Land To North East Of Lambridge Training Ground, London Road West, Lower Swainswick, Bath
The proposed site of development is a portion of land formerly associated with the neighbouring Lambridge Training Ground, situated within the Bath City-Wide Conservation Area and at the eastern entrance into the City of Bath World Heritage Site along London Road. The site is bordered by the Green Belt to the immediate south where the Green Belt encompasses the southern side of the River Avon. The site is located outside the Cotswolds AONB where the boundary starts to the south of Warminster Road, along the edge of Bathampton Down, but this does not negate the potential contribution of the site into views from the AONB, as well as its role in sustaining the rural green edge of Bath’s periphery as this transitions between the built and natural environment. The southernmost strip of the site falls within the Site of Nature Conservation Interest (SNCI) associated with the river. The site is positioned to the immediate south-west of the neighbouring garden setting of the Grade II listed Lambridge House.
The Bath City-Wide Character Appraisal (2005) notes the south-west area of Bath as being “rural with an open character”; the grain along London Road and London Road West is primarily residential, of a noticeably lower density with an increasing number of detached dwellings set back from the road within generous garden plots. There has been an increasing amount of built encroachment on the eastern edge of Bath towards Batheaston, including the 2014 development at Hicks Field and the recent granting of planning permission for further housing on the south-western corner of the bypass, as well as ongoing incremental development to the south-east of Lambridge House.
London Road remains a principal historic route into the World Heritage Site, as identified in the City of Bath World Heritage Site Setting SPD. Approaching the City via Batheaston, open views are experienced from the road across the valley towards Bathampton Down, merging into views of Bath’s city centre and eastern edge. From a site visit, clear sightlines were established towards Bathampton and Bathampton Down to the south, as well as views across London Road to Little Solsbury Hill and encompassing the Lansdown area, when the tree cover was at its thinnest. Key landmarks in views from the site include St Stephen’s Church on Lansdown Road.
The site is not currently allocated for development within the adopted Local Plan, although it has previously been identified as a site for a Park and Ride facility, for which planning permission was originally granted.
BPT has previously been involved in pre-application discussion with the applicant and responded to a series of design iterations, the most recent of which has come forward in the submitted planning application.
Our response to the development as presented, and pre-application advice has been with the aim of shaping excellence in design quality as appropriate for the gateway to the World Heritage Site, and mitigation of visual impact in landscape setting, should the principle of development on undesignated land be accepted.
Principle of Development:
We continue to advocate for the prioritisation of sustainable development on brownfield sites. Consideration of alternative brownfield sites for retail development should form part of the justification for development within the Design & Access Statement, and why these sites are considered to be unsuitable.
We highlight serious concerns with the principle of development on green sites where there would be a risk of perpetuating further development creep on the edge of Bath. In particular, the eastern end of Bath is particularly susceptible to development infill where there are opportunities for roadside development with strong connections to outlying settlements such as Batheaston. The perceived open green character and connection between built edge and countryside in this area is largely dependent on an acting green buffer between London Road and Warminster Road, made up of Bathampton Meadows but reinforced by further segments of green undeveloped land that break up the built presence of roadside development. Development in this area therefore risks exacerbate existing issues with development creep and threatens the erosion of Bath’s green landscape setting, it sets a precedent for this type of development, and places adjoining green sites such as Bathampton Meadows, albeit in the Green Belt, under increasing pressure.
We do, however, acknowledge that there is a historic precedent for the site’s development, where it was previously allocated within the 1997 Bath Local Plan for Park & Ride use under Policy T9, though this allocation was omitted through the later iterations of the Local Plan, and later the Core Strategy and Placemaking Plan. Planning permission was granted in 2005 for the construction of a park & ride car park with associated facilities (see 03/00057/EREG03). Therefore, the site has previously been deemed acceptable for development in line with local policy.
While BPT has strong landscape and World Heritage Site setting impact concerns regarding the principle of development, should the principle of development on undesignated land be considered by the LPA to be policy compliant, the approach to any building, infrastructure and site layout should appropriately consider, assess, and mitigate any resulting impact to the landscape setting of the World Heritage Site, conservation area, and AONB.
Landscape & Ecology:
The proposed landscape assessment appears to be incomplete, with a lack of corresponding visuals uploaded to the planning portal to support the LVIA as submitted. We maintain that an informed assessment of landscape impact cannot be made without provision of the appropriate documents for consideration, both by the case officer and as part of the public consultation process.
We have serious concerns that the development of this open site would have a negative visual impact on the verdant landscape character of the World Heritage Site setting and semirural character of London Road as a principal historic route and gateway to into the World Heritage Site, as identified in the City of Bath World Heritage Site Setting SPD. Development would have a visual impact on open views are experienced from the road across the valley towards Bathampton Down and Little Solsbury Hill and from within the Camden area, and result in a degree of harm to the landscape setting of the City of Bath World Heritage Site, and neither preserve nor enhance the rural open character and appearance and setting of this part of the Bath City Wide Conservation Area.
