Western Riverside Development Area, Midland Road, Westmoreland

Approval of reserved matters (scale, appearance and landscaping) pursuant to outline application 06/01733/EOUT for the erection of 2 no. 5-storey buildings comprising 290 student bedrooms (Sui Generis); retail floorspace (Class…
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 south of the River Avon on the site of the existing Dick Lovett Mini car dealership opposite the Bath Press, a 19th century industrial complex of which its road-facing façade retains architectural merit and interest. Whilst not within the Bath conservation area, the proposed site of development remains within the boundary of Bath’s World Heritage site.

BPT acknowledges that the layout, height, and function of the proposed buildings has already been consented within the parameters of the overall masterplan. However, we have the following concerns with the appearance of the scheme with regards to its design and relationship with the surrounding townscape and its contextual setting:

Townscape setting:

The proposed site of development is located along Lower Bristol Road, an area now largely characterised by its volume of Victorian two-storey residential terraces such as Victoria Buildings and St Peter’s Terrace. It additionally features a couple of surviving examples of 19th century industrial heritage, such as the Bath Press, and has been an area of some 20th century commercial redevelopment. Due to the site’s location along the southern edge of the masterplan boundary, it is situated within a primarily residential area that lacks the claimed distinctive presence of industrial architecture, with the exception of the Bath Press, and Camden Mill to the far west. The area is similarly defined by its dominant use of Bath stone in both a residential and commercial context. 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.

Consequently, the Trust feels that the proposed design does not suitably demonstrate an understanding of the area, and is not locally distinctive in its use of form, material, or detail. The use of brick is highly inappropriate within an area defined by its use of a Bath stone palette; Camden Mill remains the only historic use of red brick, mirrored by the adjacent construction of the late 20th century Loss Management Group building. These buildings remain to the far west of the proposed development site, and do not actively contribute to the development site’s immediate context. Whilst we appreciate the D&A Statement’s exploration of the intangible heritage of the site, we do not feel that the extant material heritage of the Lower Bristol Street area is suitably reflected in the consequent overuse of red brick. Therefore, due to the site’s setting at the inland, southern edge of the Western Riverside development, its industrial-inspired appearance is fundamentally incongruous with its material context.

Despite confirmation that the layout of the site has been consented, we are additionally concerned regarding the close proximity of the building’s south elevation to the road and pedestrian pavement. Given the current low density of the existing site, with the use of parking as a spatial buffer between the dealership building and the pavement, the proposed position of the student accommodation block will dominate and ‘box in’ the streetscape, an effect that will be exacerbated by the upcoming four storey development of the Bath Press directly opposite.


We feel that the proposed buildings need to be designed carefully with regards to the mitigation of their height and massing, whilst ensuring a retained aesthetic connection with this distinctive area of Bath’s 19th century architectural character.

Therefore, the Trust maintains that the proposed use of red brick will be over-dominant within its setting, and will negatively impact the existing, largely harmonious use of Bath stone through the conspicuous introduction of a new material and colour palette out of keeping with its immediate environment. The Trust is additionally 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 are additionally uncertain about the proposed use of red fibre cement cladding in combination with red brick. BPT would prefer that the lack of colour specification be remedied so as to enable a better assessment of the proposed building design. However, we feel that the presentation of the fibre cement cladding in coloured elevations attached to this application (see Drawing 1539.P.201) is potentially unsuitable; the uniformity of the red colour emphasises the unbroken bulk of the building, resulting in a building that is blocky and heavy in appearance.

We recognise that the Alison Brooks houses at Western Riverside have roofs in a material that is the same colour as the elevations (Bath stone) to some success; however, these buildings are not of the same scale or colour.

The use of a different, more suitable colour scheme for the cladding (and brick) would enable the two sections of the building to be visually defined from one another, highlighting the asymmetrical use of cladding to offset the buildings’ massing whilst ensuring a complementary, contemporary replication of a roofline that would be more in-keeping with the traditional building forms of the area’s terraces.

Ultimately, the Trust does not support this current design due to its failure to reinforce local distinctiveness and lack of alignment with or contribution to local townscape character. The lack of detailing around the window reveals, roofline, or corner elevations further emphasises a blandness of appearance that fails to compliment the local townscape character. Its position opposite the Bath Press, a building façade “which is one of the key elements that characterises the immediate surroundings of this area” according to the D&A Statement, does not appear to have influenced its design, resulting in a standalone building that is architecturally and materially isolated from its environment contrary to Paragraph 127, Section 12 of the NPPF, and Policies D1, D2, D3, and D5 of the Core Strategy and Placemaking Plan.

Future Use:

Considering the scale and residential capacity of the scheme, we feel that it is important that the proposed buildings remain functionally active within Bath by ensuring their future sustainability of use. BPT continues to question the viability of student housing on this scale; therefore, we would encourage the consideration of futureproof design that considers the long-term flexibility of interiors and amenity space and the ease of adapting the space to alternative uses.


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 and local townscape character 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 detailing or form. 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. This application is therefore contrary to Section 12 and 16 of the NPPF, and Policies B1, B4, BD1, CP6, D1, D2, D3, D5, and HE1 of the Core Strategy and Placemaking Plan; we would encourage the appearance and materials to be reconsidered to better complement the existing streetscape of Lower Bristol Street whilst becoming of greater visual interest in its own right.

Application Number: 19/05165/ERES
Application Date: 27/11/2019
Closing Date: 11/01/2020
Address: Western Riverside Development Area, Midland Road, Westmoreland
Our Submission Status: Comment