Site Of Former Ministry Of Defence Offices, Warminster Road

Proposed construction of 3no. new buildings to provide a total of 10 new apartments, additional car parking spaces and strategic landscaping on part of the former MOD site at Warminster…
Our Response


The Trust commented in response to the initial planning applications for this site that the character of this Georgian terrace design aesthetic is inappropriate to the character of this part of Bath which, rather than being made up of Georgian terraces, is marked by the transition from terraces to villas during the mid-19th century. We do not consider that the three villa-style apartment blocks along the northern boundary of Holburne Park are in keeping with the local vernacular.

Ultimately the bulk, massing and style of these four-storey blocks would cause a visual disturbance to their surrounding historic environment and landscape setting, including the Kennet and Avon canal. The gradual encroachment of buildings onto the northernmost green buffer is symptomatic of overdevelopment that will be harmful to local character and views, potentially establishing a harmful future precedent.

The supplementary documentation and CGI is poor-quality and misleading. This should be a more accurate rendering in terms of colour and appearance.

Fundamentally, the lack of affordable housing 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:

This application provides inadequate information regarding the proposed design and material palette of the three villas. We maintain the position that an informed decision cannot be made without suitable, high-quality building elevations. Similarly, the photomontages provided are misleading, and predicted views utilising proposed colours and materials would need to be submitted for comment due to reports of the use of render instead of Bath ashlar stone on other north-facing elevations. The inclusion of multiple ‘Existing Views’ with no comparable visual proposals is additionally confusing and irrelevant.

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.

Furthermore, we feel that the consequent visual impact of the ‘villas’, and how this will affect Bath’s World Heritage site and its setting, has not been demonstratively understood. The description of the north-facing elevations as “the rear elevations” in the Design & Access Statement significantly indicates a lack of consideration for the visual impact these villas will have outside of the development site, in which the north elevations should be considered as equally important to the south-facing internal elevations. Therefore, this justification for the positioning of balconies and minimal high-quality detail facing onto the canal is considered to be insufficient. Considering Viewpoint 6A, the location and massing of the villas along the Kennet and Avon canal footpath will have a drastic visual impact on an important aspect of Bath’s natural heritage. The villas’ high visibility in Viewpoints 8 and 9 from Camden Road and Ringswell Gardens dominates the cityscape, a position exacerbated by their projected placement and high rooflines which will not be suitably softened by suggested natural screening measures.

Ultimately, BPT believes that this is an overdevelopment of an already high-density site. The encroachment of the three oversized villas beyond the Holburne Park boundary, despite claims that the land falls within the previous MoD boundary, will consequently impact the buffering green space to the north of the site, and we fear this will establish a precedent for future high-density periphery construction. In conjunction with the expansion of the site to the east and west (see 19/03838/FUL), this proposal forms part of a continued intensification of development that the Trust considers would have a harmful impact on Bath’s World Heritage site and its setting, and views across the Bath Conservation Area.

Affordable Housing:

We strongly object to this development’s low provision of affordable housing. The Planning Statement claims 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”. 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. Whilst the Planning Statement emphasises the potential for the three villa apartment blocks to “allow for the delivery of some further affordable housing”, the Accommodation Schedule gives no indication that the villas will be used for anything other than private housing. This application therefore contravenes Policy CP9 of the B&NES Core Strategy and Placemaking Plan in which 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.


The proposed size, massing, appearance, materials and siting of the three villas alongside a sensitive area of Bath’s natural landscape would neither preserve nor enhance the conservation area, and would be of a detriment to the Outstanding Universal Value of Bath as a World Heritage city. Therefore, this scheme is contrary to the Planning (Listed Buildings and Conservation Area) Act 1990, Section 5, 12, and 16 of the NPPF, and Core Strategy and Placemaking Plan Policies B1, B4, BD1 D1. D2 D3, D5, HE1, NE2, and CP6.

Failure to deliver the required percentage of affordable housing is contrary to Core Strategy Policy CP9; this is unacceptable when considering the scale and location of the site. The relevant documentation submitted requires further clarification as to the affordable housing allowance included in phase 2-3.

Application Number: 19/03836/FUL
Application Date: 04/09/2019
Closing Date: 10/10/2019
Address: Site Of Former Ministry Of Defence Offices, Warminster Road
Our Submission Status: Object