Planning Applications Reference:18/02831/FUL

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Type of Application:Full Application
Status:Pending Decision
Address of Proposal:The Old Bakery , Jews Lane, Twerton, Bath, BA2 3DG
Proposal:Demolition of existing building and redevelopment comprising erection of a student accommodation building (sui generis) and erection of a flexible employment building (class B1).
Decision Type:Planning Committee
Planning Portal Reference Number:PP-06752421
Applicant Name:Deeley Freed Estates
Agent Name:Cushman And Wakefield
Agent Address:Rivergate House, 70 Redcliffe Street, Bristol, BS1 6AL
Case Officer Name:Tessa Hampden
Date Application Received:27/06/2018
Date Application Validated:03/07/2018
Neighbourhood Consultations sent on:18/09/2018
Standard Consultations sent on:14/09/2018
Last advertised on:12/07/2018
Latest Site Notice posted on:12/07/2018
Expiry Date for Consultation :02/08/2018
Actual Committee Date:26/09/2018
For details of this Development Control Committee Meeting please visit the Councils Democracy Website.
Target Decision Date28/02/2019


ConstraintsAgric Land Class 3b,4,5, Article 4 HMO, Contaminated Land, HMO Stage 1 Test Area (Stage 2 Test Req), MOD Safeguarded Areas, Policy B4 WHS - Boundary, Policy B4 WHS - Indicative Extent, Policy CP9 Affordable Housing Zones, Policy NE1 Green Infrastructure Network, Railway, Railway, SSSI - Impact Risk Zones
Related Property:Strawberry Field Catering Ltd,Jews Lane,Twerton,Bath,BA2 3DG.
Related Property:The Old Bakery,Jews Lane,Twerton,Bath,BA2 3DG.
Reference Proposal Application Received Status
18/02831/FUL .Demolition of existing building and redevelopment comprising erection of a student accommodation building (sui generis) and erection of a flexible employment building (class B1).27/06/2018Pending Decision

The Comments tab lists all public comments received on this application (not statutory consultees, e.g. The Environment Agency, Highways DC, etc). The majority of comments are submitted via our Comments Form through the website and you can expand the comment to view all of the text by clicking on the plus button. A minority of comments are submitted by post or email and it is not possible to include all the text here, however when you expand the comment you will see a link to our Associated Documents page where you can search for the comment.

Name Address Comment type Comment1 Comment2 Comment3 Date
Jayne Parfitt 1 Lansdown View, Twerton, Bath, Bath And North East Somerset, BA2 1BE O 28/07/2018: I wish to strongly object to this planning application.

The 3/4 story student accommodation proposed is far to high. I live very close to this site and my privacy will now be invaded by both the student accommodation and business proposed buildings. Not to mention the light impact. These buildings are going to be higher than the current surrounding resident properties.

This area is saturated by students with purpose built tower blocks on the Lower Bristol Road. There is a high volume of private accommodation being used by students with landlords making a huge profit and are not even paying any council tax.

Twerton has lost a healthy community balance as students are taking up properties which should be made available for our own bath people who support vital Bath businesses across the spectrum. More affordable housing is needed not more student accommodation.

Parking will be a huge issue with another 63 Students coming to our streets. I really do not think how the the non-car policy is going to be policed. It hasn't worked out with the existing buildings. The residence in Lansdown View no's 1 - 10 are not able to park outside their properties so Albany Road or King Georges Road is used for parking. Not sure how the 30 minute planned time for term commencement or leaving is going to work as most students live away from Bath. Another problem for residents to put up with.

I read in one of the documents that Jews Lane is a quiet road. This is not true it is very busy and noisy. At least 1 vehicle a day hits the 6ft 6in bridge a day. What will happen if a vehicle gets stuck under the bridge which will happen and traffic is diverted and trains stopped while Network Rail carry out safety inspection of the bridge.

How is the priority traffic controlling going to work. Does this mean that there will be calming changes to the road layout on Lansdown View. If so where will these be. Not convinced on the proposed access and exit road is going to work as there is not a clear view of vehicles coming down Lansdown View.
Since the arrival of Lidl's the Jews Lane junction onto the Lower Bristol road is very busy and dangerous.
Where are the people who work in the proposed Business building going to park their cars plus their customers.

I am concerned about pedestrians safety as this is used frequently by elderly, children, parents of young children and disabled alike. Has this been looked into to address and mitigate any possible accidents.

Looking at another document with reference to Wildlife. I can assure you that there are bats, Badgers and Foxes currently present at this location. The reason no Badger runs have been seen is probably that the site is built on concrete. I have photographic evidence of that they do exist.

More affordable housing is needed with allocated parking spaces.

If this planning proposal goes ahead then the quality of life for the nearby existing residents will suffer.

