Bath Quays North Development Site, Avon Street, Bath

Variation of condition 42 (Approved Drawings, Development Specification and Design Codes) of application 18/00058/EREG03 (Outline planning application for comprehensive mixed use redevelopment, comprising B1, C1, C3, A1, A3, A4, D1…
Our Response

Given that this application is a variation of previously approved outline planning application we are repeating those comments we have made previously in response to general approach which remain applicable, as well as responding to the elements of the proposal which have changed. This application seeks to amend approved Drawings, Development Specification and Design Codes – specifically site layout, open space and Back Street, and building massing, scale and height.

General Comments:

BPT commends the approach to stakeholder engagement and the openness and receptiveness of the team responsible for taking the project forward. We have had considerable involvement in stakeholder meetings and the team have attended a number of meetings with our Planning and Conservation Team and Architecture & Planning Committee. We recognise that there has been considerable contextual analysis at a depth appropriate for a site of such significance. We welcome the clarity of the Planning Application Documents and scope of the Outline Application and the level of detail included for approval the design guidance and illustrative material.

The site of the historic ‘Broad Quay’ provides a unique opportunity for the former industrial nature of the site and historic street pattern to inform future development. We recognise that the redevelopment of the Avon Street site brings potential for significant public benefits, both economic and physical. In particular, at the local context high quality development would repair a fragmented townscape and re-connect it to the city, create new homes and public realm, employment and leisure opportunities.

The site is located within the Bath City-Wide Conservation Area and the City of Bath World Heritage Site. Development will have an impact on these heritage assets and the setting of many listed buildings and locally important buildings, the river frontage and views across Bath from the surrounding hillsides. The current buildings, uses, and car park occupying the site detract from the character of Bath.

BPT therefore supports the strategic ambition and aspiration to regenerate and repair this city centre site within the Enterprise Area, with new development to create a mixed-use riverside quarter. This site, like no other, offers a new city environment connected to the riverside, and a re-connection of the river and street pattern to the Georgian city.

A site-specific response, a vibrant public realm and a high-quality townscape which reflects and complements the historic character of the locality and sustains and enhances the Outstanding Universal Value of the World Heritage Site is encouraged.

Advice from BPT on the principle of development has generally placed an emphasis on:

• Consideration of the impact on views across the World Heritage Site, landscape setting, and setting of heritage assets, and views from surrounding hill sides.
• Heritage impact assessments and verified views/LVIA.
• The precision of the Masterplan parameters – including varying volumes and heights across the site – we would not support any breaking of the upper envelope of the parameter plans.
• Heights 5 of storeys or lower.
• The careful articulation and variation in roof profiles - the 5th elevation that is looked down upon.
• The robustness and integrity of roof design and associated landscaping.
• Architecture, materials and public realm that complements historic character.
• Considered approach to bulk and massing, and bulk of upper storeys.
• Variety in materials.
• Avoidance of covered through routes.
• Considered approach to corners.
• Restoring or maintaining the historic N-S street routes and re-establishing the E-W ‘Back Street’.
• Enough residential to provide an out of hours community, with proportionate provision of affordable housing.
• Integrated sustainability – e.g. designed-in solar PV.
• Ground floor active frontages on the riverside.
• Cycle hub.
• Pattern Book principles in urban design and landscaping.

Site Layout, Public Space and Back Street:

A street pattern that recreates the historic grain and enables views and routes through to the riverside from the city centre is welcomed. It is important that historic street patterns should be retained as an historic layout that connects to the riverside and should be a street that can been both seen through and moved through.

The width of Corn Street could be more generous and the lane looks squeezed by the buildings around it. Here there should be a greater provision for cycles and the pavement could be wider.

We note Back Street is widened by 1-2m and this is an accepted diversion from the parameter plans. We encourage some enlivening of Back Street through active uses at ground floor.

The reinstatement of Little Somerset Yard as a small square is encouraged.

The public realm needs to be very high quality and to be forward looking in terms of sustainability and biodiversity. There needs to be a place-specific approach that relates to the Pattern Book for Bath and has a visual cohesion with other parts of the city.

