Apr – May 2014

2014 Weeks 16-20

15 April – 13 May 2014

Week 16

14/01216/AR – 10 St Lawrence St

Display of internally illuminated fascia and projecting signs.

OBJECT The Trust objects to illuminated signs on listed buildings and within the Conservation area and in the World Heritage Site. While the illuminated box itself is enough to be of detriment to the visual amenity value of the area, the signs, by virtue of the materials, colour, and position are incongruous. The application therefore fails to comply with Local Plan Policies BH6, BH17 and BH19, the Planning (Listed Buildings & Conservation Areas) Act 1990 and Section 12 Conserving & Enhancing the Historic Environment of the NPPF and should be refused.


14/01234/LBA – Champneys, 20 New Bond Street

Internal and external alterations for the refurbishment of shop and provision of new shop front signage

OBJECT We regret that works have be undertaken prior to obtaining listed building consent. The hand painted signage is considered sensitive to the character of the building and its surroundings. However, the Trust objects to illuminated signs on listed buildings and within the Bath Conservation area and World Heritage Site. The light fittings are detrimental to the special architectural interest and appearance of the listed building and harm the visual amenity value of the conservation area.

The application therefore fails to comply with Local Plan Policies BH2, BH6, BH17 and BH19, the Planning (Listed Buildings & Conservation Areas) Act 1990 and Section 12 Conserving & Enhancing the Historic Environment of the NPPF and should be refused.


14/01381/AR – 37-39 Stall Street – Primark

Display of 1no. non illuminated fascia sign above entrance, 2no. external period lights to match existing, replacement of 4no. timber hanging signs and internal seasonal light boxes on rear wall of window displays

OBJECT The Trust objects to the proposed light boxes. This means of illumination is unacceptable on this significant listed building in the heart of the Conservation Area and World Heritage Site. The illumination itself is enough to be of detriment to the visual amenity value of the area.  The proposed illumination would harm the special character of this Grade I listed building and is totally inappropriate. The application therefore fails to comply with Local Plan Policies BH2, BH6, BH17 and BH19, the Planning (Listed Buildings & Conservation Areas) Act 1990 and Section 12 Conserving & Enhancing the Historic Environment of the NPPF and should be refused.


14/01124/FUL – Parcel 2866, Woolley Lane, Charlcombe, Bath, Bath And North East Somerset

Erection of 2 Mobile Sheep Shelters

OBJECT Bath Preservation objects to application submitted on behalf of Golden Valley Paddocks. This application should also be viewed in the context of the planning history of the site. The addition of mobile field shelters would result in further accumulative harm to the special character of the AONB, the special character of which contributes significantly to the wider landscape setting of the World Heritage site, which is of Outstanding Universal Value. In our view the size, siting, design and appearance of the field shelters amount to inappropriate development and visually intrusive development in this sensitive location contrary to policies BH1, GB.2 and NE.2.

In conclusion, the development individually and collectively represents an inappropriate development in the Green Belt, the appearance of which individually and collectively detract from the openness of the greenbelt and adversely affects the natural beauty and character of the AONB and the landscape setting of the World Heritage Site. The proposal is therefore contrary to Policies NE1, NE2, GB1, GB2 and BH1 of the B&NES Local Plan and guidance contained within the NPPF and should be REFUSED.


14/01245/FUL – Field Between City Farm And Cotswold View, The Hollow, Southdown, Bath, Bath And North East Somerset

Erection of 1.8m high fence (Retrospective)

OBJECT The Trust regrets that the application is made in retrospect. Work has been undertaken without due regard for the planning application process, which exists to protect the City of Bath World Heritage Site from inappropriate developments which harm the special character of the city and its landscape setting.

The timber fence which has been erected is too high and is visually intrusive into the view of the surrounding hillsides from The Hollow. By virtue of the material, construction and solidity it jars with the hedgerow boundary treatment and verdant character of the area.

In the interest of maintaining the visual amenity value of the street scene and special qualities of the WHS and its landscape setting the appropriate solution here would be the continuation of a low fence and a planted hedgerow, as is exists further along and adjoining the fence.

The proposal fails to enhance the character of the public realm, respond to the local context, or enhance the surroundings and is therefore contrary to Local Plan Policies D2, D4, and BH1, and the Planning (Listed Buildings & Conservation Areas) Act 1990, and Section 12, Conserving & Enhancing the Historic Environment of the NPPF. The application should therefore be REFUSED and appropriate enforcement action taken to remedy the breach in planning regulations and reach an acceptable solution.


14/01392/FUL – Octagon Hall, 25 Milsom Place, City Centre   

Use of levels 02 – 05 of the building for A1 retail and/or A3 restaurant use (Resubmission).

COMMENT Bath Preservation Trust requests that if the case officer is minded to permit this change of use, that an informative condition be attached to the permission if stating that although the change of use is granted, a listed building application will be required for any works and that the change of use does not guarantee consent of a listed building application.


14/01407/FUL – 1 St James’s Park, Lansdown

Erection of part single storey and part two storey rear extension, addition of rear dormer window, repositioning and addition of roof lights to front elevation, internal alterations, external works, including works to boundaries and alterations to front garden to provide much improved disabled access.

COMMENT Whilst the proposed extension is large it is of a sympathetic style and matching materials. It is considered that there will not be any harm to the conservation area providing that proposed new stone boundary walls use natural stone in a traditional lay. We would ask that the use of natural stone is clarified prior to permission and not by way of condition.


