April – May 2013

16nd April – 19th May 2013

Weeks 16-20 2013

Week 16 (2013)

13/00905/FUL & 13/00906/LBA – 13 Argyle Street, Bathwick, BathBA2 4BE

Internal and external alterations for the change of use of first, second and third floors from retail to 3no residential units with minor layout changes, reinstate front door opening to upper floors and replace shop frontage.

OBJECT In principle Bath Preservation trust welcomes this development and believes that the proposed shop front elevation is a marked improvement on the existing. Unfortunately, we feel we must object to this application as the the new shop frontage elevation is not consistent with the proposed plan drawing, therefore, this inconsistency in the application makes it impossible to accept the scheme as it stands. Furthermore, some improvements could be made to the proportions of the panels to the central door as they are quite jarring in the proposed scheme; alignment with the new fenestration pattern of the shop windows and the door to the residential accommodation would be more appropriate.

With regards to the interior alterations, the Trust is pleased with the level of detail provided in regards to the inventory of architectural features and the intention to retain them. Unfortunately, due to the inconsistencies within the application this development contravenes Local Plan policies BH.2 and BH.19 and should be REFUSED.

13/01076/LBA – 26 Upper Borough Walls, City Centre, Bath BA1 1RH

Internal and external alterations to convert 2no. existing retail unit into 1no. retail unit for the basement of 26 Upper Borough Walls and the ground floor of 26 Upper Borough Walls and 12 -13 Union Street.

OBJECT The Trust objects to this application on the grounds that further information is required before any permission could be given objectively. Within the application reference is made to the necessity for a Structural Engineer’s Report which is not yet submitted, and to damp proofing with no specification provided. There are also no detailed proposals for the retail space, or justification for the large amount of intervention proposed.

It is clear that these interconnected properties in Union Street and Upper Borough Walls have a complicated history which Bath Preservation trust believes requires further research as, without doubt, there is significant fabric in these buildings which has not yet been fully assessed or documented. For this reason and for the more integral reason of a lack of information in the application, this development is contrary to Section 12 12 ‘Conserving & Enhancing the Historic Environment’ of the NPPF and Local Plan policies D.4, BH.2, BH.3, BH.6 and BH.19 and should be REFUSED.

13/01335/FUL & 13/01336/LBA – 1 – 4 New Bond Street, City Centre, Bath BA1 1BE

Internal and external alterations to remove existing shopfront and associated construction excavate to reduced levels and provide new Bath stone stall riser and fully glazed shopfront immediately behind the existing colonnade with new staff and public entrances.

OBJECT Bath Preservation Trust strongly objects to this application. The shop front proposal is poorly designed and a resounding example of commercial wants over the preservation the historic environment of Bath. The current arcaded shop front is set in a predominately historic, listed street scene whose group value would be damaged by the proposed intervention. Furthermore, the design in its current form would have a harmful effect on the appearance of the conservation area.

The Trust questions the validity of the statement within the design and access guide which deems the modern arcade as having ‘no authentic connection with historic Bath’ as seemingly Bath Street is a clear influence on the current scheme which calls into question the justification for the proposed alterations. The proposed scheme of glass placed directly behind the columns is clumsy and lacking in architectural merit as well as incongruous in this setting. This obtrusion into the public realm and the drop in pavement level is likely to have a significant and dangerous impact on foot traffic in front of the building, on a busy road junction. Therefore, not only is the design inappropriate, it will also result in a sizable loss of public amenity in reducing the pavement and the Trust questions whether an increase in retail space justifies this loss. In combination these elements of the proposed scheme constitute entirely inappropriate development within the conservation area and World Heritage site of Bath and therefore contravenes Section 7 ‘Requiring Good Design’ and Section 12 ‘Conserving & Enhancing the Historic Environment’ of the NPPF, as well as Local Plan policies D.2, D.4, BH.1, BH.2, BH.6 and BH.19 and should be REFUSED.

13/01401/FUL  – Starbucks   13 – 14 High Street, City Centre, Bath

Use of public highway for outdoor seating (6 tables and 22 chairs) to the front of Starbucks store in connection with its use

OBJECT Bath preservation Trust feels that this proposal for the provision of outdoor seating presents and excessive amount of visually intrusive clutter that would detract from the historic setting of Bath. In turn this would be detrimental to the character of the conservation area as well as an impressive street scene in Bath’s historic centre.

Prior to the ongoing street improvement works this very busy stretch of pavement was frequently difficult to negotiate because of waiting/alighting bus passengers. The current works and extension of the pavement intended to ease this not to provide extra ‘trading space’. More importantly the work was intended as ‘celebration’ of public realm with coordinated and minimal street furniture. This scheme would contravene this intention and set unhelpful precedent. Due to the loss of visual amenity of the street scene and the loss of public amenity this application is contrary to Section 12 ‘Conserving & Enhancing the Historic Environment’ of the NPPF as well as Local Plan policies BH.1, BH.2 and BH.6 and should be REFUSED.

