Additional Development Area, Holburne Park, Bathwick

Proposed erection of 8 additional dwellings, landscaping, car parking and associated works on land adjacent to Holburne Park, Warminster Road, Bath (Resubmission of 19/04772/FUL).
Our Response

This application concerns the proposed Phase 3b development of the undeveloped western parcel of land associated with the Holburne Park housing development along Warminster Road, situated within the Bath conservation area and World Heritage site with significant views across the valley to the north. Formerly, this section of land was identified as “school land”, but a Section 106A application was approved in May 2020, allowing for the site to be used for further residential development.

Following consideration of this application, there appears to be no changes made to the design, layout, or density of the proposal following on from 19/04772/FUL. Therefore, our previous comments regarding the poor quality of the submitted architectural drawings, and overall lack of coherence of development across the site remain valid. Fundamentally, we must continue to oppose this application due to the continued, unacceptable under provision of affordable housing; as stated in Policy CP9 of the District-Wide Strategy and Policies Plan, development in this area of Bath is expected to have a 40% allocation of affordable housing, a quantity this development unfortunately fails to reach.

Site Layout and Design Approach:

We maintain that the documents submitted with this proposal are insufficient to make a proper assessment of the application. We would expect, and encourage high-quality, detailed architectural elevations and all intended material selections to be submitted for a development of this scale.

Furthermore, we maintain that this application provides inadequate information regarding the proposed design and material palette of the proposed 8-dwelling terrace. The use of materials remains vague, “utilising a mixture of Bath stone ashlar and render dependent on the location and hierarchy of the elevation” without further design specifications. We maintain that due to the prominent position of the Holburne Park site overlooking the valley, with views out as far as Camden Road, the site significantly factors into sensitive landscape views of the World Heritage site. The north elevation in particular, whilst a gable end, faces directly out of the site, and the use of render on this elevation would consequently be highly visible and inappropriate within its setting.

Therefore, BPT continues to object to the unclarified use of render on these prominent elevations, and the focused use of Bath stone on elevations facing into the Holburne site, as presented in past applications; we maintain that all elevations should be Bath stone ashlar.

Affordable Housing:

We continue to strongly object to this development’s lack of affordable housing, as part of the wider Holburne Park development’s minimal provision of affordable housing. The D&A Statement highlights that none of the 8 proposed dwellings will be of an affordable designation. The Planning Statement states that there will be no increase in affordable housing beyond the 29 affordable homes included in Phase One of construction, and an additional proposed provision of 10 discounted market value apartments as part of application 20/02921/FUL, due to “abnormal costs and commercial considerations”, a number that remains inadequate and contrary to local policy. BPT remains opposed to this lack of affordable housing and feels that its provision should not be reliant upon the unplanned commercial or construction costs of a residential development. This proposal contravenes Policy CP9 of the B&NES Core Strategy and Placemaking Plan. The Warminster Road site falls within the Bath area with a target of 40% affordable housing. We continue to strongly recommend that this development’s sub-standard allocation of affordable housing be amended before any aspects of the scheme are approved.

Application 19/04772/FUL went to Planning Committee on 1st July, and it was unanimously voted that the application should be refused on grounds of:

“The proposed development fails to provide a policy compliant level of affordable housing and this is not justified by the viability appraisal or any other material considerations. The proposed development is therefore contrary to the development plan, in particular policy CP9 of the Bath and North East Somerset Core Strategy.”

We maintain that this application fails to provide a policy-compliant level of affordable housing without adequate justification, and therefore has not suitably addressed its reason for refusal. The insufficient affordable housing provision is ultimately contrary to Policy CP9 of the Placemaking Plan, and therefore should be refused or withdrawn until an appropriate proportion of affordable, mixed housing is proposed.

Application Number: 20/02926/FUL
Application Date: 14/08/2020
Closing Date: 18/09/2020
Address: Additional Development Area, Holburne Park, Bathwick
Our Submission Status: Object