Given the existing ecological value of the riparian zone along the south-eastern boundaries of the site, adjacent to the Lam Brook and the River Avon, we maintain that great care is required as to how existing habitat is maintained and enhanced on the site whilst balanced against the delivery of a supermarket and associated hard landscaping works. We trust that this will be appropriately considered by the ecology officer to ensure that the proposed landscape mitigation works would be effective in securing valuable areas of riverside habitat in the long-term whilst reinforcing the site’s green landscape contributions to the setting of the river as a SNCI.
We have serious concerns regarding the scale of proposed artificial lighting on the site, both in the use of lighting columns in the car park as well as down-lighting installed across all elevations of the proposed building. There appears to be some inconsistencies in the drawings provided regarding the scope of lighting; in some of the proposed drawings, lighting is identified along the northern elevation looking onto the tree boundary of Lambridge House. The use of lighting would appear to be somewhat redundant in this area, and would be spread across the entire elevation rather than focusing exclusively on the area for delivery vehicles. The scope of lighting in this particular area wouldn’t appear to be sufficiently justified.
There are further questions regarding the level of lightspill on adjacent habitat zones, where these areas are identified as being within Dark Zone 3, to be kept below 3 lux levels of illumination. The area to be kept below 0.5 lux is identified as a thin strip directly alongside the riverbank. We maintain that given the ecological and visual sensitivity of the riverside setting of the development, this area in particular should be identified as an area of zero levels of lightspill, and lighting proposals should be amended accordingly to achieve this.
Design & Appearance:
We reiterate that our response to the development as presented, and pre-application advice has been with the aim of shaping excellence in design quality as appropriate for the gateway to the World Heritage Site, and mitigation of visual impact in landscape setting, should the principle of development be accepted.
BPT offered updated comments in response to the revised design proposals presented at pre-application consultation stage in May 2023. We therefore reiterate those comments as follows, where the proposed design as submitted matches what we were presented with during the consultation period.
We maintain, in principle, that the intention to deliver a bespoke, rather than off the peg, supermarket design in response to its sensitive landscape and heritage context should be commended. In accordance with Bath’s Outstanding Universal Value as a World Heritage Site, development is expected to respond to the distinctive characteristics of its local context.
We continue to emphasise the site’s significance as one of the first views into Bath along the London Road, for visitors coming off the A46, but commend the design team’s decision to avoid the creation of a ‘gateway’ landmark.
We recognise that the building’s low profile, understated elevational articulation, use of vernacular materials and soft landscaping helps the building fit into street scene in an innocuous and subdued fashion, though its success would remain partially dependent on ensuring that the belt of trees and planting along the roadside edge is allowed to thrive. The use of a ‘featureless’ rubble stone façade would more strongly reflect Bath’s edge of city boundary treatment and its rural character and appearance.
The use of timber cladding at the upper floor level where this ‘steps’ up to the sedum roof is considered by BPT to be appropriate within this location on the edge of the city, where an open, green character more indicative of Bath’s rural setting is prevalent. We have previously suggested that there could be further opportunity for planting at this level to increasingly ‘green’ this elevation and enhance its boundary wall-style typology.
Further information would be required regarding any proposed use of downlighting across the building frontage and associated brightness levels.
Impact on Local Retail Centres:
In accordance with Policy CR2, “Retail and commercial leisure development outside of centres will not be permitted if […] it would be liable to have a significant adverse impact on the vitality, viability and diversity of existing centres […].”
We have concerns regarding the potential impact of a new supermarket within close proximity of the thriving local retail centre of Larkhall, identified as a local urban centre within Policy CP12. It is anticipated that there would be some redistribution of customers from the local high street to a nearby supermarket offering products at a cheaper price point and within a convenient location for those living in the Larkhall area. The Planning & Retail Statement has already acknowledged that there would be an impact on the Larkhall centre of -5.53%, but there are some questions regarding the methodology used, particularly the assertion that the proposed Lidl store would target “local shoppers already travelling to a large supermarket to complete their weekly shop,” or those using identified convenience/food stores for “‘top-up’ shopping trips.” This does not appropriately account for the anticipated influx of new local customers, rather than just those already using supermarkets, where Lidl would likely provide a more appealing and affordable alternative. In this case, we consider the degree of impact on the local area may be understated.
Where the Planning & Retail Statement summarises that the Larkhall high street appears to be trading well, noting an absence of vacant unit, this is not necessarily indicative that there would be limited impact resulting from a new Lidl supermarket. Indeed, this may instead better illustrate the ability of local high streets to thrive where there is an absence of larger commercial competitors in close proximity.
We note that consultation responses and feedback from local traders are conspicuously absent from the Statement of Community Involvement as submitted, and as such there are continued questions as to how engagement and collaboration with local traders and businesses may have informed proposals which BPT has asked throughout our pre-application consultation engagement.