Week 17

14/01403/FUL – The Rectory, Anchor Lane, Combe Hay, Bath, Bath & North East Somerset, BA2 7EG

Erection of garage with staff accommodation and extension of the curtilage of the Old Rectory. (Resubmission).

OBJECT The Trust objects in principle to land use of the Green Belt and AONB for inappropriate development especially in the absence of ‘very special circumstances’ relevant to planning policy. In considering the Trust’s position on this we can think of only one exception but in that case there was substantial benefit to the local community.

Para 88, Section 9 ‘ Protecting Green Belt Land’ of the NPPF states that ‘When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.’

We do not consider that this proposal for a garage and staff accommodation in the Green Belt is made with exceptional or meritable circumstances and there is no obvious public benefit to outweigh the harm of the proposals. We note also that the land lies outside the Parish Development boundary.

Furthermore, the style and use of the new building are not named in the exempt development types as outlined in in Para 89, Section 9 of the NPPF. This inappropriate development would cause harm to the openness and character of the Green Belt, and is therefore contrary to Section 9 ‘Protecting Green Belt Land’ of the NPPF and Local Plan policies GB.1 and GB.2.


14/01271/FUL & 14/01272/LBA – Carfax Hotel, 13 – 15 Great Pulteney Street, Bathwick, Bath, Bath, BA2 4BS

Refurbishment and extension of the existing hotel. Reverse much of the previous damaging interventions, particularly the removal of utilitarian fire partitioning screens, fire doors and stair enclosures. Reinstatement of previous entrance to No 15 Great Pulteney Street, and dining room extension to the rear of the property. Change of use to the existing coach house from the previous managers residential accommodation to hotel use.

OBJECTION Whilst we generally welcome the intention to improve the hotel we have serious concerns about three elements of this application;

1. Rear extension

2. Air conditioning

3. Flood lighting to front elevation

4. Partial reinstatement of street entrances

Rear extension

Great Pulteney Street is comprised of tall terraced houses with long thin gardens which provide a verdant setting proportionate to the grand scale of the houses.  The garden setting is integral to the historic, architectural and aesthetic significance of the Street and ought to be preserved and enhanced as positive elements  of the Bath Conservation Area.

Whilst we do not object to the principle of a contemporary intervention, which minimises any harm to the listed buildings, we do not consider that an extension of the size and form proposed is at all appropriate.

We consider that there is some merit in infilling the external ‘dead’ space between  the existing buildings and connecting it to the use of the hotel.  However, we find that the width and depth of the extension is overly large and squat and would introduce an inappropriate horizontal emphasis to the rear of these tall and elegant buildings. By spanning the width of two buildings this extension would severely detract from the character and appearance of the individual buildings. Any (small) extension here should attempt to reflect the linear form of the houses, maintain the sense of separate plots and pattern of the street and retain and strengthen the character of the garden setting.

We consider that the size, form and scale of the proposed extension would be harmful to the character and significance of the Grade I listed buildings and their setting, would fail to preserve the special qualities of the World Heritage Site, and would neither preserve nor enhance  the character and appearance of the Conservation Area.

Air Conditioning

We are not convinced that air conditioning is necessary and would therefore cause unjustified harm to historic fabric.

External flood lighting 

Great Pulteney Street is a residential street and the external illumination of houses is inappropriate. Bath is a city which is low luminous in character and should be preserved as such.  Flood lighting the front elevation of the hotel buildings would harm the group value and setting of Great Pulteney Street. Furthermore illuminating  the facades would detract from the traditional means of external illumination provided by the existing and restored over throws and lanterns and would detract from this subtle historic lighting and ambience it creates.

Partial reinstatement of street entrances

We would welcome the complete reinstatement of appropriate entrance doors to both No. 13 and 15. This would restore the appearance of the houses and unify the terrace.

For the reasons stated above this proposal would cause unjustified harm to the grade I listed buildings, fails to respond to the local context or enhance the character of Bath and is contrary to Local Plan policies BH1, BH2, BH6, D2, D4,  Sections 7 and 12, Conserving & Enhancing the Historic Environment of the NPPF and the Planning (Listed Buildings & Conservation Areas) Act 1990, and should therefore be REFUSED.


14/01319/FUL – Candywood Leys, Meadow Lane, Bathampton, Bath BA2 6SN

Erection of hay/mower shelter, cattle stall, solar rig, chemicals and sundries store, composting toilet, log store.

COMMENT As these buildings are related to the use of the wider site by a traveller family seeking to live by sustainable means, and as the location of these buildings in the Green Belt in the long term is undesirable, we ask that if the case officer is minded to permit, that the permission is subject to a condition that the development shall ensure only for the benefit of the applicant as per Condition 2 of the related permission for the mobile home (ref: 13/02745/FUL). This condition should ensure that the buildings are ancillary to the approved dwelling.


