Proposed 18.0m Phase 8 Monopole C/W wrapround Cabinet at base and associated ancillary works.
Our Response

The proposed site of development is located on the junction of Wellsway and Midford Road, within the Odd Down character area of the Bath World Heritage Site, and the immediate, indicative townscape setting of the conservation area. The area is of a low rise, residential character with open land to the north in the form of the Odd Down Sports Grounds. The immediate setting is made up of mid- to late 20th century development of predominantly two storey, residential grain; earlier development incorporates the early 19th century workhouse at St Martin’s Hospital and further 19th century development to the north-east including the Grade II early 19th century pair of cottages at 372-374 Wellsway, formerly Barrack Farm Cottages. An unusual example of taller, three storey contemporary development has been introduced to the north at Millennium Court. The area is of a medium to high density as part of Bath’s suburban residential periphery, but features frequent green and well-treed breaks within the streetscape, particularly to the immediate north of the site proposed for development, indicative of the interaction of Bath’s residential fringe with the beginnings of open countryside.

We note this application forms an increasing number of applications in and around Bath for new telecommunications and 5G masts. These include:

• 19/05534/FUL, Woolley Lane, Charlcombe – Refused.
• 20/01315/TEL, Woolley Lane, Charlcombe – Withdrawn.
• 20/02388/TEL, Claverton Buildings – Refused.
• 20/03255/FUL, Larkhall Sports Club, Charlcombe – Permitted.
• 21/02310/TEL, Locksbrook Road - Approved.
• 21/03024/TEL, Odd Down – Refused.
• 21/03528/TEL, The Hollow – Refused.

BPT continues to emphasise that we appreciate the necessity for the upgrade of the existing provision of access to 5G networks throughout Bath; it is an important and positive improvement of public amenity and technological access. We note the increasing pressure for 5G installation and the upgrade of existing telecommunications services that are reaching the end of their lifespan, although we have concerns regarding the current piecemeal approach of installation proposals by multiple different service providers.

We feel that the current, more slender monopole design is preferable to a bulkier, more top heavy design as has previously been proposed elsewhere (see application 19/05534/FUL).

However, we do have some concerns regarding the proposed location of the mast in close proximity to residential housing and in sharp contrast to the predominantly low profile and medium density character of this residential area. The proposed monopole would be positioned on the pavement and would therefore directly overshadow the immediate streetscape without the mitigation of a set back or recessed position from the pedestrian highway. We acknowledge the existing tree screening along the roadside in this area, but note that tree cover is estimated to be 12m in height in the proposed elevations, and the monopole would remain a significantly taller feature within the townscape. It is unclear as to how the proposed monopole would “respect and continue to maintain the appearance of the area” as claimed in the D&A Statement. Alternative locations have been dismissed as unviable such as location D8 due to proximity to residential properties with insufficient screening, but the application doesn’t appropriately account for the proximity of dwellings to the north, east, and west of the proposed installation site.

We note that recent applications 21/03024/TEL and 21/03528/TEL in similar, residential areas have been refused on grounds of “harm to the visual amenities of the locality” and a failure to respond to the character of the area due to the monopole’s excessive height.

BPT reiterates the need for a cohesive city-wide operations plan for the future installation of telecommunications equipment. We maintain concerns that the permit of singular applications would establish a precedent for piecemeal development without consideration of the wider cumulative impact on the character and appearance of the conservation area and the special interest of the World Heritage Site. Due to the shorter range of 5G wavelengths, an unspecified increase in volume of telecommunications installation would be required to provide connectivity both in and around Bath, as well as increasing pressure to deliver within sensitive historic environments and landscapes. We therefore maintain concerns regarding this application as a further precedent for the intensified roll-out of 5G masts within the sensitive townscape setting of the Bath World Heritage Site without the formulation of a demonstrated scheme or operations plan regarding ongoing upgrades, either within a single supplier or across multiple suppliers.

BPT consequently urges this increasing trend in telecommunications applications to be accompanied by a cross-operator masterplan that highlights appropriate sites, mast designs, and volume caps across Bath and north-east Somerset to ensure a cohesive and sustainable approach to district-wide upgrades. We maintain that operators should be encouraged to share masts wherever possible to reduce the total amount of infrastructure required. We encourage the consideration of a palette of potential monopole designs to ensure citywide consistency whilst favouring a slimmer profile which would be less visually bulky or top heavy, and therefore of reduced visual harm.

We highlight similar collaborations in the creation of a Joint Accord between service providers and the Cotswold Conservation Board in 2011.

There appears to be no reference to telecommunications equipment within the current Bath Pattern Book which is of concern, and allows for an increasing variety of incongruous and intrusive designs without guidance on what may be appropriate within the historic city core of the conservation area and World Heritage Site, and its interconnected urban setting.

Application Number: 21/03944/TEL
Application Date: 20/08/2021
Closing Date: 14/09/2021
Address: Street Record, Wellsway, Bath
Our Submission Status: Comment