Summary Proof of Evidence
by Amanda Reynolds
for Sainsbur y ’s SL, Rule 6 Par ty
with respect to an appeal by
Tesco Stores Ltd,
Bath Press Site, Bath
Ref: SSL AR
FINAL
JUNE 2013
Town and Country Planning Act 1990
On behalf of Sainsbury’s Supermarkets Limited
as a Rule 6 Party to an Appeal by Tescos
In respect of a refusal of planning permission
by B&NES Council
for an application on a site at Former Bath Press
Premises, Lower Bristol Rd, Bath
Proof of Evidence by Amanda Reynolds,
Director of AR Urbanism
Architect and Urban Designer, B.Arch, MA UD
(Dist.), RIBA, UDG
For a Public Inquiry dated 2nd-9th July 2013
Council ref: 12/01999/EFUL
Planning Inspectorate ref:
APP/F0114A/13/2191952/NWF
Contents
1.0 Introduction & Scope of Evidence
1
2.0 Policy Context
3
3.0 BWRE Design in Context
5
4.0 Design Commentary - Bath Press
7
5.0 Conclusions
9
6.1 Pedestrian Routes Concept Plan
6.2 Master plan for BWRE Proposal
6.3 Streets and Squares - ‘Lattice’ Extension
6.4 Design and Access Statement for
Sainsbury’s BWRE Proposal
3
Artist’s view of Green Park Square opening out under the existing canopy
1
Introduction and
Scope of Evidence
1.1
Name and Qualifications
1.1.1 My name is Amanda Reynolds. I hold a Bachelor of
Architecture degree (NZ) and a Master of Arts in Urban Design
(Distinction, UK). I am registered to practice architecture in the
UK and New Zealand and have worked extensively on a range of
architecture and urban design projects throughout the UK and
other countries. I have lived in and worked from London for the last
13 years.
1.1.2 I have over 25 years experience as an architect and over
20 years in urban design. During the last eight years I have
participated in a number of Planning Inquiries and Hearings as an
expert design witness.
1.1.3 I have been working with Chetwoods Architects on the
planning application for the Bath Western Riverside East (BWRE)
Site for the Sainsbury’s mixed-use proposal (the BWRE Proposal),
since November 2011 and have been responsible for the urban
design structure supporting the overall vision as well as production
of the Design and Access Statement which forms part of the
planning application.
1.2
Scope of Evidence
1.3.1 The purpose of my evidence is to demonstrate that in urban
design terms Sainsbury’s proposal to redevelop the Homebase
site represents an holistic redevelopment of BWRE, the aim of
which is to deliver a location for retail provision that will operate as
part of a thoroughly integrated city centre expansion as required
by relevant local design policies and in line with accepted good
principles of urban design.
1.3.2 I highlight the quality and benefits that the Sainsbury’s
scheme will deliver in urban design terms, and explain why, for
design reasons, Sainsbury’s existing store has to move from its
current location to the Homebase site if the Council’s vision of an
expanded city centre is to be realised. I also demonstrate that the
Appeal Proposal cannot and will not deliver a retail scheme that
will connect with or operate as part of the city centre.
1
Concept plan in terms of main pedestrian connections and linked spaces
2
2
Policy Context
2.1
National Planning Policy Framework (NPPF)
2.1.1 Government Guidance set out in the NPPF has a presumption
in favour of sustainable development and advises that in
relation to decision-taking this means approving development
proposals which accord with policy without delay and where
the development plan is silent, granting planning permission,
unless any adverse impacts of doing so would significantly and
demonstrably outweigh the benefits when assessed against the
policies in the NPPF.
2.1.2 Chris Hays and Nick Bradshaw’s evidence will refer to
clause 24, which states that “preference should be given to
accessible sites that are well-connected to the town centre”
and clause 26 which requires consideration “of the impact of a
proposal on.....planned public and private investment in a
centre”.
2.2
Local Planning Policy and Relevant Design Guidance
2.2.1 This section sets out the design guidance and planning
policies - national and local - which relate to my proof of evidence.
2.2.2 The relevant local design guidance includes the ‘Bath Western
Riverside SPD’ (BWR SPD) which explains the Council’s vision for the
broader area of Bath Western Riverside and refers specifically to the
BWRE part of the site as ‘city extension’.
2.2.3 ‘Creating the Canvas for Public Life in Bath’, is the public realm
and movement strategy for Bath city centre and this document
also establishes that the BWRE site is considered to be part of the
city centre. The guidance sets out a vision and aspirations for the
future quality and integration of new and existing public space and
streets in the city of Bath as a highly walkable city.
2.2.4 In terms of national best practice guidance, the principles of
‘By Design - urban design in the planning system - towards better
practice’ provide the most widely accepted guidance, particularly
in relation to larger, urban projects in an existing context.
3
Bath Western Riverside East - Proposed Masterplan
4
3
BWRE Design in Context
BWR SPD, Creating the Canvas & By Design
3.1
The Sainsbury’s BWRE Site Proposal
3.1.1 This section describes Sainsbury’s proposal for the BWRE Site
in the context of local and national urban design guidance as set
out in the previous section.
