165 Rush Hill, Odd Down, Bath

165 Rush Hill is the site of a former petrol station, now hand car wash, situated within the Odd Down region of the Bath conservation area and World Heritage site. The area features a mix of Bath stone ashlar and coursed Bath rubble stone with clay pantile roof tiles; whilst there are some contemporary-style dwellings, it remains characteristically an area of mid- to late-19th century, two storey dwellings in simple, symmetrical form.

The Trust does not object to redevelopment of the site for residential use; indeed we feel this is an opportunity to improve the site’s appearance from the main thoroughfare and connect it better within its historic, residential context.

However, we cannot support this application because it neither responds to nor contributes to its local context. Furthermore, it fails to meet the minimum nationally described space standard 2015 for new dwellings which results in overdevelopment of the site.

We feel that the insertion of an Edwardian-style terrace within the primary streetscape of the Odd Down character area does not complement or respect the local historic vernacular in the Rush Hill area. Whilst the D&A Statement takes inspiration from the housing type along Somerdale View, this style of elevation does not contribute to Rush Hill’s immediate streetscape and is a much later addition to Odd Down’s retained Victorian architectural appearance. Considering the immediate position of the site between two mid- to late- 19th century buildings, 159 Rush Hill and 167-169 Rush Hill, we feel that this development neither preserves nor enhances the appearance and character of the conservation area.

Furthermore, the mix of drastically different housing types results in a conflict of architectural styles and materials. Due to the insular position of the courtyard and mews houses, a more homogenous design would have served to define the site as a whole.

It appears that the proposed 2-bed courtyard dwellings and the 3-bed terraced dwellings fail to meet the minimum nationally described space standard 2015. A 3-bed 2-storey dwelling capable of housing 6 residents is required to have a minimum internal floor area of 108m², rather than the proposed 100m² and a 2 bed 2-storey dwelling capable of housing 3 residents is required to have a minimum internal floor area of 70m², rather than the proposed 61m². This development therefore should not be considered as an acceptable or sustainable provision of residential accommodation.

We also note that the D&A Statement is misleading with regard to height, describing the mews house as 2-storey when it is shown as 2.5 storeys minimum, and the courtyard house as 1-storey, when it is shown as 2 storeys. We would ask that that these details are clarified throughout the application with the LPA.

For these reasons we consider that this is an overdevelopment of the site, with insufficient internal space and an inadequate provision of outdoor private amenity space. It will also be out of character with the existing density and layout of the Odd Down area, where dwellings along Rush Hill have generous outdoor space to both the front and rear. There are some concerns regarding overlooking onto Somerdale View and the Corston View bungalows and consequent impact on existing residential amenity due to the close proximity of the mews and courtyard dwellings to the site boundary, and in particular the mews’ elevated position and reliance on artificial, temporary screening measures such as high boundary fences and tree planting in private gardens, which could be removed by future residents. Furthermore, the provision of parking spaces falls short of the requirements set out in Policy ST7 of the Core Strategy and Placemaking Plan, in which 2 parking spaces are required per 2-3 bed dwelling, and 0.2 visitor parking spaces are required per dwelling. This totals 18 residential spaces and 1.8 visitor spaces, which this development fails to deliver.

Therefore, this application will neither preserve nor enhance the character or appearance of the conservation area, and is in breach of local policy and national living standards. This application is therefore contrary to the Planning (Listed Buildings and Conservation Areas) Act 1990, Section 2, 11, 12, and 16 of the NPPF, The Nationally Described Space Standard 2015, and Policies B1, BD1, D1, D2, D3, D4, D5, D6, D7, HE1, and ST7 of the Core Strategy and Placemaking Plan, and should be withdrawn or refused.