Many thanks for your time on reading this.
Mr D Reynolds 13 Albany Road, Twerton, Bath, Bath And North East Somerset, BA2 1BW O 14/07/2018: I would think Twerton has got its fair share of students.When I purchased my house it was a quiet terrace with people and young families getting their first step in the housing market.Along came the students and landlords after a quick profit and sending house prices soaring.Those of us that remain ,and it is not many, have had to put up with unkempt houses,noise at all hours of the night and car parking that is a lottery.Now we have planning for yet more students and their cars(and dont say they are not alllowed them) for if they pay their tax they can use their cars( I would).So where are they going to park?
I would think it is about time affordable housing for young families should be a priority.We have more than enough students.
Mrs J Fenwick 9 Albany Road, Twerton, Bath, Bath And North East Somerset, BA2 1BW O 01/08/2018: I am very concerned that if planning permission is granted, the extra parking problems in the area will be exacerbated. CRM have said that they will monitor the site for student's cars but they will not be able to monitor the surrounding neighbourhood and are expecting local residents to police it on their behalf.

This is grossly unfair and could lead to possible verbal or physical abuse if the driver is questioned.

Local roads are already being used by students from the many students halls in the Lower Bristol Road.

If a student is found to have brought a car into Bath, will the Council have to find alternative accomodation if the student is made homeless half-way through a semester?

Matthew Jones 11 Albany Road, Twerton, Bath, Bath And North East Somerset, BA2 1BW O 20/07/2018: This application provides insufficient public information to be judged fairly by the public.
How many proposed student accommodation facilities will be provided?
How far back from the road will student accommodation be set?
What is the nature and intent of the flexible employment building?
How many stores will the building be?
Will there be on site parking for the students or will they be expected to park on the surrounding public roads?

There is already significant student accommodation on the Lower Bristol Road. Affordable housing and/or retail space to serve the local community would be a far better and more responsible use of this space.
Paul Evans 19 Lansdown View, Twerton, Bath, Bath And North East Somerset, BA2 1BG O 20/07/2018: The area currently is already saturated with student accommodation. The issue of students and their cars, which cannot be enforced or even monitored will swamp the surrounding areas. We have HMOs (students) already in Lansdown View and Lower Bristol Road in two separate buildings plus new developments on the north side of the river. The drain on public utilities will be increased creating a greater burden. 20/07/2018
Carol Brake 48 Lansdown View, Twerton, Bath, Bath And North East Somerset, BA2 1BQ O 21/07/2018: This area of Bath specifically has already been heavily developed to accommodate a large amount of students. This development is planned on an already very busy Jews Lane. The junction to the main road is already dangerous, the road can not cope with further traffic. Despite the development being 'car free' there has be no evidence in previous 'car free'developments that this is ever monitored and enforced once planning permission is granted. How can the local streets be checked to prevent future residents from parking close by? The streets are already horrendous for parking. The public transport will not cope with additional usage, the buses are jam packed.
This development will overlook the houses at the bottom of Lansdown view eating into the resident privacy. It'll be so high that it becomes an eye sore to those residents.
Hannah Brownell 144 Locksbrook Road, Newbridge, Bath, Bath And North East Somerset, BA1 3EJ O 21/07/2018: I really do not think we need more student housing, it’s everywhere! It’s only a small junction for cars which is hard enough to get out from now. Please build something useful for the community, like affordable housing 21/07/2018
Steph Hobbs 80 Holcombe Vale, Bathampton, Bath, Bath And North East Somerset, BA2 6UX O 21/07/2018: I'm not sure why I'm wasting 2 mins of my life objecting to this, as you are going to build it anyway.

I object as there is more than enough contained housing at extortionate prices, as well as Student HMOs still being applied for and accepted in the twerton area.

You want to know why the council has no money to spend? Lack of council tax.. thousands more people, no money. About time LANDLORDS were charged the council tax.

