Sep – Oct 2014

2014 Weeks 37- 40

9 September – 14 October

14/01772/REG 13 & 14/01773/REG13 – Colonnade beneath street, Grand Parade, City Centre, Bath, Bath and North East Somerset, BA2 4AN.

Change of use of vault and undercroft spaces below Grand Parade to restaurants and ancillary facilities (A3), with works to allow pedestrian access to Boat Stall Lane and The Colonnade and to facilitate access to Slippery Lane. Alteration of the public highway, the creation of pedestrian space, the realignment of bus and service parking capacity along Grand Parade and towards Orange Grove, provision of a new loading bay, and construction of vertical pedestrian and service receptions.

Object: We refer to our previous objection which remains applicable to the amendments proposed and should be read in conjunction with this submission.

The changes which have been made to the scheme are not sufficient to address the main objections we have raised. We urge the applicant to consider alternative options. We refer to the points previously raised which encourage access via Parade Gardens or internal access from within adjacent buildings/shops.

The entrance ‘beacons’, even if smaller, would be the focus of attention, particularly at night by way of lighting and advertising. The design and appearance will add considerably to local street clutter that would harm the setting of the balustrade on Grand Parade. Most importantly, they will be visually intrusive in the townscape setting and partially obscure of one of Baths (the worlds?) most iconic views, that towards Robert Adams Grade I Pulteney Bridge from the south.

The current proposal would detract from important architectural features and composition, historic fabric and character of the Colonnades, and would lead to harm to the listed building. The ‘beacons’ proposed would cause substantial harm to the setting and significance of the listed buildings (Pulteney Bridge and the Grand Parade balustrade), would neither preserve nor enhance the character and appearance of Bath Conservation Area, and would have a detrimental impact on the special qualities and Outstanding Universal Value of the City of Bath World Heritage Site.

For these reasons we consider that the proposed works would fail to preserve the architectural and historic significance and character of the heritage assets and is contrary to Planning (Listed Buildings and Conservation Areas) Act 1990 and the NPPF and should not be approved.

 

14/02272/EFUL – Ministry Of Defence, Warminster Road, Bathwick, Bath, Bath and North East Somerset, BA2 6SF

Demolition of existing buildings and erection of 201 no. dwellings; 2 no. accesses from Warminster Road, vehicular parking; open space; landscaping (including tree removal); pumping station; and associated engineering works.

Object: We refer to the amendments dated the 17th September. The Trust has since met with the applicants to discuss the detail relating to the changes to this application. Much of our previous objection, which should be read in conjunction with these comments, remains applicable to the amended application. In particular our comments relating to the design aesthetic for the site, and its relationship to the character of this part of Bath which  is marked by the transition from terraces to villas during the mid 19th century (refer to submission dated 17/07/14).

The most significant change relates to the design and positing of buildings BF 4 & 5. This is better solution although we do have some concerns about the design approach.  We are concerned that the style competes with, rather than complements, the grade II listed Hampton House, further up the hill. We also have reservations about the depth and bulk of the building to the rear and the amount of development stepping down. This side elevation is likely to present an overbearing effect on the street scene. We would suggest that the building is set back from the road and a mid storey to the rear is removed. This would allow for roadside planting and tree between the blocks to create a more harmonious green frontage.

Whist we recognised that an attempt has been made to introduce more natural Bath stone to the elevations, including side and rear elevations, we notice that there are many elevations that are still shown to be rendered. Unfortunately this fails to satisfy our concerns relating to the quality of materials and finishes across the site. The use of natural Bath stone is preferred on all elevations across the site, and in the construction of chimney stacks.

For the reasons stated above the Trust is unable to support the proposal in its current form. We would welcome improved justification for the design approach, and would welcome the opportunity to engage in any further design review.

 

14/01853/EFUL – Ministry Of Defence Ensleigh, Granville Road, Lansdown, Bath.

Full planning permission sought for the erection of 181 residential units (Use Class C3), a neighbourhood retail store of up to 267 sqm GIA (Use Class A1), associated highways works, infrastructure and public open space. Outline planning permission sought for a 72 unit Extra Care Facility (Use Class C3).

Object: We refer to our previous objection which remains applicable to the amendments proposed and should be read and reported in conjunction with this submission.

The changes which have been made to the scheme are not sufficient to address the main objections we have raised.

Whilst we recognise improvements have been made to the design and appearance of the shop, we remain concerned about the commercial nature of this building and associated advertising in this sensitive location. As we have previously stated, we consider this to have a permanent negative impact on the setting of Beckford’s Tower, and to be detrimental to the landscape character and setting of the World Heritage Site.

We repeat our disappointment in the failure to even try to meet the sustainability aspects of the Concept Statement for the site.

The design and layout seems almost wilfully to ignore the possibility of using Beckford’s Tower a focal point for the street pattern and layout of the development. The main diagonal street axis is set so that it cannot be seen in any focal views across the site. We do not consider this approach responds sufficiently to the local context, or reinforces or complements this locally distinctive feature.

We remain concerned that the development is consistently bulkier than that anticipated by the Landscape strategy (that is 2 storey with 3rd storey setback). Much of the development remains at 3 storeys.

We remain particularly concerned about the incredibly bulky (3 storey plus roof) outline proposal for the care home facility, which would completely dominate the site and setting and is nearest to the Tower.

We remain concerned that the applicants seemed unaware of the fact that the cemetery gates are a listed building in their own right and that the churchyard, far from being deconsecrated, is still in use for ash interments and should be seen and indeed supported as a place of quiet contemplation.

