The BID welcomes B&NES Council’s endeavours to improve air quality in the city.

In collating this document, the BID levy payers were invited to respond to an internal survey.  An overwhelming majority (86%) felt that it would be bad for their business.  Most respondents supported the initiative to improve Bath’s Air Quality subject to an amended implementation plan.

Comments received reflected an anxiety about the risks of impact on recruitment as well as a loss of customers.

The BID formal comments are set out in the table below, with some background reasoning in the body of our response.

A summary of the Bath BID Response

Economic Impact

The BID is disappointed at the absence of an economic impact assessment as part of the consultant work on the Clean Air Zone.  Further economic modelling should take place before implementation to enable the Council to seek funding for mitigation which reflects a proper assessment of the impacts – see below for a list of suggested analysis.

Behavioural Change modelling

That table 3-2 should be amended to show the predicted behavioural change more clearly – separating out figures for cancelling their journey or changing mode.

Mitigation Measures

Some additional mitigation is required – to be informed by the outcomes of more appropriate economic impact assessment.

We propose:

That the Council should pursue with utmost endeavour further opportunity to improve Park and Ride Facilities in the city – Let’s have the best P and R in the South West and have something to shout about.  We welcome the later night time opening proposals, but feel there is additional scope for improvement.  Our levy payers complain about the reliability and regularity of the service and it is not helpful to shift workers in the hospitality sector.

Significant Improvements in public transport across the area.

That the Council pursues the opportunity with urgency to create a relief road which will address the casual use of the city for lorries in transit.


That the Council allows the period of deferment for natural changeover of vehicles to take place without the massive infrastructure costs over 2 years, which will be eclipsed by the impact of the vehicle changes. A threat of a CAZ has the potential to encourage behaviour change at the same time.  This extended period will allow for further and more logical uses of infrastructure funding such as better public transport and cycling facilities.

Background to Bath BID’s response

Economic Impact

Challenges faced by the High Street 2018

High Streets across the country are subject to a number of factors which are contributing to a decline in footfall; these include increasing costs of parking, enthusiastic uptake of internet shopping and therefore the changing habits of shoppers and visitors to the city.

Between 2007 and 2018 online sales increased 6-fold while growth of in-store sales has lagged behind. In 2000 online retailing accounted for less than 1% of retail sales while in August 2018 almost a fifth of all retail sales took place online (Office for National Statistics).

Here in Bath, the city’s retailers have already faced challenges due to the realignment of parking charges which were introduced in Charlotte Street.  The city is now falling behind the rest of the UK with footfall during October dropping in comparison with 2017 at an increasing rate.  The cells in the right-hand column in red show where Bath is underperforming in footfall when compared with the rest of the UK (2017 compared to 2018 by week).

  Week Bath percentage Change (2018 vs 2017) UK percentage Change (2018 vs 2017) Difference between Bath & UK (2017 vs 2018)


30 0.86% 0.00% 0.86%
August 31 -3.59% -0.10% -3.49%
32 -1.72% -1.20% -0.52%
33 -4.58% -2.80% -1.78%
34 -0.76% -2.80% 2.04%
September 35 -3.38% -4.30% 0.92%
36 -1.52% -0.60% -0.92%
37 0.86% -1.80% 2.66%
38 1.59% -3.70% 5.29%
39 1.33% 0.40% 0.93%
October 40 -3.89% -2.70% -1.19%
41 -8.41% -1.40% -7.01%
42 -7.94% -1.10% -6.84%
43 -11.06% -3.70% -7.36%
November 44 -8.82% -1.90% -6.92%


Regarding the economic impact on the businesses of Bath, the consultation document states:

We have a resilient, unique economy but we accept that some businesses might need help adjusting to the CAZ in the short term. We are therefore inviting business owners to meet with us at our regular surgeries. Details are online at Our assessment indicates that the majority of vehicles (75%) will naturally become compliant by 2021, and we will be doing everything we can to ensure that people have the information they need to get compliant in cost-effective ways, or find alternative transport into Bath.

Within the JACOBS report, there are scant references to the impact on the business community apart from Table 2.10 Logic Map which mentions an unquantified ‘loss of some economic activity’ and in table 3-2 which makes reference to Final Primary Behavioural Response rates.

It is essential that the economic impact assessment should not be limited to the impact on B&NES council but to the wider business community in the city.