Debbie Greenslade 14 Argyle Terrace, Twerton, Bath, Bath And North East Somerset, BA2 3DF O 21/07/2018: i do not wish to have anymore student accommodation in this area, i think we have far to many as it is!!!! 21/07/2018
Emma Milk 72 Roundhill Park, Southdown, Bath, Bath And North East Somerset, BA2 1NN O 21/07/2018: I understand that there is a need for more student accommodation across the city but I believe if there was an accommodation block at this location it would increase the already high amount of traffic at the junction with lower bristol road which has already been made 100 times worse since the arrival of Lidl, it would totally over saturate the area with students considering twerton mill, waterside court and charlton court are very close by - perhaps a location on the other side of town would be better? 21/07/2018
Diane Shearn 12 Belmont, City Centre, Bath, Bath And North East Somerset, BA1 5DZ O 21/07/2018: Enough with the student accommodation. Time to consider Bath residents and provide some affordable housing for those who live work and pay council tax. 21/07/2018
Rebecca Tudball 10 Priddy Close, Twerton, Bath, Bath And North East Somerset, BA2 1BT O 21/07/2018: The traffic around this area is already ridiculous and parking on residential streets is going the same way. There isn't the infrastructure in place to deal with new builds students or not. Need to relieve the traffic issues ( which are now as bad as the London road). Need more doctors etc aswell to cope with the increasing population. 21/07/2018
Sarah Roberts 7 Willow Green, Moorlands, Bath, Bath And North East Somerset, BA2 2DW R 21/07/2018: Already over populated with student accomodation and the infrastructure will not cope in that area. 21/07/2018
Penny Graham 48 Frenchfield Road, Peasedown St. John, Bath, Bath And North East Somerset, BA2 8SL O 21/07/2018: Seriously, how many more student flats do we need in Bath? The additional student provisions built over the past few years have made no difference to the number of student houses/flats in Oldfield Park or Twerton. What about families and young people starting out, where do they live? The people that work in our shops, cafes and restaurants serving the tourists that visit our town, what about them? Also, the cars will be a problem, the local roads are already choked with cars and, what with the new L&G BTR development, where do all the cars go? We can’t just say you can’t have a car if you live here. People will still have them and park them wherever they can. Seriously, this needs to stop. You can’t keep piling people in cheek by jowl. Enough now. 21/07/2018
Emma Cooney 20 St Kilda's Road, Oldfield Park, Bath, Bath And North East Somerset, BA2 3QJ O 21/07/2018: Yet again no consideration for the area. The increase in the student population is having a negative effect on the area and the increase in noise and traffic will become a nightmare. Please rethink this. 21/07/2018
Lesley Gillard 16 Lansdown View, Twerton, Bath, Bath And North East Somerset, BA2 1BG O 21/07/2018: Others have put the reasons for objecting so much better than I can eg. K Priddle and M Backoff. I agree with all their points and therefore strongly object on the same grounds. 21/07/2018
Sue Revell 88 Heather Shaw, BA14 7JT O 21/07/2018: My elderly mother lives very close to Lansdown View and is surrounded by students who bring their cars to the city.
There does not appear to be any enforcement of token bans on students bringing their cars. The parking near the accommodation on the Lower Bristol Road is so much easier when there are no students.
Let both universities build mor accommodation on Camus or in the city centre, away from a residential area and on a relevant bus route.
Dawn Kelly Brook Road Bath , BA2 3RS, O 21/07/2018: we really dont need any more student in & around this area we have enough & as for cars theres not eoungh room for the people that live there to accommodate any more because no matter what you try to enforce on cars & parking they will bring there cars & park where ever...why cant you build accommodation for people of Bath to live in like the young ones who want to rent lovely homes plus the council get council tax....but not from the students its ridiculous that the owner of all these student accommodation dont pay any council tax just think this council would have loads more money coming in if they did...just saying???
please no more students....grrrrr
Jennifer Milliner 59 Third Avenue, Oldfield Park, Bath, Bath And North East Somerset, BA2 3NZ R 21/07/2018: It should be housing for locals. There are enough student accommodation in bath. The no car policy won't be managed. Our you trying to drive out all our young people from the city. Not everyone wants to go to university 21/07/2018
Rebecca Marks 14 New Queen Street, Kingswood, Bristol, BS15 1DF, S 21/07/2018: I think it's an excellent idea as my partner is a student in Bath and he struggled to find accommodation as I do not think there is enough for the number of students in Bath. 21/07/2018
Alan Parfitt 1 Lansdown View, Twerton, Bath, Bath And North East Somerset, BA2 1BE O 31/07/2018: I strongly object to this planning application.

Over development of the site due to the scale and site coverage of the buildings as well as the density of occupation.

The overbearing effect of the buildings close to existing houses and noise disturbance.

By moving the entry and exit points nearer to the bridge will be a danger to cars and pedestrians on a very busy road.