Public art needs to be curated for the context. We would like to see a clear place-specific brief for the selection of any artist rather than ‘presenting’ the use of one who has worked elsewhere, and potential with an element of public choice in the final selection.

We encourage the animation of place through creative responses to the design of the bus stop at Ambury Place and the kiosk. We like the idea of a Bath School of Architecture design competition and encourage this to be brought forward.

We recognise the need for flood-resistant planting and landscaping along the riverside which is not coming through in this application.

We remind the Council that public realm proposals must follow the adopted principles set out in the Streetscape Manual and Pattern Book for Bath.

Massing and Height:

We support the principle of Parameter Plans which set the maximum quantum, floor uses, height and foot print, build lines and depth specific to plots – as this is particularly beneficial to limit maximum height to specific locations. This doesn’t necessarily mean, however, that we agree with the maximum building heights set out in the proposed Parameter Plan – see below.

We support the principle of street-based place making. The proposed design approach which breaks the site up into zones relating to the street and place is supported in principle. A general form and block depth characteristic of the Georgian period is encouraged.

We support contemporary and innovative architecture within the appropriately agreed parameters. Formal frontages along Corn Street seem appropriate. We support a ‘fine grained’ approach to the pattern and rhythm of streets and buildings.

This riverside site was historically idiosyncratic, having a different character when compared to the classical formality of Bath. Therefore, we feel that riverside location provides an opportunity for development on this site to be different while complementing the homogeneity of tone and palette of the wider city.

BPT has previously welcomed Design Codes that relate more strongly to the industrial character of the area rather than Design Codes which support more formal fronts.

We welcome Design Codes that break down massing to provide variety and articulation. More ‘ups and downs’ would be visually interesting and would relate better to the development on the south side of the river.

We are concerned that some elevations lack local distinctiveness or ‘Bathness’. Particularly the active, internal elevations such as Back Street have a London feel.


Changes to heights have been stated as “Amendments to maximum building height zones to capture certain small extensions in height, which exceed the blue veil, they are: within the maximum 36.1m AOD height zone that the Plot 2 shoulder height would increase by 1.45m to 37.55m and the Plot 5 shoulder height by 2.95m to 39.05m; and within the maximum 34.9m AOD height zone that the Plot 5 shoulder height would increase by 2.65m to 37.55m. The maximum quantum of upper floor massing in Parcel B would be increased from 900sqm to 1,050sqm.”

Maximum heights plans are stated as:

Plot 6 facing onto Avon Street max height of 19.7m
Plot 7 facing onto Milk Street/Corn Street max height of 18.5m
Plots 1-2 facing onto Corn Street/Ambury max height of 20.5m (concentrated onto Back Street) with max height of 15.9m-18.5m along Corn Street/Ambury/Riverside
Plots 3-4 max height of 21.4m (set back from roof edge) with max height of 18.5-19m along Corn Street/Riverside
Plot 5 max height of 21.4m (set back from roof edge) with max height of 19m along Corn Street/Riverside corner frontage.

We welcome a general reduction in height across the site. However, we still have some concerns about the proposed maximum height parameters. We recognise that the height of nearby buildings is 17.5-17.75m – therefore in the context of the Building Heights Strategy buildings proposed with a shoulder height of 19m would appear above the acceptable height.

If buildings are to be above this height (and there may be a case for well-designed higher elements on the site) this would need to be assessed and supported by enforceable Design Codes.
We maintain concern that any buildings above 5 storeys would be visually prominent and may have adverse impacts on the special qualities of the World Heritage Site, specifically the city in the hollow of the hillsides.


We have always encouraged articulation and variation in the roofscape and it is good see that roof articulation is specified within the Design Codes, however more needs to be stated about depth and the roof levels need to have form.

The proposed ‘variety’ in roof form felt to be more honest than the use of a mock mansard profile. We generally encourage contemporary, 21st century design rather than faux-historic roof profiles, especially fake mansards.

Even if it is a flat roof a change in material is needed to provide harmonious visual distinction. There needs to be much greater coherence between the ‘activated’ or ‘living’ roofscape and elevations.