We would propose that such an assessment should consider:

  • Loss of traffic and by extension footfall
  • Extra costs – deliveries and operational costs
  • Recruitment challenges – workers on a low wage could be paying a significant proportion of their salary in parking and clean air fees. Impact on salaries and challenges to business vacancies
  • Fewer customers and a potential drop in revenue per customer (what is the impact on shopping basket value of a customer who may have already paid out £25 just to come to the city?)
  • Analysis of neighbouring cities in terms of both recruitment and footfall/visitors to quantify the risk of displaced employees and customers

Predicted Behavioural Change

Table 3-2 suggests that 37.9% of car users will either avoid the zone or cancel their journey/change mode.  With 2011 Census data showing that almost a third of employees commute in to Bath from outlying areas and 82% of them being car users, it is easy to see that this will have a significant impact on the workforce at the heart of the city.  In addition, the loss of 24.6% of the customers to the city centre who will now cancel their journey would also have a catastrophic impact.

It is difficult to understand why the ‘cancel journey and change mode’ have been lumped together as the impact of one of those is much more significant to the local economy than the other, and it would have demonstrated an understanding and respect for local businesses had they been presented on separate lines.

Mitigation Measures

The report makes reference to some potential impacts and mitigation measures:

The Plan has the potential to impact the local economy depending on the measures selected. A significant proportion of jobs in Bath are located within the city centre where some of the most significant exceedances are located. In other words, where the Plan will seek to impose most clean air measures. Measures that penalise travel into central Bath could limit the attractiveness of jobs within the city centre, putting employment opportunities, business viability and investment at risk. Further, the buoyant tourism industry in Bath, attracting 4.8 million day-visitors to the authority as well as £411 million in tourist expenditure, could also be at risk from any measures that deter travelling to the city centre. It is therefore desirable to select an option which has the least impact on the local economy, and if possible, a neutral or positive impact.

 Funding is available from Central Government for non-charging measures to mitigate this impact should it materialise. Longer term benefits from a transition to a greener economy could include an increased attractiveness to businesses.

Government guidelines for introducing a Clean Air Zone recommend:

They will also need to take action as necessary to support growth and protect the economy of their local high streets and town centres, whilst ensuring that their Clean Air Zone proposals will not result in the displacement of the most polluting vehicles away from town centres to surrounding areas.

Local authorities can use the provision of Clean Air Zones to support academia and business in trialling innovative approaches to improving air quality. New technologies and innovation can provide growth opportunities for the UK and for local businesses. It is important that such approaches are evidence based, focused on evaluating the impacts (costs and benefits) of the innovation and support the aims of the Clean Air Zone.

As part of mitigation impact measures, we are aware of research from the Institute of Place Management:

Well-designed parking policy, active management of change of use of retail units and reinstatement of roads promptly to full use after roadworks can also support vibrant town centres. (Institute of Place Management)

It is therefore disappointing that mitigation measures around public transport,  more Park and Ride sites and daytime P & R  capacity are not part of the early mitigation proposals below:

  • Provide additional cycle parking across the city centre in visible locations and pilot a management scheme to improve proper usage of cycle parking
  • Expand proposal (included in Go Ultra Low package) to increase the public electric car charging network
  • Provide 24hr secure parking at all three P&R sites to encourage overnight use and facilitate extended operating hours
  • Scoot/cycle to school initiative
  • Financial support for replacing uncompliant vehicles with compliant ones
  • Financial support for electric charging points on private land

It would be helpful to understand the limitations of the proposed measures.  More regular and cheaper public transport is widely requested by our levy payers, not just additional evening services.  First Bus is already facing difficulties with its services and there is concern that this will not be addressed as part of the mitigation measures.

In order for the mitigation measures to have the desired modal shifts in transport use and for a data driven understanding of the economic impact of the changes, a deferment of 1 or 2 years in the proposed implementation of a CAZ would be appropriate. Linked to a 2021 target date for vehicles to be compliant, it is our view that a scheme which is more proactive in providing transport alternatives stands a greater chance of actually delivering the desired results of cleaner air for all and would not require the massive investment in number plate recognition technology.

We have included at ANNEX 1, verbatim individual comments received for your information.

