Formal Representation: Objection to the Local Plan Option to remove Green Belt designation from the Sulis Club, Claverton Down, in order to Facilitate the redevelopment into Purpose Built Student Accommodation (PBSA)

Introduction

This statement objects in the strongest possible terms to the Bath & North East Somerset (B&NES) Local Plan Option proposing removing Green Belt designation from the Sulis Club site at Claverton Down, in order to facilitate development primarily for PBSA.

This document will demonstrate The Sulis Club plays an irreplaceable role in supporting the University of Bath’s sporting, ecological, and landscape setting, as well as Bath’s World Heritage Site Outstanding Universal Value (OUV) and Green Infrastructure network. Its protection is critical to preserving Bath’s unique balance of built form, natural setting, and community wellbeing. Furthermore, the addition of further PBSA does not contribute to B&NES Planning Balance undersupply and the proposal to remove the estate from the Green Belt does not demonstrate exceptional circumstances.

1. Policy and Planning Framework

Policy SB19 of the B&NES Placemaking Plan designates the Sulis Club as an Outdoor Sports Area within the Green Belt. The policy explicitly states that any proposals must be consistent with the NPPF, particularly in relation to the Green Belt, Cotswolds AONB, World Heritage Site (WHS), and OUV. In addition, Bath’s Local Plan and Placemaking Plan set out a spatial strategy focused on protecting the city’s landscape bowl, its open edges, and the visual harmony between built form and countryside. The Bath Placemaking Plan (Volume 2) emphasises that the southern plateau edge — including Claverton Down and the Sulis Club — forms part of the “essential green infrastructure” that maintains the separation between urban Bath and the wider Cotswolds landscape.

The Sulis Club’s pitches and open space are further protected under Sport England’s Playing Fields Policy and Guidance (2021). Sport England will object to any development that results in the loss of playing fields unless one of five narrow exceptions (E1–E5) applies, none of which are relevant. In addition, NPPF paragraph 99 prohibits the development of existing sports and recreational land unless equivalent or better provision is made elsewhere. No such replacement exists and the Sulis Club has already been cited withing the University of Baths recent planning application for a 3G pitch, App Ref 22/04720/FUL, as part of the existing grass pitch provision (including the Junior grass pitch provision), despite the local Playing Pitch Strategy evidence and Sport England formal planning objection to the contrary.

This option would directly undermine this policy framework by removing Green Belt protection, weakening safeguards that preserve openness, prevent urban sprawl, and protect the city’s landscape setting. The NPPF (paras. 147–151) only permits alteration of Green Belt boundaries in exceptional circumstances, following a comprehensive strategic review, circumstances which have not been demonstrated here.

2. World Heritage Site, Landscape, and Character

The Sulis Club sits within the setting of the City of Bath World Heritage Site, whose Outstanding Universal Value derives from the “harmonious integration of architecture, urban form, and natural landscape.” The site’s openness and treed margins contribute directly to Bath’s southern skyline and the green amphitheatre setting that defines the city’s OUV. Removing Green Belt protection risks enabling development that would:

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• Erode the visual unity of city and countryside,

• Interrupt long-distance views; and

• Diminish Bath’s internationally recognised landscape character.

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The Sulis Club contributes directly to the visual coherence and ecological value of this area. Any removal of Green Belt protection for an inevitable subsequent built development would compromise the area’s landscape integrity, fragment open space, and detract from the rural character that is central to Bath’s setting. This would breach NPPF paragraphs 199–208, which afford the highest level of protection to WHS settings and directly contravene UNESCO guidance on preserving heritage landscapes.

3. Ecology and Biodiversity

The Sulis Club forms an essential component of Bath’s “dark corridor” ecological network, as identified in the B&NES Green Infrastructure Strategy and protected under the Conservation of Habitats and Species Regulations 2017. This network provides critical foraging and commuting routes for Greater and Lesser Horseshoe Bats and Bechstein’s Bats, key species within the Bath and Bradford-on-Avon Special Area of Conservation (SAC).