14/01491/FUL  – Public Toilets  Sydney Gardens Sydney Place Bathwick

Change of use of Public Convenience (Sui Generis) to Office space (Use Class B1) with associated Public Convenience (Sui Generis) and associated external alterations

OBJECT The existing toilet provision is a necessary amenity of Sydney Gardens and ought to be retained. The design and appearance of this building is an important consideration given that it is sited within a registered park and garden forming the setting to a Grade I listed building. The proposed alterations are wholly unsympathetic and utilitarian which will destroy the symmetry of modest little ‘lodge’ on its front elevation and sides. The materials and finishes for ‘joinery’ are unspecified, proportions clunky, and roller shutters hostile. For the reasons stated above this proposal fails to respond to the local context or enhance the character of Bath and is contrary to Local Plan policies BH1, BH2, BH6, D2, D4,  Sections 7 and 12, Conserving & Enhancing the Historic Environment of the NPPF and the Planning (Listed Buildings & Conservation Areas) Act 1990, and should therefore be REFUSED.


14/01492/FUL – Public Toilets, Charlotte Street Car Park, City Centre, Bath,

Change of use of Public Convenience (Sui Generis) to 53 sq m of Car Valeting (Use Class B1) with associated Public Convenience (Sui Generis) and associated external alterations.

COMMENT This application is lacking in detail and the design approach is poor quality. Shutters aren’t shown, the arrangement of doors fights the overall composition of the building. Furthermore there is no information pertaining the use of the car wash. We encourage the applicant to review and improve this proposal.


Week 18

14/01587/AR – Paperchase 31 Milsom Street City Centre Bath Bath And North East Somerset

Display of 1no. internally illuminated fascia sign

OBJECT The Trust objects to illuminated signs within the Conservation area and in the World Heritage Site. While the amount of illumination is, in itself, enough to be of detriment to the visual amenity of the area, the signs, by virtue of the stainless steel material and offset fixing are incongruous. Steel is not a material which is sensitive or appropriate upon a historic shopfront and a listed building and it opposes the traditional palette of Bath. Whilst the current signage is of a similar nature it is regrettable that the opportunity to enhance and restore the aesthetic of this traditional shopfront has not been taken. The application therefore fails to comply with Local Plan Policies BH2, BH17 and BH19, the Planning (Listed Buildings & Conservation Areas) Act 1990 and Section 12 Conserving & Enhancing the Historic Environment of the NPPF and should be REFUSED.


14/01652/FUL & 14/01653/LBA – Horseshoe House 51 Sydney Buildings Bathwick Bath Bath And North East Somerset

Erection of two storey replacement side extension (garage with bedroom over) following

demolition of single storey side extension (garage) – (Resubmission).

OBJECT This application is identical to the proposal previously submitted, except for the dormer window which we are pleased remains omitted from the scheme. The Trust objected to that scheme, which was not looked on favourably by the Local Planning Authority. The Trust continues to strongly object and our reasons are repeated:

Bath Preservation Trust continues to object to this scheme as in relation to the previous submission for a two storey extension on this property, very little has been altered and no real attempt has been made materially to change the scheme. The overall design is still not taking its cue from the existing building and terrace, and rather superimposes its own proportions and plan; for example the horizontals of the extension do not relate to the historic horizontal lines and look like a mis-statement. The principle of making a 21st century statement is understandable and can be laudable, but not if, as in this case, the design of a subservient feature is so aggressively unsympathetic that it devalues the visual amenity of both the main structure and its group value. Furthermore, due to this site’s prominent position, we have concerns about the impact of the long site lines from the National Trust land above and the canal below onto this development. The deliberate asymmetry in design contradicts the classical tradition of Bath, and aluminium is a material alien to the city’s palette. The cornice and string course of the new extension do not align comfortably with those of the main house, and the window is disproportionately large.

The proposal remains in conflict with Section 12 ‘Conserving and Enhancing the Historic Environment’ as well as Local Plan policies, D.2, D.4, BH.1, BH.2 and BH.6 and should therefore be REFUSED.


14/01093/LBA – 9 Somerset Place Lansdown Bath Bath And North East Somerset BA1 5AD

Internal and external alterations including the lowering of 1st floor window sills, replacement

6 over 9 sash windows and balconettes, reinstatement of original internal arch openings onground and first floor and replacement dado to first floor landing.

OBJECT Bath Preservation Trust recognises that evidence provided within this application demonstrates that the infill fabric is relatively modern and that the level of the cills has been lowered in the past and raised to the current position.  However, we consider that the existing height presents the historically correct design which ought to be retained in the interest of the integrity and authenticity of the listed building. We draw attention to the fact that BPT obtained listed building consent to raise the cills to No.1 Royal Crescent to restore the original design and proportions of the building. At Somerset Place many houses have their cills at the original height, including the central pair therefore the uniformity argument isn’t well justified. It seems unreasonable to revert to a precedent which in itself is an alteration of the original building. The proposed alteration is considered to be detrimental to the special architectural and historic interest of the listed building, the setting of adjacent listed buildings and the conservation area. This application therefore, fails to comply with the Planning (Listed Buildings & Conservation Areas) Act 1990, Section 12 ‘Conserving & Enhancing the Historic Environment’ of the NPPF and Local Plan Policies BH2, BH6 and BH17 and should be REFUSED.


14/01620/FUL – Flat 1 8 Walcot Terrace Walcot Bath Bath And North East Somerset.

Conversion of a two level-flat into two separate self contained dwellings including erection of single storey extension at rear of property.

COMMENT Bath Preservation Trust considers that the principle of the extension sounds acceptable, and there is little or no further loss of historic fabric or plan. However, the proposal needs better drawings and more detail to enable proper consideration of the impact  – the elevation drawings are simply outlines, and there is only a photograph of another extension elsewhere given as a suggestion of the design. The door drawings are labelled “proposed typical” and the mouldings “ogee profile or similar” which is not definitive. The date of external rear door is not given – if original, thought should be given to its retention. Furthermore, the materials to be used are entirely unspecified and only described as ‘reclaimed materials, matching materials and approved materials where required’. As such the materials need to be clarified prior to determination and not secured by way of condition to ensure that the integrity of this listed building is preserved and enhanced.


