Jubilee Centre, Lower Bristol Road, Twerton

Mixed-use redevelopment of site for storage and distribution (Class B8) and erection of 127 units of purpose-built student accommodation (sui generis) following demolition of existing building and associated access and…
Our Response

The Jubilee Centre is an unlisted 20th century industrial building situated along Lower Bristol Road, within the Bath conservation area and World Heritage site. The site sits adjacent to Rackfield Place, a terraced series of Grade II early Victorian artisan cottages in coursed rubble stone which appears to be a rare example of early back-to-backs in Bath. The site additionally runs opposite the Grade II 1840 Twerton Viaduct, and consequently forms a significant part of the Viaduct’s riverside view and streetscape setting.

The Trust has objected to past iterations of this scheme which proposed purpose-built student accommodation (see application 17/05536/FUL). We maintain a strong in-principle opposition to this proposal on the grounds of the unjustified provision of further student housing, and the proposed height, scale, and massing of the development which would be of detriment to the appearance and character of the Twerton region of the conservation area, and harm the setting of two Grade II heritage assets.

Student Accommodation:

We acknowledge the varied development potential of the Twerton Riverside Enterprise Zone as noted in Policy B3 of the Core Strategy and Placemaking Plan. However, we strongly maintain that this site should provide a mixed-use scheme for local residents and essential workers with close proximity to the RUH and Bath’s industrial sites and offices. This application does not account for the predicted impact on student numbers by the Covid-19 pandemic, and the recent statements made by Professor Sue Rigby regarding the lack of proposed future growth by either of Bath’s universities. There is consequently no justifiable demonstration that this development will meet a future demand. We additionally feel that the development of further Purpose-Built Student Accommodation (PBSA) adjacent to the Twerton Mill site and to the west of Charlton Court represents a disproportionate concentration of student accommodation within the Twerton area, contrary to the aims of B&NES’ HMO SPD 2013 to encourage a sustainable balance of communities throughout Bath.

We would additionally question the suitability of the building to be effectively adapted to alternative, long-term residential use by local individuals and families in future when considering the small size of the internal residential units, and lack of appropriate outdoor private amenity space.

Height, Scale, Massing, and Appearance:

In accordance with B&NES Building Height Strategy, new development within Zone 3 should have a maximum shoulder height of four floors, with a maximum of one additional setback storey within the roofscape. Whilst one additional storey may be deemed permissible within developments along Lower Bristol Road, this is not applicable to sites “in close proximity to existing 2-3 storey residential areas”, and a height of under four storeys is encouraged in response to nearby heritage assets and the amenity existing residential dwellings. Therefore, the development as proposed constitutes overdevelopment of an excessive height and massing, which is contrary to local policy guidance, and would be over-dominating and incongruous, resulting in a detrimental impact to the established scale and townscape character and local views.

We do not feel that the comparison with the Twerton Mill student accommodation block is appropriate due to the setback of Twerton Mill’s five-storey building along the river behind a lowered three-storey elevation which better complements the Lower Bristol Road streetscape, and the adjacent Rackfield Place, without overshadowing designated heritage assets such as the Twerton Viaduct. We would further assert the success of the Twerton Mil scheme is furthered by its use of amenity space and pedestrian access to break up the scale and density of residential blocks, and improve the site’s permeability and streetside presence.

Conversely, the proposed scheme constitutes overdevelopment and would be monolithic in height, massing, and appearance, in views from both Lower Bristol Road and Weston Island, with little variation in its roof articulation or recession which might help to break up an otherwise imposing and bulky insertion within the streetscape. This drastic increase in height would have a ‘canyoning’ effect on this narrow portion of Lower Bristol Road and would significantly overshadow the Grade II Twerton Viaduct, and views from the Viaduct itself, which remains a prominent feature within this region of the conservation area. Furthermore, we do not feel that the proposed design suitably accounts for its close proximity and consequent harm to the setting of the Grade II Rackfield Place; the three storey eastern block would sit above the ridgeline of the terrace, and leads sharply into the four and five storey central block, with an additional half storey in the sawtooth roof profile and exaggerated ground floor height, without adequately setting the development back to avoid direct overshadowing.

We additionally feel that the extensive use of buff brick across the primary road-facing elevation is incongruous in an area of primarily coursed Bath rubble stone and Bath stone ashlar. We are additionally concerned by the lack of specification of the brick and mortar type that will be used, and consequently what finish the building will have. We would strongly recommend that materials, specifically the type and colour of brick, are resolved within the timeframe of this application and not left to a Condition. All materials should be specified, with samples provided, before this application is approved. We would additionally advise that the type of rubble stone being used is specified as part of the application; we would recommend the selection of an oolitic limestone that would better complement the extant material character of the conservation area.


The development proposed by virtue of its excessive and visually dominating height, massing and appearance, constitutes overdevelopment of the site with associated harm to multiple heritage assets; the conservation area and the setting of Grade II listed buildings. The development would therefore neither preserve nor enhance the distinctive streetscape character of the Bath conservation area, and would fail to contribute positively to local character and distinctiveness.

There is no suitable justification for the further provision of PBSA along Lower Bristol Road, and no demonstrated consideration of the future impact of Covid-19 on future student numbers and an associated decline in accommodation demand. This application is therefore contrary to the Planning (Listed Buildings and Conservation Areas) Act 1990, Sections 12 and 16 of the NPPF, and Policies D1, D2, D3, D4, D5, HE1, and B5 of the Core Strategy and Placemaking Plan, and should be refused.

Application Number: 20/01794/FUL
Application Date: 28/05/2020
Closing Date: 25/06/2020
Address: Jubilee Centre, Lower Bristol Road, Twerton
Our Submission Status: Object