“Rugby on the Rec, but not ‘at any price’.”
The Recreation Ground (the Rec) is a green space in the centre of Bath which is held in trust for use ‘for outdoor recreation’. Bath Rugby has occupied part of the site since its inception in the 19th century.
The Rec and its use by Bath Rugby have long been a topic of debate and discussion within the city. BPT has been actively engaged as a stakeholder, we have attended design review workshops and monitored and responded to many planning applications and consultations over the years.
BPT’s position on the principle of development on the Rec has always been clear. We are open to the opportunities for a new rugby stadium on the Rec and regeneration of the riverside but our primary focus will be the protection of the Outstanding Universal Value of the World Heritage Site and the impacts any structure would have on Bath, its heritage and its landscape setting. We will continue to consult closely as a design comes forward.
In reaching this position, BPT Trustees heard from all interested parties in relation to the legal position at the Bath Recreation Ground and agreed a response which in the judgement of the Trustees reflected most appropriately the views they had heard, including views from members.
You can read the BPT 2009 position statement here.
Conflicts of Interest
BPT Trustees recognise that any conflicts of interest in relation to a planning application for a rugby stadium will be scrutinised and have submitted a letter to the Charity Commission explaining the position they have taken.
Read BPT’s Charity Commission letter here.
Understanding Heritage Impact
BPT has undertaken to assess views and vistas from within and into the Rec from key points across the city. This work will help inform an understanding of the buildings, landscapes, features that may be impacted by any development, how important these are, and how the view will be changed by the proposals that are eventually put forward.
Download ‘A View of the Rec’ here.
When considering the impact of any development on the Rec we will also be taking account of the following guidance and documents:
- The Core Strategy and Placemaking Plan
- BPT Local Policy Overview
- Bath Conservation Area Character Appraisal (Pulteney Road)
- The City of Bath World Heritage Site Setting SPD
- The Bath Building Heights Strategy
- The City of Bath World Heritage Site Management Plan 2016-2022
- Historic England – The Setting of Heritage Assets
- Kay Ross – The Recreation Ground Heritage Impact Assessment (2014)
The Legal Position
In October 2020, the High Court judge decided against Bath Rugby’s legal challenge of the 1922 covenants on ‘the Rec’, by deciding that these are in fact enforceable. Consequently, any development on the land that may cause a “nuisance” is open to a legal challenge by objectors. This ruling was not considered in relation to any particular design proposals associated with Bath Rugby, but could be interpreted to pose a barrier to future development. In response, Bath Rugby and Bath Recreation Limited submitted a joint appeal where the decision was overturned and it was concluded in December 2021 that the covenants would not in fact be enforceable.
In October 2022, the Supreme Court refused an application for appeal of the final High Court ruling. It is expected that the design process for a new stadium on the Rec will resume, with development proposals coming forward in 2023.
Timeline and Responses
BPT has been actively engaged with the project since its inception and have given detailed responses to public consultations and emerging plans at each stage.
2023 – Submission of Planning Application
You can read BPT’s response dated the 10th November 2023 here. Trustees were supportive and encouraged by the improvement to the scheme, however remained to be convinced that the public benefits of the scheme (specifically the riverside public realm) is sufficient to outweigh a degree of harm to multiple heritage assets, character and appearance of the conservation area, and Outstanding Universal Value of the World Heritage Site. We called for the application not be approved in its current form and encouraged further work to demonstrate enhanced design quality, a reduced impact on townscape character and views, including Orange Grove, Grand Parade, the Recreation Ground and Pulteney Road, and further improvements to the Riverside public realm.
2022/2023 – Stakeholder Engagement
BPT has been invited to re-engage in design review following the project being paused through the COVID-19 pandemic.
2020 – Renewal of Planning Permission for Existing Temporary Stands
Application 20/00137/VAR was submitted in January 2020 as an amendment of original application 15/05237/FUL, to allow the temporary stands and related development to remain in situ until 30th May 2022, which has been permitted.