Finally, the application has referred to the impact on views from the top of Beckford’s Tower. However most people’s experience of this Grade I listed building in its landscape is in long views TO the Tower, which given its prominence as a building in a landscape seems more important. We therefore retain the view that the impact assessments are inadequate.

For the reasons previously submitted and stated above the Trust is unable to support the proposal in its current form. We would welcome improved justification for the design approach, and would welcome the opportunity to engage in any further design review.

 

14/02412/FUL – The Johnsons Group Ltd, James Street West, City Centre

 

Erection of student accommodation (sui generis) comprising 190 student bedrooms in studio/cluster flats; together with 2 no. disabled parking spaces; 56 covered cycle spaces; 2 no. covered refuse/recycling stores; covered plant rooms; vehicular access from James Street West; new hard/soft landscaping treatment, following demolition of existing industrial/office buildings. (Resubmission)

 

Comment

Principle

We recognise that the applicants have made an effort to respond to concerns about the design, scale, roof profile and relationship with Green Park. We consider the amendments to this application to be a general improvement however we remain concerned about the following elements of the scheme;

Design

We consider that the contemporary idiom adopted for the proposed buildings is appropriate. However, despite several iterations, the appearance of the buildings, particularly facing James Street West is not yet at a stage where it is considered to respond to its surroundings or make a positive contribution to the street scene and public realm.

Materials

We welcome the provision of the materiality study which provides a much clearer indication for building facades. We feel that the proposed contextual street views demonstrate the inappropriateness of the proposed metal cladding materials in James Street West.

The landscaping, as proposed, seems appropriate in quality, if not in quantity. The lack of external social space remains of concern.

Over provision of student accommodation

We are particularly concerned about an oversupply of student housing which would potentially use up brown field sites within the city centre. A report obtained from B&NES planning policy team concludes that there is a forecast shortfall in deliverable supply of student housing to 2021 of only 203 bed spaces.  This contrasts with the following planning applications:

  • Green Park – 461 bed spaces;
  • James Street West – 250 (min) bed space;
  • Transport Depot, Brougham Hayes – 103 bed spaces;
  • Site of Old Gas Works, Upper Bristol Road – 404 bed spaces;
  • Hartwells, Upper Bristol Road  – 194 + 70 beds paces;

This would suggest a massive overprovision when one compares applications against need. The key issue here is that in the provision of student housing will prevent much needed affordable housing being developed on this and other brown field sites.

Sustainability and future use

Whilst we welcome the submitted plan showing the buildings adapted for a non-student use, we feel that the design does prejudice against a viable future use. The design as proposed creates few active frontages and no public uses or pedestrian routes through. The rear elements of the development will adjoin the Sainsbury’s car park and, as such, active frontages should be proposed at this stage to create a good quality public realm and avoid prejudicing potential redevelopment of this site.

 

Week 37

14/03977/OUT – Hartwells Of Bath, Newbridge Road, Newbridge, Bath, BA1 2PP

Outline planning application for erection of three blocks of student accommodation comprising 194 student bedrooms in studio/cluster flats and 70 bedrooms in a terrace of 14 two storey HMOs with access from Newbridge Road, shared foot/cycleway, associated car parking, cycle parking, amenity space and landscaping following demolition of existing buildings

Object:  The Trust does not object to the principle of the redevelopment of this site for housing. In terms of the layout of the site, redevelopment has the potential to enhance the townscape character of the area and we would welcome residential development on the site that would effectively repair the street scene along Newbridge Road.

We do not however consider that the provision of student accommodation is at all appropriate in this part of the city which is strongly characterised by family housing. We are concerned that student housing here, which would be unoccupied for part of the year, would have a negative effect on the vibrancy of the local, residential character.

We are particularly concerned about an oversupply of student housing which would potentially use up brown field sites within the city centre. A report obtained from B&NES planning policy team concludes that there is a forecast shortfall in deliverable supply of student housing to 2021 of only 203 bed spaces.  This contrasts with the following planning applications:

  • Green Park – 461 bed spaces;
  • James Street West – 250 (min) bed space;
  • Transport Depot, Brougham Hayes – 103 bed spaces;
  • Site of Old Gas Works, Upper Bristol Road – 404 bed spaces;
  • Hartwells, Upper Bristol Road  – 194 + 70 bed spaces;

 

This would suggest a massive overprovision when one compares applications against need. The key issue here is that in the provision of student housing will prevent much needed affordable housing being developed on this and other brown field sites.

The development of this site for student accommodation would not make any provision towards much needed affordable housing, nor any contribution to local community facilities. The proposal is therefore contrary core strategy policies CP9, CP10, and CT3.

Furthermore this proposal should not be approved unless the future adaptability of the buildings for other residential uses is demonstrated.  We therefore urge the LPA to refuse this application.

 

14/03658/LBA – Clinton Cards 27 – 28 Stall Street City Centre Bath, Bath & North East Somerset BA1 1QF

 

External alterations to replace the existing fascia sign and paint the timber panel above shop front.

 

Object: We object to this retrospective proposal as the use of PVC is unsuitable for a listed building within the World Heritage Site and conservation area.  The material would not improve the appearance of the principal elevation of the building and therefore not enhance the character of the street scene.  We appreciate the applicant’s desire to change the front of their premises; however more appropriate materials should be used.  We would suggest that the fascia sign be hand painted and that the background finish be in a more traditional colour, drawing on the prevalent historic palette of the city.