Elizabeth Reilly 6 Albert Terrace, Twerton, Bath, Bath And North East Somerset, BA2 3RZ O 31/07/2018:
1. The proposed development will over shadow and block natural light adversely affecting the properties in the middle of Albert Terrace. This has not been adequately considered in the assessment provided.
2. Allowing a 305 room purpose built student accommodation block at this location, does not help meet the local need for affordable housing, and contravenes the local planning policy objectives and policies.
3. The proposed large three story development is not in character with the area.
4. The proposed development will add more cars to areas which are already subject to high parking pressures. The proposed management plan is unworkable, and any restrictions on the amount of cars brought to the site are unenforceable.
5. The design of the roof takes no account of the seagulls the Bath and North East Somerset guidance on roof design.
6. There is no detail within the current planning application regarding the noise impact on local residents during the construction of the proposed building.
C Gillard O 31/07/2018: I object to the application on the grounds that there is too much student accommodation in this area already. The buildings are too tall for and do not fit in with the surrounding area. There are no parking spaces for the students and this will mean they will park in the streets close by no matter what we are told in the application. How is the parking going to be policed 24 hours a day for 7 days a week over a 3km radius area. This is total nonsense.
It is interesting to see that Highways have no objection as usual. This is a department that seems to think that the more people who live in an area the fewer vehicles are in use. It is noticeable that the Lidl junction which is a very dangerous junction has never been improved. I would have thought Highways should have made this safer a long time ago. Instead of that they have done nothing to improve safety in that area.
The University is now seeking to build a school in Claverton. If they have room for a school they have room to build student accommodation. There is plenty of room at Newton to build student accommodation. The University should be compelled to build accommodation in these areas. Students live in this city, using the facilities that I pay for, taking up housing that should be occupied by local residents who are being forced out of the city, and they contribute nothing except to businesses which would survive without them. These businesses would have the custom from local people who would stay in the area. In turn the local people would be employed by these businesses which would replace the jobs at the University. It is difficult to see how the University benefits the ordinary working people in the city.
I have no doubt that this application will be permitted because the University appears to have the Council in its pocket. The council has steadily wrecked this area together with Oldfield Park by permitting so many homes to become HMO's. So I suppose I am wasting my time writing this comment.
Mrs S Wilson 5 Inverness Road, Twerton, Bath, Bath And North East Somerset, BA2 3RX O 15/07/2018: The buildings are still too high! It is disingenuous of you to use the photograph montage that you have, to show how these buildings 'fit' into the present landscape! Three or four (and lets face it most likely to be four) storey buildings are NOT the same height as a two floor terrace. It looks as if it would be half a size higher, maybe a bit of roof. What nonsense! They would TOWER over our little houses!

Parking - students and probably office workers will be using our already overcrowded streets to try to park in. It cannot be policed by the university. It will not. We will just have yet more cars in an already overused area.

Please reconsider the use of this area. It would have been nice to see local houses being built for people who live here & work in Bath. Affordable houses for people who work in the jobs we need, such as retail/buses/cleaning/office work, with space allocated for parking. Not students. Again.
Mr Michael Newbound 24 Blackmore Drive, Twerton, Bath, Bath And North East Somerset, BA2 1JN R 22/07/2018: I note that the application if approved will allow access to the new development to impinge upon the current use of Jews Lane by moving the access point closer to the railway bridge and narrowing the road to allow lines of sight for vehicles leaving the site. Associated with this it is proposed to change the informal give and take for the single track section under the bridge to a formal give way line for vehicles heading northbound, that is from Lansdown View to Jews Lane. I have been using this route for over 38 years to access the Lower Bristol Road and it is very rare for there to be a problem with the existing arrangement. I do not see the need to introduce a formal give way and indeed believe that this will cause more problems rather than facilitate easing of traffic flow. My reason for this is observed behaviour of a minority of drivers who being aware that they have "priority" will drive at full speed with a get out of my way mentality as if the road is completely clear and create a danger for vehicles that have already crossed the give way line before the vehicle coming in the opposite direction is visible or should, if observing the speed limit, be sufficiently far away. Leaving doubt on priority makes traffic proceeding in both directions more cautious and is safer, and everyday politeness maintains traffic flow. The locations local to me where I regularly observe the "I have right of way so I am going to floor it attitude" are in Lyemore Avenue, the Hollow (where we have alternate priority designed for 30 mph unaltered for 20 mph) and for much longer in Coronation Avenue. I have seen more conflict in Lyemore Avenue since the introduction of the give way than was there before. Only in Coronation Avenue do the priority markings make a real difference to behaviour and even there maintenance of proper traffic flow requires drivers to be polite and pragmatic at times and give way even when they have the formal priority. So please do not make the passage from Lansdown View to Jews Lane under the railway bridge a formal give way. 22/07/2018
Kirsty Priddle 21 Leighton Road, Upper Weston, Bath, Bath And North East Somerset, BA1 4NF O 16/07/2018: Objection to the planning application 18/02831/FUL
I strongly object to the application of the demolition of the Old Bakery on Jews Lane to redevelop into student accommodation and an employment building.
The area is already overcrowded due to the proximity of Lower Bristol Road student accommodation. With recent developments within the area there is an increase in traffic and footfall already.
Parking around the area is already at its limit and whilst it has been proposed that as part of the legally binding tenancy agreement students will be prohibited from parking cars anywhere within a 3km radius, I struggle to understand how this is going to be monitored and enforced without the support of the locals? Students from the existing accommodation blocks park their cars on King Georges Road and Albany Road already and this is on top of the RHU staff cars and the commuters for Oldfield Park train station. It is all well and good the university prohibiting students from obtaining a parking permit when they live in the BA1, BA2 and BA3 postcodes but the cars are not being used for university (There are plenty of buses), they are being used to go home, go to work, and general living.
I do find it ironic that on ‘move in’ and ‘move out’ days that a 30minute parking allowance will be kept. Where do you think parents will park afterwards? And I believe it is naïve thinking that not all students arrive by car. I’ve never seen a student arrive at university with home furnishings, clothes, books etc by train on ‘move in’ or ‘move out’ days.
Whilst I appreciate that there will be no parking spaces (Other than disabled) for the student accommodation there will be some for the employment building. Depending on the type of business that accommodates the building depends on the number of vehicles visiting. For example, if the business has a huge number of visitors for training, conferences etc where are they expected to park? Will they be encouraged to park on the roads around Albany Road and King Georges Road where there are currently no parking restrictions.
Overall the increase in on-street parking in the vicinity of the site will affect residential amenity.
On page 31 of the Transport Statement (1of4) it states:
The resultant traffic generation of the proposed development will be less than is currently generated by the existing use…The proposal will therefore result in a beneficial impact upon the local highway network.’
The traffic generation of people will most certainly not be less. An increased number of pedestrians using the pedestrian crossing, the increase in time to wait for buses to be loaded with passengers and drivers having to become much more aware of the volume of people around will have a detrimental effect on the local highway network and is in contradiction to Policy ST7.
The Transport Statement admits that Jews Lane and Lansdown View is considered a minor road and it has also been admitted that there is not currently sufficient space for a refuse or large vehicle to turn and exit in forward gear and therefore have to reverse. In the case when it comes to waste collection and building of the proposed site, safety comes to mind.
With increased traffic for Lidl’s, Pets at Home, Hobby Craft etc highway safety is prejudiced and increase the already excessive traffic volume.
Furthermore, I’m concerned at the height of both buildings. They will be overlooking neighbouring properties having a detrimental effect to the privacy and amenity of the neighbouring buildings. The Daylight and Sunlight Amenity Report confirms that the properties will be impacted in one way or another.
The proposed site is located in a ward with a high proportion of students. In addition is there a demand for office/employment buildings when Frome House is currently empty?
I implore you to consider the implication upon the local area and residents this project would have if allowed to proceed.
Thank you for your time.
Andrew Notman 10 Cleveland Court, Bathwick Hill, Bathwick, Bath, Bath And North East Somerset, BA2 6JY O 16/07/2018: Dear Tessa Hampden,