13/01483/FUL & 13/01484/LBA  – Flat 1 Beckford House, 66 Great Pulteney Street, Bathwick, Bath

Internal and external alterations for the erection of a replacement conservatory

COMMENT This proposal does not increase the footprint of the existing conservatory, which is of no great architectural merit. However, the statement that the scheme is not “overly architecturally fussy” is open for debate. The roof lantern and finial give the design an emphatic character which does not accord with its subsidiary situation nor the date and style of either the main building or the rear extension.

13/01495/LBA – Imperial Tattoo Company, 12 Cleveland Place West, Walcot, Bath BA1 5DG

External alterations for the removal of existing security shutters and redecoration of the shop frontage.

OBJECT Bath Preservation Trust is disappointed that this application is poorly compiled, with information which is essential to making an informed planning decision having been omitted, as this application concerns a building of special architectural interest.

There is considerable doubt as to what is proposed as only an overall elevation drawing has been submitted. To approve any signage, a more detailed drawing in a larger scale of the proposed sign is required so as to fully consider the schemes impact on the visual amenity of the listed building and the setting of those around it. Furthermore, no information on how this signage is to be applied has been provided which, if approved, could result in unnecessary damage to the shop front.

Whilst we welcome the removal of the inappropriate security shutters, no drawings have been provided of what is existing and what is proposed, nor has any statement been made about the applicants intention to carry out any repairs to the shop front or the masonry resulting from the works of either the installation or removal of the shutters, which should absolutely be their intention.

The works, by virtue of the lack of information, are considered to be detrimental to the special architectural and historic interest of the listed building, adjacent listed buildings and the conservation area and contravenes Section 12 “Conserving & Enhancing the Historic Environment” of the NPPF and Local Plan Policies BH.2, BH.6, BH.17 and BH.21 and should be REFUSED.

13/01423/LBA – 1 Woodland Place Bathwick Hill, Bathwick, Bath

Removal of part of the wall and railings to the front of the property to accommodate off-street parking; removal of partitioning walls in basement vault and associated damp-proofing

OBJECT The Trust is concerned that if this proposal were to be permitted and the railings removed as proposed, that there would be a downgrade in the visual aesthetic of this important terrace. Whilst we appreciate that the desire for off-street parking, that the railings are not historic and the precedent has been set by the removal of railings at neighbouring properties, it must be recognised that Woodland Place was designed to be a balanced composition and the removal of the railings and part of the boundary wall would disrupt this balance. We take the view that the terrace has been degraded by previous works to remove the railings at other properties and we feel that inappropriate development should not be permitted on the grounds of precedent alone.

The works by virtue of their impact on a listed building and its setting and the impact of the conservation area and the world heritage site contravene Section 12 ‘Conserving & Enhancing the Historic Environment’ of the NPPF and Local Plan Policies BH.1, BH.2, BH.6, BH.7 and BH.8 and should be REFUSED.

13/01068/FUL – Walcot Rugby Club Lansdown Road, Charlcombe, Bath

Erection of replacement floodlights comprising of 6no. 15m columns for winter use.

OBJECT In Consultation with the Campaign for Dark Skies, Bath Preservation Trust objects to this application.

Within the application it is stated that the proposed illuminance of 116 lux at 0.35 uniformity meets the RFU requirement for training, however the RFU’s ‘Facilities Guidance Note 4 – Floodlighting’ calls for 100 lux and a uniformity 0.5 (note BSEN 12193 calls for 75lux at 0.5).  Uniformity of illumination is perhaps more important than the actual illuminance, which in this proposal is more than adequate. It is disappointing, therefore, to see that such a poor value of uniformity has been achieved where the illuminance is far less economical than required.

The design includes the ILE (now ILP) ‘Guidance for the Reduction of Obtrusive Light’ and purports to demonstrate compliance in terms of Light Intrusion 5 lux and Luminaire Intensity 7500 cd. However, the matter of the Environmental Zone in which Walcot Rugby Club is situated is not discussed within the application, and these given values reveal that Zone E2 has been assumed. However, the Rugby Club clearly falls within the Cotswold AONB and the ILE Guidelines class this as Zone E1, calling for Light Intrusion  2 lux and Luminaire Intensity 2,500 cd. It is worth reinforcing the point that this light is intrusive as even if the pitch were just outside the AONB, the guidance states that, “Where an area to be lit lies on the boundary of two zones the obtrusive light limitation values used should be those applicable to the most rigorous zone.” Therefore, it has been shown that Zone E1 values apply and therefore that this proposal is not compliant with the guidelines as the Light Intrusion and Lumimnaire Intensity ratings far surpass those which should be present in the AONB.