In addition to its importance for bat species, the Sulis Club supports and adjoins the wider habitats of a rich assemblage of protected and priority wildlife, including:

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• Nesting birds, safeguarded under the Wildlife and Countryside Act 1981 (as amended);

• Badgers, protected under the Protection of Badgers Act 1992, with established setts and foraging territories recorded within and adjacent to the site; an

• Protected reptiles and amphibians, including great crested newts, which depend on the site’s ponds, grassland, and hedgerow habitats for breeding and foraging.

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Beyond this statutory policy the University of Bath has undertaken significant ecological enhancement works at the Sulis Club as part of its Section 106 obligations associated with offsetting the School of Management (SoM) development on the main campus. Under this Woodland and Tree Management Plan (WTMP), the University provided off-site ecological and landscape mitigation through planting approximately 5,000 trees and native wildflowers. This scheme enhances foraging opportunities for bats, nesting and shelter habitats for birds, badger habitats, and breeding and foraging opportunities for great crested newts; establishing the Sulis Club as an ecological compensation area integral to the University’s planning compliance and Bath’s wider biodiversity network.  Any removal of Green Belt status or redevelopment under this option would irreversibly compromise this ecological mitigation, contrary to Habitats Regulations and NPPF paragraphs 179–180, which support both the onsite and adjoining biodiversity of the local ecosystem.

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Whilst any development has to commit to a Biodiversity Net Gain (BNG) of at least 10%, the BNG Environment Act is still relatively new and as such there remain concerns surrounding the calculations’ validity and actual observed long-term impact on biodiversity. Undervaluing particular habitats containing protected species; lack of consideration for the wider ecological framework and system and Local Authoritys’ limited capacity to monitor and enforce any BNG, environmental obligations and management, whose commitment terms are set at a statutory 30 years are particularly pertinent in this instance. Case in point, some of the University of Baths SoM S106 environmental obligations appear, yet, unfulfilled, raising concerns about future post-development compliance and ongoing protection of the site’s ecological functions.

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With limited space both off and on campus and the Sulis Club often being cited as an offset for main campus development within planning documentation, with little cohesive public record to the extent of this, it seems unlikely the University of Bath can maintain both their original environmental obligation and any new ones should PBSA granted.

4. Sporting and Recreational Value

The Sulis Club is a vital outdoor sports facility, supporting pitches, training areas, and green space for University and community use, from much needed Grassroots to National level. It has also been identified within the B&NES Council’s Playing Pitch Strategy, prepared in consultation with Sport England, as a strategically important community sporting asset that should be protected and enhanced to meet both current and future population demands for playing field provision in B&NES. 

The sustained interest from numerous local and regional sports clubs and bodies, including Bath Cricket Club & Somerset Cricket Board, Bath Combination Rugby, England Lacrosse, and Somerset Football Association; demonstrate its continued demand, relevance and strategic importance as a hub for sport across multiple disciplines. Until recently - owing to the internal demolition of the clubhouse as part of planned– the facilities were in frequent use.

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The site was subject to a joint University – local community focused plan to reinvigorate the Sulis Club with modern changing facilities and a climbing centre, which would have significantly enhanced its community and recreational value. The Climbing center alone yielding an annual social value of ~£1.5M, such is the power of sport. The University pulled out of this plan in, informing its stakeholders in March 25.

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Moreover, as already mentioned, In the University of Baths most recent planning application for a 3G pitch, which clears space for their subsequent application of circa 950 PBSA units on the main campus; the Sulis Clubs grass pitches have been further cited as compensatory justification for the loss of numerous grass pitches on campus. If considered in isolation, the loss of this green sporting space will create a compound deficit. The disregard of this is even more concerning given the forecast growth of the region and greater need for more easily accessible community sporting facilities.  