Week 19

14/00772/LBA – 23 Broad Street City Centre.

External alterations for the display of new signage

OBJECT The Trust welcomes non-illuminated signage on listed buildings within the conservation area and world heritage site. However, the amount of advertising as proposed is considered to be excessive and adds unnecessary clutter to the detriment of the visual amenity of the street scene. Furthermore, the materials proposed oppose the traditional palatte of Bath and are inappropriate upon a listed building. The application therefore, fails to comply with Local Plan policies BH.2, BH.6 and BH.17, the Planning (Listed Building and Conservation Areas) Act 1990 and Section 12 ‘Conserving and Enhancing the Historic Environment’ of the NPPF and should be REFUSED.


14/01607/AR – 4 Abbey Street, City Centre.

Display of 1No fascia sign, 1No non-illuminated hanging sign and 1No internal blinds with logo

OBJECT Bath Preservation Trust objects in principle to the proposal for a hanging sign in this location and considers that the commercialisation of this location should be strongly resisted and the residential character of this area of the conservation area preserved. The paucity of detail for the hanging sign should in itself be regarded as reason enough for determination against this element of the proposals. We also object to the Perspex material as it opposes the traditional palette of materials in Bath and is inappropriate upon a listed building. The size of the proposed lettering on the blinds is also considered to be inappropriate and should be reduced. Overall the proposals contained within this application will have a detrimental impact on the character and visual amenity of the street scene and therefore they do not comply with S16 and S72 of the Planning (Listed Buildings & Conservation Areas Act) 1990, Section 12 of the NPPF and Local Plan Policies BH.2 and BH.6 and should be REFUSED.


14/01738/AR – 23 Milsom Street, City Centre,

Display of 1no. replacement panels to existing projecting sign 700 x 754mm, 1no. new d/s projecting sign with internal illumination 700 x 754mm, 1no. A3 portrait brass menu case on black back tray 480 x 810mm and 1no. brass engraved plaque

OBJECT The hanging sign specifically excluded in previous consent – should be upheld. Following earlier objections, the existing new signage showed admirable restraint when installed, and this further application should be resisted. Illumination and materials are unacceptable, as is the proposal to affix a menu box to the historic stonework. The menu box, together with the proposed over-large new hanging sign and the brass plaque on the door will increase street clutter, detract from the ambience of Milsom Street, and damage the historic fabric and character of the building by reducing the coherence and intrinsic strength of design of this elevation. Overall the proposals contained within this application will have a detrimental impact on the character and visual amenity of the street scene and therefore they do not comply with S16 and S72 of the Planning (Listed Buildings & Conservation Areas Act) 1990, Section 12 of the NPPF and Local Plan Policies BH.2 and BH.6 and should be REFUSED.


Week 20

14/01476/LBA – KC Change 13 Abbey Church Yard, Bath

Alterations to shop front

OBJECT In the interested of preserving and enhancing the character and appearance of the building and its setting, a plain canvas material for the awning blind would be more appropriate than acrylic covered in logos. We are particularly concerned about the approach to re-decoration. Paint colours and finishes have not been sufficiently specified and samples have not been provided. We would expect to see a full and detailed specification for redecoration submitted for consideration prior to any approval of this application. This important detail should not be agreed by Condition. We object to this proposal in its current form and would encourage the applicants to amend their proposals accordingly.


14/01830/LBA – Jollys of Bath

Internal alterations for the replacement of the internal staircase.

COMMENT We recognise that the internal timber staircase is a modern intervention. The design is of its time and there will be many customers who will be sad to this familiar feature go.  Indeed some of our members have already expressed concerns to BPT. We are interested to know what style of staircase may have existed before, it could be assumed the original late 19 century staircase would have been rather grand and swept shoppers upwards on a highly polished handrail.

The new neo-Georgian stone staircase looks good but the ethos of the store – albeit cluttered and badly laid out – is very much late 19th century art nouveau, not Georgian. The store retains some wonderful pieces from that era, such as the peacock frieze and the ornate store entrance.

If stone is too be used we would encourage the use of natural limestone in the construction of the staircase.


14/01838/LBA – Rickards of Bath , 11 Northumberland Place, Bath

Internal and external works including insertion of door to modern shop front and installation of demountable partitions and basins to upper floors to form treatment rooms ancillary to ground floor shop.

COMMENT The proposed new door is in a modern shop front, and the design looks appropriate, however more design detail would be helpful.


14/01764/LBA – 26 Queen Square plaque

External alterations for the display of 1No company plaque

COMMENT This proposal to instal yet another plaque would cause further damage to this significant listed building. The commercially driven and essentially ephemeral nature of these constantly changing plates and plaques and the damage they cause to the stone is simply unacceptable. Detailed design guidance for advertising on highly significant groups of listed buildings such as Queen Square would be helpful.


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

Full planning permission sought for the erection of 180 residential units (Use Class C3), a neighbourhood retail store of up to 306 sqm GIA (Use Class A1), associated highways works, infrastructure and public open space. Outline planning permission sought for a 60 bed Extra Care Facility (Use Class C3).

