The applicant seeks consent for change of use from hospital (D1) to a 169 bedroom hotel (C1) with ancillary uses including a restaurant/café (A3). The proposal appears, in general, to be consistent with the Council’s Core Strategy Plan (2014) and Placemaking Plan (2017) and we have no objection in principle to the change of use.
However, the proposed disposition of buildings on the site is a different matter. We contend that the application be REFUSED on the following grounds
- It fails adequately to take into account the potential loss of amenity currently enjoyed by residents living in the area.
- It fails to take the opportunity provided by the removal of one of Bath’s most cherished institutions to provide benefits to the wider community
- It would result in the removal of mature trees which should be permitted in a Conservation Area in a city centre only under exceptional circumstances
- It proposes an extension at the rear of the existing hospital building in an area which is currently a Scheduled Ancient Monument with un-resolved archaeological issues.
- It relies for vehicular access on surrounding streets including Upper Borough Walls and Westgate Street where the council is evaluating major changes to traffic management and the use of road space which are, as we understand it, still under review.
Our particular concern relates to the extension which would be positioned at the rear of the existing Grade II listed hospital buildings. We contend that this four-storey block is over-bearing, encroaches too close to residential buildings to the south and, though the term escapes precise definition, represents over-development of the site. As a result, local residents are likely to be confronted by
- Substantial loss of amenity including daylight and sunlight
- Overviewing from hotel rooms (the applicant shows more concern about the view from hotel windows than from the windows of neighbouring homes and the suggested angled louvres proposed in mitigation seem entirely unconvincing).
- Risk of noise and disturbance from hotel rooms
- Light pollution from hotel rooms at night
To date there have well over eighty objections to the application, most relating to the loss of trees and of amenity at the rear of the property and many from among the eighteen households that are the immediate neighbours of the hospital to the south and east. The consultation process entered into by the applicant, comprehensive as it may in some respects have appeared, seems to us to have been flawed in that while most households were leafletted and informed about the public presentation of the proposals, there is no evidence that the applicant has responded positively to any of the concerns raised. As the principal residents’ group in the area, TARA should arguably have been invited to participate in the consultation process but was not. To this extent the applicant failed to take account of the interests of residents living adjacent to the site, contrary to policies D.6.a and D.6.b of the council’s Core Strategy and Placemaking Plan which state respectively:
Development must…allow existing and proposed development to achieve appropriate levels of privacy, outlook and natural light
‘Development…must 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, increased noise, smell, overlooking, traffic or other disturbances.
We, therefore, contend that, unless it is withdrawn or reconsidered, the application as it stands should be REFUSED. An alternative proposal which reduced the damaging impact of the proposals on local residents, particularly at the rear of the existing buildings, while providing a valuable resource to the wider community, funded if necessary by a Community Impact Levy, would be likely to receive the support of this association.