Near/ mid distance – part of open landscape

4

East end of Abbey

200m

Pedestrians/ cyclists tourists,

View to Bathwick, wooded hillsides/ AONB Visual settings of Listed Buildings

High

Moderate

Mod/ High

Transient/ sequential

Not visible – visual dead ground

5

Parade Gardens

25m

Pedestrians/ tourists

Reg. Park View of river Visual settings of Listed Buildings

High

Moderate

Mod/ High

Transient

Near distance – element of riverside corridor landscape

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 14

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

View No.

Location

Distance from site

Receptors

Key references

Value of view (table 2)

Receptor susceptibility to proposed change

Sensitivity

Duration/ type of view

Context of site in view

6

North Parade/ Duke Street

150m

Pedestrians/ cyclists/ tourists, drivers

View to Bathwick, wooded hillsides/ AONB Visual settings of Listed Buildings

High

Moderate

Mod/ High

Transient

Near distance – beyond sports centre

7

North Parade bridge

100m

Pedestrians /cyclists, drivers

View to Pulteney Bridge View of river Visual settings of Listed Buildings

High

Moderate

Mod/ High

Transient/ sequential

Near/ mid distance – part of framed view

8

Riverside footpath (north of North Parade bridge)

30m

Pedestrians / cyclists, boat users

View to Pulteney Bridge/ Grand Parade View of river Visual settings of Listed Buildings

High

Moderate

Mod/ High

Transient/ sequential

Near/ mid distance – part of framed view

9

Riverside footpath, Spring Gardens Road

150m

Pedestrians / cyclists, drivers, boat users

Historic route View of river

Moderate

Moderate/ low

Mod

Transient/ sequential

mid distance – part of framed view

10

Riverside footpath adjacent to Beazer Gardens

20m

Pedestrians / cyclists, boat users

Visual settings of Listed Buildings View of river

High

Moderate

Mod

Transient/ sequential

adjacent – part of framed view

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 15

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

View No.

Location

Distance from site

Receptors

Key references

Value of view (table 2)

Receptor susceptibility to proposed change

Sensitivity

Duration/ type of view

Context of site in view

11

Riverside footpath adjacent to existing NW gate into Rec

0m

Pedestrians / cyclists, boat users

Visual settings of Listed Buildings View of river Historic route

High

Moderate

Mod

Transient/ sequential

adjacent – part of framed view

12

Riverside footpath adjacent to existing west stand

0m

Pedestrians / cyclists, boat users

Visual settings of Listed Buildings View of river Historic route

High

Moderate

Mod

Transient/ sequential

adjacent – part of framed view

13

Riverside footpath, rear of Hilton Hotel

200m

Pedestrians

Visual settings of Listed Buildings View of river

Moderate

Low

Low

Transient/ sequential

Mid distance beyond intervening built form

14

Johnstone Street (looking south)

5m

Pedestrians / cyclists, residents

View to hills Visual settings of Listed Buildings

High

Mod/ high

Mod/ high

Transient/ static

adjacent – part of framed view

15

Johnstone Street (looking south east)

5m

Pedestrians / cyclists, residents

View to hills Visual settings of Listed Buildings

High

Mod/ high

Mod/ high

Transient/ static

adjacent – part of framed view

16

Recreation Ground

100m

Pedestrians, sports participants

View to hills Visual settings of Listed Buildings

High

Moderate

Mod

Transient/ sequential

Near distance – part of local panorama view

17

Great Pulteney Street/ William Street

30m

Drivers/ Pedestrians / cyclists, residents

View to hills Visual settings of Listed Buildings

High

High

Mod/ high

Transient/ static

adjacent – part of framed view

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 16

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

View No.