The Campaign for Dark Skies consultant notes that in this proposal the luminaires are tilted at 68 and 70 degrees. With the main beam at 60 degrees, that means that the glass is tilted 8 or 10 degrees and this may account for the excess obtrusive light values. It is suggested that with these luminaires there would rarely be problem at zero tilt, failing that perhaps a tilt up to 5 degrees. However, the uniformity on the pitch may be compromised by the lower tilt values.

By virtue of the non-compliance of this application with the sensitive needs of the Cotswold Area of Outstanding Natural Beauty, the resulting impact of glare from excessive luminance onto neighbouring land and properties and the clear need to reconsider the design to provide better uniformity of illumination, this application is contrary to Section 11 ‘Conserving and Enhancing the Natural Environment’ and Section 12 ‘Conservation and Enchancing the Historic Environment’ of the NPPF, as well as Local Plan policies D.2, D.4, GB.2, NE.2, BH.1, BH.6 and BH.22 and should be REFUSED.

13/01288/LBA – Parish Centre 5 Harley Street, Lansdown, Bath

External alterations for repairs to roofs, external walls, external building services, external doors and windows

COMMENT Much of this application looks commendable and the Trust is pleased with the proposed materials and the care which has been taken to identify individual problems. We are, however, uneasy with the decision to leave so much of the final detail to ‘the surveyor’ and also with the lack of a detailed specification for cleaning the stone; sulphurous deposits and paint will need different treatments, which should be described. In particular we feel it integral that trials should be carried out on small areas of the stonework to establish the optimum methods and to understand any adverse impacts which may arise from the cleaning. The Trust encourages the applicant to consult ‘The Cleaning of Bath Stone’, a conservation guidance document produced by the Bath Preservation Trust and Bath & North East Somerset Council for more detail, and advice on the benefits and constraints of cleaning Bath stone.

Lastly, we feel that the capping of cornices in lead is only a suitable intervention where it is absolutely necessary to the conservation of historic fabric. We would urge the applicant to be sure that this is the only method by which the continued preservation of the stonework is achievable as it will cause a visual and physical impact which needs to be carefully considered.

13/01340/FUL – Cobden House,1 Bloomfield Avenue, Oldfield Park, Bath

Erection of an extension/roof terrace following demolition of existing car port/roof terrace, infill rear courtyard with sun room, provision of a part attic conversion with new dormer and new photovoltaic panels

OBJECT The Bath Preservation Trust is supportive in principle of measures to increase the energy efficiency of Bath’s existing historic building stock, conserve energy and reduce the carbon foot print of the city as a whole. The Trust is in support of photovoltaic panels provided they are fixed in concealed locations with restricted visibility. The visibility of the roof should be considered not only in the immediate location but also in the wider context taking into account views onto the site from other parts of the city.

The Trust considers that the proposed roof mounted array of photovoltaic panels, would be highly visible, and would have a detrimental impact on the character and appearance of the Conservation Area and World Heritage Site as well as being poorly assimilated into the street scene. However, although the East-facing sloped mounted PV’s would be visible from the Wellsway, we feel that they are a more acceptable development, though their acceptability should hinge on whether they are proven economically viable or not; linked to this the Trust feels that this application, in proposing development of this nature, would benefit from having a succinct Design and Access Statement being drafted and submitted for consideration to ensure that the design process and factors influencing the consideration of the application can be assessed and understood.

Whilst the Trust does not have any issue with the built elements of this application (i.e the demolition of the incongruous carport or teh attic extension), by virtue of the insensitive placement of the roof-mounted PV’s, this application fails to comply with Conserving & Enhancing the Historic Environment’ of the NPPF and Local Plan Policies BH.1, BH.2, and BH.6 and should be REFUSED.


Week 17 (2013)


13/01587/AR & 13/01589/LBA – Chimichanga, Bluecoat House, Sawclose, City Centre, Bath

Internal works to display 7 no. internally illuminated free standing signs behind glazed windows.

OBJECT The Trust objects to illuminated signs on listed buildings and 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 materials, colour, amount and position are incongruous. This signage scheme is not sensitive or appropriate upon a unique listed building, in such a prominent area. This excessive number of additions to the buildings windows will add to the visual clutter of the street scene. Furthermore, the trust regrets the significant lack of detail within the application; no historical information accompanies the application, nor are there any supporting documents justifying the signage.

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.