A ‘living’ roof needs to be reinforced by design as well as human activity.

A more robust approach to roof design and landscaping is encouraged. The LPA need to be convinced (at application stage) that a deliberately different roof form, in the shape of flat forms with significant green landscaping, has solid integration with the design. At the moment the D&A statement says that the roof ‘could’ be developed in certain ways. If it is to be supported, it is essential that the green landscaping is ‘locked in’ to the design, and not able to be value engineered out leaving us with a plain flat roof.

We have some concerns about the over-cluttering of the roof, and how this would be viewed from the pavement.

We query whether the volume of usable roof space be increased?
We are pleased to see the inclusion of integrated solar. We will be urging the LPA to Condition this and compliance-check any consented provision. However, we would not wish to see the solar provision cramp the landscaping provision and they must be designed together in order to ensure appropriate place for each.


We have made clear that we do not think the proposed paired and squared off corners are successful. The only precedent in Bath is not one we would encourage. We accept the rationale for curved corners, as a nod to Bath’s ‘special corners’. Any paired/square corners and special corners should be reinforced with contextual analysis within Bath.

We remain particularly concerned about the articulation of the Ambury-facing east elevation/corner.

Any potential for projecting, ‘kick-up’ corners are of concern and risk being intrusive in townscape views.

Design Codes:

We have concerns about how the Design Codes are to be enforced, and therefore we are unconvinced by the acceptability and effectiveness of the Design Codes unless they are embedded in Conditions, legal agreements or planning policy. We would therefore wish to see the detail of Design Codes as a Condition of any permission granted, or included in an adopted masterplan SPD for this site.

Viability and Affordable Housing:

We note that there is no affordable housing being delivered through the planning application due to scheme viability, however the Planning Statement (para. 4.17) mentions that “through the intervention of public funding towards common infrastructure, …a minimum of 25 dwellings will be delivered in Phase 1 and made available for sale at a discount of 20% from market value”.

Setting aside the issue of affordability and the Council’s preferred tenure mix, unless the units were secured through a planning obligation/s.106 agreement their delivery would be entirely dependent on a separate agreement between the Council and the developer i.e. outside the planning process/the control of the local planning authority. We note that the Applicant has not proposed the units would be secured through a planning obligation/s.106.

The hotel element has not changed since the original outline planning permission. When that application was considered by Committee the report considered the issue of policy compliance and concluded that whilst a hotel is not specifically identified as a use for the site, it was considered acceptable.

We recognise that the funding package across this site, South Quays and Bath Riverside is complex and that there are a number of submissions to HCA in relation to the site as a whole. If the receipt of any of those grants influences the capacity to deliver affordable housing on this or a related site it is important that this is conveyed and integrated into the viability/affordability model before the planning application is determined as it is a key criterion in establishing whether not the scheme is compliant with policy.

In considering Best Value (rather than maximum price) the Council needs to recognise that they need politically to set a standard for developers in delivering to B&NES’ policy standards in relation to affordable housing.


We support the removal of Avon St car park. We must emphasise that we don’t oppose the removal of some of the parking places. We wish to see reduction in city centre car parking to discourage car use and the impact of traffic on the special character of Bath.

What’s in a Name?

We note that the name Bankside has been dropped. We would prefer the name to refer to the local history and identity of the site. The original name – Broad Quay – would seem a more appropriate starting point. We are unclear whether the name ‘South Quays’ has been fixed but if each developer is looking for distinctiveness there is no reason why the ‘South Quays’ site could not refer to Newark Works while the North Quays site could reclaim its (Bath) Broad Quay identity. We remain concerned about the previously trailed ‘No.1’ identity for the main office building for the simple reason that there is already a ‘No. 1’ in Bath at our long established museum at No 1 Royal Crescent which is a specific historic address rather than an arbitrary name choice.

Application Number: 20/02787/VAR
Application Date: 04/08/2020
Closing Date: 01/10/2020
Address: Bath Quays North Development Site, Avon Street, Bath
Our Submission Status: Comment