1) Height

"Key recommendation is that development is related to the existing prevailing heights of Georgian buildings in the immediate area... Height and scale of new development should respect, respond and contribute to the character of Bath" (Bath Building Height Strategy). Loss of privacy for residents of New King Street terrace with overlooking and light spill.

2) Bath Western Riverside Supplementary Planning Document (BWR SPD)

Whole of JSW frontage is included within the area covered by the BWR SPD. Lack of an acceptable Context Plan as required by SPD. Main purpose of the SPD is strongly to discourage exactly this type of piecemeal development in favour of a comprehensive approach to regeneration.

3) Design

BWR SPD Design Code states development should “reflect character on north side of street... have traditional roof form... provide direct access to ground floor units”. Developments should "respond to local character & history and reflect identity of local surroundings". (National Planning Policy Framework (NPPF) sect. 58). Little outside space for so many residents.

4) Proposed use

Kingsmead >20% privately-rented. 12% to 18% properties Council-Tax exempt, suggesting existing high proportion of HMOs (Houses in Multiple Occupation). "No evidence to justify wholly student accommodation use.” (Pre-app advice, B&NES). Scale of single use will impact on character of a largely-residential area. Draft Core Strategy: off-campus student accommodation “will be refused where this would adversely affect the realisation of other aspects of the vision and spatial strategy for the city”. Potential for noise & disturbance. Not university-owned so possible management issues.

5) Community consultation

From inception (June 2012) to exhibition (April 2013) absolutely no attempt to consult or involve local residents. "Applicants will be expected to work closely with those directly affected by their proposals to evolve designs that take account of the views of the community. Proposals that can demonstrate this in developing the design of the new development should be looked on more favourably." (NPPF sect. 66)

6) Air quality

No air quality assessment provided even though both Little Stanhope Street and James Street West already exceed EU annual permitted NO2 levels. (Annual mean concentration, 2009: LSS 49 µg/m3, JSW 48 µg/m3. EU limit is 40 µg/m3.) Canyon effect of tall buildings will exacerbate situation.

7) Open aspect of existing site

Inappropriate overdevelopment of site which has had open aspect since at least 1870. Loss of existing views from JSW and rear of NKS of Green Park Station and surrounding hills. Proposed development is over-bearing, out-of-scale and out of character in terms of its appearance compared with existing development in the vicinity.

8) Overshading/sunlight

No sunlight or shading assessments provided even though will breach recommended Building Research Establishment (BRE) guidelines. Will impose significant enclosure and shadow over James Street West. Guidance also applies to potential development land which might be affected by any proposals on neighbouring sites.

9) Setting of heritage assets

Green Park Station should retain intended visual prominence. Development will block sight lines to and from trainshed. New buildings should be subservient in height and massing. Norfolk Buildings and New King Street also Grade II listed terraces. "May harm views of the World Heritage Site and Conservation Area from elevated viewpoints." (Pre-app advice, B&NES)

10) Sustainability

Future use of redundant building. “Development form institutional and appears inflexible... doubt that could respond positively to future changes in housing demand... Will consume valuable land in the central area potentially capable of supporting commercial uses... Both buildings capable of continued active employment use." (Pre-app advice, B&NES)

11) Traffic and parking

Although no parking permits likely many students will have cars. No provision for access or mass arriving/leaving at term ends. Inadequate provision for regular servicing despite being busy street.

Reasons to object