I would like to object to the proposal of more student accommodation in the Lower Bristol Road area, as I am concerned about the lack of affordable housing in the region and the disproportionate number of students in this city. This isn't anything against students, as I believe they make a valuable contribution to this city, but I believe the numbers needs controlling.

Bath benefits enormously by being a world class city and it relies on the availability of local staff to work in the shops, restaurants and other services and industries. If they can't afford to live in the city, then we risk losing these vital workers and businesses will ultimately suffer in the long run. I am disappointed to see the number of shop closures over recent months and years, and I fear that this will continue.

My other concern is the high percentage of students in this city. Approximately 22000 students equates to roughly a 25% student population. By increasing this percentage we risk not having enough people contributing council tax to meet the demands of the city. Our local services are struggling and 63 council tax payers instead would provide a much needed cash injection (at least £64,000 per year on band A).

Thank you for taking the time to process my objection.
Jonathan Blain 8 Albert Terrace, Twerton, Bath, Bath And North East Somerset, BA2 3RZ O 24/07/2018: I object to the proposal for the following reasons;
1) The drawings are disingenuous, replacing one two storey building (that is one storey for a large portion of it) with three and four storey buildings will not as it claimed fit into the aesthetic of the area, it will over power the terraces on Argyle Terrace, Albert Terrace and will protrude above the railway line, therefore also impacting on Lansdown View and Albany Terrace.
2) Jews Lane traffic. Since the opening of Lidl’s at Fielding’s Road the junction between Jews Lane, Lower Bristol Road and Fielding’s Road has become much more congested than previously, this has led to traffic building up on the Lower Bristol Road as far back as Vernon Park as people wait to turn into Lidl’s. Building on the Old Bakery site will cause numerous problems, with the demolition vehicles, construction vehicles, then the large number of student cars when people move in and out. The planning claims this will be regulated by people being given timeslots, in reality this will mean people arriving early so they don’t “miss their slot” and will then be idling on Jews Lane causing issues or trying to find spaces in adjoining streets.
3) By creating a priority to traffic from Lansdown View into Jews Lane it is increasing the likelihood of traffic heading southbound to end up backing onto Lower Bristol Road, increasing the already horrendous congestion at this junction.
4) Parking. This planning application lists a completely unenforceable proposal to stop students parking nearby. Both the Twerton Mill and Charlton Court student accommodation blocks are meant to be car-free, however, the difference in finding parking around Burnham Road, Bellotts Road and Vernon Park are obvious when Charlton Court is empty, while you just need to drive down LBR to see how many student cars come from Twerton Mill, the difference between term time and not is stark. An unenforceable policy that is clearly a sop to planning will not make any difference, it is putting all the onus onto local residents to track the movement of all cars in the area, somehow recognise that the car belongs to a student, that the student lives at the Old Bakery and then register a complaint. Even if all that is done, I refuse to believe the company would do anything about it as they will lose the revenue from terminating a student’s contract. There will be an increase in cars from this development and the developers know this, so have put in an unenforceable policy to hoodwink planning.
5) Over provision of student accommodation in the area. East Twerton and Oldfield Park are disproportionality impacted by the greed of the universities in chasing more and more student money. Within a small walk of Jews Lane there are the two student blocks at Twerton Mill & Charlton Court, numerous student HMOs on Argyle Terrace, Lansdown View, Albany Terrace, Inverness Road and Burnham Road. These are only the ones I know of, and I’m sure there are more. This is unfair on existing residents and is having the effect of hollowing out communities, if the universities seem hell-bent on exponential growth, given that they are both campus uni’s they should be building housing (for all years, not just freshers) on their ample sites, rather than having the residents of Oldfield and Twerton bear the brunt of the increasing numbers.
6) There is no seagull management plan for the buildings, given how the seagull population is a known issue for Bath, and that they have been seen nesting on the Twerton Mill site, this seems a major oversight.
Max Foster 6 Albert Terrace, Twerton, Bath, Bath And North East Somerset, BA2 3RZ O 31/07/2018: Referring to Noise Impact Assessment Reference: 6963/DO/ Revision B dated 21st May 2018