4a. Impact on Ralph Allen School and Educational Sport Provision

The Sulis Club also serves as an important off-site sporting resource for Ralph Allen School, providing essential playing fields for physical education, team sports, and outdoor recreation. Loss of these facilities through this proposal would directly restrict access to high-quality sports grounds, forcing the school to either reduce sports provision or seek alternative, potentially distant sites.

This would have significant implications for children’s physical and mental wellbeing, undermining opportunities for regular exercise, team-building, and social development. School sport is a critical component of healthy lifestyles, educational attainment and social cohesion which the Sulis Club currently supports these outcomes by offering a safe, accessible, and well-maintained green space.

The loss would serve to reduce the already limited accessible high-quality recreational facilities and undermining the potential and current role of the site in supporting active lifestyles. In doing so would contradict the Council’s own policies promoting active lifestyles for communities and children, including the Bath & North East Somerset Physical Activity Strategy (“Fit for Life”), which emphasises the importance of accessible facilities for improving health, wellbeing, and lifelong physical activity; the Being Active initiative, which promotes integrating physical activity into children’s daily routines; and the Active Travel Strategy 2020–2030, which encourages walking, cycling, and healthy, active lifestyles. Removing the Sulis Club would therefore negatively impact both community, educational provision and child health outcomes, while undermining local strategies to promote active, healthy communities.

5. Population Wellness and Social Value

The Sulis Club contributes directly to population health, wellbeing, and social cohesion. Access to outdoor sports facilities, green space, and natural landscapes is linked to:

• Improved physical health and fitness,

• Reduced mental health pressures such as stress and anxiety,

• Strengthened social cohesion through shared recreational and community activities, and

• Reduced associated Health and Social care costs.

Indeed, this Local Plan highlights the role of sport as well as places in influencing health outcomes. In particular, stating that an additional 200ha of accessible green space will be needed to accommodate B&NES population growth. Moreover, advocating that the Local Plan should be used as an opportunity to shape, promote and deliver healthy and sustainable spaces that generate positive social interaction, encourage active participation in healthy lifestyles and reduce inequalities. An accessible community sports venues with green space, such as the Sulis Club, is a pre-existing example of such provisions, albeit with significant unmet potential due to the current policy of underinvestment by the University of Bath. Retention of the Sulis Club site as Green Belt land contributes necessary accessible green space and ensures that multi-functional public and social value continues to be delivered, complementing its ecological, heritage, and recreational roles, in line with policy ranging from the Local Plan, B&NES Health and Wellbeing Strategy and NPPF (paragraphs 92 and 99). It seems inefficient to remove this pre-existing site from the community, when it already provides significant scope to meet the Local Plans needs from a health and welfare perspective.

More generally, increased traffic, noise, artificial lighting, and the loss of surrounding green space associated with redevelopment would also have an irreversible negative impact on residential amenity along Claverton Road. This would harm the quality of life and wellbeing of local residents, contrary to the Council’s own Placemaking and Liveable Neighborhoods policies, which seek to promote healthy, quiet, and accessible streets.

6. Transport, Access, and Infrastructure Constraints

The Sulis Club is accessed via Claverton Road, already identified by the Council as a congestion hotspot. Traffic arises from local schools, Wessex Water, the University of Bath, and the A36.

Although the Council has proposed the “Scholars Way” cycle route to improve sustainable access, Claverton Road remains narrow and constrained, with limited on-street parking, meaning it lacks sufficient capacity to accommodate additional traffic nor more frequent public transport from any redevelopment. These road conditions continue to present safety concerns for pedestrians and cyclists, particularly children and other vulnerable road users.

Currently, both Ralph Allen School and Wessex Water have formal agreements with the University to use the Sulis Club car park to help reduce congestion and improve safety during peak times by keeping vehicles off Claverton Road. Loss of the Sulis Club site, without a nearby replacement for parking, would remove this important traffic management measure, further worsening congestion, delays, and of more concern safety risks.

