Western Riverside Development Area, Midland Road, Twerton, Bath

(Revised August 2007) 

The Bath Preservation Trust’s Architecture and Planning Committee has considered the proposed amendments to the above applications. The Committee recognises that the development of the site for housing will make a considerable contribution to the Government’s housing requirements for Bath, especially in the area of affordable and social housing. BPT is very keen to see the site developed rather than remain a derelict waste ground and fear that if a scheme of some form is not granted consent even more of the precious green belt surrounding the city could be exhausted in the provision of more homes.

We recognise that the amendments Crest have made are responsive to some of the concerns we raised; however, we continue to OBJECT. BPT considers that the application is contrary to Local Plan Policies contained within the Bath and North East Somerset Local Plan (as adopted for development control purposes on the 13 September 2007) particularly policies, BH.1, BH.2 and BH. 6, and advice contained within National Planning Guidance, and the adopted SPG by virtue of the following:

Departure from the principle of Comprehensive Development:

The Draft SPD and the adopted 2003 SPG both promote the principle of comprehensive development. We accept that the SPD has been ratified for development control purposes and it is our understanding that it will be adopted following the adoption of the Local Plan after the 18 October. Under the SPD most of the application falls into Zone 2. A fundamental objection to the process is that it should be known what is proposed for Zone 1 before an OPA is approved for Zone 2.

Height, Scale and Mass:

The reduction in height of the seven storey blocks in the central part of the site to six storeys is a welcome proposal that should help to reduce the overbearing impact of the buildings. We remain concerned that the 6 storey buildings here may still exceed the comparative heights of building in the historic city, which are only six storeys when measured from basement level.

The three pavilion riverside buildings remain at eight and nine storeys, a height that is considered inappropriate and would have a harmful impact on and would detract from:

The World Heritage Site and its Outstanding Universal Values.

It is our view that the tall riverside blocks will have a detrimental effect on the appearance of the 18th Century city and it’s “harmonious and logical Palladianism in concord with the natural environment” (Bath World heritage Management Plan 2003-2009).  These riverside pavilion buildings would stand contrary to the prevailing patterns of 18th century town planning and landscape design.

The Character and Appearance of the Conservation Area.

Section 72 of the Town and Country Planning Act (1990) requires that special attention shall be paid in the exercise of planning functions to the desirability of preserving or enhancing the character or appearance of a conservation area.

We accept the contemporary approach to the design of development at Western Riverside however it is our view that the proposed pavilion buildings by virtue of their inappropriate height and massing fails to preserve or enhance the character (as defined by the City Wide Character appraisal) and appearance of the citywide conservation area. We feel that the pavilion buildings could be more respectful of their context, in particular in terms of scale and fenestration and relation to the contours of the river. On the matter of fenestration we remain to be convinced that the size, alignment and proportion of the windows to Building 5 are at all appropriate.

The Special Architectural and Historic Interest and Setting of Listed Buildings.

Sections 16 and 66 of the 1990 Act requires Local Planning Authorities to have regard to the setting of listed buildings. Planning Policy Guidance Note 15, Planning and the Historic Environment paragraph 2.17 states that the setting of a listed building may include some land some distance from it, even if the building has no ancillary land (for example the Victoria Bridge). Paragraph 2.17 supports our view that high or bulky buildings, such as the riverside buildings, may affect the setting of listed buildings some distance away, or alter views of a historic skyline.  We consider that the height and massing of the riverside buildings would have an adverse impact on the setting of Norfolk Crescent, Victoria Bridge and other significant listed buildings in the wider context including the Royal Crescent and Bath Abbey.

The revised SPD (Appendix 2 (revised) Schedule of Proposed Changes to the SPD), as approved for development control purposes includes a new paragraph, which accepts buildings of up to 6 storeys. It states that applicants wishing to promote development of a greater height will need to demonstrate through a justified design that their proposals will create a design solution that meets the “Vision Statement” for BWR and the “Overarching Design Principles” set out in the SPD Spatial Master plan. On consideration of the new Design Statement added to the application, for the reasons of inappropriate height, scale and massing as stated above we do not consider that the revised proposals meet with many of the Overarching Design Principles set out in the SPD, or meets the requirements of the Vision Statement, in particular paragraph 2.2.12, which states that as the first part of the future vision for Bath BWR must be an “exemplar of the quality of new urban fabric of the city that respects the unique context of the World Heritage Site”. Therefore the proposal is not in compliance with the SPD.

We also object to:

Density

The density of all the buildings on the site appears far too great in comparison to the city centre. The required numbers of dwellings per hectare in order to make the project financially feasible is achieved by the retention of tall buildings on the site. Whilst we encourage the highest density development this should be a height comparable to the city tradition. High density does not have to equate to high-rise!

Housing Mix

The revised scheme proposes 1,903 residential units including 1, 2 and 3 bed apartments and 3 bed houses and 482 student rooms.  We are concerned about the proportion of smaller units and the effect that this will have in the creation of a balanced community.

Provision for Parking

We remain concerned about the lack of car parking spaces. A provision of 0.7 spaces per dwelling has been allocated, this is not enough and has severe implications on the surrounding area in terms of the impact of overspill parking on nearby streets. There should be a minimum of 1 space per dwelling or ideally 1.5 spaces per dwelling.

BPT would like to be notified of the date and time of the Development Control Committee meeting at which the application will be determined and would like the opportunity to speak at this meeting.

On the point of determination BPT considers that planning applications of this scale are of more than local importance and, in accordance with guidelines restated before the House of Commons on 12 December 2000, should be called-in under Section 77 of the Act for determination by the Secretary of State for the following reasons:

Proposals conflict with national policies on important matters;

- Proposals have,  and will continue to give rise to substantial regional or national controversy;

- Proposals raises significant architectural and urban design issues.

A letter has been sent to Phil Warry at the Government Office for the South West to request that an Article 14 Direction is held in place and that the applications are called-in. This letter draws attention to the above reasons in more detail.

We are eagerly anticipating the response from English Heritage and would like to be notified of any further amendments to the scheme that may arise prior to determination.