3.1.2 The SPD clearly describes the BWRE Site as Bath’s westward
‘city extension’, encouraging an urban mix of uses which would
connect and integrate with the existing historic city centre. The
document also states that “The success of BWR will be judged
primarily by its quality of public realm.....Experience has
shown that successful urban regeneration is often led by
excellent public realm.” (p.22, 2.5.2).
3.1.3 My evidence shows that the proposed public realm for this
development will add diverse and exciting spaces of high quality
design, providing linked spaces well-connected into the existing
city centre. It is also clear that the proposal meets the council’s
vision and aspirations for this area and would provide a unique
development for Bath city’s westward expansion.
3.1.4 My evidence demonstrates that the proposal is designed in
accordance with the Creating the Canvas strategy and would be
‘beautiful, simple, functional and coherent’ as the strategy
requires, as well as meeting the urban design objectives as set
out in By Design, that is, not only a place that is ‘easy to move
through’ but also one that is desirable to go to and linger in.
3.1.5 The complementary nature of heritage and contemporary
buildings and the knitting together of natural and urban landscape
treatments - particularly along the river, will contribute ‘beauty’
in both built and spatial form; the design approach is based
around ‘simple’ and direct movement routes which are also highly
‘functional’ as well as being attractive and, through their simplicity
and clear following of natural desire lines, create a highly ‘coherent’
result - the BWRE Proposal.
3.1.6 The development will satisfy the council’s vision for the area,
as expressed in the BWR SPD, that it becomes a clear extension
of the city centre and facilitates the centre as a whole becoming
a place to which and within which people increasingly travel by
walking, cycling or by using public transport. This approach also
satisfies the Movement and Public Realm Strategy in its focus on
linked public spaces, overall urban connectivity and a development
which is centred on the river.
3.1.7 By Design’s more general urban design objectives are also
met in both broad and more detailed senses with the proposal
creating an attractive and distinctively Bath-style set of highly
connected new places.
5
6
4
Design Commentary
Appeal Site and BWRE Site
4.1
Comparison of Proposals
4.1.1 The three primary elements sought by the Council’s policy
in terms of new major developments are: connections with and
activities in relation to the River Avon; improved pedestrian,cycle
and public transport connectivity throughout the city and
improved connections to the city centre; and high quality,
attractive and usable public realm.
4.1.2 The Appeal Proposal has no direct connection with the River
Avon and, although it may hope that a future access through the
BWR site towards the river meets its proposed entry point, there is
no guarantee of this. By contrast, the BWRE Site embraces the river
and proposes multiple areas of improvements and activity which
engage with and enhance the river itself.
4.1.3 The Appeal Proposal does not add any new pedestrian/cycle
connections through its site which would be used by choice over
existing ones. The BWRE Site builds on an existing pedestrian
desire line through the site to make this a more direct, convenient
and desirable route for pedestrians and cyclists. Other new routes
are also upgraded and added. Further connections and access
points into the site are also added, transforming the pedestrian,
cycling and public transport experience on, through and to the
site.
4.1.4 The Appeal Proposal includes a new square which may be of
high quality, however it is not on a natural pedestrian desire line
and it is hard to see who will use it other than the occupants of the
new office block. The BWRE Proposal includes a large number of
new spaces, ranging from an intimate scale and treatment through
to riverside green space to major squares with a strong public and
activity focus. All of these are connected to the main spine route
which is the natural route to the wider city centre.
4.2
Summary:
4.2.1 The appeal proposal does not improve local permeability, it
does not create usable new pedestrian routes nor enhance existing
links, while the new public walkways it creates are for the benefit
of internal circulation only, their complexity being an unfortunate
result of the podium-based proposal.
4.2.2 The public realm proposed does not create new connections
beyond the site and does not improve the usability of the adjacent
streets for existing residents.
4.2.3 The BWRE Proposal offers greater benefits to the city of Bath
than the Appeal Proposal and should not be put in jeopardy by this
lesser scheme.
7
“The aspiration
to make Bath
the UK’s most
walkable city
should be a
central tenet
of movement
planning and
public realm
design for the
entire city....’’
‘Creating the Canvas’ p.32
8
5
Conclusions
5.1
Conclusions
5.1.1 On the basis of my evidence I conclude that the Sainsbury’s
BWRE Proposal offers wide regeneration benefits to the Bath
Western Riverside site, to Bath City Centre, to which the site
belongs and to Bath City as a whole, through the integrated
development proposal as set out in my proof. By contrast none of
these benefits are offered by the Appeal Proposal and, if approved,
the Appeal Proposal will ensure that the Sainsbury’s BWRE
opportunities are lost to Bath.
5.1.2 For the reasons given above and as set out in more detail
in my complete proof of evidence, I conclude that the refusal of
planning permission for the Appeal Proposal should be upheld.
Artist’s sketch view from west of Sainsbury’s BWRE Proposal
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11
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www.ar-urbanism.com
amanda@ar-urbanism.com