Objection to expansion of Sea Cadet’s Building

17/01939/FUL  30 ST JOHNS ROAD
In summary we ask that this application be REFUSED.

Planning Policy.  Under a previous decision, 16/03359/FUL, permission was granted for improved facilities for the Bath Sea Cadets who have been based at this location for many years together with accommodation on two upper floors for university students comprising eighteen units in single and double occupancy.  This proposal is currently under construction.

While we accept that the placing of student accommodation on this site is consistent with national and local planning policy and guidelines the council nevertheless has various Retained Policies from the 2007 Local Plan under which it is obliged to consider any impact on the amenity of local residents when planning applications are being considered.  These include Policies S6, S7 and D2f which states: ‘Development will only be permitted if it will not cause significant harm to the amenities of existing or proposed occupiers of, or visitors to, residential or other sensitive premises by reason of loss of light or increased overlooking, noise, smell, traffic or other disturbances’. 

We contest that, while the term escapes precise definition, if the current application is granted and the building currently under construction enlarged accordingly the result will effectively be over development of the site to the disadvantage of existing residents.


We understand from local residents that for all practical purposes there has been no consultation whatsoever on this or on the previous proposal.  Attempts by residents to initiate  a dialogue with the Sea Cadets, the developer and the contractor have all failed.  It should be noted in this connection that the present applicant is not the Sea Cadets who applied for and received planning consent for the building currently under construction but an agent for an un-named third party.  Indeed we are informed by local residents that it is their understanding that the statement on the front of the Design and Access Statement that its contents are presented ‘On Behalf of the Sea Cadets and Rengen Ltd’ is false in that the application for the proposed extension was not initiated or asked for by Sea Cadets and was carried out without their prior knowledge.

Scale and Context.  Notwithstanding the policy context as well as efforts by the design team to modulate the roofline and the east elevation this project has always seemed to local residents as a bulky and unwelcome intrusion into the quiet residential street in which they live.  The addition now proposed in our view tips the balance and will result in an excessively overbearing presence in the traditionally domestic scale of the street.

It should be noted here that the Grade 2 listed former Bathwick Church of England School which was described in the Committee Statement relating to the previous application, 16/03359/FUL, as having ‘a strong presence in the street and…particularly important in its interpretation of Gothic Revival architecture’ lies immediately across the street from 30 St Johns Road.   The council is reminded that under Planning Policy Statement 5, DCLG March 2010, (Policy HE8.1) ‘The effect of an application on the significance of…a heritage asset, or it’s setting, is a material consideration in determining the application’, and that under Policy HE8.7 ‘local planning authorities should take into account the desirability of new development making a positive contribution to the character and local distinctiveness of the historic environment.  The consideration of design should include scale, height, massing, alignment, material and use.’

It would be one thing in this context for the proposed extension to be to be seen to be adding significantly to the community purpose for which it was primarily intended and  which was seen as a positive factor when the previous proposals were under consideration.  However not only do the benefits of the current proposals seem marginal to the point of insignificance but it is our contention that the resulting structure, already overbearing in relation to the varied and domestic scale of the streetscape surrounding it, by its additional bulk, risks compromising the setting of a valued heritage asset, something which in a World Heritage Site and Conservation Area should be firmly resisted.

Social Impact.  If the impact of the building in its completed form can be said to be overbearing in relation to its surroundings the same can be said of its social impact.  The provision of storage for rubbish bins for a resident population of 29 appears to be totally inadequate when the needs of the Sea Cadets themselves are taken into account.  This raises the likelihood that bins will be left on the street.  Provision of storage for nine cycles also appears to be too low.  In neither case do the current proposals provide additional storage space despite the increase in student numbers.

Car ownership and use by students is higher than is generally realized.  A 2010 UWE study showed that 87% of students surveyed had full driving licences and 57% of those living off campus arrived on campus by car as drivers or passengers.  No on-site parking space is provided in the proposals under consideration.  St John’s Road has about 80 numbered residential addresses, mainly one to three storey single household homes with a number of apartment complexes ranging from nine to twelve apartments and a care home.  There are roughly thirty on-street residents parking spaces.  Clearly the addition of 29 students in a single location will put pressure on this scarce resource.

Space and Light.  While we recognize that the council does not enforce standards for a minimum distance between buildings this proposal reduces the distance between its north wall and the south wall of No 31 St Johns Road from 3.0m to, by our measurement, about 800mm.  This is not in our view sufficient space to allow for the maintenance of the neighbouring property such as replacement or repair of the bathroom window.

In addition the proposed extension reduces light and direct sunlight available to the from and rear bedrooms of the neighbouring property to the north.

Conclusion.  We conclude that this application should be REFUSED on the grounds that it constitutes unnecessary over-development of a constricted site in a street of traditionally domestic and residential scale which will lead to a deterioration in the amenity of existing residents.