- The actual measured background noise level has not been declared. Nor is it clear if the typical background noise level has been used to set the limits. I would expect to see statistical analysis of the LA90 parameter to demonstrate that plant limits are set based on the appropriate background noise level.

- BS 4142 states that at night time (23:00 - 07:00 hours) the reference time interval, Tr should be over a shorter period of 15 minutes at night instead of 1 hour as the report states which could lead to a less onerous noise limit.

- No mention of a construction noise assessment for the building works. Usually this would need to be assessed in accordance with BS 5228 to protect surrounding neighbouring residential properties, which are in proximity to the development site.
Rose Snook 3 Albert Terrace, Twerton, Bath, Bath And North East Somerset, BA2 3RZ O 07/07/2018: I live in Albert Terrace and object to a 3 or 4 storey building to accommodate students being built in a residential area just within sight of my front door. It is affordable housing for local residents that is needed in the area, not temporary accommodation for a transient population of people coming and going. This proposal would change the area for ever and destroy the bit of community that we are desperately hanging on to. It is well known that there are already too many new buildings dedicated to students in this part of Bath. We need to stop this happening now and encourage affordable housing in this area. 07/07/2018
Dick Hemming 26 Argyle Terrace, Twerton, Bath, Bath And North East Somerset, BA2 3DF O 19/07/2018: I object to this application on grounds of parking congestion. The developers have proposed a ban on students bringing cars and have outlined an enforcement plan that is completely unworkable and impractical.
Twerton Mill has a no car policy that is a complete farce; cars are parked opposite this development.
Much of the parking congestion in the area is generated by students cars; finding a space is much easier outside term-time.
Philip Hippisley 15 Burnham Road, Twerton, Bath, Bath And North East Somerset, BA2 3RY O 17/07/2018: I object to this application as the Twerton area is saturated with student accommodation.
There is already a lack of parking in the area. The developers have said a strict no car rule will be in place.
How will they monitor and enforce this.
When Waterside Court was built this was also promised in reality it never happened. When local residents reported cars from Waterside Court being parked in the local streets we were told there was nothing they could do about it. Just a false promise.
Mr Martin Bakhoff 11 King George's Road, Twerton, Bath, Bath And North East Somerset, BA2 1BJ O 17/07/2018: Planning Applications Reference:18/02831/FUL
Key points of objection:

1. Detrimental impact upon residential amenities
Public services, such as drainage and water supply are already over stretched in this area due to the recent & on-going developments, in particular large multi roomed student accommodation developments along the A36, from ‘Student Roost’ at Brougham Hayes, Charlton & Waterside Courts through to Twerton Mill. I fear that further developments such as the proposed redevelopment of the Old Bakery site at Jews Lane, has the potential of stretching those amenities to breaking point or beyond.

2. Need to avoid town cramming
A further 60+ bed accommodation unit solely for housing students would be a superfluous addition to the existing accommodation blocks along the A36 in this area & would exacerbate the existing student over-population problem existing in the Twerton/Oldfield Park neighbourhood. Further it would do nothing to alleviate the severe shortage of social & affordable housing locally. Neither would it help nor assist in resolving the ever increasing HMO situation within the ward.

3. Further grounds for objection are the responsibilities of the council under the Human Rights Act.
In particular Protocol 1, Article 1. This states that a person has the right to peaceful enjoyment of all their possessions, which includes the home and other land.
My home is adjacent to the Linear Park & backs onto what has become a pedestrian thorough fare between Twerton & Oldfield Park & regularly utilised by late night revellers & returning home in the early hours of the morning seven days a week during University Term times. A situation that is not conducive to a good nights sleep, especially when one has to be up at 05:30 or earlier to prepare for an early commute & a long day at work.
Additionally, Article 8 of the Human Rights Act states that a person has the substantive right to respect for their private and family life. In the case of Britton vs SOS the courts reappraised the purpose of the law and concluded that the protection of the countryside falls within the interests of Article 8. Private and family life therefore encompasses not only the home but also the surroundings. Arguably, this could mean that Article 8 (2) would also apply where a listed building or a conservation area is affected, enabling people to demand respect for the special interest of the conservation area in which they live or nearby listed buildings as a human right.