13/01633/LBA – Flat 1, 17 Brock Street, City Centre, Bath

Internal and external alterations and refurbishment of garden flat (Basement, lower ground and ground floors).  Alteration to front drainage pipes and change to cast iron.  Replace 1959 rear kitchen window with a box sash window.  Enlarge terrace and associated landscaping to the rear garden.

SUPPORT The proposed works to the exterior would broadly enhance the architectural and historic significance of this building which is so prominently situated within the World Heritage Site and conservation area. The proposed replacement of the UPVC rainwater goods and modern iron grill with traditional, cast iron goods is commendable and far more harmonious with the listed building and its setting. With regards to the interior works, we are satisfied that there will be no loss of historic fabric, and welcome the applicants intentions to restore much of the original floor plan and architectural details.

13/01604/FUL – Monkton Combe Junior School, Church Road, Combe Down, Bath Bath BA2

Erection of replacement Pre prep building; access works; associated landscaping; and a change of use of Glenburnie to a single dwelling.

COMMENT The Trust recognises the requirement to expand the school and improve vehicle access to the site. However, we wish to comment on the choice of materials within the application for the new school building, specifically the cedar cladding used prominently upon the southern facade of this building. While we are pleased to see a reduction in the amount of cladding used on the facades, there remains some confusion as to whether the cladding is to be treated or not. We feel this ought to be clarified, since the Design & Access Statement expresses that the cedar will have a ‘natural finish’ and the elevations state it will be ‘unfinished’. The Trust strongly feels that cedar ought to be left to weather naturally, and that attempts to treat or finish cedar undermine its aesthetic quality. We also question the appropriateness of employing horizontal cedar cladding where there is articulation in the form of the building, such as a curved wall face. Here the detailing at junctions may result in a fussy and relatively poor finish appearance.

In relation to this application, the Trust notes that it is increasingly common for applications for development near the Greenbelt to be timber-clad, and we are concerned that a propensity for such a material does not always respect the local vernacular.

13/01046/FUL – 18a & 19 Queen Square, City Centre, Bath, BA1 2HR

Refurbishment and conversion of 18A and 19 Queens Square from mixed office and residential use to 2no Town Houses

COMMENT The proposed works to convert these historic and important listed buildings into two townhouses is very much welcomed by the Trust. In particular we are delighted with the discovery of the interiors on the upper floors of the building, and as such we feel it extremely prudent that a full and detailed survey of these interiors be carried out in a similar vein to those undertaken in other properties in Bath, by the Bath Interiors Committee. It is hoped that the details will be carefully researched and recorded and that the building team will include skilled craftsmen and conservators.

13/01060/AR – Lloyds Tsb Bank 18 Newbridge Road, Newbridge, Bath BA1 3JY

Display of 1no internally-illuminated fascia sign, 1no non-illuminated hanging sign, 1no internally-illuminated hanging sign, 1no internally-illuminated ATM header, 2no internally-illuminated window light strips, 1no non-illuminated nameplate, non-illuminated reverse applied vinyl and 1no non-illuminated car park signage.

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 materials, colour, amount and position are incongruous. Steel and applied vinyl materials are not sensitive or appropriate as tehy oppose the traditional palette of Bath. The excessive number of additions to the shop frontage will not only add to the visual clutter of the street scene, but it is also expected that the method of fixing would cause wholly unnecessary damage to the fabric of the building. 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.

13/01314/FUL – Kingswood School, Lansdown Road, Lansdown, Bath BA1

Erection of a replacement boarding house for 43 boarders and ancillary accommodation.

COMMENT The Trust does not object to the development of this site, nor to the plans proposed in principle, however, our concerns are two-fold.

Primarily, we regret the quality of the proposed elevation drawings submitted for consideration as we feel they could better illustrate the breaks in the facade which are suggested by the plan drawings. Taken in whole, without the breaks, the drawings suggest a barrack like facade. While we appreciate this was not the intention it does make the proposal difficult to evaluate or comment on objectively.

It is unclear as to whether the cedar cladding is to be treated or not. We feel this ought to be clarified; the Trust strongly feels that cedar ought to be left to weather naturally, and that attempts to treat or finish or treat cedar undermine its aesthetic quality.

Whilst we find the design scheme to be acceptable we would suggest, for the applicants consideration, that oak cladding weathers more pleasingly in the long run and that a more sensitive approach to the overall design would be to realise the ground floor is Bath Stone with the upper floors finished in render.

Our secondary concern relates to the succession of planning applications Kingswood School has submitted in succession as it leads us to question whether the school has a coherent development plan in place to best make use of its facilities before any serious development is proposed.


