Planning Policy BANES
RESPONSE TO DEVELOPMENT MANAGEMENT CONSULTATION REQUEST
App ref No: 15/05026/EFUL
Site Address: Pinesgate Lower Bristol Road Westmoreland Bath Bath And North East Somerset
Proposal:
DC Case Officer: Rachel Tadman
No Objection or comments - NOOBJECT
No Objection subject to conditions described below - CONDITION
Not acceptable in the current form. See comments suggestions below -
NAICF
Object, Please see comments below - OBJECT x
Full response:
NPPF
Core Strategy – adopted development plan
Pre-submission Draft Placemaking Plan – approved by B&NES Council for public consultation. Material consideration with increasing weight.
The proposed mix of uses of office and a self-contained educational facility needs to be assessed against the requirements of Core Strategy Policy B2, Policy B5 and the
Western Riverside SPD.
Policy B5 Strategic Policy for Bath's Universities
… Off-Campus Student Accommodation
Proposals for off-campus student accommodation will be refused within the
Central Area, the Enterprise Area and on MoD land where this would adversely affect the realisation of other aspects of the vision and spatial strategy for the city in relation to housing and economic development.
Part of the policy test is whether Policy B5 applies in this instance as the student accommodation proposed is integral and ancillary to the teaching facilities, rather than ‘off-campus student accommodation’.
The Objective of Policy B5 is to manage the development of student accommodation in order to prioritise the delivery of housing and economic development. Whilst it is worded in the context of the Universities, it is not reasonable to expect the plan to foresee every potential development scenario. Changes proposed in the Draft Placemaking Plan seek to clarify this, and make it clear that the policy approach applies to all types of student accommodation and to additional
teaching space. It is the Council’s contention that this underlying objective is of significance to the determination of this application. This contention is demonstrably supported by the Inspectors Report into the Core Strategy. The relevant extract from para 64 is reproduced below:

… with this change, the plan would leave off-campus purpose-built student accommodation to be determined on its merits other than in the Central Area and Western Corridor (Enterprise Area) where policy B5 indicates that such proposals would be refused if they would adversely affect the realisation of other aspects of the vision and spatial strategy. This approach is reasonable given the other priorities for these areas which cover only a small part of the
City. In any case, avoiding additional student pressures in the housing market is part of the underlying strategy which the Council would need to take into
account in determining whether any proposals conflicted with this policy. A growing need for such off-campus accommodation would be a matter to address in a review of the plan.
This then leads onto how the proposals would satisfy the policy requirements as set out in Policy B2 of the Core Strategy, specifically with regards to the delivery of
housing and employment within the Enterprise Area. The important issues here are to ensure that the development needs as set out in the Core Strategy are being delivered.
Employment
There is an expectation in the Core Strategy that there will be some loss of the least suitable office floorspace and that there will be a net gain of at least 40,000 sqm of new floospace.
The delivery of employment floorspace is currently falling below the expectations as set out in the Core Strategy as the loss of existing or previous office floorspace has not yet been compensated by the delivery of new office floorspace.
The loss of previous office floorspace is typically through buildings either converted or replaced with other uses. Most of these buildings are considered to have been either unviable or unsuitable for refurbishment to meet modern office standards, or which have been permitted by virtue of the recent changes to the permitted development order.
Notwithstanding this, there are a number of office led development proposals being actively pursued, including that which is the subject of this pre-application submission.
It is envisaged that these development proposals will emerge, and be modified the planning process, and once delivered will more than compensate for the recent losses in office floorspace that the city has experienced.
Based on current projections and market activity, it is considered that the office floorspace expectations contained in the Core Strategy will be met.
Housing
The Core Strategy sets out the housing requirement for B&NES, and for the city as a whole. Policy B2 for the Central Area has an expectation to achieve ‘about 500 additional dwellings as part of mixed use schemes on the key development opportunities that have been identified’.

Following on from the Core Strategy, the Placemaking Plan Options document consulted on a range of between 343 – 491 dwellings for the Sydenham Park area.
The Draft Placemaking Plan will need to refine the land use expectations across all site allocations to ensure that the quantum of development as agreed in the Core
Strategy is delivered.
As the Pinesgate site represents approximately 20% of the Sydenham Park area, it is reasonable at this stage to presume that is should accommodate approximately 20% of the likely housing requirement. This being the case, the Pinesgate site should accommodate a range of between 64 and 92 dwellings, which represents between
5600 – 8000 sqm of residential floorspace. [Current proposal for the educational facility amounts to 13,800 sqm GIA].
The proposed development does not include any residential element, and therefore puts an additional pressure on other sites within the central area to deliver a greater proportion of housing development to meet the requirement as set out in the Core
Strategy. This will put the delivery of the Council’s housing requirement at significant risk.
The Draft Placemaking Plan has now been agreed by the Council, and is currently subject to public consultation. It is to be used in the determination of future planning applications for this site, and is a material consideration, with greater weight than previous versions.
Core Strategy CP4 - District Heating Priority Area
In response to the GVA pre-app statement (para 5.23):
The application site falls within an identified district heating priority area (Core Strategy policy CP4), therefore there is a requirement for the scheme to incorporate infrastructure for District Heating, and to connect to an existing system (where and when this is available), unless it has been demonstrated that this would render the scheme unviable. A thermal Masterplanning approach should be employed to ensure that opportunities for district heating are not designed out at an early stage.
The Council’s Regeneration and Sustainability Teams are currently working with engineering consultancy Buro Happold on a major DECC funded Heat Network Delivery/Business Case Development
Project for Bath Riverside/Central area, as part of this work and this site has been identified as a red flag – where the latest evidence shows it is critical that the policy is addressed.
The applicant currently fails to address this District Heating policy, without doing so this would be a clear reason for refusal of the scheme in its own right. To rectify this, it is requested that the applicant undertakes the following steps:

Provide evidence that your have contacted E-ON (operator of the nearby Bath Western Riverside
District Heating Energy Centre whose contacts are below) to establish:
(i) the potential of the scheme to connect to the existing BWR District Heating system and
(ii) identify and implement within the scheme appropriate design solutions to allow either immediate or future connection (i.e. inclusion of a wet heating system, and avoidance of

electrical heating, sizing and location of power room/boiler room(s), facilitating potential pipe routes for future connections etc.).
(iii) provide evidence about whether a building based CHP solution be achieved if wider connection if connection is not feasible at the current time
John Armstrong is Head of Operations – john.m.armstrong@eon.com
tel 02476 193836
Relationship to Public Realm, Height, and Massing
These issues have been commented upon by the Council’s Urban Designer.
Summary of observations, recommended conditions and relevant policies
Conclusions
 Whilst a mix of uses on this site is supported, as evidenced by Core Strategy
Policy, the BWR SPD, and the comments on the previous application, it is clear if the Council is to meet its housing requirement, that an important component of that mix of uses must include residential. The applicants are asked to respond to this.
The applicant needs to:
 Provide evidence that your have contacted E-ON (operator of the nearby Bath Western Riverside
District Heating Energy Centre whose contacts are below) to establish:
(iv) the potential of the scheme to connect to the existing BWR District Heating system and
(v) identify and implement within the scheme appropriate design solutions to allow either immediate or future connection (i.e. inclusion of a wet heating system, and avoidance of electrical heating, sizing and location of power room/boiler room(s), facilitating potential pipe routes for future connections etc.).
 provide evidence about whether a building based CHP solution be achieved if wider connection if connection is not feasible at the current time
Name: Stephen George Date: 17.12.15