Western Riverside Development Area, Midland Road, Westmoreland

Approval of reserved matters pursuant to outline planning permission 06/01733/EOUT for the erection of 176 dwellings; retail / community space (Use Class A1/D1); access; parking; landscaping and associated infrastructure works…
Our Response

This application site forms part of the Western Riverside masterplan site that was consented in 2010. The proposed site of development is situated north of the River Avon on the site of the Bath Recycling Centre along Upper Bristol Road. It is located within the Bath conservation area and World Heritage site, and the proposed area for development is adjacent to multiple Grade II Victorian buildings, Kelso Villa and Kelso Place, associated with Bath’s decommissioned gas holders. The Grade I Royal Victoria Park, a late Georgian landscaped park, is north of the site. Therefore, whilst the area maintains a significant industrial character associated with the gas works, Upper Bristol Road maintains a strongly residential function and mid-density setting that should similarly be reflected in the material aspects of Western Riverside’s proposed design.

BPT acknowledges that the layout, height, and function of the proposed buildings have already been consented within the parameters of the overall masterplan.

We acknowledge the description of this application seeks reserved matters approval for access, parking, landscaping and associated infrastructure. This application makes clear in the planning statement that it includes proposals for the amount, scale, materials and appearance, so or comments will address these as set out in the Design and Access Statement submitted with the application.

We have the following concerns about appearance of the scheme with regards to its design and relationship with the surrounding townscape and its contextual setting:

Townscape setting:

BPT acknowledges that due to the site’s immediate riverside position and contextual association with the Victorian gas works, there is a stronger industrial association with this portion of the masterplan than others (see application 19/05165/ERES). However, the area remains strongly characterised by its volume of Victorian two-storey residential terraces such as Cork Street, Cork Terrace, and Tennyson Road. Therefore, it is important that the appearance of the main front-facing elevation connects to this aesthetic, architectural, and functional tradition to ensure the congruity of the streetscape.

Whilst we appreciate that the height of development is limited to three storeys along the roadside, the Trust maintains that the proposed design does not suitably demonstrate an understanding of the area through a lack of local distinctiveness in its use of form, material, or detailing. In particular, an excessive use of brick is highly inappropriate within an area defined by its use of a Bath stone palette in either coursed rubble or ashlar. 1-4 Kelso Place is the only immediate example of red brick used in the vicinity of the development site, but it remains a subtle addition to the streetscape through its low roofline and use of stone fenestration that does not redefine the material tradition of the area. Whilst we appreciate the consideration of different materials and designs to better integrate the north-facing elevations of the development into the Upper Bristol Road townscape, we do not feel that the extant material heritage of the area is suitably reflected in the proposed overuse of red brick. We feel that a material and colour palette more aligned with the visual character of this portion of the Bath conservation area should be demonstratively considered.


New development must positively reinforce local distinctiveness and local townscape character. We are not convinced that the buildings proposed would do this. The use of incongruous brick materials, particularly along the Upper Bristol Road in Blocks A, B, and H, and the lack of form or detailing relating to the existing historic environment would have little relation to the character of the Bath conservation area. The scale, massing, and uniformity of Blocks D, E, and F along the riverside could result in an over-dominant yet undistinctive appearance that is architecturally and materially isolated from its local environment contrary to Paragraph 127, Section 12 of the NPPF, and Policies D1, D2, D3, and D5 of the Core Strategy and Placemaking Plan.

We are concerned by the lack of specification of the brick and mortar type that will be used, and consequently what finish the building will have. We would strongly recommend that materials, specifically the type and colour of brick, are resolved within the timeframe of this application and not left to a Condition. All materials should be specified, with samples provided, before this application is approved. We would additionally advise that the type of limestone being used is specified as part of the application; we would recommend the selection of an oolitic limestone that would better complement the extant material appearance of the Western Riverside character area and the wider Bath conservation area.

The elevations along the River Avon would be highly visible and have potential to define the riverside landscape, therefore should be considered with particular sensitivity to their scale, material usage, and relationship to the historic environment. We feel that the current balcony design visually disrupts the proposed gabled form of the buildings facing onto the riverside and overrides any attempt at building articulation. A more recessive balcony design is encouraged.
We question the appropriateness of the proposed use of timber cladding on-site, and emphasises the unsuitability of this material within the Bath conservation area and World Heritage site. We maintain that it should not be used for any external-facing elevations.

Affordable Housing:

Whilst the current total of affordable housing proposed within this portion of development is 25%, BPT feels that this is insufficient when considering that the expected proportion of affordable housing within the Bath North and West area is 30% as defined by Policy CP9 of the Core Strategy and Placemaking Plan. The provision of affordable housing being “dependent on the availability of subsidy and scheme viability” as outlined in the Planning Statement should be challenged by the LPA. We feel that the provision of affordable should not be reliant upon the unplanned commercial or construction costs of a residential development, nor on the potential availability of subsidy funding. We would therefore strongly recommend that this development’s sub-standard allocation of affordable housing be amended before any aspects of the scheme are approved.


BPT asserts that whilst we appreciate the potential of the site for regeneration and positive redevelopment that can benefit Bath, we feel that the proposed design fails to reinforce local distinctiveness, neither preserves nor enhances the character of the Bath conservation area, and would harm views into and across the World Heritage Site and conservation area by virtue of its discordant use of materials, and lack of meritorious aesthetic connection with the historic environment. It is demonstrative of ‘anywhere’ design that does not reflect, respect, or contribute to distinctive architectural aspects of local character, and consequently does not relate to or participate in its residential setting. We would encourage that the use of materials and form is reconsidered to better complement the existing streetscape of Upper Bristol Street as well as the Blocks D, E, and F’s riverside setting whilst also becoming visually distinctive buildings in their own right.

Application Number: 19/05471/ERES
Application Date: 18/12/2019
Closing Date: 14/02/2020
Address: Western Riverside Development Area, Midland Road, Westmoreland
Our Submission Status: Comment