Frome House, Lower Bristol Road, Westmoreland, Bath

Frome House is a late 20th century unlisted building situated within the Bath World Heritage Site and the indicative townscape setting of the Bath conservation area. The existing building is three storeys in reconstituted Bath stone with an attached two storey building on the corner junction between Lower Bristol Road and Jews Lane. The ground floor currently functions as the premises of Bathwick Tyres, whilst the upper floors are vacant offices. The immediate setting of the site is predominantly residential to the north and west; adjacent to the site are a number of two storey Victorian terraces, Argyle Terrace, fronting Lower Bristol Road. There are examples of smaller, low-rise commercial properties at Avon Buildings, as well as the Grade II 1960s former cabinet maker’s factory, now a Lidl.

There is already a high concentration of student accommodation provision along Lower Bristol Road. Accommodation to the east includes Waterside Court and Charlton Court, which front Lower Bristol Road with four storey frontages. Similarly, Twerton Mill further west fronts the roadside at three and four storeys, forming a sense of visual enclosure adjacent to the Grade II Twerton Viaduct in sharp contrast with the more visually open setting of Frome House. In all cases, student blocks of an increased height are restricted to the rear, pushed back from the roadside to minimise visual impact.

BPT previously objected to application 21/04147/FUL on grounds of excessive height and massing and incoherent design which would fail to sustain local distinctiveness. We maintained an in-principle objection to speculative purpose-built student accommodation (PBSA) without evidence of justified need from an education provider.

The scheme as currently proposed would use the existing envelope of the building, occupying the first and second floors without a proposed increase in height or significant alterations to the building exterior. We therefore have no design comments to raise at this stage.

We maintain that we are supportive of the reuse and refurbishment of the existing building. We maintain that ‘the greenest building is the one that already exists'; in light of the declared Climate Emergency, it is clearly of increasing importance to reuse our existing building stock and reduce carbon emissions generated through demolition and the construction of new buildings and construction materials. The retention of existing buildings also prevents the release of ‘embodied carbon’, or the carbon footprint generated from a building’s initial construction.

However, we maintain our in-principle objection to the provision of speculative PBSA. The site is located within an area of high PBSA provision and over 25% HMO saturation, and therefore already has a disproportionate makeup of student-orientated housing. We maintain that accommodation provision should be properly integrated with the anticipated growth and expansion of Bath’s universities and education providers, rather than speculative development driven by market demand. There is no indication or justification that the provision of PBSA would “release” existing HMOs back into the family housing market.

We maintain a preference for the use of these sites to provide much-needed housing for local residents and key workers within close proximity to the city centre.
We therefore remain resistant in principle to speculative PBSA. This application is contrary to section 7 of the NPPF and Policies B1 and D1 of the Core Strategy and Placemaking Plan and should be refused or withdrawn.