Week 18 (2013)


13/01678/AR – Co-Operative Retail Services Ltd, 4 Burlington Place, Lansdown, Bath BA1 2SQ

Display of 1no trough light fitted above existing fascia sign to front elevation, 1no externally-illuminated fascia sign to side elevation and 1no non-illuminated projecting sign to front elevation.

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 materials, colour, amount and position are incongruous. Aluminium and applied vinyl materials are not sensitive or appropriate as they oppose the traditional palette of Bath. The addition of signage to the side fascia contributes to an excessive number of additions to the shop frontage that will not only be visually intrusive and add to clutter in the street scene, but that the Trust feels is also entirely unnecessary as the proposed projecting sign to the front elevation would serve to alert approaching potential customers. With regard to the projecting sign, the Trust feels is would be improved with a simple bracket, and not be decorated as shown. 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.

13/01642/FUL & 13/01643/LBA – 24 Sydney Buildings, Bathwick, Bath BA2 6BZ

Erection of single storey extension following demolition of existing conservatory to rear of property.

OBJECT While the Trust is pleased to see that the applicant is seeking to develop in a more sensitive manner than has occurred previously, we feel that this application, which seeks to replace a glass conservatory with a much larger extension, cannot justify the proposed development as visually less intrusive. The Trust feels that the dominance of the development over the canal side resulting from the increase in footprint will have a harmful effect on the canal’s setting, and as such, does not serve to preserve or enhance the conservation area. Furthermore, once it is dark, it is anticipated that there will be significant light glare from the proposed extension onto the canal which, under the Local Plan 2007, is designated a Site of Nature Conservation Interest.

We are pleased to see that the proposal seeks to uncover the window, which has been hidden by the current conservatory, and to reinstate stone ashlar into the old doorway. However, we feel that the proposal does not go far enough to ensure a better legibility of the building’s fenestration as, as proposed, the extension does sit comfortably alongside the first floor window. This relationship should be addressed and the application would be strengthened by some larger scale drawings of the proposed elevations. Lastly, it is worth noting that whilst Bath Stone ashlar and lead are appropriate materials, the use of aluminium for the sliding doors is less so, especially given that they appear to be an off-the-peg design.

By virtue of the impact of the increased footprint this development is deemed insensitive to the listed building and its setting, a designated SNCI, the conservation area and the world heritage site and therefore, contravenes Section 12 of the NPPF ‘Conserving and Enhancing the Historic Environment’ and Local Plan policies D.2, D.3, NE.9, BH.1, BH.2 and BH.6 and should be REFUSED.

13/01694/FUL & 13/01695/LBA – Lonsdale, Sydney Road, Bathwick, Bath BA2 6NT

Erection of single storey garden room replacing existing structure.

COMMENT Bath Preservation Trust is pleased to see that there will be no loss of historic fabric and that the applicant has scaled down this proposal already, however, we feel there is more to be done to the design. We regret that greater consideration has not been given to the fenestration of the building or to the effect of the extension on the buildings legibility.

The design as proposed disrupts the fenestration and massing of the building, resulting in an uncomfortable balance; currently the building reads as a firm structure, however, the extended width across the across the window makes the new extension overly dominant, causing the broad overhang of the roof to appear top heavy. Furthermore, the footprint encloses a window on the North elevation which is unfortunate and, as proposed, the extension does sit comfortably alongside the first floor window. Therefore, the relationship between the proposed garden room and the building’s Northern elevation should be revisited.

To the West elevation, the design of the extension bears little relation to the Italianate character of the original architecture; in fact appearing more Classical in composition. Lastly, the applicant may like to consider that on the proposed panelled doors of the garden room a quirked beading bar would serve better to direct water away from the structure.

13/01649/ERES – Western Riverside Development Area, Midland Road, Twerton, Bath BA2

Approval of reserved matters with regard to outline application 06/01733/EOUT for the demolition of existing Destructor Bridge and construction of replacement bridge and steps.

COMMENT The plans for removing the bridge appear to be of necessity. There is unfortunately no assessment of the fabric or design of the bridge, or indication of what will happen to it. If it is wrought iron, as is supposed, and the presumption is to sell the metal, it should at the very least be sent to specialist salvage for re-use in historic situations; Chris Topp & Co Ltd is, as far as we know, the only recyclers of wrought iron, which is in demand for high class restoration of our national heritage of great ironwork, who look to buy at well over the current scrap value.

At the public meeting held on 20.2.13, the ornamental scrolled brackets on the current bridge were mentioned, and the hope expressed that they could be incorporated. This should be pursued, and if not retained on site, their future should be discussed, as part of Bath’s industrial heritage.