Transport & Traffic:
The Transport Assessment as submitted appears to conclude that the proposed development and associated works such as a new access junction and road improvements for pedestrian and cyclist users would not have a significant impact on existing traffic levels: “The proposed alterations to the London Road West / Gloucester Road junction have the benefit of being able to enhance the movement of pedestrian and cyclists whilst ensuring the impact on the road network are not severe.”
This doesn’t appear to correlate with the modelling figures as provided for traffic saturation along London Road and Gloucester Road. Despite accounting for a natural increase in saturation between 2022-2028 from a mean average practical reserve capacity of 46.5% down to 40.1% (with the highest figures of congestion being weekday peak hours in the afternoon), modelling with Lidl would bring this further down to a mean average reserve capacity of 25.9%. This would be further reduced to 3.8% when modelling associated pedestrian crossing measures. The practical reserve capacity during weekday peak afternoon would be -4.3%, indicating the strong likelihood of overloading and vehicular congestion on London Road east and west. Similar issues have been identified in the modelling results for traffic coming off the London Road junction; modelling results incorporating pedestrian crossing measures would see a practical reserve capacity of -0.0& on peak weekday morning hours, and -3.4% peak weekday afternoon hours, again indicative of overloading (note no modelling results have been provided for Saturdays).
Where the Transport Assessment concludes that “the junction will operate within theoretical capacity in 2028 with the proposed development in place and when accounting for the pedestrian and cycle enhancements proposed at the junction,” we have concerns that this modelling results are instead more indicative of increasingly worsening traffic conditions along London Road, where this key entry point into the city is already heavily congested.
It could be considered that this site is primed for ‘vehicle-first’ access due to its position along a busy arterial road off the Batheaston Bypass. Its eastern fringe location may appeal to those making trips from outside of the city. Whilst we wholeheartedly support efforts to improve pedestrian and cycle access along this route to readjust spatial priorities in line with the hierarchy of road users, the site is not well-supported for prioritising sustainable transport by virtue of its location and existing issues with the road network. Further, supermarket shopping continues to be predisposed towards private car users where undertaken larger, infrequent shopping trips (eg. the weekly shop). We therefore question whether development would realistically meet the requirements of Policy ST1.
Where there may be an opportunity for the delivery of a new supermarket to the east of Bath, we maintain that the principle of development remains dependent on the level information and quality of detail submitted in support of the planning application to enable a proper assessment of the impact and demonstrate that any harmful impact on the surrounding area has been sufficiently considered and mitigated as part of the design process. We therefore have serious concerns regarding the development’s impact on local traffic infrastructure, the viability of the Larkhall high street, and potential impact on the existing ecological value of the site’s riparian habitat. We maintain that at this stage, insufficient information about the proposed degree of landscape visual impact has been submitted to enable a proper assessment of the degree of harm to the World Heritage Site and its landscape setting. We may, therefore reserve further comment pending the submission of the necessary documentation.
For the reasons stated above the development proposals risks harm to local landscape character and views into and across the landscape setting of the City of Bath World Heritage Site, without demonstrated public benefit, and fails to demonstrate compliance with the NPPF and Core Strategy & Placemaking Plan Polices, B1, B4, CR2, DW1, CP6, and HE1.
Policy B1 sets out the spatial strategy for Bath which above all else sets out the intention to sustain and enhance the significance of the city’s heritage assets and green infrastructure, to which all following objectives will be considered in relation. Proposals currently fail to demonstrate that designated assets (The Outstanding Universal Value of the City of Bath World Heritage Site and its setting, the Bath city wide conservation area and its setting) associated with the site would be sustained and enhanced.
In accordance with Policy B4, there is a strong presumption against development that would result in harm to the Outstanding Universal Value of the World Heritage Site, its authenticity or integrity, including its setting.
Retail and commercial leisure development outside of centres will not be permitted if […] it would be liable to have a significant adverse impact on the vitality, viability and diversity of existing centres […]
The development fails to accord with strategic objectives to promote sustainable development.
6) There continues to be insufficient information to demonstrate that the designated heritage assets associated with the site would be appropriately protected, conserved, and enhanced as part of the development proposals.
There is insufficient evidence that proposals would protect and enhance the distinctive quality and character of the site’s local context, the wider district, or its townscape setting, contrary to Policy CP6. The build-up of the site in townscape and landscape views, would not enhance the historic landscape, and would instead be of detriment to the character and setting of designated heritage assets including the World Heritage Site and its setting, and the Bath City-Wide Conservation Area.
In accordance with Policy HE1, development that has an impact upon a heritage asset is expected to enhance or better reveal its significance and/or setting, and make a positive contribution to its character and appearance. Proposals would fail to sustain or enhance the OUV of the World Heritage Site, and there is insufficient justification to demonstrate how development would contribute to the asset’s conservation.