Outline planning application for comprehensive mixed use redevelopment, comprising B1, C1, C3, A1, A3, A4, A5, D1 and D2 uses, with total combined floorspace of up to 38,000sqm (GIA, above…
Our Response

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 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.

Viability and Affordable Housing:

While we appreciate that the main policy driver for this site is the provision of quality city centre office space, there remains a residential and a potential hotel element which do not fulfil B&NES policy objective for affordable housing. Given the presence of a residential element of the scheme, we are extremely concerned about this divergence from policy, particularly as the Council is the promoter of the site. It is a very worrying precedent if the Council, as developer, fails to comply with its own Policies.

The viability assessment made by the planning department must be seen to be undertaken completely independently and preferably transparently. We would encourage that assessor to test thoroughly the basis of the viability assessment, in particular the capitalisation as a land value of the car park.

The Council already owns this site and its revenue contribution (other than any loss during construction) is maintained after construction. While the developer will be expected over time to ‘repay’ the capital value through leases, the inherent land value is not lost to the promoters of the scheme.

We encourage the Council on the Property side to examine the financial parameters they have set for this scheme given the need for its delivery in order to fulfil the economic development strategy for the City. 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 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.

Design Approach:

We support 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. We believe that there is merit in the riverside frontages taking cues from, or hinting at, the former industrial warehouses which survived in this area prior to the 1960’s. The new Wapping Wharf development in Bristol is a great example of contemporary design, which has some traditional forms that relate well to local industrial heritage.
Enforceable Design Codes set to support architecture that can reflect this aesthetic are supported.

We support variation and articulation in development along the riverside. More ‘ups and downs’ would be more visually interesting and would relate better to the development on the south side of the river.

It is good see that roof articulation is specified within the Design Codes, however there is nothing mentioned about depth. The roof level needs to have form. Even if it is a flat roof a change in material is needed to provide visual distinction.

We have concerns about how the Design Codes are to be enforced, and therefore like Historic England we are unconvinced by the acceptability and effectiveness of the Design Codes unless they are embedded in Conditions or legislation. 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.

Application Form:

We have some concerns about the specifics given on the Application Form, which need to be properly cross referenced to the relevant parts of the application. E.g. Q9: Materials – proposed – only brick and metal cladding? (no stone shown for proposed); Q17: housing numbers is not answered, nor is Q19 employment.


We have welcomed a general reduction in height across the site as shown at pre-application stage. 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 19.5m-23.5m 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.

Buildings proposed at 23.5 metres high on Avon Street and 19.5 on Ambury would appear too great in the views from Beechen Cliff in particular. We are also concerned that 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 will review any additional verified views, as requested by Historic England, to assess the impact and degree of harm further.

Layout and Public Realm:

A street pattern that recreates the historic grain and enables views and routes through to the riverside from the city centre is welcomed. We remind the Council that public realm proposals must follow the adopted principles set out in the Streetscape Manual and Pattern Book for Bath.

The width of Corn Street could be more generous and the lane looks squeezed by the buildings around it. Here there is no provision for cycles and the pavement could be wider.

We are concerned that Milk Street appears blocked (in parameters plan – connection between blocks 6 and 7). While we recognise that efforts would be made to allow visual transparency we feel that this street pattern 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.


Very clearly 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.

Next Steps:

We will wish to be notified of any further documents submitted in support of this application so that we may have the opportunity to comment further. In particular the verified views as requested by Historic England. Please do notify us of the committee meeting date so that we can consider making a statement.

Application Number: 18/00058/EREG
Application Date: 10/02/2018
Closing Date: 20/01/2018
Address: North Quays North, Avon Sreet, City Centre
Our Submission Status: Comment