Week 19 (2013)


13/01816/FUL – Rear Maisonette 31A Southgate Street, Bath BA1 1TP

Erection of a third floor extension

OBJECT Bath Preservation Trust objects to this development due to the lack of design quality. We are not convinced that this proposal demonstrates a high standard of architecture and design, as is appropriate in respect of the local townscape character of the City of Bath World Heritage Site. The scheme as proposed is a wholly inadequate response to an opportunity to improve the appearance of this building.  The fenestration on the proposed elevations is incoherent. No attempt has been made to make the building legible with its surroundings, despite being visible from Somerset Street. The use of larch cladding is incongruous in this setting and does not seek to enhance local distinctiveness.

If implemented, this proposal would be an opportunity missed for enhancing the quality of architecture and design in Bath. In our view the proposal is contrary to Section 7 ‘Requiring Good Design’ of the NPPF and Local Plan policies, D.1, D.2 and BH.1 and should therefore be REFUSED.

13/01842/AR & 13/01843/LBA  – 47 Milsom Street City Centre Bath BA1 1DX

Display of 2 no. non illuminated projecting signs, 1 no. non illuminated applied vinyl and 1no. brass name plate

OBJECT The Trust is pleased to see that the applicant has taken on board our comments relating to the illumination proposed previously (ref:13/00059/AR) and has excluded illumination from this scheme. We also welcome that the applicant intends to fit the projecting signs to the existing brackets to minimise damage to the building’s historic fabric. Unfortunately though, as with the previous application, the quality of the accompanying documentation is poor. The listed status of the building is not mentioned in the all too brief design and access statement, nor is there any assessment of the impact of the proposed scheme on the historic fabric or setting of the building.

The quality of the drawings is below standard and the rusticated stonework of the facade is missed off the elevations entirely, and as a result the hugely detrimental impact of the brass wall-mounted name plate on the legibility of the rustication is missed. The name plate will, in all likelihood, sit over the lines of rustication which we regret, especially as the there is ample identification of the building without it.   It will cause damage in attachment to the historic fabric. Furthermore, aluminium and applied vinyl materials are not sensitive or appropriate materials for the projecting signs as they oppose the traditional palette of Bath, and detract from the visual amenity of the conservation area and World Heritage Site of Bath.

Although this application has improved on the previous scheme, the Trust feels that corporate re-branding, as cited in the design and access statement, is not grounds to impose negatively upon a listed building and its setting. Many of the issues highlighted here make up the Conservation Officer’s grounds of refusal for the last application and the Trust finds it hard to understand why they would not have been rectified in this proposal. The lack of adequate documentation leaves questions as to what is proposed and the signs themselves, by virtue of the materials used in a highly sensitive, prominent, city centre location are incongruous. This application is contrary to Section 12 ‘Conserving & Enhancing the Historic Environment of the NPPF and Local Plan Policies BH2, BH6, BH17 and BH19 and should be REFUSED.

13/01745/FUL – 61 Bloomfield Road, Bloomfield, Bath BA2 2AW

Erection of a replacement single storey rear conservatory and a rear window.

COMMENT The trust does not object to this development and is happy with the design of the new conservatory. However, we regret to see that no explanation is given for the proposed replacement window, and although the base of the conservatory is stated to be built to match the original building, brick supports are also mentioned. These elements should be clarified prior to consent.

13/00574/LBA – 1 Macaulay Buildings Widcombe Bath BA2 6AS

Internal and external alterations for the replacement of 6no. single glazed 2 sash windows by 6no. double glazed 2 sash windows with identical number of window panes

OBJECT Bath Preservation Trust regrets that that the Design and Access Statement and the Heritage Statement submitted with this application are totally inadequate.  No information is provided about the age of the current windows and their current condition.  Judging by the photographs, it is possible that these may be the original windows, and if this is the case then those situated in the curved elevation of the building may well be a rare example of traditional bowed sashes. To propose complete replacement of historic windows requires strong justification. As it stands, with no condition report or information to show that the applicant has looked to less intrusive interventions before the replacement of the windows, we feel strongly that the proposed works cannot be justified.

As this building is one of a pair of villas, and part of a prominent historic streetscape, we believe that proposals will have a detrimental impact; not only on the listed building itself, but also on the adjacent listed buildings, the conservation area and the World Heritage Site.

The justification given for this proposal is that the thermal efficiency of the current glazing is below standard and is causing discomfort to the applicants. We would advise the applicants to refer to Warmer Bath (our published guidance for the energy efficiency of traditional buildings), in particular the energy hierarchy guidance, to consider whether  there is  a simpler, less invasive and more cost-effective solution. One such solution that may be more appropriate is draught-proofing.  English Heritage suggests that in terms of reducing heat loss, ‘draught-proofing a leaky single glazed window has roughly the same effect as changing the U value from that of single glazing to that of double glazing’.   Draught-proofing, in combination with every-day measures such as closing curtains (which would be improved by lining them with thermal interlining) and traditional shutters whenever practicable, would improve the building’s efficiency whilst still retaining its special architectural and historic interest. It should be noted, however, that listed building consent will be required for draught proofing that has a visual or physical impact on a traditional window.