Location

Distance from site

Receptors

Key references

Value of view (table 2)

Receptor susceptibility to proposed change

Sensitivity

Duration/ type of view

Context of site in view

18

Vane Street, near Pulteney Road

150m

Pedestrians / cyclists, residents

View to hills; city centre Visual settings of Listed Buildings

Moderate

Moderate

Mod

Transient/ static

Mid distance – part of framed view

19

St Mary’s Church, Bathwick

300m

Pedestrians / cyclists, drivers

View to city centre; hills Visual settings of Listed Buildings

High

Low

Mod

Transient/ static

Glimpsed, mid distance – part of framed view

20

Pulteney Road, Bathwick

300m

Pedestrians / cyclists, drivers, residents, hotel

View to city centre; hills Visual settings of Listed Buildings

Moderate

Low

Low/ Mod

Transient/ static

Glimpsed, mid distance – part of framed view

21

Camden Crescent

750m

Pedestrians / cyclists, residents

View from landmark View to hills Visual settings of Listed Buildings

High

Low

Mod

Transient or static/ sequential

Limited part of city panorama

22

North Road

850m

Pedestrians / cyclists, residents

View to hills Visual settings of Listed Buildings

Moderate

Low

Low/ mod

Transient/ sequential

Limited part of city panorama

23

Sham Castle

1200m

Pedestrians

View from landmark/ AONB View to hills Visual settings of Listed Buildings

High

Mod

Mod/ high

Transient/ static

Limited part of city panorama

24

Bathwick Fields

750m

Pedestrians, residents

View from hills/ AONB Visual settings of Listed Buildings

High

Mod

Mod/ high

Transient/ sequential

Limited part of city panorama

25

Smallcombe Vale/ Widcombe Hill

1000m

Pedestrians, drivers residents

View from hills/ AONB Visual settings of Listed Buildings

High

Mod

Mod/ high

Transient or static/ sequential

Limited part of city panorama

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 17

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

View No.

Location

Distance from site

Receptors

Key references

Value of view (table 2)

Receptor susceptibility to proposed change

Sensitivity

Duration/ type of view

Context of site in view

26

Alexandra Park, Beechen Cliff

750m

Pedestrians,

Landmark view View from hills Visual settings of Listed Buildings

High

Mod

Mod/ high

Transient/ sequential

Limited part of city panorama

27

Prior Park

1750m

Pedestrians, school

Landmark view/ Reg. Park View from hills Visual settings of Listed Buildings

High

Mod

Mod/ high

Transient/ sequential

Very limited part of city panorama

28

Claverton Down, Rainbow Woods

1750m

Pedestrians,

View from hills Visual settings of Listed Buildings

High

Mod

Mod/ high

Transient/ sequential

Very limited part of city panorama

29

Twerton Round Hill

3250m

Pedestrians, residents

Landmark view

High

Low

Mod

Transient/ static

Barely perceptible

30

Little Solsbury Hill

3000m

Pedestrians,

Landmark view View from hills/ AONB

High

Low

Mod

Transient/ sequential

Barely perceptible

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 18

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

CITY OF BATH WORLD HERITAGE SITE SETTING - SUPPLEMENTARY PLANNING DOCUMENT - Site: Bath Recreation Ground Reference

Map

Viewpoint Location

Is development potentially visible?

Distance

Notes/ why not visible

Appendix 3 â&#x20AC;&#x201C; Selection of views 1

8a

Prospect Stile

N

Topography/ built form/ vegetation

2

8b

Beckford Tower

N

Topography/ built form/ vegetation

Landmark 2

8c

Area which Beckford Tower is visible from

N

Topography/ built form/ vegetation

2

8d

Lansdown Cemetery

N

Topography/ built form/ vegetation

3

8e

Lansdown Crescent

N

Topography/ built form/ vegetation

Landmark 3

8f

Area Lansdown Crescent is visible from

N

Topography/ built form/ vegetation

Approach Golf course

N

Topography/ built form/ vegetation

4 5

8g

Royal Crescent

N

Topography/ built form/ vegetation

Landmark 5

8h

Area Royal Crescent is visible from

N

Topography/ built form/ vegetation

6

The Circus

N

Topography/ built form/ vegetation

7

Terrace Walk view to Bathampton Down

Y

100m

Representative view 3

8

North Parade Bridge

Y

50m

Representative view 7

9

Old Newbridge Hill

N

Different direction

10

8i

Little Solsbury Hill

Y

3.2km

Representative view 30

11

8j

Camden Crescent

Y

900m

Representative view 21

Landmark 11

8k

Area Camden Crescent visible from

Y

12a

8l

Alexandra Park, Beechen Cliff (north)

Y

850m

representative view 26

12b

8m

Alexandra Park, Beechen Cliff (East)

N

Different direction

12c

8n

Alexandra Park, Beechen Cliff (South)

N

Different direction

12d

8o

Alexandra Park, Beechen Cliff (West)

N

Different direction

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 19

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

Reference

Map

Viewpoint Location

Is development potentially visible?