The proposed scheme, by virtue of the material would be detrimental to the listed building, and visual amenity value of the area and neither preserve nor and enhance the character and appearance of the Conservation Area, and be contrary to the Planning (Listed Building and Conservation Areas) Act 1990, Section 12 (Conserving and enhancing the historic environment) of the NPPF, policies; B1, B2, B4 and CP6 of the B&NES Core Strategy and saved policies; D2, D4 and BH19 from the B&NES local plan.   We would therefore recommend that the application be refused.

In addition, we consider that the work – which has already been undertaken prior to consent – is in breach of Planning and Listed Building Control, and we would therefore request that you undertake an investigation and pursue necessary enforcement action.

 

14/03802/AR – 38 Milsom Street City Centre Bath, Bath & North East Somerset BA1 1DP

 

Display of 2no. hanging signs and 1no. painted sign.

 

Object: We object to this proposal as the fixing of the metal signage to the stonework will cause unnecessary harm to the fabric of the listed building.  Also the hanging signs are too large in a street where this form of advertising is not prevalent.  Neither of these elements of the proposed scheme would improve the appearance of the principal elevation of the building and therefore they would not enhance the character of the street scene. We would suggest that the two hanging signs – at a reduced size – along with the door signs are sufficient means of advertising/identifying the business premises, and would take away the need to harm the stone work by fixing metal signage.

The proposed scheme, by virtue of the size of the hanging signs and the fixing of metal to the stonework would be detrimental to the listed building, and visual amenity value of the area and neither preserve nor enhance the character and appearance of the Conservation Area, and be contrary to the Planning (Listed Building and Conservation Areas) Act 1990, Section 12 (Conserving and enhancing the historic environment) of the NPPF, policies; B1, B2, B4 and CP6 of the B&NES Core Strategy and saved policies; D2, D4 and BH19 from the B&NES local plan.   We would therefore recommend that the application be refused.

 

14/03789/FUL – 98 Wellsway, Bath.

Removal of a section of stone boundary wall (2m in length) and relevant section of planting.

Comment: If the proposal is granted consent we would recommend that it is ensured that the end section of the remaining wall is completed in a satisfactory manner, in keeping with the materials and form of construction of the rest of the structure.  In addition we would also recommend that any work undertaken has adequate measures in place so that no harm is done to the root-zone of any of the established trees, that from a significant part of the street-scene.

 

14/03652/AR – Platinum Renault Lower Bristol Road Westmoreland Bath BA2 3DN

Display of 3 no. internally illuminated fascia signs and 1 no. internally illuminated pylon sign and 2 no. internally illuminated portal signs.

 

Object:  Whilst we appreciate the applicant’s desire to promote their commercial interests, we will maintain our position in objecting to illuminated signs in the World Heritage Site and in the setting of the conservation area.  Many car dealerships have illuminated signs but these should not be a precedent for a low illuminated city like Bath.  Overhead street lighting should be sufficient to allow advertising to be seen on the site.

 

The proposed scheme, by virtue of the illuminated signs, would be detrimental to the setting of the conservation area – in this gateway location – and the visual amenity value of the area, and neither preserve nor and enhance the character and appearance of the World Heritage Site.  The scheme would be contrary to Section 12 (Conserving and enhancing the historic environment) of the NPPF, policies; B1, B4 and CP6 of the B&NES Core Strategy and polices; D4 and BH 17 of the B&NES Saved Local Plan.

 

Week 38

14/03685/AR & 14/03707/LBA – 11 Northumberland Place Bath BA1 5AR   

Display of 3no non-illuminated fascia signs and 2no projecting non-illuminated signs.

Object: We object to this proposal as the use of vinyl and aluminium is unsuitable for a listed building within the World Heritage Site and conservation area.  The materials would not improve the appearance of the building, at a prominent site in the city centre, and therefore not enhance the character of the street scene.  We appreciate the applicant’s desire to promote their business; however more appropriate materials should be used.  We would suggest that the fascia sign be wholly hand painted and that the hanging signs be made from timber, drawing on the historic palette of the city.

The proposed scheme, by virtue of the materials would be detrimental to the listed building, and visual amenity value of the area and neither preserve nor and enhance the character and appearance of the Conservation Area, and be contrary to the Planning (Listed Building and Conservation Areas) Act 1990, Section 12 (Conserving and enhancing the historic environment) of the NPPF, policies; B1, B2, B4 and CP6 of the B&NES Core Strategy and saved policies; D2, D4 and BH19 from the B&NES local plan.   We would therefore recommend that the application be refused.

 

14/03892/AR & 14/03896/FUL – Vacant Shop 49 Southgate Street Bath BA1 1TG  

Display of 1no internally illuminated fascia sign, 1no non-illuminated fascia sign and 1no internally illuminated projecting sign.

Object: We object to this proposal as the use of vinyl, aluminium and perspex is unsuitable for a building in the World Heritage Site and conservation area.  The materials would not improve the appearance of the building and therefore not enhance the character of the street scene.  We appreciate the applicant’s desire to promote their business; however more appropriate materials should be used.  We would suggest that the fascia sign be of wholly hand painted timber and that the hanging sign also be made from timber, drawing on the historic palette of the city.

We object to illuminated signage in the World Heritage Site and conservation area, as Bath is a low-illuminated city and the proposal seeks to introduce unnecessary sources of light into an adequately lit area.

The proposed scheme, by virtue of the proposed materials and illuminated signs, would be detrimental to the character and the visual amenity value of the conservation area, and neither preserve nor and enhance the character and appearance of the World Heritage Site.  The scheme would be contrary to Section 12 (Conserving and enhancing the historic environment) of the NPPF, policies; B1, B4 and CP6 of the B&NES Core Strategy and polices; D4 and BH 17 of the B&NES Saved Local Plan.