4. Highway safety, inadequate parking and access
I feel that highway safety will be compromised. Initially during the construction phase of this development with constant site access required by heavy plant, lorries & construction personnel then subsequently by additional traffic generation & on street car parking issues.
Road capacity on Lansdown View/Jews Lane is currently a concern during peak times, especially as the road narrows form two way traffic to no priority single lane access under the railway bridge which also has a height restriction.
Congestion as the Jews Lane/Fielding’s Road/A36 junction is also a grave concern. During most of the day on a daily basis, it is an extremely busy & hazardous access & egress point for road users, cyclists & pedestrians alike. The addition of 60+ new inhabitants of the proposed block accessing & egressing onto Jews Lane as well as those utilising the “employment amenity”, will only increase this hazardous lane & junction.
As has been witnessed opposite Tweton Mill student block, the volume of parked cars has increased dramatically, leading to the reduction if not complete obstruction of the pavement on the south side of the A36. With only seven (7) proposed allocated parking bays, (including two (2) disabled bays), for the 60+ bed accommodation block & “employment amenity, it is my belief that should the proposed Old Bakery development be granted permission, the problem of on street & in some instances pavement parked cars will be replicated on Lansdown View, Albany Road & King Georges Road, further jeopardising road safety in the vicinity.

5. Other Environmental Issues
I am also concerned that visually, as depicted on the submitted plans, both the proposed student accommodation building & the “employment amenity” are not in keeping with the immediate surrounding & adjacent residential buildings, thus reducing the aesthetics of the area.

6. Ground stability and drainage
It is my understanding that the proposed development will be “cut into the site so that its roof isn’t higher than existing properties”. If this is the case my concern is that the footings of the adjacent railway embankment & railway bridge will be jeopardised in the process & subsequently the safety of rail road users alike.