13

8p

Twerton Round Hill

N

Topography/ built form/ vegetation

Bloomfield Road

N

Topography/ built form/ vegetation

14 15

8q

Sham Castle

Y

Landmark 15

8r

Area Sham Castle visible from

Y

16

8s

Widcombe Hill

17

8t

Landmark 17

8u

18

Distance

Notes/ why not visible

1.15km

representative view 23

Y

1.2km

representative view 25

Prior Park

Y

2km

representative view 27

Area Prior Park is visible from

Y

Great Pulteney Street

Y

0-100m

Not visible in view from Sydney Place due to intervening buildings. Side streets - representative views 14/ 15/ 17

19

8v

Kelston View

N

Topography/ built form/ vegetation

20

8w

Primrose Hill

N

Topography/ built form/ vegetation

21

8x

Ralph Allens Carriage Drive/ Meare Road

N

Topography

22

8y

Ralph Allens Carriage Drive/ Bathampton Down

Y

23

8z

Ralph Allens Carriage Drive/ Limekiln Lane

N

Different direction

St James's Rampire

N

Topography/ built form/ vegetation

Gascoyn's Rampire (Seven Dials/ Saw Close)

N

Topography/ built form/ vegetation

Counter's Tower (north east corner of city wall)

N

Topography/ built form/ vegetation

The Orange Grove

Y

1.15km

representative view 23 and 28

Appendix 4 â&#x20AC;&#x201C; Historical views Inside Bath

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 20

120m

representative view 2 and 4

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

Reference

LVIA Baseline Summary

Map

Viewpoint Location

Is development potentially visible?

Distance

Notes/ why not visible

Terrace Walk

Y

100m

representative view 3

The Parades (North and South Parades)

Y

100m

representative view 5 and 6

Former Prior's House (North Parade Buildings)

Y

100m

representative view 6

The Shury Garden (south east part of city wall)

N

Topography/ built form/ vegetation

Topography/ built form/ vegetation

Places and sights outside Bath a

Beechen Cliff - eastern end around Lyncombe Hill

N

b

Beechen Cliff - from the crest

Y

c

Beechen Cliff - from the summit

N

Topography/ built form/ vegetation

d

Beechen Cliff - from the western end

N

Topography/ built form/ vegetation

a

Oldfield Park and Wells Road, toward Lansdown

N

Topography/ built form/ vegetation

b

Oldfield Park and Wells Road, toward Twerton

N

Different direction

Twerton Round Hill (High Barrow Hill)

Y

The Avon Valley West

N

Topography/ built form/ vegetation

5

Crescent Fields (in front of Royal Crescent)

N

Different direction

6

The Common (now Victoria Park)

N

Different direction

7

Sion Hill - looking south

N

Topography/ built form/ vegetation

8

Lansdown - generally west and south

N

Different direction

/

Beckford Tower

N

Topography/ built form/ vegetation

Belvidere - towards Beechen Cliff

N

Topography/ built form/ vegetation

1

2

3 4

9

a-e

a-b

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 21

850m

3.3km

representative view 26

representative view 29

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

Viewpoint Location

Is development potentially visible?

10

Beacon Hill (Camden Road)

Y

representative view 21

11

Grosvenor

N

Different direction

Reference

Map

Distance

Notes/ why not visible

12

a

Batheaston Villa

N

Different direction

12

b

Batheaston - St Catherine Valley - looking north

N

Different direction

12

c

Charmy Down Farm

N

Different direction

12

d

Little Solsbury Hill

Y

13

Shockerwick and Warleigh looking east

N

Different direction

14

Bathampton Down - The Rocks

N

Different direction

3.5km

representative view 30

15

a

Bathampton - towards Batheaston

N

Different direction

15

b

Kennet and Avon Canal

N

Topography/ built form/ vegetation

15

d

Meadows near Grosvenor Bridge

N

Topography/ built form/ vegetation

16

a-b

Bathwick looking west

Y

0-150m

representative view 22, 24 and 25

17

Sham Castle looking west

Y

1.15km

representative view 23

18

Claverton - various views

N

19

a-b

Widcombe Hill

Y

20

a-b

Lyncombe Vale and Widcombe Village

N

21

a-b

Prior Park

Y

22

The Lodge (now demolished), near Prior Park

N

23

The Southern Skyline (generally Foxhill to Bathampton Down)