 

14/03898/AR, 14/03899/LBA & 14/03897/FUL – Next 33 Stall Street City Centre Bath, Bath and North East Somerset BA1 1QG

Display of 1no. externally illuminated fascia sign and traditional victorian black awning over sign & Internal and external works for the redecoration of the shopfront facade, ground floor front windows to be replaced with timber framed bifold windows and decorated to match rest of shopfront and associated internal works.

Object: We object to this proposal as the use of powder coated signage letters is unsuitable for a listed building within the World Heritage Site and conservation area.  The material would not improve the appearance of the building and therefore not enhance the character of the street scene.  We appreciate the applicant’s desire to promote their business; however more appropriate materials should be used.  We would suggest that the fascia sign be hand painted, drawing on the historic palette of the city.

The fixing of lighting to the building may cause unnecessary harm to the fabric of the designated heritage asset and will introduce an unwarranted source of light into the World Heritage Site and conservation area.  Bath is a low-illuminated city and there are ample levels of light in the street so allow the premises to be clearly visible.

We believe that the design of the bi-folding doors will lead to a design that is not in-keeping with the traditional form of shop-fronts within the city, as the proposal is rather bulky.  The etched vinyl application to the ground floor windows is also unsuitable for a listed building within the World Heritage Site and conservation area.  The proposed awning, which would not fit comfortably into the design of the existing shop front, would present an element that would protrude, add visual clutter to the appearance of the front of the building and have a detrimental impact on the street scene.

The lack of any acknowledgment by the applicant of the significance of the designated heritage asset is a concern, as this may suggest a lack of consideration of how the proposal would impact on the listed building and the wider historic environment.

The proposed scheme, by virtue of the materials, lighting array and elements of the design would be detrimental to the listed building, and visual amenity value of the area and neither preserve nor and enhance the character and appearance of the Conservation Area, and be contrary to the Planning (Listed Building and Conservation Areas) Act 1990, Section 12 (Conserving and enhancing the historic environment) of the NPPF, policies; B1, B2, B4 and CP6 of the B&NES Core Strategy and saved policies; D2, D4, S5, BH6, BH19 and BH22 from the B&NES local plan.   We would therefore recommend that the application be refused.

 

14/03811/LBA & 14/03738/AR – Former Herman Miller Premises, Lower Bristol Road, Bath

Minor internal and external alterations to previously approved Listed Building Application 13/04409/LBA (Internal and external alterations for the change of use of the western part of the building from B2 use to an A1 foodstore) & Display of 3no internally illuminated bubble signs located on building elevations, 1no non-illuminated pole sign located at front of site and externally illuminated hoarding along new boundary spanning between rear of building and rear boundary.

Object:  Whilst we want to see this building brought back into an active use, and better maintained, and appreciate the applicant’s desire to promote their commercial interests, we will maintain our position in objecting to illuminated signs in the World Heritage Site.  Many retail outlets have illuminated signs but these should not be a precedent for a low illuminated city like Bath.

 

The proposed scheme, by virtue of the illuminated signs, would be detrimental to the visual amenity value of the area, and detract from the special qualities of the World Heritage Site.  The scheme would be contrary to Section 12 (Conserving and enhancing the historic environment) of the NPPF, policies; B1, B4 and CP6 of the B&NES Core Strategy and polices; D4 and BH 17 of the B&NES Saved Local Plan.

 

Week 39

14/02619/FUL – Pinesgate, Lower Bristol Road, Bath.

Erection of an office building (use class B1) with basement parking, associated infrastructure and landscaping following the demolition of the existing office building.

Object:  Whilst we welcome the reduction in the height of the proposed scheme, this does not overcome our initial concerns and objections to the bulk and scale of the proposed office building, and therefore our previous objections still stand are re-submitted as follows.

Background and summary

BPT welcomed the opportunity to engage in the early stages of the development process and provide comments. Our response has been informed by an earlier meeting between Ediston and BPT and the exhibition, which was attended by members of our Architecture and Planning Committee. We have provided pre-application comments to the applicants, expressing concerns about the height, design, appearance and materials which do not appear to have been taken into consideration.

Commercial viability

Although the issue of commercial viability is slightly beyond our remit, BPT remain to be convinced that there is a commercial case for an office development of this scale. We note that a recent proposal for office accommodation further down the Lower Bristol Road was recently withdrawn due to lack of commercial interest and has been reconfigured for housing development. We also note that this development constitutes 25% of the Enterprise Zone office accommodation for the whole of the Local Plan period to 2029 which would suggest that if the other end were also developed similarly, a full 50% of the Enterprise Zone requirement would be met on a single site rather than creating a ‘Zone’ of multiple developments of differing sizes spread through the Enterprise Area.  Given this disproportionate scale, we do not consider that the case for commercial viability is sufficiently justified in support of the proposal. We fear that if this building were built and then left unoccupied, a large and relatively brutal building such as this could be a severe blight on the city. Moreover, we are concerned that if a building of a certain scale and height is agreed in principle, then, if there is no commercial interest, a subsequent proposal for residential accommodation of equivalent height and scale would prove difficult to refuse.