Annex 1 – Verbatim comments from the BID survey of businesses


  • It will make it harder to recruit staff & deter customers from coming to Bath. Double Whammy!
  • It will make it harder to recruit and retain current staff and will also have an impact on clients/consultants visiting the office for meetings. Internal office CPD sessions where we have visiting external speakers will also be impacted by this.
  • People will not visit the city and staff will struggle with getting to work
  • We will not be able to retain staff that aren’t local to Bath and who commute in and our clients who travel into Bath will be put off and could possibly move to another company
  • Recruitment & retention is already a massive issue, this will add to that and visitors have a choice of other cities!
  • it will make it harder recruit and/or retain staff It will deter customers from coming into Bath
  • A charge of £9 to enter the city on top of a 60% rise in the price to park would not make it financially viable for anybody working in retail to accept a job in the city, which would seriously impact on recruitment. It will also deter customers when there are many other nearby shopping destinations without such charges


  • The Council has not provided the infrastructure to introduce such a scheme especially a Park’n’Ride to the east of Bath
  • It doesn’t provide viable alternatives for those traveling from the east of the city. Without a park and ride on that side of the city people don’t have options other than go through the zone.
  • supply enough park and ride and make sure it continues into the evening, this is to make sure staff who work in public service sector can get home safely
  • Only when the missing infrastructure has been put in place such as a Park’n’Ride to the east of Bath, the A46 / A36 link road and better access to/from the Lansdown Park’n’Ride.
  • BANES need to sort out the final park & ride. The Eastern side is the most important as it’s the closest to the M4 / London Road. At present traffic crosses the city to access other P&R sites which makes NO sense. Also upgrade current P&R sites – take a look at Cambridge for a great forward thinking service with additions such as delivery & collection points for shopping so customers can spend longer in town without being weighed down with bulk loads. Electric vehicles support this supplementary service. I feel BANES do very little for local business
  • Put a park and ride on the London rd side of bath
  • The council must improve transport into the city first
  • Create a better infrastructure before implementing the CAZ. The current P&R service isn’t good enough and there is gaps in the bus services around Bath to give locals and visitors viable alternatives than using their cars. Free parking should also be offered otherwise shoppers will be charged too much to even consider parking and shopping in the city centre


  • this will kill the high street which businesses are trying to revive, locals & visitors to Bath are the bread and butter of Bath
  • Worry about added costs for delivery
  • My main concern is that I will be charged – While all of our staff walk or use public transport my commitments during the day mean I need a vehicle but we would struggle to afford the additional costs
  • Price change for deliveries into the city will be charged back to us by suppliers
  • only able to tick one box as system doesn’t allow multiple – both answers apply
  • it will be a deterrent for customers to come in and also for staff. it will stop people coming to bath
  • Both of the above. It will also be a problem for deliveries, services to our business like track fitters etc many of whom I am sure will want to pass the charge on to us when they need to visit the store.
  • it may make your guides or private taxis more expensive to enter the city in the zoning area
  • Cost of deliveries to and from business will be significantly increased.
  • this will also have a huge impact on cost for deliveries to stores daily.


  • To be honest we need to clean up the air in Bath. However I don’t think the Council have thought it through and considered all options. The road system is at fault, they are selling off accessible warehousing for housing, there is a lack of a P&R on the Chippenham side of town and public transport is poor. Businesses will need deliveries and increased costs for those deliveries will inevitably be passed on with the end result of the consumer paying more. I’m in retail and there is already so much pressure on retail overheads with the cost of parking etc.
  • Business is reliant upon commuters/customers using a car park and dependent upon terms of the agreement/ arrangement has the ability to deter customer entering the city.
  • The zoning isn’t in the correct zone .. London road?! very heavy with traffic main pollution is there … also bath is a small city centre with businesses and retail stores suffering with trade as it is. Majority of customers find the parking charges too high but pay it due to cheaper transport than bus and train to the city before Christmas. and this will have a massive effect on footfall and trade for all businesses if a pollution air charge is put into place. Also I find it hard to state that these charges will apply to certain dated cars as for some they will and cannot and might not be able to afford to have a modern car, therefore I feel this is penalising and will put off a lot of customers especially those that are within the age group 18-23 & 50+. I feel this plan isn’t well thought through nor a business plan… Bath is a small city had it been larger with a bigger city footprint ) or like Bristol) then maybe however Bath centre is pretty much a one way system also. overall I feel this will have a massive effect on Bath a lot and feel this is not appropriate. Also this is causing a lot of profiling within the locals stating this will also creat the profile between who can afford the modern car / rich and poor. Which I think is not the way Bath should be going or be known for.
  • The Bath / car situation is already a notorious nightmare for shoppers in Bath – this is just going to be yet another thing for people to complain about and give as a reason nobody wants to come shopping here on a regular basis anymore.