Y

24

Combe Down looking south

N

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 22

Topography/ built form/ vegetation 1.2km

representative view 25 Different direction

2km

representative view 27 Topography/ built form/ vegetation

1.15km

representative view 27 and 28

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

Reference

LVIA Baseline Summary

Map

Viewpoint Location

Is development potentially visible?

Distance

Notes/ why not visible

Roads The Upper Bristol Road Kelston / Bitton K1

Road passing Kelston Park

N

Topography

K2

Road approaching junction with Penn Hill

N

Topography

K3

Old Newbridge Hill

N

Topography

K4

Down past Locksbridge Cemetry

N

Topography/ built form

K5

Into the city with Lower Common on the left

N

Topography

Lansdown North into the city L1

Plateau toward Bath and Lansdown Park and Ride

N

Topography

L2

At MOD complex

N

Topography

L3

Descending into the city, nr Lansdown Grove Hotel

N

Topography/ built form

L4

Anslies Belvedere, views into city

N

Topography/ built form

L5

Approaching cross road with London road

N

Topography/ built form

Fosse way into Batheaston and London Road L01

nr Ashwick Hall before descent to Batheaston

N

Different direction

L02

South across valley Bathampton Down in background

N

Different direction

L03

Passing the coaching inn of St George

N

Topography

L04

Narrow road through Batheaston

N

Topography

L05

Outskirts near Bailbrook

N

Topography

L06

Entering Bath along London Road Grosvenor Place on left

N

Topography/ built form

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 23

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

Reference

LVIA Baseline Summary

Map

L07

Viewpoint Location

Is development potentially visible?

Approaching junction with Bathwick Street

N

Topography

Distance

Notes/ why not visible

Brassnocker Road, Claverton Down Road and Widcombe Hill W1

Along Avon Valley toward Limpley Stoke

N

Different direction

W2

From Brassnocker Hill toward Combe Down Village

N

Different direction

W3

Top of Widcombe Hill towards City

N

Built form/ vegetaton

W4

Macauley Buildings

Y

1.2km

Widcombe Hill representative view 25

W5

Widcombe Hill North across Meadows

Y

1.2km

Widcombe Hill representative view 25

W6

Cottages lining lower part of Widcombe Hill

N

Built form/ vegetaton

W7

Views of Widcombe and St Andrews Church

N

Built form/ vegetaton

Upper Wellsway and Wellsway Wel1

Old Upper Bloomfield Road at junction with Englishcombe Lane

N

Different direction

Wel 2

Road near crossroad with Combe Hay Lane

N

Different direction

Wel 3

Gentle descent into Bath to the west of Entry Hill Golf Course

N

Different direction

Wel 4

Approaching junction with Old St Anthony Hill

N

Different direction

Wel 5

Distant views

N

Different direction

Wel 6

Junction with Old Warminster Road and Wells Road

N

Different direction

Wel 7

From modern Wells Way

N

Topography/ different direction

LBR1

Descending Hill from Saltford

N

Different direction

LBR2

Along flat river valley

N

Topography

Saltford to Bath

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 24

NICHOLAS PEARSON ASSOCIATES

Bath Rugby Stadium for Bath

LVIA Baseline Summary

Viewpoint Location

Is development potentially visible?

LBR3

Into old industrial district of Bath

N

Topography/ built form

LBR4

Flat land between steeper hills and river

N

Topography/ built form

Reference

Map

Distance

Notes/ why not visible

Rivers Views from the River into the City R1

Close to the site of The Old Bath Bridge, Widcombe, Beechen Cliff

N

Topography

R2

Towards North Parade Bridge with South Parade in foreground

Y

representative view 9

R3

North Parade Bridge looking back towards North Parade

Y

representative view 11

R4

Parade gardens to the west with Pulteney Bridge

Y

representative view 8

R5

Look at the 'back' elevation (N. facing facade) of Pulteney Bdge

Y

representative view 13

R6

Riverside path at Walcot

N

Built form/ vegetation

R7

Cleveland Bridge looking towards city

N

Built form/ vegetation

R8

From banks of Kensington Meadows Local Nature Reserve

N

Built form/ vegetation

R9

Close to probable site of Westhall Spa

N

Buildings

R10

River lock on Twerton Island

N

Vegetation

R11

Newbridge crossing the Avon

N

Topography

ARENA/NPA/11002 LVIA baseline summary - April 2018

Page - 25

NICHOLAS PEARSON ASSOCIATES

Appendix 6:

Zones of Theoretical Visibility (ZTV)

Copyright of Turley

n

This drawing is for illustra ve purposes only and should not be used for any construc on or es ma on purposes. To be scaled for planning applica on purposes only. No liability or responsibility is accepted arising from reliance upon the informa on contained within this drawing.

Plans reproduced by permission of Ordnance Survey on behalf of The Controller of Her Majesty’s Sta onery Office. © Crown Copyright and database right 2019. All rights reserved. Ordnance Survey Licence number [100020449]

ZTV extent 1000m / 500m ZTV Poten ally not visible Poten ally visible

CLIENT:

Arena 1865 Limited

PROJECT:

Recrea on Ground redevelopment, Bath

DRAWING:

ZTV

PROJECT NUMBER:

ARER3004 DRAWING NUMBER:

CHECKED BY:

GIS_100

KL

REVISION:

STATUS:

1.0

Dra

DATE:

SCALE:

May 2019

@ A3

Copyright of Turley

n

This drawing is for illustra ve purposes only and should not be used for any construc on or es ma on purposes. To be scaled for planning applica on purposes only. No liability or responsibility is accepted arising from reliance upon the informa on contained within this drawing.

Plans reproduced by permission of Ordnance Survey on behalf of The Controller of Her Majesty’s Sta onery Office. © Crown Copyright and database right 2019. All rights reserved. Ordnance Survey Licence number [100020449]

ZTV extent 1000m / 500m ZTV Poten ally not visible Poten ally visible

CLIENT:

Arena 1865 Limited

PROJECT:

Recrea on Ground redevelopment, Bath

DRAWING:

ZTV - wider

PROJECT NUMBER:

ARER3004 DRAWING NUMBER:

CHECKED BY:

GIS_101

KL

REVISION:

STATUS:

1.0

Dra

DATE:

SCALE:

May 2019

@ A3

Copyright of Turley

n

This drawing is for illustra ve purposes only and should not be used for any construc on or es ma on purposes. To be scaled for planning applica on purposes only. No liability or responsibility is accepted arising from reliance upon the informa on contained within this drawing.

Plans reproduced by permission of Ordnance Survey on behalf of The Controller of Her Majesty’s Sta onery Office. © Crown Copyright and database right 2019. All rights reserved. Ordnance Survey Licence number [100020449]

ZTV extent 1000m / 500m ZTV Poten ally not visible Poten ally visible

CLIENT:

Arena 1865 Limited

PROJECT:

Recrea on Ground redevelopment, Bath

DRAWING:

ZTV - Zoom

PROJECT NUMBER:

ARER3004 DRAWING NUMBER:

CHECKED BY:

GIS_102

KL

REVISION:

STATUS:

1.0

Dra

DATE:

SCALE:

May 2019

@ A3

Appendix 7:

Potential sensitive designated heritage assets

Designated Heritage Assets The following designated heritage assets were identified through desk based assessment, site visit and review of the ZTV to be potentially sensitive in relation to the Proposed Scheme. Further assessment was then carried out to identify likely significant effects.

Those assets scoped out of the ES are identified by an asterisk (*).