Height and Mass

This planning application proposes a building which in our view is overly large and oppressive in the context of the Lower Bristol Road. Despite the claims of the D&A statement that the BWR SPD has been followed, we do not believe that the ‘overarching design principles’ of the SPD have been properly taken into account; for example see highlighted sections of the ‘overarching principles’ below:

  1. Bath Context

 

The design solutions must be sensitive to, responsive and inspired by their Bath context. In particular designs must be respectful of the wider city and the outstanding universal values and characteristics that have led to its designation as a World Heritage Site. Designs should be inspired by and complement the historic fabric of the city but not compete with it in terms of their overall visual presence. BWR should, by way of contemporary interpretations, continue the Bath tradition that is based upon classical proportions and detailed to give visual delight. Overall the design of BWR must continue the tradition of strong visual harmony which has resulted from respect for the outstanding universal values, that has created this distinctive city.

  1. Scale and Proportion

 

The tradition of a human scale in Bath must be recognised in BWR and this is based on hierarchy, order, proportion, rhythm, and harmony. Where greater scale is proposed sufficient setting will be required to retain human proportions. Retention of the human scale will reinforce the quality of the environment as a walking city.

 

  1. Visual Connectivity

An important design consideration for BWR is the nature of the visual relationship it establishes with the Georgian city centre and the rest of the city, as it extends over the adjacent hillside. The redevelopment of the site must not reduce the visual connection to the natural landscape. In this regard it must use the opportunity to bring the country into the city by a feeling that you can reach out to the wider green surroundings whilst being able to enjoy immediate green space.

In line with (3) above, we consider that the footprint of the built form occupies too much of the site and would like to see the size reduced to allow landscaping to provide a better setting and environment. We welcome that there is some widening of the pavement and provision of trees along the Lower Bristol Road which would be a definite environmental improvement. Unfortunately this is the only positive comment we are able to make.

The height, bulk and scale of the proposed building, sited at the edge of the Enterprise Zone, does not relate at all comfortably with the adjoining townscape. The proposed building makes the marked change in land use and building type very abrupt. We re-emphasise a point made previously that the height and scale of any new building on this site must sensitively address the transition from domestic scale and character where this change takes place.

As it is, a building of the proposed height and bulk would have an overbearing impact on the character of the local townscape.

We note that the proposed roofscape is articulated, which we understand should reduce impact when seen from above. Verified views are said to be provided within the application, but these cannot be found. Also, it is not easy to assess the context heights provided – The D&A statement 2.5 gives surrounding building heights, but, not only are floor-ceiling heights varied, the colours in key & diagram are inconsistent, precluding certainty.

Materials

We have serious concerns about the use of a ‘brick’ material, particularly on a building of this size and prominence. The use of natural Bath stone is preferred in general in the City due to the homogeneity of material being part of the description of OUV of the World Heritage Site.  Preferably stone should be integral to the design i.e. it should not be used as a cladding. However, the use of Bath stone alone would not make this building acceptable in terms of mass and scale.

In relation to the appearance of the building we are not convinced that the design aesthetic which is in existence at BWR should be accepted as the design aesthetic for all new buildings in Bath or even in BWR.  The other end of Pinesway ‘island’ provides potential for a ‘twin’ with more seriously significant impact, especially on local viewpoints. We are strongly concerned that the proposed building, if approved, should not set a precedent for a design approach for the Enterprise Zone.

Contrary to the overarching principle (1) above, the building proposed fails to express ‘Bathness’ in its design and appearance and fails to reinforce the local distinctiveness of the Conservation Area.

The proposed development, by virtue of its inappropriate height, bulk, massing, design, appearance, materials and failure to respond to the local context, would neither preserve nor enhance the city of Bath Conservation area and would compromise the special qualities of the World Heritage Site.

 

Therefore it is in our view contrary to the NPPF, the Planning (Listed Building and Conservation Areas) Act 1990, Policies BH1, BH6 and D4 of the B&NES Local Plan and should be REFUSED.

 

14/03974/AR – Guildhall, High Street, City Centre.

Provision of six sheet internally illuminated advertisements in bus shelters serving the St James Parade (Rampire) (Southbound), James Street West (Westbound) and Avon Street (North Bound) stops.

Object: Whilst we understand the applicant’s desire to increase their revenue through advertising, we will continue to object to illuminated signs in the Conservation Area and World Heritage Site. Many city bus shelters have illuminated advertisements but these should not be a precedent for a low illuminated city like Bath. Secondary sources of light in the proposed locations will emit sufficient light for the advertisements to be seen, and there is little need for additional illumination.

We regret the undue commercialisation of the public realm, especially by commercial agencies as opposed to local-interest information. We have concerns that the absence of information about the content of such advertisements is becoming a precedent. As such, we feel that a condition for local interest content only ought to be sought.

The inappropriate and visually intrusive illuminated signs would be detrimental to the special qualities of the World Heritage Site and will neither preserve nor enhance the character of the Conservation Area. The proposal is contrary to the Planning (Listed Building & Conservation Areas) Act 1990, Section 12 ‘Conserving and Enhancing the Historic Environment’ of the NPPF, B&NES Core Strategy polices; B1, B2, B4 and CP6 , and ‘Saved’ Local Plan Policies D2, D4, BH6 and BH17 and should be refused.

14/04195/EREG03 – Coach Park, Riverside Coach Park, City Centre.

Flood risk mitigation works enabling the development of the Bath Quays to Include: Realignment of Green Park Road; Changing Corn Street to be two-way traffic and Ambury to dual-lane; Relocating access points to Avon Street Car Park; Changing the Coach Park to be drop-off and pick-up only; Widen the River Channel in places between Churchill Bridge and Midland Bridge; Replace Riverside ground floor windows and doors at Waterfront House, Camden Mill and Bayer Building; Demolish existing walls and replace with higher walls between Churchill Bridge and Camden Mill; Provision of new flood wall between Bayer Building and Midland Bridge and Realignment of Riverside footpath at Green Park.