OBJECTION BPT welcomes the principle of development of housing on the former MOD site on grounds that is a way of meeting some of the City’s housing need on a brownfield site, and that it offers potential for enhancement of a currently unappealing, though relatively unobtrusive, site.  In responding to consultations on Concept Statements for the site our concerns related to the layout, density, height and design of the development and the impact of development on setting and views of heritage assets, in particular Grade I listed Beckford’s Tower and the city of Bath World Heritage Site. Where possible we seek to support the development of the site for housing, and enhance development proposals for this site. To achieve this end it is essential that BPT challenges aspects of these proposals that lack clarity or would potentially allow detrimental development in the city of Bath.

Note: Bath Preservation Trust is sole trustee of the Beckford Tower Trust and therefore has a specific interest in this site in addition to our general charitable remit.

Impact Assessments

First we must correct inaccuracies and inconsistencies within the supporting documentation (EIS and ES) so therefore they have not been properly taken into account in the Design & Access Statement/Heritage Impact Assessment.

In EIA and ES Lansdown cemetery is referred to as deconsecrated.  It is not.  Much of it is occupied by historic burials but the cemetery but still consecrated and at its far end still in use for new burials.  There has therefore been no assessment of it as a consecrated space, still regularly visited by bereaved relatives and descendants, and the significant increase in negative impact the proposed development will have in contrast to the relatively low negative impact the MOD occupation of the site has had on this quiet space for contemplation has not been considered at all.

The gateway to Beckford’s Tower and walls flanking the gateway, have not been identified as a heritage asset – the gateway is listed grade II* in its own right, and is a separate heritage asset.

Also there is no mention of Lansdown Road as a significant route between Bath and Gloucester, another Roman city, where there is likely to be significant archaeology/potential Roman roadside burials.

An application for a proposal of this scale within a World Heritage ought to be supported by a proper Heritage Impact Assessment rather than have parts embedded in the D&A.

We feel that the significance of the Grade I listed Beckford’s Tower and its setting, and the harm the proposed development will cause to it, has therefore not been adequately considered in accordance with paragraphs132-134 of the NPPF which state that substantial harm to the significance of a designated heritage asset can be caused by development within the setting of that asset, and that any harm should require clear and convincing justification.  The NPPG  (para 019) highlights  that ‘studies [of heritage assets and their settings]  can reveal alternative development options, for example more sensitive designs or different orientations, that will deliver public benefits in a more sustainable and appropriate way’. The duty to heritage assets is to ‘protect and where possible enhance’ as well as the avoidance of harm. Substantial harm to heritage assets of the highest significance, notably grade I and II* listed buildings, such as Beckford’s Tower and Lansdown Cemetery Gateway, should be wholly exceptional.  We refer in particular to East Northamptonshire Council v. Secretary of State ex parte Barnwell Manor Wind Energy Ltd on the issue of damage to the setting of a heritage asset.

Proposed Building Layout and Views 

We regret that the layout of the site, the axis of roads and creation of vistas fails to take account of views of Beckford’s Tower. We would encourage a layout which better reveals the significance of this important heritage asset.

The EIA (8.0 MITIGATION AND ASSESSMENT OF RESIDUAL LANDSCAPE IMPACTS, Historic buildings and spaces 8.1) states “Positive relationships are maintained with adjoining historic buildings and spaces, including visual connections from within the Site which are made with the local landmark of Beckford’s Tower.”  This is repeated in the D&A Statement page 28.

We do not consider that this has been successfully achieved. There is no single clear view to the Tower from the site and are very few views of the Tower at all, only the ‘glimpses’ noted in the D&A Statement.  We question why the Tower has not been used as a focal point for a view/vista down a street or across the open space.  The view of the Tower would be almost entirely blocked from the site by the bulk and height of the care home facility and the adjacent tall dwellings.

Page 28 of the D&A statement states “the distribution (of housing) seeks to maintain views through the site”, however lack of open space between built forms prevents this.

ES 4.3.25 and D&A Page 14 state that central green space is a “focal point in the development from which glimpsed views of the top of Beckford’s Tower can be seen.”  This glimpsed view is not good enough.

The complete enclosure of open space by 3-storey buildings does not offer any clear view of Beckford’s Tower.  The layout of the site should offer at least some full views of the Tower and surrounding landscape, not just glimpses of the very top. In particular the play area should have a clear view of the Tower.

The orientation of buildings to allow future solar technologies is welcome.

The almost ubiquitous presence of single storey garages set between the several forms of houses creates a continuous bulk of buildings which again creates a barrier to through views. We would prefer to see the provision for parking integrated within gardens, perhaps below ground with gardens or green space on top rather than the provision of intrusive single storey garage blocks.

Permanent negative impact on Views from and to Beckford’s Tower

The EIA states that the mitigation for the permanent negative impact the development will have on Beckford’s Tower and cemetery is the ‘provision of open space between built forms’.  While the central open space and the street layout is no doubt an attempt to meet this, the continuous bulk of built form remains apparent due to the minimal amount of open space between plots and therefore does not adequately address or mitigate this issue.  Linden homes section RR with plots 126-111 clearly shows that this central open space will be largely indecipherable when viewed from Beckford’s Tower due to the height of the proposed buildings on those plots (Linden type). Similarly, the minimal open space between built forms, that is apparent on sections RR, is also an issue on Bloor homes section AA plots 85-102(Bloor type 5).  The presence of garages set between the houses creates a continuous bulk of buildings that creates a barrier to any through views both to and from the central open space.

