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					Mandy Dando
From:               Development Control
Sent:               22 December 2006 09:08
To:                 Gary Collins; Mandy Dando
Subject:            FW: 06/0413/FUL Bath Western Riverside

-----Original Message-----
From: Brian Cassidy []
Sent: 21 December 2006 14:32
To: Development Control
Subject: 06/0413/FUL Bath Western Riverside

*Bath Western Riverside

06/04013/EFUL Bath Western Riverside OBJECTION
This Full Application for Phase 1a of the Bath Western Riverside
development is described as a Detailed Planning Application for 371
dwellings of 1bed, 2bed, & 3bed flats & houses in a residential quarter.
25% of the dwellings are to be “affordable”. The area is 5.59 hectare.
The density of is 66 dwellings/hectare.
This Application follows on from the two previous Outline Applications,
06/01733/EOUT dated May 2006 & the amended 06/03396/EOUT dated October
The Society agrees with ICOMOS that one overall Master Plan should have
been prepared for the whole of the river area when the Council became
aware that large scale development was to take place along the river
banks. The present position is that each development, as it occurs,
generates its own Master Plan which has little to do with the
neighbouring Master Plans. The lack of such an overall Master Plan is a
fundamental objection to the present development. The piecemeal
development of the river corridor, of which this Application is an
illustration, cannot be in the best interests of our World Heritage city
This Application is the starting point for a development that might last
10-15 years in the building & might well be in occupation until 2070 or
2100 & beyond. Because of this, & because of the size of the final
development & the accommodation it offers, it assumes great importance.
ICOMOS has stated that this is the largest development on any World
Heritage city site, anywhere.
While the submitted documents are beautifully presented, do not seem to
be complete. The requirements for a FUL Application state that the
drawings “should be to a scale of not less than 1:100 &
“indicate…thickness of walls, type of materials used ..should clearly
show the type of external finish (e.g. stone, render). Drawings
detailing facing and roof materials should be included where
appropriate. Most of the drawings are to 1:200 scale & the detail
drawings are missing.
The containment of flood water on the site is covered but, as there is
no overall plan for flood mitigation along the river, it is not possible
to comment on the effect this would have on neighbouring sites up & down
stream. In view of the increasing risk of potential flooding of all the
development sites along the river, the lack of the Council’s coordinated
strategy for dealing with the situation is another objection.

Not withstanding the foregoing, detailed comment follows.

The layout shown in the Application seems to be the same as that in the
previous Outline Application 06/03396/EOUT. 1.5.11 of the Strategic
Framework calls for mixed-use development. Whilst the ground floor of B5
& a corner of B3b is commercial , the overwhelming remainder of this
Application is residential. This layout was an improvement on the
previous Outline Application which had the distinct feel of a local
authority housing development of four decades ago, some of this feeling
carries through to the present Application.
The Society’s general impression then, & remains now, is that the
proposed development is simply not Bath as it is out of scale with
Georgian housing & completely out of scale with Victorian housing in Bath.
Part 2 of the Spatial Masterplan 10 Scale Height and Massing states that
“Bath is a city founded on the principles of human scale and proportion,
it lacks tall buildings. The appropriate scale for the development of
Western Riverside needs to respond to local contextual conditions and
respect the established scale.” The Society agrees with this as a basis
for development but considers that the current Application does not
respond to the conditions or respect the scale.
Although “mixed development” is called for the Application is for a
predominantly residential development of two large, tall slab blocks of
flats (Buildings B3a & B3b of 6 stories), an isolated block (Building B5
of 9 stories), two smaller blocks of flats (Buildings B4 & B7 of 4
stories) & a row of houses (Building B6 of 4 stories). .
The two large, tall flat blocks B3a & B8 are 8 stories high & longer
than the existing Georgian terrace of Queen’s Parade & the north side of
Queen Square respectively. There is some limited commercial use in the
ground floors of B5 & a small corner of B3a & B3b. The situation
regarding Building B1 &B2 is uncertain. The building is within the
Application boundary & is shown on some drawings but not on others.
Where shown, B2 is 9 stories & B1 7 stories high. It is assumed that it
is not part of this Application but will inevitably be so in future
With sustainability in mind, the effect of sunlight on, & in, the
buildings assumes greater importance. The plight of the “affordable”
houses, B6, between the two higher blocks of B3a, B3b, & B8 requires
study at least. B2 is 9 stories high &, as it faces B3a across Victoria
Bridge Street some 40 m. away, is likely to have an effect on sunlight
penetration in B3a. Proper assessment of sunlight penetration for all
the buildings requires shadow diagrams at crucial times of the day &
year. They are not included in the Application.
Supplementary Planning Document (SPD). References are to the Draft SPD
Adopted for Development Control purposes in June 2006.
There an equivocal situation regarding the applicant’s compliance with
the SPD. The intention of the SPD is to set up a Strategic Framework, a
Spatial Master plan & Implementation plan. 1.1.14 states that the SPD
“is a material consideration and when adopted will have significant
weight during the consideration of planning Applications”. 2.1.12 states
“Failure to comply with this SPD or to demonstrate that the design
solution is equal or superior to the spatial master plan is likely to
result in a refusal of planning consent. To this end any planning
Application for the site must be accompanied by a thorough design
statement that explains how it complies or departs from the SPD,
the spatial master plan and the design codes”. This seems to leave the
applicant free to depart from the SPD as it suits them, with an
explanation, & this is demonstrated here but without the explanation.

The principal facades of the buildings are clad in ashlar Bath stone.
Secondary facades are rendered but in off-white coloured acrylic render.
The SPD Schedule 1 suggests (if that is the correct word) Bath stone
coloured lime render. Unacceptable materials are listed as White or
coloured renders. The extent of these two surfaces has a bearing on the
future appearance of the buildings. As large scale detailed drawings
showing the construction are not included, it is not possible to see if
any measures have been included to deal the blank facades of ashlars &
render. They seem to be devoid of any of the projections, cornices, &
string courses or drips that liven & protect the surfaces of “classical”
facades. A new technique for long blank unrelieved ashlar walls is
required to liven them up & alleviate the effect of time & future
pollution. The lack of these large scale construction drawings makes the
assessment of these buildings as “high quality” open to question.
The elevational treatment of Building B5 gives it the appearance of a
giant cheese grater & its comparison with a palazzo on the Grand Canal
in Venice, Bath’s sister World Heritage city site, is impertinent.
Design Code 2.3 calls for right angled corners but Building B5 is not
rectilinear on plan. 2.2 Roof design calls for Top floors must be
treated as a proper roof form. Buildings B3a & B3b have an unusual form
of mansard but the others simply end. The mansards are covered with zinc
sheeting but the Design Code allows this material for flat/shallow
pitched roofs only.
This Application is not of the standard, completeness or quality
necessary to do justice to the importance of this site as a forerunner
of the full development.


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