Site Of Former Ministry Of Defence Offices, Warminster Road

Proposed construction of 42no. new dwellings and 2no. new blocks of apartments to provide a total of 70 new homes on part of the former MOD site at Warminster Road…
Our Response


Fundamentally, the Trust objects to the application on the grounds of insufficient affordable housing provisions. This under provision is inexcusable; as stated in Policy CP9 of the District-Wide Strategy and Policies Plan, development in this area of Bath is expected to have a 40% allocation of affordable housing, a quantity this development unfortunately fails to reach.

Design Approach:

We maintain that the documents submitted with this proposal are of an inadequate standard (see response to 14/02272/EFUL submitted 29/09/2016), and we would expect high-quality, detailed architectural elevations and all intended material selections to be submitted before this development progresses further. Similarly, the provided photomontages and predicted views are misleading. Whilst the view along Warminster Road has been significantly improved in the removal of large blocks from the southern boundary of the site, the expansion of the site to the north, east, and west is cause for concern. Our objection to 19/03836/FUL should be noted in relation to this application.

The Trust feels that this proposal would lead to the problematic overdevelopment of the site, consequently impacting on previous landscaping and screening efforts with resulting aesthetic harm. We feel that this development would establish a precedent for further peripheral development, and the continued expansion of the permitted development boundary that would result in a greater harmful visual impact on the conservation area and Bath’s World Heritage site and setting.

BPT objects to the use of render on these prominent elevations, as stated in responses to previous applications on this site; all elevations should be Bath stone ashlar.

Affordable Housing:

We strongly object to this development’s low provision of affordable housing. The Planning Statement states that there will be no increase in affordable housing beyond the 29 affordable homes included in Phase One of construction due to “abnormal costs and commercial considerations”. The Viability Assessment has amended the scheme with a 15% inclusion of affordable housing, taking the overall percentage across the Holburne Park site to 24.13%, a number that is still inadequate in line with local policy demands. BPT is opposed to this loss of affordable housing and feels that its provision should not be reliant upon the unplanned commercial or construction costs of a residential development. The documentation provided is fundamentally inconsistent with regards to proposed affordable housing inclusion and this should be rectified before the application goes any further.

This proposal therefore contravenes Policy CP9 of the B&NES Core Strategy and Placemaking Plan. The Warminster Road site falls within the Bath area with a target of 40% affordable housing. We would strongly recommend that this development’s sub-standard allocation of affordable housing be amended before any aspects of the scheme are approved.


This new scheme’s massing alongside Warminster Road has significantly improved; however, the scale of expansion towards the east and west of the site as well as the provision of villas along the northern boundary raises strong concerns about the overdevelopment of the site and how this will impact the historic character of the area. The insufficient affordable housing provision is contrary to Policy CP9 of the Placemaking Plan, and should be amended to increase the provision before any permission is granted.

Application Number: 19/03838/FUL
Application Date: 06/09/2019
Closing Date: 10/10/2019
Address: Site Of Former Ministry Of Defence Offices, Warminster Road,
Our Submission Status: Object