The works, by virtue of the loss of potentially original sash windows and historic fabric, as well as the lack of information to justify the works as proposed leaves this application in conflict with Section 12 ‘Conserving and Enhancing the Historic environment’ of the NPPF and Local Plan policies BH.1, BH.2 and BH.6 and should be REFUSED.


Week 20 (2013)


13/01912/LBA – 4 Sydney Place, Bathwick, Bath BA2 6NF

Conversion of ground floor from office use to self contained flat with internal alterations and revision to the front elevation at roof level to install an additional dormer window and internal alteration.

OBJECT Whilst the Trust acknowledges that the desire to return the ground floor of this important building to residential use is reasonable, the methods and level of intervention proposed are completely unacceptable. The changes previously made to this building are cited as part of the justification for this work, but in fact the ground floor appears to have survived in remarkably unscathed plan form to date, with authentic fireplaces, skirting boards and cornices in situ. The Trust regrets that the applicant is seeking to make provision for a door through the arched recess as this is an important feature of buildings of this date; therefore, knocking a door through it would result in a degradation of the original design. Furthermore, there does not appear to be a drawing of where the opening will be, or of the appearance of the proposed elevation, to enable a proper judgement to be made. The proposed new door to the hall will also result in loss of historic fabric and plan.

With regard to the dormer window enlargement, currently there is a window provided to each room, and therefore the undoubted resultant damage to the roof structure cannot be justified on the grounds of amenity. With regard to the external appearance, the terrace’s original design is already much compromised by a proliferation of large dormers, and more should be strenuously avoided. Removing a large section of wall to the third floor is also unacceptable; again there is no convincing justification for the loss of historic fabric and plan which would be the result of this proposal.

Due to the harmful works proposed to this important listed building and the expected deterioration of the group value and setting of the listed terrace by the citing of an inappropriate dormer, this development is contrary to Section 12 ‘Conserving and Enhancing the Historic Environment’ of the NPPF and Local Plan policies D.4, BH.1, BH.2, BH.4, and BH.6 and should be REFUSED

13/01901/FUL & 13/01902/LBA – 5 Bladud Buildings, City Centre, Bath BA1 5LS

Amalgamation of 2no. existing residential flats to create 1no. 6 bedroom maisonette on first, second and third floor, erection of rear glazed extensions to replace existing marquee structure and external alterations to building including replacement of existing UPVC windows with timber sash windows.

OBJECT Bath Preservation Trust finds this application to be oblivious to the requirements of a listed building in a World Heritage Site and within a conservation area, despite paying lip service to planning regulations. The proposal to run a new downpipe on the front elevation, as well as the rear, is as unbelievable as it is inappropriate. There is no assessment of the date or historic significance of many of the architectural elements which are to be altered, nor sufficient detail given of the alterations to the windows, nor to doors and floors. The ceilings to the third floor which the applicant proposes to remove, as well as the lath and plaster to the third floor staircase, may be original elements of the building; more information and a fuller understanding of the building and its historic value are both required. The proposed extension to the rear, and the effect it will have on historic fabric, is again not sufficiently explained.

Lastly, it appears that the design an access statement is exactly the same as that submitted under the previous (withdrawn) planning application 12/03004/LBA, and as such it describes the proposals to create 4 apartments rather than the proposed 6 bedroom maisonette. This glaring oversight renders making any objective judgement on this application unachievable.

Due to the incongruous nature of the works proposed to this prominent listed building, this application is deemed to be contrary to Section 12’ Conserving and enhancing the Historic Environment’ of the NPPF as well as Local Plan policies D.2, D.4, BH.1, BH.2, and BH.6 and should be REFUSED.

13/01969/VAR – Abbey Hotel, 1 North Parade, City Centre, Bath BA1 1LF

Variation of condition 4 of application 10/04296/FUL (Use of the public highway for the siting of 12 tables and 48 chairs).

COMMENT The Trust regrets that the storage issue was not considered prior to the application for the citing of tables and chairs on the pavement, and believes that there may be quite an important principle at stake here – namely that businesses do not ‘own’ the pavements and therefore it remains appropriate that the tables and chairs etc have to be removed overnight.  We deplore the tendency of businesses to apply for relaxation of conditions which are put in place for good reason. Whilst it is not a major practical issue in this location where the pavement is wide, once the precedent is set there’s a risk that others will seek to follow suit.

