Parcel 4234, Combe Hay Lane, Combe Hay, Bath

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Full planning permission for the erection of 171 residential units, open space, green infrastructure, landscaping and associated works including provision of vehicular access from Combe Hay Lane (Revised Plans February…

Our Response

The Trust has reviewed the large amounts of additional information supplied by the applicant and whilst we commend the level of detail covered, we maintain our objection to this application on the basis that provisions of Policy B3a regarding a comprehensive masterplan are still not satisfied. Moreover, as B3a envisages “around 300” dwellings on the whole site, the provision of 171 in Phase 1 comprises an unreasonable proportion, in relation to the viability of further phases and potential traffic generation of the whole.

We refer to our response of July 2017 where we detailed our support for the overall architectural designs and garden suburb themes of the scheme and this has not changed. We note the decrease in units by 2 to 171 and the minor changes that have been made to individual buildings within the scheme to take account of concerns regarding long range visibility. In particular we welcome the changes which sees the Derryman’s field without any allotments or play equipment and the strengthening of landscape planting in this area. Likewise we welcome the additional tree planting and mitigation landscaping to the perimeter of the site, especially to the south and the augmentation of green infrastructure within the site including a reduction in parking spaces and an increase in the size of some gardens and verges. These changes are all welcome and improve the Phase 1 scheme to a certain extent, although the additional space allowed for 'buffer' planting is still inadequate for its purpose and it is not satisfactory that the important landscape setting should be compromised by housing numbers.

Comprehensive Masterplan:

We fail to understand how the removal of the word 'illustrative' from the title 'comprehensive masterplan' can solve the issue of the lack of appropriate detail. We note the information contained in the Comprehensive Masterplan Update Note of January 2017; and in particular that the masterplan is now specifically accompanied by Landscape Design Parameters, LVIAs and Ecological Principles; that these now form part of the application and are not ‘illustrative’ is welcome. However other than the changes noted in the Section 6 of the above note (p.5) which we will discuss later in this response, we cannot see any meaningful improvement to the document and it does not satisfy the placemaking requirements of Policy B3a.

We refer to our July 2017 comments on this issue which still stand (for ICM read CM):
“This concern centres on the uncertainty that the lack of an overall site masterplan engenders, and the possible future incremental ‘boundary creep’ and over-development that could occur as the planning system and the priorities of the B&NES/West of England authorities change and develop over time so that subsequent phases could undergo different levels of scrutiny in an as yet unknown policy environment. The legal opinion submitted by the developers to B&NES regarding the comprehensive masterplan issue and the ‘risk of pre-determination’ (should the scheme be reviewed by DMC as per Policy B3a) makes clear that the masterplan should be considered as part of a planning application not as a stand-alone item by DMC. Therefore we recommend that, in order to comply with B3a, the overall masterplan should be considered as an outline application with detailed phases coming forward as reserved matters applications.

The Illustrative Comprehensive Masterplan (ICM) document outlines the masterplan principles for the site that are ‘intended to inform all later stages of the scheme’. Yet the CM does not comment on the general extent of built development, massing, density and height of buildings; these are key issues that would be expected to be included in a comprehensive plan, because these matters control the quantum as well as quality of development. In addition key infrastructure is not being forward planned, this includes green recreation space and site/surroundings connectivity but also crucially local services for residents such as a food store and community places. This leaves the Phase 1 scheme isolated, without an assured future as part of a planned and integrated community with adequate local services”.

Policy B3a refers to a comprehensive masterplan reflecting best practice principles in ‘In Design’ which is essentially a detailed urban design tool kit. Aside from a site map noting phases there does not appear to be any urban design work undertaken for the overall site, only for Phase 1.

In the updated masterplan map, we question the allocation of a school site in an area that is already well provisioned with schools; it is very possible this site could also be put over to housing, increasing numbers yet again. Similarly, the lack of clarity regarding Sulis Manor is of concern, clearly a number of options are on the table for this site, including, apparently, demolition of the fine Arts & Crafts house, to which we would strongly object. Sulis Manor has been deemed by Historic England a local non-designated heritage asset with strong local interest as an unusual example of Arts & Crafts design in the Bath area. This historic building must be retained as it would reinforce the sense of place and contribute to placemaking and has a strong relationship with Ben Pentreath’s designs. How, therefore, the masterplan can be considered comprehensive is puzzling, given the development parameters of a key part of the site are very unclear.

Use of the Great Broad Close:

We strongly object to the use of this field for any type of development including allotments and play space. It is very clear in B3a that this field is not to be developed in any way, and even with conditions preventing structures on the allotments and playing fields, these will undoubtedly appear. This is a prime example of the ‘boundary creep’ that we have warned against since the release of this site from the Green Belt. Space for these community facilities should be found within the delineated development site, not outside it. At a density of 33ph and with 171 houses, the Phase 1 site is already overdeveloped and given that the entire site should only be developed with around 300 houses, surely space within the scheme should be found at the expense of some housing and would help contribute to the garden suburb character? It is also of concern that the residents of Phase 1 will have no access to these community facilities until some considerable time in the future when other phases are built out.

Transport Impacts:

We have reviewed and absorbed the key findings of the Transport Assessment Addendum (TAA). As many of the appendices conclude, the traffic in the area will reach capacity by 2022 regardless of the development at Sulis Down. We are not satisfied that this has been properly addressed or analysed in the main body of the TAA report. We also disagree with the conclusion that the impact of Phase 1 traffic would be ‘not severe’. The Trust is of the opinion that the impact of significant additional traffic to a transport network that is deemed to be running at capacity should be considered as 'severe'.

We would also expect the transport assessment to thoroughly examine and model for the whole masterplan as a requisite of policy B3a but obviously given that the amount of housing (and thus cars) has not been formally quantified or agreed this cannot be achieved. The current (Jan 2018) CM does not refer to numbers but the Jan 2018 TAA refers in para 2.5.1. and in Appendix G to a 'Full Masterplan Quantum' of 450 units. A sensitivity test for this amount has been undertaken but this cannot go into enough detail for the Trust to be satisfied that the impact of the whole masterplan has been fully evaluated. Additionally no account has been taken of the impact of a possible school in Phase 3 nor of the units that might be proposed instead of a school.


As things stand with the current application we do not believe that effective and successful placemaking can occur without a detailed forward plan for the overall site. We refer to our initial objection to this application, namely that in order to discharge the requirements of B3a an outline application for the entire site (including the Business Village) should be submitted. Treating Sulis Manor notionally, as it is not under the applicants' control, although it is clearly a crucial part of the overall site is unacceptable. This masterplan should cover the normal ground of an outline application, establishing site boundaries, development parameters, design codes, housing density, local community infrastructure and access arrangements. Once the overall masterplan is consulted upon and agreed, this could be followed closely by a Phase 1 reserved matters application. We therefore continue to object to this application on the basis that it is contrary to the local development plan, namely Policy B3a of the Core Strategy.

Application Number: 17/02588/EFUL 
Application Date: 22/02/2017
Closing Date: 20/01/2018
Address: Parcel 4234, Combe Hay Lane, Combe Hay
Our Submission Status: Object