2 Spring Gardens Road, Widcombe, Bath

The proposed site of development is the unlisted interwar terraces at Spring Gardens Road, situated within the Bath conservation area and World Heritage Site. Within the Pulteney Road Character Appraisal, Spring Gardens Road is highlighted as an example of interwar council housing developed around the Dolemeads Estate, and features as one of the distinct types and ages of social housing development within the overall estate. Whilst Broadway and a cul-de-sac to its north are noted specifically as unlisted buildings of merit, it appears that “similar housing” of semi-detached and terraced varieties along Ferry Lane, Spring Crescent and Spring Gardens Road from 1937-1939 are included within this list, and could therefore be argued to be non-designated heritage assets (NDHAs). The terrace is a simple, attractive example of its type, and significantly retains a number of its traditional style 1930s timber doors in a variety of colours, examples of which are also seen along Spring Crescent. Notably, the Character Appraisal highlights the positive retention of original, historic features such as windows and doors in this area.

We are therefore opposed in principle to the replacement of traditional style timber joinery with composite equivalents, and feel that this would neither preserve nor enhance the character or appearance of the conservation area, and would instead constitute a notable loss of historic fabric and detailing. Composite doors are typically polymer-based; the Character Appraisal notes that the “increasing prevalence of uPVC glazing and doors erodes the character of pre-1950 unlisted buildings” and is featured as one of the principle risks to this area of the conservation area.

The replacement of the existing timber doors with composite would have a directly negative impact on the streetscape overlooking the river, and establish a precedent for the removal of traditional timber joinery with resulting detriment to the distinctive appearance and character of the area. No justification is provided for their replacement.
We additionally refute the claim that the proposed doors would match those existing due to the much-reduced scale of the 6-pane glazing and the loss of the central door panel. They would be visually ‘heavier’ in profile and fenestration, and are clearly a standardised door design ill-suited to the specific joinery characteristics and detailing of the area.

We query that no elevations, existing or proposed, have been provided of the proposed door replacements across the rear elevations. The application form appears to indicate that the rear doors are also timber, and may also be a retained traditional feature shared across the terrace, albeit concealed from public view.

We maintain that this application constitutes the significant removal of remaining historic detailing and the further erasure of the area’s distinctive character which would neither preserve nor enhance the character and appearance of the conservation area. This application is contrary to the Planning (Listed Buildings and Conservation Areas) Act 1990, Section 16 of the NPPF, and Policies B1, BD1, CP6, D1, D2, D3, and HE1 of the Core Strategy and Placemaking Plan and should be refused or withdrawn.