Comment:  We welcome work to mitigate flood risk in this location and to improve access to, and the enjoyment of the riverside.  We do recommend that the materials used to form the walls to the south bank, and the materials used in the landscaping to the northern bank are suitably resilient to function as surfaces to assist in the mitigation of flooding, yet are in keeping with the character and appearance of the traditional material palette of the city.  Such material should be selected to retain its function and aesthetic after any period of flooding.  In addition we would recommend materials that are in line with the B&NES Streetscape Manual (SPD) and Public Realm and Movement Strategy, and harmonious with the prevalent traditional types used across the city. The Trust will respond to detailed planning applications accordingly.

14/04025/FUL – Land rear of Dixon Gardens, Upper Lansdown Mews, Lansdown.

Erection of 1no. four bed dwelling.

Object:

The significance of the site

The site on which this dwelling is proposed forms the immediate setting of two designated heritage assets; Beckford’s Gate (grade II) and the walls enclosing Nursery Gardens (N and E sides) and ride to Beckford’s Gate (grade II).  With regard to the latter the proposed site of the dwelling is immediately to the south of the revetment walls which are approximately 70m in length running east –west at the northern edge of the site.

In our view the proposal site forms part of the curtilage of the designated heritage asset – Walls enclosing Nursery Gardens (list entry number 1394472) – and should therefore be treated as part of the structure, as per paragraph 1 (5) (b) of the Planning (Listed Buildings and Conservation Areas Act) 1990.

The remains of Beckford’s garden provide an open setting and context for these heritage assets.  This relationship provides great relevance to the significance of the assets in that they demonstrate the function of the assets as the remnants of the historic designed landscape.  The significance of these garden remains, which form the proposal site are clearly linked to work of one of the city’s most famous residents and designers, whose work can still be seen to dominant the cityscape in Lansdown Tower, commonly known as Beckford’s Tower.  The site of the proposal is a clear element of the wider designed landscape conceived and designed by Beckford culminating in the now grade I listed Tower.

The proposals

The application proposes a two storey dwelling positioned within the garden. Whilst we acknowledge that the design gives consideration to the height of the walls and the palate of materials we have an in principle objection to any development on the site and the loss of the garden setting.

The building proposed on the site, by virtue of its siting, position, design, massing and form in such close proximity to the listed structures creates a visually intrusive structure which in our view would cause substantial harm to the character and setting of the heritage assets.

It is proposed to remove a section of stone wall to southern end of the site to create an access and drive way – this wall, although unlisted is an attractive feature of the street scene and conservation area. The creation of the access drive way, and the associated loss of the stone wall and gate would neither preserve nor enhance the character and appearance of this part of the Conservation Area and is unacceptable.

Substantial harm

The development of a dwelling on this site would substantially harm the physical remains of part of the lower section of a garden designed between 1822 -1844 by William Beckford (1760-1844) and the Bath architect Henry Edmund Goodridge (1797-1864).

The siting, massing and appearance of the proposed dwelling will harm the setting of these heritage assets by curtailing views to and from the structures (Beckford’s Gate (grade II) and the walls enclosing Nursery Gardens (N and E sides) and ride to Beckford’s Gate (grade II), and therefore impacting negatively on the experience of those assets. Whilst the site is not currently publically accessible it has been considered that the contribution that setting makes to the significance of a designated asset, is not dependent on public rights or ability of access to experience the setting, as this will vary over time (English Heritage Guidance – The Setting of Heritage Assets: 2011).

If the garden is to be lost to the proposed scheme, then the significance of the heritage assets will be greatly harmed by lessening the experience of the assets and damaging their context.  Paragraph 132 of the National Planning Policy Framework (NPPF) states, “When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification.”  This makes clear the importance of the concept of setting in decision making and reflects the relevant legislation in the form of the Planning (Listed Buildings and Conservation Areas Act) 1990 at paragraphs 16 (2) and 66 (1).

If this scheme goes ahead it will cause irreversible harm to the garden remains of a currently non-designated heritage asset within the World Heritage Site and conservation area.

Lack of supporting evidence

We also object to the proposal, as given the significance of the heritage assets in close proximity to the site, a proportionate and informed consideration of the impact of the scheme on the significance of the assets is lacking.  The very brief heritage statement contained within the Design and Access Statement fails to recognise that the wall on the northern edge of the site is listed at grade II and does not acknowledge Beckford’s Gate, also a grade II asset.  The NPPF at paragraph 128 makes it clear that local planning authorities should require that an applicant describes the significance of any heritage assets affected, including any contribution made buy their setting.  The detail provided is required to be proportionate to the significance of the heritage assets, something which the applicant has clearly failed to do.  At the very least any proposal for development on this site should be supported by a historic building report and a properly considered heritage impact assessment.

For the reasons given above, the application will detract from the composition, character and setting and would lead to substantial harm, and therefore the significance of two designated heritage assets and a currently non-designated heritage asset, all of which are situated with the World Heritage Site and the conservation area.  The application would be contrary to the Planning (Listed Building and Conservation Areas Act) 1990, Section 12 of the National Planning Policy Framework, Core Strategy policies B1, B4 and CP6, and saved Local Plan policies BH2, BH6 and BH11. 