2019 – Stakeholder Engagement
Bath Rugby were consultative and open in their approach and BPT has participated in several stakeholder meetings alongside Historic England and specialist Local Authority officers. Our understanding from stakeholder meetings is that the design has changed since the last public consultation in 2019 and we await any new proposal being put forward by Bath Rugby. This reinforces BPT’s view that it is premature to take a firm position on the design of the previous consultation until we know whether this is going to be part of the application design.
2019 – Pre-Application Environmental Impact Assessment Scoping Opinion
In July 2019, Bath Rugby filed scoping application 19/03133/SCOPE for the Environmental Impact Assessment (EIA) which they will be required to submit with their substantive planning application. This suggests that they are on track to submit a planning application in the foreseeable future.
Read BPT’s response to the Scoping Opinion here.
2019 – Stadium for Bath Round Two Consultation
The presentation of detailed plans enabled an in-depth response to all aspects presented at the consultation. The Grimshaw design team were urged to ensure that the planning application contains all the necessary and very specific assessment documentation required for a scheme of this size and impact, including a thorough and accessible analysis of harm versus specifically defined public benefit.
See the Grimshaw plans here.
Our response indicated concerns over heritage impacts as a result of the height of the stands and the associated visual impacts on key views over, out and across the World Heritage Site. We are also concerned regarding the current design for certain parts of the stadium including the principle corners (NW and SE) and the East Stand, which is currently unresolved and uninspiring.
Read our Round 2 consultation response in full here.
2018 – Stadium for Bath Consultation
BPT responded to a questionnaire on emerging concepts and ideas for the proposed new stadium on the Rec. There were no design proposals on the table and therefore our response reflected this and examined the issues and concepts covered in the consultation only. We were not able to make any definitive statements on design/height/scale/materials and heritage impact until we more developed designs were made available to review.
Read our consultation response to the questionnaire here.
2018 – Stadium for Bath Draft Development Brief
In 2018, a Draft Development Brief was published with a planning application expected in late 2018.
The Development Brief documents are available here.
2017 – Stadium for Bath Pre-Application Stakeholder Workshops
BPT was involved in key stakeholder and technical planning workshops to help the new Stadium for Bath project team begin their assessments and research to inform a development brief for a new stadium for Bath Rugby on the Rec. An ‘Exploring the Opportunity’ document was published in late 2017 and the project team subsequently appointed the architects Grimshaw (of Thermae Spa and Herman Miller fame). The architects were scheduled to work on a design brief and design options, with a view to consulting on a design later in the summer.
2015/2016 – West Stand Demolition
BPT responded to Bath Rugby’s planning application 15/05235/FUL & 15/05237/FUL for the demolition of the existing West Stand and the temporary installation of a larger West Stand. Whilst we considered that the proposed temporary West Stand would have a relatively minimal impact on the public realm, we expressed concerns about proposals for a new permanent West Stand being incorporated into the temporary stand permission.
Read BPT’s planning application response here.
Proposals for the permanent West Stand were subsequently omitted, instead just proposing a temporary replacement Stand in place of that existing. The application was permitted at Planning Committee in 2016 where the impact on heritage assets was concluded to be “less than substantial.”
2013/2014 – Wilkinson Eyre Architect Stadium Designs
BPT sent an ‘open letter’ in response to stadium proposals by Wilkinson Ayre for the Rec. We raised serious concerns about excessive height of the proposed West and East Stands causing significant detriment to the landscape setting of the site and the views into, out of and across the ground. It is recommended that significant further negotiation needs to take place between Bath Rugby and B&NES, English Heritage and other partners in order to achieve the best outcome for all.
Read our open letter here.
Bath Rugby listened to our concerns about the heights of the stands and made some adjustments as a result.
2011 – Recreation Trust Consultation
BPT responded to the public consultation conducted by B&NES Council in 2011. Our response recognises the need to regularise the legal position of the land on the Recreation Ground. This was referred to in the BPT’s interim statement on the Rec in 2009.
BPT’s response to the 2011 online survey is available here.
BPT submitted a detailed supplement to the online consultation response which is available here.