World Heritage Sites: ‒ The City of Bath World Heritage Site ‒

Great Spas of Europe Tentative World Heritage Site

Conservation Areas: ‒ The Bath Conservation Area Scheduled Monuments: ‒ The Eastgate, Bath (HAP ref 1)* ‒

The Roman Baths and site of Roman Town, Bath (HAP ref N/A)*

Registered Parks and Gardens: ‒ Parade Gardens (grade II RP&G, HAP ref 1) ‒

Sydney Gardens (grade II RP&G, HAP ref 2)*

‒

Prior Park (grade I RP&G, HAP ref 3)

Listed Buildings: Within the Site Boundary: ‒ Lime Kiln/ President’s Lounge, Bath Rugby Club (grade II listed building, HAP ref 85) ‒

Sports Pavilion at the Bath Recreation Ground (grade II listed building, HAP ref 86)

‒

Entrance Kiosks and Gates to Recreation Ground (grade II listed building, HAP ref 87)

‒

Viaduct leading to North Parade Bridge with associated Lodges (grade II listed building, HAP 88)

Within the 500m Study Area: ‒ Newmarket Row (grade II listed building, HAP ref 1) ‒

Guildhall Market (grade II listed building, HAP ref 2) *

‒

East Gate (grade II* listed building, HAP ref 3)*

‒

The Empire Hotel (grade II listed building, HAP ref 4)

‒

Victoria Art Gallery and Library, Bridge Street (grade II* listed building, HAP ref 5)

‒

The Old Police Station (grade II listed building, HAP ref 6)*

‒

Guildhall (grade I listed building, HAP ref 7)*

‒

The Abbey Church of St Peter and St Paul (grade I listed building, HAP ref 8)

‒

Nos. 1-7 Orange Grove (grade II listed building, HAP ref 9)

‒

Obelisk (grade II* listed building, HAP ref 10)

‒

Roman Catholic Church of St John (grade II* listed building, HAP ref 11)

‒

North Parade Bridge (grade II listed building, HAP ref 12)

‒

24 – 29 Pulteney Road (grade II listed building, HAP ref 13)

‒

Church of St Mary (grade II* listed building, HAP ref 14)

‒

1-4 Bathwick Terrace (grade II listed building, HAP ref 15)

Listed Building Group 1 - Great Pulteney Street Terraces: ‒

1-7 Great Pulteney Street, Nos. 4, 5 and 6 Laura Place and Nos. 36 and 37 Henrietta Street (grade I listed building, HAP ref 16)

‒

8-20 Great Pulteney Street (grade I listed building, HAP ref 17)

‒

Nos. 21-27 [Great Pulteney Street] (consec) and attached railings and gates (grade I listed building, HAP ref 18)

‒

Nos. 28-31 [Great Pulteney Street] (consec) and attached railings and gates (grade I listed building, HAP ref 19)

‒

Nos. 32-34 [Great Pulteney Street] (consec) and attached railings and gates (grade I listed building, HAP ref 20)

‒

Nos. 35-39 [Great Pulteney Street] (consec) and attached railings and gates (grade I listed building, HAP ref 21)

‒

40 Great Pulteney Street (grade I listed building, HAP ref 22)

‒

41A Great Pulteney Street (grade I listed building, HAP ref 23)

‒

42-52 Great Pulteney Street (grade I listed building, HAP ref 24)

‒

53-65 Great Pulteney Street (grade I listed building HAP ref 25)

‒

66-77 Great Pulteney Street (grade I listed building, HAP ref 26)

‒

Nos. 7, 8 and 9 Laura Place (grade I listed building HAP ref 27)

‒

Nos. 10, 11 and 12 Laura Place (grade I listed building, HAP ref 28)

‒

Nos. 1, 2 and 3 Laura Place (grade I listed building, HAP ref 29)

‒

1 Henrietta Street (grade I listed building, HAP ref 30)

‒

Fountain [Laura Place] (grade II listed, HAP ref 31)

Listed Building Group 2 – Edward Street Terraces: ‒

1, Edward Street (grade II listed building, HAP ref 32)

‒

2-5, Edward Street (grade II listed building, HAP ref 33)

‒

Nos. 6-10 [Edward Street] (consec) and attached railings, gates and overthrows (grade II listed building, HAP ref 34)

‒

Nos. 12-17 [Edward Street] (consec) and attached railings, gates and overthrow (grade II listed building, HAP ref 35)

‒

Kirkness House and attached piers, railings and lamp standards [11 Edward Street] (grade II* listed building, HAP ref 36)

‒

1-5 Vane Street (grade II listed building, HAP ref 37)

Listed Building Group 3 - Pulteney Mews: ‒

St John’s Ambulance Headquarters (grade II listed building, HAP ref 38)