Further traffic would also likely impact migrating mammals and reptiles that rely on surrounding green corridors and hedgerows for foraging and commuting. The combined traffic, safety, amenity, and ecological pressures demonstrate that the Sulis Club site is unsuitable for built redevelopment and retaining it as green and recreational space avoids these impacts while supporting active travel and ecological connectivity.

7. University Sustainability Commitments

The University of Bath’s sustainability strategy commits to:

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• Protecting biodiversity and green space,

• Reducing carbon emissions, and

• Integrating sustainability into land use decisions.

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This Option conflicts with these values by promoting potential redevelopment that would:

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• Eliminate carbon-absorbing green space,

• Disrupt ecological corridors, and

• Reduce sustainable recreational opportunities.

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Such a change would contradict the University’s public commitments to environmental responsibility and its reputation as one of Baths anchor institutions and a leader for sustainable research and practice.

8. Bath Planning Balance

B&NES currently has a 5-year housing under-supply, requiring careful management of land to meet housing needs without compromising Green Belt or ecological assets. This Option loosely suggests that redevelopment of the Sulis Club site could “potentially reduce pressure for the creation of new HMOs in the City”. Its worth noting that it does not enable existing HMOs to be returned to the housing stock. Given the already tightly controlled Article 4 provisions surrounding the creation of a new HMOs and the lack of qualification here in the Option, it seems this is a redundant statement. Removing Green Belt for development into PBSA would fail to support B&NES’s planning balance while causing irreversible harm to landscape, ecology, sports provision, and community amenity. Better to realistically coordinate the growth aspirations of a University whose student population already form ~22% of the City.

Over the past decade the City has already delivered numerous large scale PBSA developments, including, the Depot, Twerton Mill, Green Park House, Hollis Wharf and the Scala. These Schemes were also justified, in part, on reducing the pressure on family housing stock, however, the number of HMOs, in traditional neighbourhoods, such as Oldfield Park, Southdown, and Widcombe, remains high, demonstrating that student demand has not decreased in the local private rented sector, nor have these HMOs been returned to rebalance the housing stock. Adding more PBSA risks to further unbalance Baths housing provision. With Universities already operating at capacity and national data, and new government policy signalling stabilising or declining domestic numbers, further compounded by growing international competition in the higher education sector, there is no compelling demographic of economic rational for additional PBSA. It Instead comes at the cost of the local residents through the permanent loss of an important community provision, that cannot be replaced.

9. Alignment to B&NES Economic Strategy

The B&NES Economic Strategy 2024–2034 places strong emphasis on building a greener economy, where green spaces play a central role in enhancing community resilience, health, and economic productivity. The Sulis Club exemplifies these strategic priorities. It provides accessible recreational facilities that promote physical and mental wellbeing, directly supporting the strategy’s goal of improving health outcomes. As a space where diverse groups come together for sport and community activities, the club fosters social cohesion, inclusion, and a sense of belonging, key elements of a resilient and connected society.

Economically, the Sulis Club offer local employment, memberships, events, and partnerships. Planned developments such as a climbing wall and Padel tennis courts, initiatives that were progressing until the University of Bath withdrew support a rejuvenated clubhouse, represent significant untapped potential. These enhancements would stimulate local economic activity and align with the strategy’s vision for sustainable long-term growth. The economic impact of sport in the UK represent £83.1 billion Gross Value Added (GVA), circa 4.1% of UK GVA.  

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The sports industry itself is undergoing rapid transformation, driven by technological innovation, data analytics, and experiences. Bath is positioning itself as a regional hub for innovation, with initiatives like the University of Bath Innovation Centre and the proposed Innovation Corridor. The Sulis Club, with its established community presence and potential for growth in emerging sports, is well-placed to collaborate with academic institutions and startups, contributing meaningfully to this innovation ecosystem.