Alice Maynard 8 Albert Terrace, Twerton, Bath, Bath And North East Somerset, BA2 3RZ O Documents Tab 06/08/2018
Jenny Bakhoff King George's Road , Twerton, BA2 1BJ O 11/07/2018: I strongly object to this application. I live near and am finding already some of the students are parking their cars around our streets as they are not allowed to park on either complex on Lower Bristol Road. This will only cause more problems and congestion. The traffic onto Lower Bristol Road from Jews Lane or vice versa is bad enough with Lidl, it takes ages already to exit or enter. There is already too many student housing buildings around this area and feel we do not need any more in this part of the city. There are also various wildlife around this area including badgers, foxes and owls to name but a few. This is a lovely community with allotments near by and should not be spoilt by more student housing. 11/07/2018
Catherine Edwards 18 Highland Road, Twerton, Bath, Bath And North East Somerset, BA2 1DY O 12/07/2018: I object to this application on the following grounds:
- I do not believe a strategy to prevent students bringing cars would be effective. Students living at Twerton Mill are not supposed to bring cars but the parking opposite that accommodation in term time shows this is not the reality. The area around Jews Lane does not have capacity for more cars to be brought and parked, this would be detrimental to residents of the nearby streets.
- I do not believe the city needs more student accommodation. The recently built facility at Green Park is available for short term let on Airbnb, which shows there is already over capacity.
- The balance of the area between families and students has changed significantly over recent years. The Twerton Mill development has been built, along with the student facilities on the Lower Bristol Road, plus numerous houses being used at HMOs. Council statistics will not show the full picture as no licence is needed to convert a property to a HMO in the Twerton ward just two streets away from this proposed development. I support a mix of people living in an area, but this area should not become dominated by one sector. The council has expressed concern at the social mix in the south west of the city, and should act upon these concerns.
Ben Hatton 36 Blackmore Drive, Twerton, Bath, Bath And North East Somerset, BA2 1JN O 16/07/2018: I object to this proposal on the basis that it will cut off important light to neighboring streets through the height of the building. I also object on the basis that it will be impossible to enforce the no car policy. 16/07/2018
Bath Preservation Trust Bath Preservation Trust , 1 Royal Crescent, City Centre, Bath, Bath And North East Somerset, BA1 2LR R 02/08/2018: Comment: Whilst we find this scheme largely acceptable subject to officer assessment, we would comment that the scheme by virtue of its height (in particular the 4 storey element) runs the risk of being over-dominant in the townscape and in particular having an overbearing effect on Albert Terrace and other domestic scale terraces in the area. In addition we agree with the Conservation Officer comments that the use of rubblestone and other rustic materials within the Bath palette besides ashlar and stark render could well help it achieve a more comfortable assimilation with the townscape. 02/08/2018
Rob Oldfield Flat 1 Philippa House, South Avenue, Oldfield Park, Bath, Bath And North East Somerset, BA2 3PY O 02/08/2018: Enough. The point was reached quite a while ago when the number of students living in the area surpassed the maximum to provide a balanced community. The fact that the council has not managed, as yet, to modify planning regulations so that purpose built blocks are included is scandalous, so I guess that the only actual planning matter to take into account is the lack of parking for the students who really will bring cars. 02/08/2018
Aileen Oldfield Flat 1 Philippa House, South Avenue, Oldfield Park, Bath, Bath And North East Somerset, BA2 3PY O 02/08/2018: We have enough students accommodation in Bath. Being as HMO's are exempt from paying council tax and Purpose built student accommodation are exempt from paying business tax that rather puts a strain on the rest of us, being as the Council are having to cut services in order to make ends meet, which is having a detrimental affect on those of us who live here.
Also the sheer numbers of students now in Bath makes for an imbalance in the make up of our society.
I fail to see how the policing of student cars is going to work as if they can't park their cars in their own area the park them else where, as the students that live in Victoria road and Brougham Hayes do, they park them around Oldfield Park meaning a lot of blocked roads for us.
In not granting planning permission for these blocks the university will be forced to provide accommodation on their own campus or curtail expansion.
Enough is enough!
Start thinking about us who live here.
Mrs R Harvey 48 King George's Road, Twerton, Bath, Bath And North East Somerset, BA2 1BJ O 31/07/2018: I object to the planning application to erect Student accommodation on the land of the Old Bakery, Jews Lane.
The main reasons I object to the accommodation being built in the area is the extra traffic that it will incur on an already very busy road - it is also a very narrow road with no ways to make it wider !!
I have lived in the area for over 40 years and the amount of traffic using Jews Lane / Lansdown View has increased incredibly over the years that I fear for safety of Pedestrians using the road - especially Young parents pushing Buggy's under the Bridge.
I feel the area has been over saturated with Student accommodation !!!
Veronica Squires 51 Albany Road, Twerton, Bath, Bath And North East Somerset, BA2 1BW O 31/07/2018: In an area that already has more than its 10% of HMOs this proposal is for the equivalent of 20 to 30 more. On a plot suitable for 6 family homes with gardens and parking, the plan is for what looks like a 4 storey warehouse housing rabbit hutches. No-one is naive enough to believe that a high percentage of students will not own cars which will be parked on Lansdown View and Albany Road or behind the complex and it is insulting to suggest that we should believe the policing of this will be carried out by the landlords of the property once this has been built and tenanted. 31/07/2018
Susan Walker 4 Park View, Lower Bristol Road, Westmoreland, Bath, Bath And North East Somerset, BA2 3EJ O 01/08/2018: Developers in Bath need to take more care to ensure that projects cherish the existing residential housing stock from the nineteenth century. The City has a significant amount of terraced housing that that has been built at an angle to the direction of the main roads and the river, which adds to the setting of the World Heritage Site. Albert Terrace is one such terrace and should be protected from large structures being imposed in its vicinity, whatever their intended purpose.

Even the Great Western Railway was built to scale with its surroundings; the railway line and its embankment do not overpower the local housing stock. The site lies adjacent to the railway embankment, between listed Grade 2 structures (Bellotts Road Bridge to the east and the Great Western Railway viaduct to the west in the Twerton Character Area), and those structures contribute homogeneity and human scale in the area around Jews Lane.

There is a need to incorporate open spaces; the local population can’t flourish if too many high buildings are squeezed in (as has been happening too often in recent years). There should be more emphasis on landscaping to ensure that air quality is improved by suitable planting, particularly more trees (the area in the past has been agricultural in nature, after all). The existing trees on the railway embankment and on neighbouring land, even if they are not in the highest quality and value category, do have arboricultural and landscape qualities according to the submitted tree survey.

What is needed is employment for local people. The site used to be a bakery and before that a clothing factory (and it is less than 100 years since the first employment opportunities existed here). Why does the development need a large block for student accommodation and a smaller one (though still of sufficient height to dominate Albert Terrace) for the proposed flexible work spaces? If there has to be some accommodation, then that should be the smaller building of the two. And if there has to be accommodation, then it should be affordable housing for local people.

There is enough student accommodation in the area and nearby, already built or planned. The traffic congestion that will result from students bringing their cars will add to the air pollution problems of Bath. The developer is fully aware of what will happen with their wishful scheme of forbidding students to bring cars, however many penalties they threaten. The locals will be the people who suffer, not the developers – the latter will be able to go off home at the end of the project and not have to worry about the inevitable consequences on parking and quality of life on the residents who live near Jews Lane.

In my opinion, the Old Bakery site at Jews Lane, being within the Bath Enterprise Area, should be used to contribute to job growth. This would comply with Policy B1 of the Bath Spatial Strategy (ED2B) and help reverse the contraction of Twerton Riverside as an industrial location in recent decades.