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Late last month, Bath Rugby submitted a planning application for the construction of a permanent stadium by the river Avon in Bath. The building, right in the heart of the historic city, at the Recreation Ground (known informally as the Rec), would replace a smaller, temporary stadium.

The submission is available to view here:

Planning Application 23/03558/EFUL


The proposals fall well short of what this highly sensitive and significant site deserves. They threaten the heritage status of Bath, spoiling key views, while reducing the open playing space of the Rec by a fifth. With this scheme the prospects for the urban realm would be dismal, for it cements a series of existing problems, adds others and keeps the site largely disconnected from the rest of the city.

This runs contrary to several of the local planning policies, as outlined below. It also runs contrary to some of the central principles in the National Planning Police Framework (NPPF) for sensitive sites.


Shown here are the applicant’s own verified views and other information that may be difficult to find deep within the material available on the planning portal.

Proposed West Stand
Proposed East Stand


Bath Rugby’s own verified view showing the proposed West Stand viewed from Parade Gardens (top) and the East Stand looming over the remaining parts of the Rec (bottom).

We invite you to submit your own comments on the application following the link to the council website belowYou will need to provide your name and address (the latter will not be made public and does not need to be local to Bath).


You should try to base your comments on relevant planning matters. For reference we have prepared a template objection letter with several of the critical points we make below. We encourage you to adapt the text and put it into your own words. However, if you are short of time, you are welcome to borrow sections of the text and use them verbatim. 



The architects describe the design of the new West Stand with predictable lines about “a contemporary interpretation of a colonnade” which “builds upon historic references”. Such phrases can mean anything and nothing. In fact, the proposed colonnade has more in common with the faceless concrete piers of the adjacent 1970s Leisure Centre than the graceful porticoes around Parade Gardens, which actually do echo history and culture.


The design is expedient and banal, which in the context of Bath means it will be insensitive and alien. The proposals include features that are very harsh, such as the cantilevered roof which makes a hard outline, and a stark contrast with the surroundings. It will be impossible to be near such a building without it damaging appreciation of the much-loved and valued setting.


The stadium would loom large over the riverbank, cutting off critical views of the surrounding hillsides from Orange Grove and Parade Gardens (Fig. 2).

View from Grand Parade
View from Grand Parade


Verified "before and after" views of the Bath Rugby proposal as seen from Grand Parade. 

Around the other side, the design of newly proposed East Stand demonstrates even greater disregard for the highly sensitive context (Fig. 3). As the applicant’s own visualisations show, the structure would have an oppressive, overbearing presence on the remaining parts of the Rec and the neighbouring Grade I listed properties. The architecture proposed here seems better suited to an out-of-town location, not the centre of a historic city. The attempts to hide an unsightly and out-of-place structure behind a "Green Wall” cable system do nothing to detract from the obvious design failures. Nowhere does the submission address its suitability in terms of climate and orientation, and nor the costly maintenance requirements of such a “Green Wall”. Its long-term viability is very much in doubt – and what then?

The applicant’s own Environmental Impact Assessment warns of “Major adverse” effects of the proposal on its visual setting, including key views to and of significant heritage assets. Such insensitive design is at odds with Policy D5 of the Placemaking Plan, and were it to be realised, it would unquestionably cause serious harm to Bath’s status as a World Heritage Site. This is acknowledged within the applicant’s own Heritage Impact assessment which states the proposal would have “Moderate adverse” impact on the Bath World Heritage Site, the Great Spa Towns of Europe WHS and the Bath Conservation Area. In light of this, the Council should reject the proposal under Strategic Policy B4

View from Rec
View from Rec


Verified "before and after" views of the proposed East Stand proposal as seen from the Rec. Note that the existing stand in the top image is temporary and is regularly disassembled for portions of the year.

Access and Routes


Plan of the proposed development showing access points and routes through the site.

Leisure Centre junction


Ground floor plan of the proposed stadium showing the junction with the existing Leisure Centre.


Bath Rugby’ scheme offers few and poor connections with the rest of the city. This is clear from their own diagram (Fig. 4), especially given the many awkward changes in level involved (which the plan can’t show). Moreover, the problems of access will be exacerbated by the projected increase in capacity and footfall, associated not only with matchdays but the new facilities such as conferencing.

Currently the temporary stadium and the neighbouring 1970s leisure centre make for a very poor public realm within the Rec itself. The two buildings meet arbitrarily, creating nasty left-over areas where no one wants to go.

However, Bath Rugby’s proposals do nothing to improve the situation. Indeed, they make things worse, by making the site’s current shortcomings permanent. As shown on page 174 of the Design and Access Statement (Fig. 4), the new stadium effectively cuts off the left-over area of the Rec from the riverbank, and there is no connection at all. This is contrary to Policy D3(b) of the Placemaking Plan, which requires developments to be permeable and offer a choice of routes and connections.


To the south the new stadium development is to extend haphazardly right up against the existing leisure centre (Figure 5). Not only does this block a way through to the Rec, it condemns this area to be a permanent “back of house” for plant rooms, storage and toilets.

Any potential redevelopment of the leisure centre, including any new route or pedestrian space, would have to face an unsightly hotch-potch of make-do services. In this way the proposals adversely prejudice the future quality of the whole area, contrary to Policies D3(m) and SB2(7).


The enlarged stadium would result in a reduction of usable outfield playing space in the remaining area of the Rec by over a fifth, while providing no suitable replacement or other benefits. This is contrary to Policy LCR5 of the Placemaking Plan. Moreover, the quality of the environment in the left-over areas of the Rec would be reduced dramatically on account of the overbearing and oppressive design of the new East Stand (Fig. 6). The proposed building would overshadow the playing fields for significant parts of the day and remove any visual connections back to the city centre with all its recognisable landmarks.

View from Rec
View from Rec


Verified "before and after" views of the proposed East Stand proposal as seen from the Rec. Note that the existing stand in the top image is temporary and is regularly disassembled for portions of the year.

Counter Proposal from the Rec


Our own counter-proposal as seen from the Rec.

Contrary to assertions in the application documents, the “Do nothing scenario” does not necessarily have to result in the continued use of the current substandard temporary stands.


It is not a legitimate nor an honourable argument to make thinly-veiled threats that, were planning permission to be refused, the stadium may have to be relocated to an alternative site. In this scenario, the land it occupies could join the rest of the open space of the Rec to create a park.

Our own recent counter-proposal shows an alternative way (Fig. 7). This is a vision for the long term that addresses the site in its entirety, together with the leisure centre, to make a piece of urban realm in keeping with proper planning principles and the significance of the setting. In a recent visual preference survey by Deltapoll of over a thousand people across all sectors of the population, showing them a view of the east stand by the applicant and the alternative, there was a 3:1 majority in favour of this vision and against Bath Rugby’s.

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