Oldfield School, Kelston Road, Newbridge, Bath
The proposed site of development is the Oldfield School complex, situated within the Green Belt, the Cotswolds AONB, and the Bath World Heritage Site. It additionally forms part of the indicative landscape setting of the Bath City-Wide Conservation Area. The site is set away from the residential edge of the city where this terminates along Penn Hill Road to the east, and as such is perceived to sit within Bath’s rural landscape setting, surrounded by agricultural fields to the north and west. It forms an important part of the green landscape setting OUV of the World Heritage Site due to its hillside position looking south over the River Avon and wooded boundary line contributing to landscape views enjoyed from the south, such as along the Bristol Road approach into the city.
Where the entirety of the school site is located within the Green Belt, it is acknowledged that any new development on this site associated with the expansion of associated school facilities must be considered in relation to its impact on the openness and appearance of the Green Belt.
In accordance with Section 13 of the NPPF, “local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.”
The scheme would result in an anticipated -100% biodiversity net gain, with a total loss of the existing biodiversity value of the site (0.4768 habitat units), though we note that the Ecological Statement has undertaken the calculation without proposed landscaping. Ultimately, it is concluded that “the proposals will result in the loss of a significant quantity of the existing habitat on the site, as almost the entire area will be built on.” There is insufficient information provided as part of the tree survey regarding the overall loss of trees from the site to facilitate development, but the proposed site plan appears to indicate a loss of approximately 7-8 trees without adequate assessment or mitigation.
It is not proposed to address this overall loss through the provision of off-site mitigation or enhancement works, and as such there would be an overall biodiversity net loss on the site contrary to Policies NE3 and NE3a of the Core Strategy and Placemaking Plan.
We therefore strongly encourage greater consideration of how on-site measures could be implemented into the proposals to ensure that the existing biodiversity value of the site is sustained and enhanced, through either the provision of new planting or habitat, or the reinforcement of existing green areas, to address the policy reasons for refusal and demonstrate that the existing character of the Green Belt would be protected. The proposed removal of trees should also be sufficiently assessed and mitigated with appropriate replanting works. Where existing biodiversity value can be sufficiently sustained or enhanced, this may be considered to contribute towards the overall planning balance of ‘very special circumstances’ demonstrated by the applicant, to suitably demonstrate that proposals would seek to reinforce the existing green character, rural setting, and openness of the Green Belt.