92 London Road West, Lower Swainswick, Bath

92 London Road West is an unlisted residential dwelling alongside the main arterial route into Bath city centre. It is situated within the Bath conservation area and World Heritage site, and is included within B&NES’ 2018 Draft SPD on Locally Listed Heritage Assets as a positive example of vernacular design along London Road. Consequently, it is deemed to be a Non-Designated Heritage Asset (NDHA) that positively contributes to Bath’s peripheral streetscape through its highly visible use of coursed rubble masonry and clay pantile roof tiles in both the central building and its single storey western extension. It is indicated that it could date to the late 18th century, although its current plan form is more likely attributed to the mid-19th century when the site was being used as the Batheaston nurseries.

Whilst punctuated by the A4, the area is identified as “rural with open character” (Bath City Wide Character Appraisal, 2005). The plan form is of a middling density, with a large number of detached and semi-detached dwellings set back from the road in generous private gardens and with development frequently punctuated by wooded and pastoral land. New development in the area, such as Hicks Field to the south, largely conforms to this established grain.

The Trust previously objected to refused applications 19/05124/FUL & 19/04529/FUL on grounds of unjustified harm to a NDHA and the Bath conservation area.

Whilst BPT acknowledges the heightened pressure for residential housing within Bath, and is not opposed to the principle of sensitive, subservient contemporary design within the historic environment, we continue to have concerns with this application:

We acknowledge that the height of the proposed semi-detached dwellings has been reduced by a storey on the internal north elevation, and would be of a somewhat reduced visibility from the main road. However, from the south, the dwellings are clearly legible as three-storey buildings and remain a similar scale to that proposed in refused application 19/05124/FUL. The Trust therefore maintains that the erection of two three-storey properties to the rear of the existing mid-19th century NDHA constitutes an example of overdevelopment that is of strong visual detriment to both the periphery of the Bath conservation area and the setting of a NDHA. This area of London Road is characterised by its low-density semi-detached dwellings that are positioned within the centre of their plot, with the benefit of providing a spatial buffer between the building and the roadside.

Consequently, as stated in the Delegated Report attached to the refused application 19/05124/FUL, “the proposed development due to its design, siting, massing, and layout will cause harm to the setting of Bath Conservation Area. There are no clear and convincing justifications nor will any public benefits accrue in relation to the proposed development.” This application fundamentally remains very similar to application 19/05124/FUL, with the residential subdivision of a garden site within the conservation area and the creation of substantial hardstanding for off-street parking. However, we note the addition of application 21/01010/FUL for the conversion of the existing outbuilding into an additional 3-bed dwelling which further increases the residential pressures on the site. Consequently, the same issues regarding overdevelopment, harm to the setting of a NDHA, and a failure to respond to local grain and proportion remain evident. There continues to be a demonstration of adequate public benefit to outweigh harm.

We continue to object to the proposed use of uPVC windows within a conservation area due to their associated visual harm to the area.

One major cause for concern is the significant increase in the volume of glazing proposed across the south elevation of both dwellings. The site slopes steeply to the south down to the River Avon, with clear views out to the south to Bathampton and Bathampton Downs. These views form a significant aspect of the Green Setting OUV of the World Heritage Site. The proposed extent of glazing would therefore be detrimental in wider landscape views due to significant amounts of light spill and sun glare. We feel the lack of information provided as to how this new development would impact existing views and the landscape setting of the World Heritage Site is unsatisfactory, with landscape concerns being largely restricted to immediate views across the site and from the roadside. We suggest relevant documentation such as a Landscape and Visual Impact Assessment would be needed to inform design based on the site’s position and visibility within wider landscape views.

Considering the close proximity to the new development at Hicks Field immediately to the south down the slope, the volume of glazing may be the cause of overlooking issues, and we trust this will be considered by the case officer.

Whilst the dwellings are proposed to follow the natural topography of the site, it appears that part of the building to the north would need to be partially subterranean and would therefore require ground works, the potential extent of which is not expanded upon within this application. We maintain some concern as to how this will affect the archaeological integrity of the area. Historically, London Road is of Roman origin and therefore the likelihood of Roman burials and other material deposits is acknowledged to be strong. We continue to encourage that all works are either be prefaced by exploratory excavations by qualified professionals, or to include an archaeological watching brief for the duration of all ground works.

Application 19/05124/FUL states the following as a reason for refusal: “The proposed development due to its design, siting, massing, and layout would cause harm to the setting of the Bath Conservation Area. There are no clear and convincing justification nor will any public benefits accrue in relation to the proposed development.” We maintain that there have been no substantial changes to the design, layout, or scale of proposals and this reason for refusal therefore remains applicable to this current application.

In conclusion, this proposed scheme remains largely unchanged from application 19/05124/FUL with regards to the scale, massing, and density of development, lack of contextual understanding, and overdevelopment of the site. Whilst there have been some design amendments, we maintain that the proposed design remains insensitive to its historic setting and would not preserve or enhance the character of the conservation area, and be of detriment to the wider landscape setting of the World Heritage Site. Consequently, this application should be refused on the same grounds as previous, as additional dwellings to the rear of this site would ultimately result in detrimental harm to the setting of a NDHA, and the low-density character of this portion of the Bath conservation area. This application is therefore contrary to the Planning (Listed Buildings and Conservation Areas) Act 1990, section 16 of the NPPF, and Policies B1, BD1, CP6, D1, D2, D3, D5, D7, HE1, and NE2 of the Core Strategy and Placemaking Plan, and should be refused or withdrawn.