Page 6 of the Environmental Statement states “The completed development will bring largely positive effects in respect of the heritage assets close to the site with a moderate negative effect on views towards the site from Lansdown Cemetery, becoming slight negative as the proposed tree planting matures.”

The Statement fails to mention any negative effects on Beckford’s Tower.

The Statement continues to state that “The cumulative effect of the development proposal for the Site combination with other adjacent development permitted on  Granville Road, has been considered and it is concluded that this does not materially alter the assessed environmental effects in respect of heritage assets as outlined above”.

We disagree – the proposed development proposals will permanently affect Beckford’s Tower.

We also note that Verified View no.8 (from road near Beville Grenville’s monument) is not provided. This is a critical long view from that direction and shows the rural entry to the city. Furthermore there is no assessment of the view from the A46.


We find the overall approach to the design aesthetic rather muddled – it cannott decide whether it is urban or rural. In the attempt to be more Cotswold in character, as imagery and supporting statement suggests, the development ought to be more rural looking and less urban. Leaning towards an urban idiom is inappropriate in this location.

The three-storey ‘villas’ around the central space look nothing like the villa styles of the Lansdown slopes and due to the repetition of the same unit type appear more like townhouse terraces, which are not characteristic of Lansdown.

Lack of sections makes assessment of the houses difficult, especially understanding internal reasoning for such height. The roof space appears to add an extra storey to the already 3-storey form. 

In view of the closeness of many of the houses and their built-in rooms in roofs & rear extensions, we would expect that, if permission were to be granted, it would include removal of PD rights. This needs to be clarified.

The B&NES Concept Statement for the site suggests that the housing should be built to achieve Code Level 4/5 (Code for Sustainable Homes) therefore it is very disappointing that the development only seeks to achieve level 3, which is contrary to the Statement and to the aspirations of the draft Core Strategy. Regrettably, the application also fails to allow space for self-build & innovative technology e.g.Codes 5-6; this is again contrary to the Concept Statement which suggests 10%.


The recommendations made in Nicholas Pearson Associates report (Ensleigh MOD Site, Bath MOD Site Concept Statement: Evidence Base – Landscape & Visual Appraisal February 2012) are repeated within the B&NES MOD Site Concept Statements. Both state that the building height should not exceed the prevailing building height in the area and that it may be necessary for the height to be less than shoulder height of nearby buildings (1-2 storeys) to prevent intrusion into views.

Furthermore, Bath Building Heights Strategy (September 2010) refers to the appropriate height for Zone 5 as 2-storey with

  • ‘One additional setback storey generally acceptable’;
  • ‘One additional storey could be acceptable where it aids legibility, for example local centres, creates better enclosure or provides regeneration benefits and does not intrude into views onto the plateaux by exceeding the height of the tree cover.’

At least half of the proposed development is above this height, with little or no stepping back at third storey. The extra height results in many house types appearing mean – they have narrow width and reduced proportions.

Tall 3-storey narrow gable-to-road houses have been placed at the edges of the site, whereas in D&A statement 3-storeys are shown around central public open space, with lower roof heights (2-3- & 2-storeys) toward edges.  However the height map and scale map are conflicting.

It is regrettable that the height of 3-storeys has been introduced along Granville Road. We do not consider that buildings predominantly taller than two storeys from street level connect comfortably with the pattern of residential development in this peripheral part of the World Heritage Site. The Granville Road houses have already seriously compromised distant views across to the wooded plateau from the A36 and A46 and should not therefore be taken as a model for development.

A variety of buildings heights along street frontages would be more appropriate than a long run of one height which creates the appearance of a block of built form (rather than individual buildings or villas) such as can be seen on section RR. The appearance of individual buildings would be more akin to both Lansdown’s villas and the Cotswold’s  rural character.


We acknowledge that the materials specified throughout the site attempt to reflect and harmonise with the character of Bath and its setting. However, the specification for materials needs clarification and agreement within the planning application rather than by Condition.

It must be made clear before the application is determined whether Bath stone rubble/ashlar is natural or reconstituted. Reconstituted stone is NOT acceptable on this site in the World Heritage Site, as evidenced in the recent planning appeal against Gibbs Mews. Roofing materials appear not to have been specified. There is no case for the use of artificial materials. All roofing materials across the site ought to be natural slate or clay pantiles. In addition, any rubblestone should take the form of Bath blocks not Cotswold slates, whether used in houses or landcaping.

Across the site there is not enough use of natural Bath stone, and too much use of render. We regret the use of a ‘pale’ colour render – this will be very visible from Beckford’s Tower in views across the World Heritage Site. A darker stone colour maybe more suitable for any rendered surfaces. We do not consider that coloured wall surfaces (green or blue) are appropriate. In addition we would seek reassurances that the approved colour of any rendered surfaces will be maintained and controlled by the removal of permitted development rights.

The use of natural traditional materials throughout the development will help to integrate the development with its context and reinforce local distinctiveness and must be required at this stage, before permission is granted.

Visual interest would be added to otherwise bland roofscapes by the provision of chimneys which serve a purpose (ventilation). It is not clear why some larger properties have small stacks while others do not, nor of the purpose of these stacks.

