Memorandum by Bath and North East Somerset
Council (TAB 26)
Thankyou for your letter of 30 November about
the forthcoming inquiry and the invitation to this Council to
comment. I have read the outline of the inquiry set out in the
press release, and noted that the committee has asked this Council
to comment with particular reference to the status of Bath as
an historic city. I have the following comments to make on behalf
of the Council.
The city of Bath is an historic settlement located
on a wide bend in the river Avon and its steep wooded hillsides.
It is famous for its Roman Baths, Hot Springs and Georgian architecture.
The whole city is designated as a world heritage site, and a large
part is also within the Bath conservation area. Its landscape
setting is designated as an area of outstanding natural beauty
and green belt.
Bath is a major tourist attraction. Tourism
and related activities are its most important economic activity.
It also has the highest residential land values outside London,
reflecting its popularity as a place to live, largely due to its
outstanding attractiveness and good geographical location.
The Council is mindful that stewardship of this
special environmental quality is vital to the economic well being
of the area, but it is also mindful of the need to provide as
sustainable and balanced local community. Opportunities for expansion
The city has one high-rise building, a block
of flats built in the 1960's. It is the most disliked building
in the city and has had an adverse effect on a wide part of the
conservation area. Today it is doubtful whether any public housing
provider could justify building high rise flats. For many reasons
they are not regarded as a suitable means of increasing residential
density in this district.
Global companies have relocated to Bath, using
a range of historic and low-rise buildings very satisfactorily.
They come to Bath for the quality of the environment for their
staff and customers, and use electronic communications to contact
the rest of the world. Smaller commercial units are in short supply
in Bath and these generally fit well with the characteristics
of the historic buildings and streetscape. High rise office blocks
would be very damaging to the special quality of this historic
city and there would be no economic justification for them in
the current climate.
In the well-defined landscape setting of the
city of Bath it is improbable that a very tall structure could
enhance a vista or "beautify" the city. On the contrary
it would distract from the symbolic vistas of church spires, towers
and civic buildings which accentuate this city and from the wooded
hillsides which frame it.
Many historic cities do have tall structures
that play an important role in the townscape and civic identity
of their area, but these are on the whole public structures, such
as town halls, cathedrals and churches, not commercial office
blocks. The cultural significance of this should not be overlooked.
In the context of Bath all new development is
assessed for its impact on the townscape, which is generally low
and homogenous. Views and vistas are very important to the character
and historic layout of Bath. Buildings which are significantly
taller than their neighbours will have an impact on these special
characteristics; they will also have an impact on the wider setting
of the city. Full townscape and context studies would be necessary
to ensure that the location, height and massing of a building
is acceptable within the generally highly sensitive settings containing
many listed buildings in Bath. Tall buildings should have to satisfy
these stringent tests just like other proposalsthey should
not be seen as special cases.
The committee is asked not to make generalisations
about whether tall buildings should be clustered or dotted, but
to consider that all tall buildings should be judged rigorously
in their context and in the light of any urban design strategy
for the area. The protection of views, skylines etc as part of
a democratically developed urban design strategy for an area should
be seen as the determining factor.
There is certainly the fear that the same mistakes
of the 1960's could be made again, if the developers do not involve
their design teams in the context of the area. What works in one
city will not always work in another. The fact that a place has
no special environmental designation should not be a justification
for a lower quality of environmental design, especially if the
block is to be residential. Where new development is considered
possible the public should be involved from the outset in an urban
design strategy for the area. Design teams should study the context
and consult widely before preparing designs. The designers of
very tall buildings are often perceived by the public to be high-flying
technologists revelling in structural excellence rather than in
the design of the important public and semi-public spaces around
the building. The design team should be set up on a multi-disciplinary
basis from the outset to avoid this.
At present the Local Planning Authority can
take into account the impact of a development in terms of traffic
and travel, but the Planning Acts do not allow the sustainability
of the structure to be a material factor in the granting of planning
permission. The Council would welcome moves to include this in
the environmental factors to be considered. Along with CO2 emissions
in making and transporting the new materials (usually very high
for multi-storey buildings) and thermal performance, the embodied
energy and potential for re-cycling of any existing structures
should also be counted. This would give a truer picture of the
environmental impact, which is likely to be very adverse for tall
buildings, even if their cladding and structure was carefully
designed to reduce energy consumption. Other more flexible building
types, constructed from materials from renewable sources, are
likely to be better in the long term, as they can adapt to change
without major demolition. Many of Bath's important historic buildings
for example have contributed to the sustainability by being in
continuous economic use over the centuries.
It is difficult to see how a specific policy
for tall buildings could be developed by the Government. This
Council would not support a policy giving them special status
and it urges the government to strengthen the case for all buildings
to be carefully considered in their context (both immediate and
wide). It also urges the Government to recognise that many cities
such as Bath have a unique and historic character and that this
character is an economic asset, not a liability. Bath's limited
capacity for expansion should not be seen as a justification for
introducing structures which damage this special character. Bath
does not see itself as a museum piece but rather as a very sustainable
city which has adapted to change over the centuries without compromise
to its beauty or vitality. It has after all been an "attraction"
to visitors and a source of employment for over 300 years and
will continue to do so in the future.