Clubhouse, Oldfield Rugby Football Club, Shaft Road, Monkton Combe, Bath

Erection and siting of fibre exchange telecommunications infrastructure to provide a full fibre (gigabit) to the premises service.
Our Response

This development focuses on the setting of the Oldfield Rugby Football Club, situated within the Green Belt, Cotswolds AONB, and the indicative landscape setting of the Bath World Heritage Site and the Monkton Combe conservation area. The site is situated immediately adjacent to the entryway into Monkton Combe via the Shaft Road approach from Combe Down. The site as existing functions as the car park for the Oldfield Rugby Football Club clubhouse, and is of moderate visibility from the road on the north-south approach. Whilst the car park is acknowledged to be a neutral contributor to the landscape character of the area, it is attributed some visual sensitivity due to its location on the rural periphery of Monkton Combe, with the village centre being located much further south. The landscape character of the area is a mix of denser tree planting, particularly to the south of the club grounds around the clubhouse and adjacent residential housing, and open fields bordered by hedgerow planting or coursed rubble stone boundary walling as part of the area’s rural vernacular.

In principle, telecommunications infrastructure within the Green Belt is not included within the development exceptions listed in Section 13 of the NPPF and is therefore by definition considered to be inappropriate development which requires demonstration of “very special circumstances”.

We note that the D&A Statement indicates that the development would constitute appropriate development under criteria g): “limited infilling or the partial or complete redevelopment of previously developed land, whether redundant or in continuing use (excluding temporary buildings).” However, this would only be considered acceptable where development would “not have a greater impact on the openness of the Green Belt than the existing development”. We acknowledge that the existing car park is already of some harm to the openness and character of the Green Belt, but its impact is limited due to the lower-profile use of hardstanding. The increased build-up of this site would therefore result in more structures across the site of greater visibility, and would consequently have a greater impact on the openness and appearance of the Green Belt than the existing site at present.

The development would also fail to be considered “limited infilling” due to its dislocated setting outside Monkton Combe and its open, rural setting. The development is additionally located outside of the Housing Development Boundary, which typically sets out where development would be considered to fulfil the principle of limited infilling.

We therefore strongly maintain that very special circumstances must be demonstrated as part of this application to clearly outweigh harm to the Green Belt.

There is no indication that other sites of lesser sensitivity have been appropriately considered or assessed as part of this application with regards to their suitability for development. Other possible sites should be discounted as unsuitable or inappropriate to appropriately justify development on this Green Belt site. It has been indicated by the Parish Council that another application for “fibre exchange telecommunications infrastructure” has been submitted by the applicant on an alternative site, and we therefore query why a second application is considered necessary within these circumstances.

BPT highlights an increasing number of applications for telecommunications infrastructure across the district. We therefore continue to emphasise the need for a cohesive city-wide operations plan for the future installation of telecommunications equipment, both in and around Bath. We maintain concerns that the permit of singular applications would establish a precedent for piecemeal development without consideration of the wider cumulative impact on the character and appearance of the Bath conservation area and the special interest of the World Heritage Site, as well as the special qualities of Bath’s landscape setting, the Green Belt, and the AONB.

Application Number: 21/05484/FUL
Application Date: 10/12/2021
Closing Date: 02/02/2022
Address: Clubhouse, Oldfield Rugby Football Club, Shaft Road, Monkton Combe, Bath
Our Submission Status: Comment