For Bloor units there is no indication of what colour or material windows will be so we cannot visualise the ‘panels and posts’ where it is noted they will match the window material and colour. This requires more detail.

For all type 7s the specification of opaque panels requires elaboration on detail, e.g. colour, and the reconstituted stone specified is not acceptable.

In addition the importance of detailing and workmanship requires emphasis if the World Heritage Site’s Outstanding Universal Values are to be respected.

The Shop

The shop forms the gateway to the development and it situated essentially at what is the gateway to the WHS. Development in this location needs to be of the highest standard of architectural design, which accords with the style and detailing within rest of the site and served as an appropriate introduction to the City.  The proposed design is far from this.

We find the design uninspiring and bland, and its materials inappropriate. This proposed building fails to reflect or enhance the local distinctiveness of Bath and its environs, especially in the use of non-local timber cladding. There is too much glass with shop windows and glass balustrading. The retail nature of the shop will be very visible from road due to large glass windows in front and side elevations.  This will be even more apparent after dark when the interior of the shop will be illuminated.  This new and intrusive commercial use will detract from the landscape nature of the area and cause harm to this area of the WHS where there is no precedent for highly visible commercial use at City gateways. Furthermore we oppose the use of illuminated signage in this sensitive location.

There has been no attempt to evaluate the impact of having a shop opposite Lansdown Cemetery which is still in use as a place of quiet contemplation and retreat.

The view from Beckford’s Tower will have direct sight of the shop. The inappropriate design, materials and commercial nature of the building will have a permanent negative impact on the setting of the Tower and the special qualities of the Bath World Heritage Setting.

Extra Care Unit

Whilst this building is indicative and will be subject to a later detailed planning application we must take this opportunity to raise the following points in response to the details which have been presented within this application.

The overall bulk and massing of this building is of concern and a different approach could better connect with the rest of the site and views of Beckford’s Tower. As shown, albeit in outline, it places a monolithic and large plain roof-scape on the edge of the site. We would prefer the design approach to take the form of a collection of buildings rather than a large building. There also needs to be greater clarity about the number of storeys and, particularly, the ridge heights, as there is conflicting information in the D&A statement text and plans.


We regret that there is no provision for allotments, as is set out in the B&NES Concept Statement for the site, and wonder whether the proposed community gardens are really adequate substitutes.

The central green spine and ‘pocket parks’ and ‘communal gardens’ are all good for allowing residents to meet, as well as for lightening dense built development. Planting appears generally appropriate; however, the play area equipment appears rather mass-produced.

We are concerned that the creation  of the central green space – formal garden, children’s play area & ‘village green’ – which will form a natural social space for residents – will be delayed due to its location along the boundary of, or within, the retained MoD land which is to be developed in Phase 3, thus prejudicing community cohesion.

We welcome the reinforcement planting along Lansdown Rd, strengthening boulevard character and masking the shop from south travelling cars on Lansdown Road (but not from top of Beckford’s Tower), also along N & W boundaries and strategically along Granville Rd. Early planting will be required to mitigate initial visibility, especially along ECH site (as VVM1a demonstrates).

We welcome retention of existing significant trees on site and would encourage the provision of more street trees. However, we query the use of “forest scale”or “parkland” trees in private gardens. Where strategic trees are provided in gardens some means of ensuring their permanent retention is required.

Lower level street planting is also welcome but its precise detail, in particular the hierarchy of hedges and their application along Lansdown Road, is not presently clear from the drawings. Consequently, it is difficult to envisage this important ‘first view’ of Ensleigh when coming from town.

With regard to boundary treatments the park estate rail fencing run into reconstructed stone gate way piers (at a scale to reflect the hierarchy of the route) . This should not be reconstructed stone and there should be natural stone boundary walls. (see Materials above).

Photos are shown of dry stone walls – i.e. not mortared, and these are described elsewhere as random rubble walling. This walling is shown in pictures with flat coping stones, on top of which is soldier stone capping (or rubble-on-edge coping as they describe it), which defeats the object. It would appear that dry stone walling techniques are not understood. If the soldier stones are just on top of a flat coping stone they would presumably have to be concrete-mortared in place. More, and more appropriate, detailing is required.


The Bath World Heritage site is a low luminosity city and development ought to respect this feature of the historic city and its setting. The Design and Access Statement is a bit thin on detail about lighting strategy apart from the statement in Part 2,   P41.  “Street lighting will include good practice measures to limit potential light spill and sky glow to Bath and North East Somerset current specification and 3 new columns are focused at the new Lansdown junction.”

There is no statement about the ILP Environmental Zone.  One might expect E3, but since the site is on the edge of the World Heritage Site and in close proximity to the Cotswolds AONB, the next lower Zone E2 would be more appropriate.

The Proposed Street Lighting Plan L256/35 and Lighting Lux Plan L256/36 does not declare the BS13201 class designed for, but it appears to provide an acceptable illumination and the dimming proposals are welcome. The Philips Iridium luminaries have zero upward light and are designed to be and must be installed without tilt to reduce light spill.


Whilst BPT does not usually comment in detail on transport matters, we feel the need to mention the following:

Road traffic generation figures will clearly exacerbate the already difficult peak hour conditions at Lansdown Road/Richmond Road (St Stephen’s church) junction, yet apparently no mitigation contribution is considered necessary as the problem already exists (though to a lesser, more tolerable, extent). The similar problem at the A420/Freezing/Tog Hill junction is not even mentioned, though commuting via M4 is envisaged. This is already a dangerous as well as congested junction and more thought needs to be applied as to how this will be made safe in practice.