  • Introduce it in 3 years time
  • Just the very central part of the city, less than 0.5 of a mile.
  • Make it free for those commuting to work (as opposed to visitors).
  • Cheap, reliable, frequent, 24 hour public transport. Bypass needs to be built to take traffic out of the city centre & not have it pass through small surrounding roads of Bath.
  • Having a charge permanently in place would cause people to simply go around Bath, and not through the centre, making traffic around Bath worse and not really solving the problem because it would increase net emissions for journeys. Whereas going through the centre would be more fuel efficient. The charge is a great idea, but it should be enforced through peak hours (8am-6pm). This would still have a marked effect but still allow for efficient use of the roads inside the centre during quieter times.
  • Make it smaller to avoid affecting the people living on the outskirts of town who would find it impossible to avoid entering the zone. Improve bus services to discourage people from driving into town.
  • close Bath to all traffic after 10am, any vehicles which do enter are to be electric, take off the proposal of part of the A36 major trunk road, and the Cleveland bridge area, (install Batheaston by pass) this will take traffic away from the A4 straight through A46 – A36 trunk roads rethink the proposal involve local people who live / work on the ground
  • Better bus for residents. School children in uniform to have a free bus pass. This should stop big 4×4 cars driving across the city to the schools to drop kids off. Is introducing a clean air zone then all cars to be banned in centre city then extend the zone outwards introducing smaller costs.
  • There should just be a charge on the vehicles/lorry’s that are coming through the city to get to the motorway
  • park and ride system that serves a purpose and runs 24/7 365
  • cheaper for vehicles – various options for weekly / monthly
  • as bath is a small city centre it needs to be tighter and not so big zone. the area of proposal is to large and is cutting the city of to people in all areas. the charge is to high and needs to reviewed as the parking has been increased as well the daily rate is to high.
  • Look at alternatives to discourage wasted and unnecessary journeys into the zone. Consider those who need vehicles as part of their everyday function in business
  • No charge to cars.
  • Just for lorries and buses entering the city.
  • Town centre businesses to be possibly excluded, maybe just building a bypass and getting rid of all through traffic as has been proposed for the last 30 years? How about just banning tourist coaches from town centre? Maybe just a ban on goods vehicles between certain times in the day? Making the whole of town centre pedestrian during the afternoon?
  • I would have better route for the rubbish collectors. Far too many in the city operating over the same area. I would exclude cars that have low emission if they don’t pay car tax these cars are good but to are staying that a 2014 diesel under this ruling will be charged £9 a day. I would have more electric delivery van, taxi’s post van all could go electric. I would close key roads in the city centre at peak times. Like milson street. I would have more park and ride centre’s like on the Bradford an avon side. From the frome side of the city etc. increase how late park and ride centre stay open.
  • Levy for ALL fossil fuel cars and lorries. This shouldn’t be a tax on the less well off. Levy is too high and would need to b lower.
  • Support businesses with the revenue that it will create
  • Delay its implementation so more older car will be taken out of circulation and therefore there will be less pollution. Insist that all public transport and goods vehicles are clean air compliant.
  • Charges are too high and only a few years ago we were advised to buy diesel cars
  • adjust the zone so it doesn’t include the petrol station. Also I don’t think it should apply to residents, as you are punishing people for not being able to afford new cars
  • Relook at the cost and revisit the car park charges around the city – can a pass be given to staff working within the City to support with a lower charge.
  • Should definitely Not apply to Residents for this is punitive when it was the government who informed people that they should buy Diesel vehicles Another example of BANES council making poor choices when there are far more pressing matters negatively effecting the economy and seeing Bath continue to go backwards as a city and destination
  • Commercial vehicles only
  • I would make it so buses were not effected & and residents of BA1 & BA2 were nit addicted
  • Shrink the area, so people wouldn’t be penalised for going to the car parks!
  • Consider a river taxi

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