BPT has warned B&NES Councillors and the Senior Planning Team about the potential for harm to the Outstanding Universal Value of the WHS should Phase 2 of Mulberry Park be given the go ahead. Revisions to the scheme have recently been submitted but in our view do not mitigate the harm proposed.
In a letter Caroline Kay wrote:
“BPT has responded to revisions to the current planning application 17/04829/ERES which includes two large ‘landmark’ buildings facing the city. I should make clear that we regard this phase of Mulberry Park to be significantly inferior in design quality to the Phase 1 of the development or the proposed outline Phase 3, and likely to cause significant harm to Bath’s skyline and therefore to the Outstanding Universal Value of the World Heritage Site.
Harm to the green wooded ridge that frames the city (one of the key criteria of the OUV of the city) has already occurred at Bath University and Granville Road. Both these sites have been the subject of piecemeal development that has failed to account for the cumulative nature of the visual landscape harm caused by development. The phase 2 buildings at Mulberry Park are proposed to be large, monolithic flat roofed buildings that will overtop the wooded ridge, providing a hard, horizontal, urban edge to this part of the green skyline. The fact that the buildings will be visible from the points across the city is acknowledged in the LVIA’s submitted with the application, in fact they say ‘wireline imaging suggests development will be visible above the existing tree line’ but goes on to say that it will not significantly protrude and therefore the harm is ‘less than substantial’. ‘Less than substantial harm’ is still acknowledged harm nonetheless and should be weighed against the significance of the heritage asset. The NPPF is clear that the more significant the asset, the more weight should be attached to its conservation. There is no more significant heritage asset than that of a World Heritage Site. Whilst the buildings do sit ‘just’ within the height parameter agreed at outline stage, the flat roofed nature of these buildings mean the developers are overdeveloping the airspace; we believe the roofscape of these buildings should be varied and articulated to reduce the visual impact of urban development on this ridge. There are also significant other design and materials issues which are detailed in our response (attached). We strongly urge you to use your influence to ensure that this scheme is either significantly altered or refused.
Our view is that to permit this application would be an error in planning judgement that will have a negative impact on the World Heritage Site and contribute to a serious problem of cumulative landscape harm around the ‘bowl’ of the City. Please do not let this happen”
You can read our full response to the planning application revisions here .