14/03980/FUL & 14/03981/LBA – 17 Grosvenor Place, Lambridge, Bath

Conversion of semi-derelict basement to a new self-contained one bedroom apartment

Object: We object to this application as no Heritage Impact Assessment (HIA) has been submitted and therefore this indicates that the historic fabric of the grade I listed building has not been considered in an appropriate manner, as fitting a structure of such significance.  Paragraph 128 of the National Planning Policy Framework makes it clear that local planning authorities should require that an applicant describes the significance of any heritage assets affected, including any contribution made buy their setting.  The detail provided is required to be proportionate to the significance of the heritage assets, something which the applicant has clearly failed to do.  The proposed removal of a sash window in the context of no accompanying HIA is objectionable as no indication of its significance is provided.

As the application is lacking information that would enable us to make an informed decision on the proposed scheme, we will need to object in order to safeguard the significance of the grade I building, and as the proposed scheme – based on the information provided – will not conserve or enhance the World Heritage Site or conservation area and is contrary to the Planning (Listed Building and Conservation Areas Act) 1990, Section 12 of the National Planning Policy Framework, Core Strategy policies B1, B4 and CP6, and saved Local Plan policies BH2, BH6 and BH11.

Week 40

14/03180/FUL & 14/03181/LBA Cleveland House, Sydney Road, Bathwick, Bath. BA2 6NR

 

Internal alterations and external alterations for the change of use from B1 offices to C3 residential including the erection of a single storey side extension with first floor terrace following the demolition of existing single storey extension lavatory block.

Object: This further revision now seeks permission for an upper level garden and balustrade which was omitted from the approved application, at an increased height. On balance we found that the previously approved application, which was revised in response to objections from both BPT and the Georgian Group, presented a scheme which minimised harm to the heritage asset and wider conservation area while at the same time ensuring the use of this building for the future.

We object to the increase in height of the extension and glass balustrade, which at a higher level would have an intrusive impact on the architectural composition of the listed building, and have a particularly uncomfortable relationship with the level of the string course. In order to retain subservience the height of the extension should be well below the string course.

We reserve judgement on the suitability of a roof terrace on the side this building which is felt to be somewhat inappropriate.

We still have serious concerns over the use of one of the blind windows as a stone door to provide access to the roof terrace. Our reservations are founded in an understanding that the blind windows are features of high architectural and historic significance as part of the intended design and ought to be retained. This intervention, the increase in depth and impact on the string course, therefore disrupts the historic fabric and design of this elevation and results in unacceptable harm to the historic fabric.

A stone clad access door would be somewhat unauthentic. We would ask for any examples where this approach has been used successfully to be submitted in support of this application prior to any approval. We are particularly concerned about durability and potential damage which may lead to a degraded appearance over time.  We would be interested to know what alternative access arrangement could be provided if this intervention proved unacceptable and unfeasible?

The current proposal would cause the loss of important architectural features and composition, historic fabric and character, and would lead to substantial harm to the listed building. The height of the extension proposed would be harmful to the setting of the listed building, and would neither preserve nor enhance the character and appearance of Bath Conservation Area. For these reasons the proposed works would fail to preserve the architectural or historic interest and character of the heritage asset contrary to Planning (Listed Buildings and Conservation Areas) Act 1990 and the NPPF.

Should the application be approved the use of dressed natural Bath Stone ashalr in construction must be secured by Condition, and the appearance of the roof terrace must be managed by Condition or covenant to restrict the placement of potted trees, parasols and drying washing, which would amount to visual clutter and have a harmful effect on the setting of the listed building.

14/04184/FUL – Hope House, The Royal High School, Lansdown Road, Lansdown, Bath.

Residential development for the erection of 54 no. dwellings, including the conversion of Hope House, and associated infrastructure and parking following demolition of existing school buildings. (Resubmission of 13/04235/FUL)

Comment

Overall the Bath Preservation Trust welcomes these proposals which on the whole respect the nature of the site they are to inhabit and gives a renewed use to Hope House.  We welcome the revision of this application, in that it omits the 4 no. dwellings in the lower section of the site; however, will still retain reservations on other elements of the proposed scheme, and therefore re-iterate our concerns as follows.

Upper site

The Trust is generally happy with the scale of development on the upper site, reserving its concerns for a few details that we believe would make the scheme more comfortable in the setting. We appreciate that the blocks seek not to be too intrusive above the wall to Lansdown Road, however, this loss of height has lead to some regrettable aesthetics.

We recognise that effort has been made to address concerns that the windows to a number of elevations are square rather than the Georgian rectangular which adds to the sense of the buildings being too short and top heavy.

We do not consider that the addition of ‘patio doors’ on the ground floor of Blocks A and B are improvements.

Block C

We maintain our main reservation which is that Block C does not successfully achieve the palatial aesthetic it has tried to because of the broken roofline. Either the lower level element should be removed, and/or the roofline stepped down to meet the lower level so that the ‘palace front’ appears symmetrical.

Alternatively we recommend considering two breaks in roofline instead of one as shown, opting for middling-better-class terrace stepping down hill, which we acknowledge will require on street parking.

We welcome the removal of the lower bay/’Round tower’ which appears to be omitted from block C, although one elevation drawing still includes it. This requires correction.

Exterior Alterations

The Trust feels strongly that Hope House should be left to stand alone, as it once did, and that the glass link to Block E should be omitted from the proposals. The design of the proposed link appears somewhat institutional. It is in the wrong idiom and is perhaps not contemporary enough to sit in an aesthetically pleasing contrast with Hope House. If there has to be a link here it ought to have a much lighter touch or be a more creative solution.

With regards to the conversion of Hope House itself, there is a lack of detail concerning the new windows. The existing windows are to be replaced with double glazing and traditional glazing bar patterns, but it was hard to find the relevant information about the existing windows, and whether the openings are to be altered. The application does not specify if the double glazing is to slim-line, which it ought to be. Linked to this, the mouldings for the joinery look reasonable, although rather early for the date of the building, particularly the glazing bar profiles. We would ask that this design approach is further justified before any permission is granted.