‒

Office adjoining St John’s Ambulance Headquarters (grade II listed building, HAP ref 39)

Listed Building Group 4 – Johnstone Street Terraces: ‒

1-8 Johnstone Street (grade I listed building, HAP ref 40)

‒

2-5 Henrietta Street (grade I listed building, HAP ref 41)

‒

9-15 Johnstone Street (grade I listed building, HAP ref 42)

‒

6-19 Henrietta Street (grade I listed building, HAP ref 43)

‒

20-35 Henrietta Street (grade I listed building, HAP ref 44)

Listed Building Group 5 – Argyle Street:

‒

1-5 Argyle Street (grade II listed building, HAP ref 45)

‒

6 Argyle Street (grade II listed building, HAP ref 46)

‒

7 Argyle Street (grade II listed building, HAP ref 47)

‒

8-17 Argyle Street (grade II* listed building, HAP ref 48)

Listed Building Group 6 - Pulteney Bridge: ‒

Pulteney Bridge (grade I listed building, HAP ref 49)

‒

Shops Nos. 1 to 8 (consec) (grade I listed building, HAP ref 50)

‒

Shops Nos. 9 to 17 (consec) (grade I listed building, HAP ref 51)

Listed Building Group 7– Parade Gardens: ‒

Colonnades, balustrading, steps and kiosk at Parade Gardens (grade II listed building, HAP ref 52)

‒

Edward VII Memorial in Parade Gardens (grade II listed building, HAP ref 53)

‒

Retaining wall with balustrade to Parade Gardens, and the vaults beneath (grade II listed, HAP ref 54)

Listed Building Group 8 -Terrace Walk/ North Parade: ‒

9 Terrace Walk (grade II listed building, HAP ref 55)

‒

7 and 8 Terrace Walk (grade II listed building, HAP ref 56)

‒

6 Terrace Walk (grade II listed building, HAP ref 57)

‒

4 and 5 Terrace Walk (grade II listed building, HAP ref 58)

‒

The Ale House (grade II listed building, HAP ref 59)

‒

Bridgewater House (grade II listed building, HAP ref 60)

‒

The Huntsman Public House (grade II* listed, HAP ref 61)

‒

Compass Abbey Hotel (Part – List UID: 1395777) (grade II* listed building, HAP ref 62)

‒

Compass Abbey Hotel (Part – List UID: 1395779) (grade II* listed building, HAP ref 63)

‒

4 North Parade (grade II* listed building, HAP ref 64)

‒

5 North Parade (grade II* listed building, HAP ref 65)

‒

6 North Parade (grade II* listed building, HAP ref 66)

‒

Fountain, The Island, Terrace Walk (grade II listed building, HAP ref 67)

Listed Building Group 9 - North Parade/Duke Street: ‒

7-12 North Parade (grade I listed building, HAP ref 68)

‒

North Parade House (grade I listed building, HAP ref 69)

‒

Georgian House and Railings [includes 13 North Parade] (grade I listed building, HAP ref 70)

‒

14 North Parade (grade I listed building, HAP ref 71)

‒

Delia’s Grotto in Garden of No.14 (grade I listed, HAP ref 72)

‒

Nos. 6-11 [Duke Street] (consec) (grade I listed building, HAP ref 73)

Listed Building Group 10 – Raby Place: ‒

1-17 Raby Place (grade II* listed building, HAP ref 74)

‒

18 Raby Place (grade II listed building, HAP ref 75)

Listed Building Group 11 – Darlington Place: ‒

1-8 Darlington Place (grade II listed building, HAP ref 76)

‒

9 and 10 Darlington Place (grade II listed building, HAP ref 77)

‒

11, 12, 13 Darlington Place (grade II listed building, HAP ref 78)

‒

14 and 15 Darlington Place (grade II listed building, HAP ref 79)

‒

16 Darlington Place (grade II listed building, HAP ref 80)

‒

17-18 Darlington Place (grade II listed building, HAP ref 81)

‒

19-20 Darlington Place (grade II listed building, HAP ref 82)

Listed Buildings outside the 500m Study Area: ‒ Sham Castle (grade II* listed building, HAP ref 83) ‒

Prior Park College: The Mansion with Link Arcades (grade I listed building, HAP ref 84)