Site Of Former Ministry Of Defence Offices, Warminster Road, Bathwick

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

This application concerns the south and eastern portions of the Holburne Park housing development along Warminster Road, situated within the Bath conservation area and World Heritage site with significant views across the valley to the north. This application proposes amendments to Phases 3a and 5 of the scheme following on from a Section 73 permission 18/01407/EVA as a variation of application 16/04289/EFUL to reduce the overall massing and volume of the site as viewed from along Warminster Road.

Following consideration of this application, there appears to be no changes made to the design, layout, or density of the proposal following on from 19/03838/FUL. Therefore, our previous comments regarding the poor quality of the submitted architectural drawings, and overall lack of coherence of development across the site remain valid. Fundamentally, we must continue to oppose this application due to the continued, unacceptable under provision of affordable housing. The proposed incorporation of 20 discounted market units at 70% market value does not constitute affordable housing, and only constitutes 29% of the overall proposal of 70 new homes, and a total of 25% ‘affordable’ housing across the site. 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 continues to fail to reach.

Design Approach:

We maintain that the documents submitted with this proposal are of an inadequate standard and inappropriate scale, and we would expect high-quality, detailed architectural elevations and all intended material selections to be submitted for a development of this size and location.

Furthermore, we maintain that this application provides inadequate information regarding the proposed design and material palette of the proposed development. The use of materials remains vague, “utilising a mixture of Bath stone ashlar and render dependent on the location and hierarchy of the elevation” without further design specifications. Whilst we note the prominent position of the Holburne Park site on the southern slope of the Avon Valley, we would particularly highlight the exposed north elevation of the eastern parcel, and its increased massing in comparison to previously approved proposals. We would therefore highlight the importance of appropriate, sympathetic material usage and detailing on these external-facing elevations, which already intersect sharply into sensitive, elevated landscape views of the World Heritage site. The Trust would emphasise the continued failure in previous applications, such as 19/03836/FUL, to recognise the role of the development in participating with, and contributing to the OUV green hillside setting of the World Heritage site. Therefore, BPT continues to object to the unclarified use of render on these prominent elevations, and the focused use of Bath stone on elevations facing into the Holburne site, as presented in past applications; we maintain that all elevations should be Bath stone ashlar.

The Trust would further highlight the potential for visual and amenity impact on the residents of adjacent two-storey terraces NE3 & NE5 (plots 118-125) by proposing two four-storey apartment blocks BF13 & BF14 in place of an approved two-storey terrace. Whilst the view along Warminster Road has been significantly improved in the setting back of larger blocks from the site’s southern boundary, there appears to be little consideration of potential for overshadowing or overlooking, contrary to Policy D6 of the Core Strategy and Placemaking Plan.

We would therefore acknowledge the visual harm to the World Heritage site and conservation area in the initial development of the Holburne Park site, and the consistent inadequacy of the documents submitted throughout the development process with regards to proposed detailing, elevation articulation, scale, and use of materials. The Trust finds the quality of submission fundamentally lacking for a site of this prominence and size, and we hope that this could be used to drive a higher standard for large-scale residential development applications in future.

Affordable Housing:

We continue to strongly object to this development’s low contribution of affordable housing. We would additionally note serious discrepancies within this application which need to be resolved, in which the D&A Statement suggests that Phase 3a would deliver 28 affordable units, contrary to the Planning Statement’s offer of 10 discounted market units in Block BF13, and Hardrock Development’s maximum offer of 20 discounted market units in Block BF13. Discount market housing does not constitute affordable housing, and therefore there would be no increase in affordable housing beyond the 29 affordable homes included in Phase 1 of construction. Even with the discounted market housing factored in, the overall 25% delivery across the Holburne Park site falls short of the 40% requirement for the Bath North and East area, and therefore this development continues to fail to meet local policy requirements. We maintain that unintended development costs are not a valid viability argument, and neither does the possibility of delayed construction works justify unacceptable under-provision of affordable housing.

We continue to feel that this development is a missed opportunity to provide on-site affordable housing within Bath, where there is limited land availability. 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. This current application therefore continues to make no contribution to the site’s under-provision of affordable housing and should therefore be refused.


Application 19/03838/FUL went to Planning Committee on 3rd June, and it was voted 6-3 that the application should be refused on grounds of:

“The proposed development fails to provide a policy compliant level of affordable housing and this is not justified by the viability appraisal or any other material considerations. The proposed development is therefore contrary to the development plan, in particular policy CP9 of the Bath and North East Somerset Core Strategy.”

“The proposed development, due its layout, height, design and appearance, would appear incongruous, bulky and overdeveloped, particularly when viewed from across the city. The proposals would therefore adversely impact upon the setting of the World Heritage Site contrary to the development plan, in particular policies B4 and CP6 of the Bath and North East Somerset Core Strategy and policies D2, HE1, NE2 and NE2A of the Bath and North East Somerset Placemaking Plan.”

Due to the lack of changes visible in the provided drawings, elevations, and proposed visuals, we maintain the Committee’s and case officer’s refusal on grounds of its adverse visual impact on the World Heritage site has not been addressed.

We maintain that provision of discounted market housing does not constitute affordable housing, and therefore this development continues to be contrary to Policy CP9 of the Core Strategy and Placemaking Plan. Furthermore, the restriction of all proposed discounted market housing to apartment block BF13 fails to meet requirements for mixed-use housing types and sizes in order to ensure sustainable and balanced communities, contrary to Sections 5 and 8 of the NPPF, and Polices CP9 and CP10 of the Core Strategy and Placemaking Plan, and therefore should be refused or withdrawn until an appropriate proportion of affordable, mixed housing is proposed.

Application Number: 20/02921/FUL
Application Date: 13/08/2020
Closing Date: 18/09/2020
Address: Site Of Former Ministry Of Defence Offices, Warminster Road, Bathwick
Our Submission Status: Object