Landscaping

We repeat concerns about the limited detail of the landscape proposals and feel that more information is needed to understand the impact of the development on the landscape on the local and wider scale. We welcome the belated AVR report, but regret that there were no within site views re the impact upon Hope House or the retained parkland. Cross-sections across the proposed developed site, in particular illustrating the North-South section between boundary walls, and [a section depicting] the East-West section from the gate to the parkland to illustrate relative levels should be provided. The Submitted explanation and visualisation of the interrelationships within the site and contextually is still insufficient, but remains a requirement for proper consideration of the application.

We welcome the intention to retain the yew at the main entrance, but have doubts about   its survival, given the proximity of roots to building line. We would prefer that the replacement Thuja plicata near Hope House were an exact replacement for the ‘Japanese red cedar’ (T21) which will be lost nearby. The absence of any edible fruit trees within the grounds seems a missed opportunity.

We welcome the enhanced planting, in species, size & quantity, which is proposed for the area south of Block C towards St James Park. However it is not clear whether the drawing shows trees as planted (in which case not exactly dense clumps) or final numbers (in which case how many of each?).

On the hard landscaping, we would like to see further details of surfaces for pedestrian areas paths submitted. Furthermore we would encourage a continuous route from block A to inner site parkland views. Overall we regret that there is limited public access and through-routes within the site, and consider that a better connection with the townscape could be achieved by improving the permeability of the site. For example, there is still no pedestrian access from parkland and northern houses to Park Street Mews.

We note that the existing pedestrian gate onto Lansdown Road is to be closed and a convenient replacement provided under an arch; we doubt that the wall is sufficiently high for this to be practicable.

 

14/03869/AR – Wellsway Mini, Wellsway Garage, Lower Bristol Road, Bath.

Display of 1no. externally illuminated fascia sign, 1no. non-illuminated fascia sign, 1no. externally illuminated hanging sign, 1no. internally illuminated hanging sign, 6no. externally illuminated flags.

Object: Whilst we appreciate the applicant’s desire to promote their commercial interests, we will maintain our position in objecting to illuminated signs in the World Heritage Site and in the setting of the conservation area.  Many car dealerships have illuminated signs but these should not be a precedent for a low illuminated city like Bath.  Overhead street lighting should be sufficient to allow advertising to be seen on the site.  Additionally the amount of illuminated flags, aside from adding to the light levels, will add an unwelcome element of clutter to the street scene.

 

The proposed scheme, by virtue of the illuminated signs and flags, would be detrimental to the setting of the conservation area – in this gateway location – and the visual amenity value of the area, and neither preserve nor and enhance the character and appearance of the World Heritage Site.  The scheme would be contrary to Section 12 (Conserving and enhancing the historic environment) of the NPPF, policies; B1, B4 and CP6 of the B&NES Core Strategy and polices; D4 and BH 17 of the B&NES Saved Local Plan.  We would therefore recommend that the application be refused.

 

 

14/03970/FUL & 14/03971/LBA – Brasserie Blanc, Francis Hotel, 6-11 Queen Sq, Bath.

 

Remove soft landscaping, replace floor with hard standing paving and use of area for outdoor seating.

 

Comment:  This proposal is acceptable providing that it is strictly restricted to the amount of furniture as illustrated in the supporting documentation, as any more furniture would create visual clutter and therefore harm the amenity of the street scene and setting of listed buildings.  This is particularly important as the proposal site is located at an entrance to one of the most significant architectural compositions in the city.

 

 

 

 

 

 

 

 

14/03922/LBA – 8 Union Street, Bath.

 

External and internal alterations to include the repainting of shop front and fascia and the provision of new stairs, walls, door and cladding.

 

Comment:  Whilst we appreciate the applicant’s desire to have a distinctive front to their premises, high gloss paint is not in keeping with the traditional finishes that this designated building would have once had.  This block of buildings did have uniform frontages which were painted dark green, with discreet gold highlights.  A return to this consistent palette would enhance the ensemble of buildings and the street scene.

 

 

14/04091/FUL & 14/04092/LBA – 36 – 37 Milsom Street, City Centre, Bath.

 

Change of use of the ground floor to retail (Class A1), alterations to shop front and associated internal alterations.

 

Object:  We object to this proposal, as certain elements will harm the significance of this listed building.  The cutting down of the windows on the street elevation and the introduction of plain plate glass is unacceptable.  This approach detracts from the Georgian fenestration, proportions and aesthetic, which prevails in this significant setting.  This proposed work would destroy the coherence and balance of the elevation, harming the significance of the building and undermining the historic character of the street.

 

The proposed hanging sign is over-sized and is in a location where such signs are not currently prevalent.  We would suggest that the applicant should reduce the size of the sign and that it is hand-painted in a colour and finish that is in keeping with the traditional palette of the city.

 

The proposed scheme, by virtue of the works to the windows at the street elevation, would harm the significance of the designated heritage asset and would be detrimental to the setting of the conservation area – in this significant central location – and the visual amenity value of the area, and neither preserve nor and enhance the character and appearance of the World Heritage Site.  The scheme would be contrary to the Planning (Listed Buildings and Conservation Areas Act) 1990, Section 12 of the National Planning Policy Framework, Core Strategy policies DW1, B1, B2, B4 & CP6 and Saved Local Plan policies, D4, BH2 & BH6.  We would therefore recommend that the application be refused.

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