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In contrast, while additional student accommodation may offer some economic benefits, these are often unevenly distributed and come with structural trade-offs. These include increased housing pressure, seasonal economic fluctuations, and reduced community balance. With over one in four Bath residents being university students—and more than one in five from the University of Bath—the demographic balance is already heavily skewed. The economic contribution of students is typically limited by transient residency, low-wage employment, and low-value spending patterns, which can hinder sustainable economic development. Future planning must ensure that the student economy complements, rather than displaces, the city’s long-term economic and social wellbeing.

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The loss of the Sulis Club would also mean the loss of a unique opportunity to foster the benefits social integration between students and the wider community. Its removal would reduce engagement opportunities, weaken social cohesion, and reinforce divisions, undermining the resilience and vitality of the local economy.

The Sulis Club can be a vital contributor to the social and economic fabric of Bath & North East Somerset. Its retention as a Green Belt site is essential to advancing the objectives of the B&NES Economic Strategy, particularly in promoting a greener economy, enhancing health and wellbeing, collaborative innovation and supporting inclusive, sustainable growth.

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12. Community Support

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The Sulis Club has received consistently overwhelming public and institutional support for its retention and reinvestment as a community sports facility. The proposed climbing wall by Ascent Climbing sparked significant enthusiasm as its progressed, with hundreds of supportive comments across multiple platforms during its development; from social media, B&NES public consultations, Community Infrastructure Levy applications and local media, reflecting a clear desire from residents for inclusive, accessible recreational infrastructure. The news of the University of Baths decision to withdraw from their commitment to rejuvenate the site, followed by the realisation that this was founded in the aspirational Local Plan Option to convert the site to PBSA has generated a surge of impassioned public responses, expressing disappointment and frustration at the University’s and councils direction. Consequently hundreds of residents have voiced concerns about the loss of a valuable community asset and the erosion of inclusive recreational opportunities. In addition, The University of Bath Students’ Union has issued a strong public statement describing the Sulis redevelopment, including the climbing center and changing rooms, as a “long-overdue necessity” and expressed deep disappointment at the University’s decision to withdraw support. National bodies such as the British Mountaineering Council (BMC) have also shown support, recognising the Sulis Club’s potential to serve a growing climbing community and promote physical and mental wellbeing through sport. Local sports clubs and charities, including Bath Arsenal, Bath Cricket club, Sporting Family Change as well as numerous University of Bath sports societies, have echoed this sentiment, highlighting the site’s value for youth development, community engagement, and inclusive sport. Ignoring this collective voice risks significant reputational damage to both the Council and the University; both anchor institutions expected to act in the public interest and foster inclusive, sustainable development. Proceeding with plans to remove Green Belt protection and replace the Sulis Club with PBSA would not only disregard the community’s clear preferences but also erode trust in the leadership and long-term vision of these institutions. The Sulis Club represents a rare opportunity to create a truly integrative space for students and residents alike and its loss would be felt deeply across Bath and North East Somerset.

13. Exceptional Circumstances

Under the NPPF (para. 148), Green Belt boundaries may only be altered where exceptional circumstances justify and the harm is clearly outweighed by other considerations. This Option fails this test. The proposed loss of Green Belt status would:

• Harm the WHS setting and OUV,

• Damage biodiversity and dark corridors,

• Undermine local sports provision,

• Conflict with SB19, CP6, and B4 of the Local Plan,

• Contradict the Council’s own placemaking, ecological, community wellbeing objectives, and

• Fail to support B&NES housing undersupply and planning balance.

 

Conclusion

For the reasons set out above, the Sulis Club should remain designated as Green Belt land. It still holds so much potential for B&NES, beyond development to PBSA. Its ecological, sporting, landscape, and social functions are integral to the identity and sustainability of Bath. Any removal of this protection would inevitably lead to irreversible harm to the city’s heritage, environment, community wellbeing and trust.

This proposal should be rejected, and the Council should reaffirm its commitment to protecting Bath’s Green Belt, ensuring that future growth occurs in a way that enhance, not erodes, the city’s exceptional natural and cultural environment.