13/01876/EFUL – Twerton Mill, Lower Bristol Road, Westmoreland, Bath BA2 1EW

Erection of student accommodation (sui generis) (comprising 279 student bedrooms in studio/cluster flats and 50 bedrooms in 7 No. town houses) comprising 1, 2, 3, 4 and 5 storeys in height; together with 4 No. parking spaces (3 disabled and 1 management space); 96 covered cycle spaces; 2 No. covered refuse/recycling stores; covered plant room; vehicular access from the east (Mill Lane); emergency/maintenance vehicular access from Lower Bristol Road; new hard/soft landscaping treatment, following demolition of existing industrial/office buildings (revised resubmission).

OBJECT Bath Preservation Trust objects to this application for a number of reasons.

These objections should be set in the context that we think this scheme does have some merits. While our preference is for student accommodation to be provided on-campus if possible, we believe that the provision of purpose-built student accommodation off-campus, if there is proven need, offers the opportunity to reduce the pressure on family housing being used for student accommodation in Bath.

However, we are very concerned on a number of points which relate to both policy and architecture, a number of which we expressed in relation to the previous scheme for this site.

In policy terms, the planning statement provided with the application puts forward a case for this development which nevertheless breaches elements of Council policy or draft policy. First, we note that the Draft Core Strategy says the following of Twerton Riverside:

  • Twerton Riverside will function primarily as a multi-use economic development area.
  • Refurbishment, redevelopment or intensification for industrial use will be welcomed at Twerton Riverside. Proposals for the loss of industrial land and floorspace at Twerton Riverside will be assessed against evidence of current and future demand, the availability of suitable alternative provision within Bath for displaced occupiers and the benefits of the alternative uses being proposed.
  • Residential-led or non-economic development led proposals will be acceptable only where economically-led development would fail the sequential and impact texts of PPS4 or is not commercially viable.

Given there is an existing small industrial use on the site we would like to be clear where this is being displaced to; whether other industrial use was pursued on the site; and whether there has been an appropriate sequential process before the decision to the bring forward this site for student accommodation.

Secondly, the Building Heights Strategy suggests 5+1 storeys should be a maximum height even in this area which is a distance away from the City Centre.

Thirdly, we are not convinced by the sequential and exception test in relation to flooding, which suggests that in fact there are more suitable sites potentially available, especially in light of the proposed decommissioning of the gasholder.

In architectural terms we have further reservations, which were stated clearly previously, and as such we regret that more amendments have not been made to the scheme. Firstly, the gateway is the only substantial remaining fragment of the historic site, yet it is being treated in a way that denies its function. This gateway should have provided an emphasis and axis to the plans for the site rather than being shunted sideways as an afterthought. A regrettable local example of where an architectural element is not incorporated into the legibility of a development is of course Pinch’s Folly; such a deliberate failure in design on this site should not be permitted so easily.

We are pleased to see that the applicant has sought to reduce the number of students to be housed on the site, and in doing so has alleviated some of our concerns related to overdevelopment. Unfortunately, while we support the approach of very limited parking provision and good provision of bicycle stores, we do not believe there is adequate access to the site for drop off and delivery of students, nor is the potential for open areas fully realised. This is largely because of the transverse block placed behind the gateway, which blocks East/West access through the site and looks like an ‘added extra’. Linked to this lack of amenity and flow through the site, we regret that the applicant has not considered opening the development onto the canal; as proposed the design shuts off the canal and makes no use of the benefits it could bring to residents living in the development.

Overall, therefore while seeing elements to support in this proposal (in particular the attempt to respond through an industrial ‘aesthetic’ to the history of the site) we believe it is let down by a desire to overdevelop both in height and mass, with insufficient respect paid to the retained history and a dubious pathway through the policy framework.

We therefore OBJECT to this proposal on grounds that it fails to fulfil the policy framework for the draft core strategy, the draft Building Heights strategy and the Flood sequential testing as well as being contrary to policy BH 1 on grounds on height and NPPF 132 (loss of significance of a heritage asset).

13/01868/FUL – Unit C  Weston Lock Retail Lower Bristol Road Westmoreland, Bath BA2 1EP

Erection of a four storey extension to existing building to be used as offices and provision of additional parking

COMMENT Bath Preservation Trust regrets the loss of the car-parking greenery along the Lower Bristol Road and feels it would be better to retain the tree in front of the sub-station, as well as planting another in the ‘dead land’ in the car park to provide some tall greenery alongside the new tidy wall/railings. The Trust note that Q15 of the application form states that there are no trees on the development site, however street view as provided by Google (June 2012) shows otherwise; this should be clarified.


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