Proposed erection of 8 additional dwellings, landscaping, car parking and associated works on land adjacent to Holburne Park, Warminster Road, Bath.
Our Response


Fundamentally, the Trust objects to the application on the grounds of insufficient affordable housing provisions. This under provision is inexcusable; 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 before this development progresses further.

The expansion of the site to the north, east, and west remains a cause for concern. Our objection to 19/03836/FUL should be noted in relation to this application. The Trust feels that this proposal continues to perpetuate the problematic overdevelopment of the site, and contributes an additional precedent for further peripheral development that would result in a greater harmful visual impact on the conservation area and Bath’s World Heritage site and setting.

It is regrettable that an opportunity has been missed to use this site to provide public shared facilities for the residents of the site. In the original 2014 scheme (see application 14/02272/EFUL), this area was earmarked for the building of a school; whilst we appreciate there is no longer a requirement for additional educational facilities within this area, the consequent loss of the potential for community amenities within the development is discouraged by section 8 of the NPPF.

Affordable Housing

We continue to strongly object to this 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 due to “abnormal costs and commercial considerations”, a number that remains inadequate and contrary to local policy. BPT is opposed to this loss 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 would strongly recommend that this development’s sub-standard allocation of affordable housing be amended before any aspects of the scheme are approved.


The western infill of the site, in conjunction with other applications for the expansion of the site to the south and east (see applications 19/03836/FUL and 19/03838/FUL), continues to raise strong concerns about the overdevelopment of the site and how this will impact the historic character of the area. The loss of the designated ‘school site’ to private residential development has resulted in the regretful loss of the potential to integrate public community facilities into the development’s design.

The insufficient affordable housing provision is ultimately contrary to Policy CP9 of the Placemaking Plan, and should be amended to increase the provision before any permission is granted.

Application Number: 19/04772/FUL
Application Date: 31/10/2019
Closing Date: 09/12/2019
Address: Additional Development Area, Holburne Park
Our Submission Status: Object