Only the Park & Ride buses provide an adequate service into Bath. The sole suitable direct bus connection for rail commuters is the 7.30am no.2.


It is with regret that BPT OBJECTS to this planning application in its current form. The layout, design, height, appearance and materials fails to reinforce local distinctiveness and complement its surroundings and thus would substantially harm the special qualities of the City of Bath World Heritage Site, and substantially harm the significance and setting of Beckford’s Tower.

The proposal therefore fails to comply with sections 7, 9, 11 and 12 of the NPPF, NPPG and B&NES Local Plan Policies D2, D4, BH1, and BH2.


14/02005/ERES – Western Riverside Development Area, Midland Road, Twerton, Bath

Approval of reserved matters with regard to outline application 06/01733/EOUT for the erection of 97 residential dwellings (blocks B5 and B16), 750m2 of ground floor commercial uses, erection of bin and cycle stores, plant, and associated landscaping works

OBJECT In objecting to this application we nevertheless think that there are many aspects of the design, and the process by which it was reached, which are to be commended. The purpose of our objection is to reiterate our concerns about height and to request absolute clarity as to what is envisaged before any permission is granted; and also to encourage the LPA to address in detail the points made below about quality of delivery through to and after construction. If these were to be addressed during the development control process prior to approval, we would be happy to reconsider the detail of our objection.

We recognise that the design is based on thorough study of the local context and Bath’s special character and on the importance of reflecting & enhancing these parameters in these very visible buildings. We believe that the aerial view shows these buildings as more responsive to their setting (with the exception of their overall height) in a way that the already-built areas of the site fail to do, and to that end we commend the design approach taken.


We acknowledge that B5 and B16 have outline consent for 8 and 9 storeys respectively, however BPT continues to view these heights as unacceptable. This unacceptable height and bulk would, in our opinion, cause harm to the significance of the heritage assets which surround the site and have a detrimental impact on the special qualities of the World Heritage Site.

We note that the applicants’ massing comparison (3.6.2.in the D&A) indicates that only the roof gardens project above the permitted height (floor heights are as the extant planning permission) and that the overall bulk is less for both buildings. We have had reassurance from Crest Nicholson that this is the case and that structural issues are the reason for this, though our reading of the drawings is that ceiling heights have been adjusted for B16 but not in the same way for B5, which seems surprising if the reason is solely structural.

We are not clear from the information presented as to the extent by which the roof gardens project above the agreed height. The D&A para 3.8.1 suggests that this is 1.8 m, and this was confirmed in correspondence with Crest Nicholson: however, the cross sections in the D&A section 4 (specifically 4.12) suggest that the gardens will exceed 1.8m. Absolute clarity is therefore required about the height of landscaping, and a methodology for managing planning within these heights need to be made clear.

Design quality and materials

The overall design quality is recognised as contributing to the mitigation of harm. However, it is absolutely vital that the highest standard of architectural detailing is maintained and held and, most importantly, not lost or watered down through the discharge of conditions or value engineering. We would prefer to see the retention of the architects Egret West through to completion. Also, it is essential that the highest standards of craftmanship are employed throughout the construction stage, and that robust management agreements are in place to ensure the continuance of quality maintenance of hard and soft elements.

We commend the level of technical building detail presented, though we have some reservations that the stone thickness around the curves of the building will be too slim and deprive the stone of any body of strength and durability. We have suggested that there should be 3 inches depth at the thinnest points.


We welcome the concept of grounding these buildings in their parkland setting by means of green walls, but consider that much more attention needs to be given to species (especially on the south facing wall) and maintenance. One matter which does not seem to have been mentioned is the potential for a wind tunnel effect between the existing tall buildings in BWR and B5 & B16. This needs to be addressed both for the comfort of residents and visitors and for the success of the green walls on the new buildings.

The limitation of any landscaping detail within this application to the area immediately around B5 & B16 seems a little surprising in view of the importance of the square to the East of B5 and the main intervening parkland to the buildings’ character and appearance, particularly at ground level. The change in character of the open space, from formal rectilinear to more curvaceous ‘traditional parkland’, since the outline permission requires recognition. In addition, the detail provided ‘within the red line’ is really not sufficient. For example, specimen trees are located but not specified, changes in level are not detailed, the interface between existing & proposed hard surfaces is shown photographically and there is necessarily no assurance of coherence in planting & hard elements throughout the parkland setting.

We generally welcome the disguise/mitigation of rooftop mechanical plant and atrium roof by surrounding gardens, but require clarity re actual height (see above) and maintenance schedule (means and methods of necessarily intensive cultivation). Maintenance schedules are required to ensure that all rooftop, atrium, building facade and ground level gardens are permanently attractive: the applicants propose to achieve this as part of the discharge of landscape Conditions with revisions to the already approved site-wide Landscape Management & Maintenance Plan. In view of the importance of ‘landscape elements’ to this scheme, we suggest that much more detail about landscaping should be provided at the application stage.

Bearing in mind the commercial uses of much of the ground floors, taking advantage of the nearby river, parkland and footpaths, we welcome the approach to advertising which is integral to the design of the building.  We trust that this will be adhered to in perpetuity.

In view of all the above we must regretfully object to this application, at least until all our concerns are addressed satisfactorily.

Designed by Ice House Design