Broadlands Fruit Farm, Box Road, Bath

The National Planning Policy Framework in para 145 (g) sets out the policy for previously developed land. It states that an exception to the definition of inappropriate development in the GB would be the development of previously developed land where the development would “be limited infilling or the partial or complete redevelopment of previously developed land, whether redundant or in continuing use (excluding temporary buildings), which would “not have a greater impact on the openness of the Green Belt” than the existing development; or “not cause substantial harm to the openness of the Green Belt” where the development would re-use previously developed land and contribute to meeting an identified affordable housing need within the area of the local planning authority”.

The Trust objects to this revised proposal on the basis that the development would have a greater impact on the openness of the Green Belt. This is because the footprint of three of the proposed eight dwellings would extend well beyond the footprint of the existing buildings. There would therefore be a substantial impact on the openness of the Green Belt. In addition to that impact, there would be significant harm to the open rural character of the area through the extensive hard surfacing and parking in the foreground, and the poor quality materials and suburban design and layout of the dwellings. The provision of an element of social housing does not overcome this substantial harm, as it has not been demonstrated that this social housing is required locally – in fact the Bathford Parish Council is objecting to the provision of social housing in this isolated location, with no footpaths to link the site. The exclusion of the existing building and site to the west, but with an access road to the boundary, gives rise to concern about what might be planned. This development is in a prominent location on the Shockerwick Valley floor, which is within the defined setting of the World Heritage Site.

The LVIA has not taken into account that this site is particularly visible from the train as it approaches the World Heritage Site, along the Brunel line into the historic core of the city. There is a real sense of arrival through undeveloped countryside – the train swings around to catch the first glimpses of the eastern parts of the city with a particularly iconic view of the rear of Grosvenor Place. The Box Road is also an important easterly approach, for which this development will be seen, and the Trust notes that the Council’s Landscape Officer has expressed concern about the required visibility splays and the amount of hard landscaping. This proposal would add to the string of random suburban dwellings along the valley floor approach (the prevention of which is the very purpose of Green Belt designation) and so would have a harmful impact on the setting of the World Heritage Site.

The NPPF para 144 states that “When considering any planning applications the LPA should ensure that substantial weight is given to any harm to the Green Belt. “Very special circumstances” will not exist unless the potential harm to the Green Belt by reason of inappropriateness and other harm resulting from the proposal is clearly outweighed by other considerations.” The Trust considers that this proposal fails this very high test. It would also be contrary to Place Making Plan Policy HE1 (a) and Policy B4 (World Heritage Site and its Setting). It would also be inappropriate development within the Green Belt (contrary to Policy CP8) and there are no demonstrated “very special circumstances”. It would also fail to enhance the visual amenities of the Green Belt as required by Policy GB1.