Loch Fyne Fish Restaurant, 24 Milsom Street, City Centre

24 Milsom Street is a Grade II mid-19th century former bank, now restaurant, situated within the commercial core of the Bath conservation area and World Heritage Site. It forms a significant corner frontage on the junction of George Street and the top of Milsom Street and forms part of the setting of a high concentration of Grade II and Grade II* terraced buildings. It is one of a pair of mid-19th century former bank buildings with 23 Milsom Street (also Grade II listed), although they are credited to different architects and are not architecturally homogenous. Whilst the main focus of works is largely on internal refurbishment, the building is attributed high significance due to its imposing scale and prominent streetscape appearance, and the quality of detail across its ornamental façade. The building, previously in use as a mixed-use restaurant and hotel, has now been vacant for several years.

We note that applications have been submitted for the proposed signage alterations to the exterior (see 22/02222/LBA & 22/02216/AR), to which BPT will be responding separately.

We welcome proposals to bring this building back into sustainable long-term use. The building is currently vacant and boarded up at ground floor level, with detriment to the visual amenities of the street scene and the wider character and appearance of a significant historic shopping thoroughfare within the World Heritage Site. Plans to bring the building back into commercial use would therefore reactivate this area of the streetscape whilst securing the building’s future.

However, we have some comments on the following aspects of the scheme:

Proposed Installation of Secondary Glazing:

• In light of the Climate Emergency, BPT is supportive of the principle of secondary glazing where this does not have an adverse impact on the special architectural and historic interest of a listed building or the wider historic environment. We appreciate the potential for thermal improvements in this building to improve its commercial viability as well as suitable comfort for occupiers, but this must be balanced against possible heritage harm.
• The use of secondary glazing must be combined with a whole building approach to energy efficiency and insulation and we would expect this to be included in this application in the process of justifying the proposed intervention.
• Recognising the refusal of a similar proposal in 2015, and the current, improved scheme, we continue to feel that the use of sash-style secondary glazing would more appropriately mirror and sit behind the frames of the existing windows as the preferred option.
• However, we recognise that the installation of secondary glazing is a measure to increase the energy efficiency and thermal performance of the building and will contribute to reducing carbon emissions and therefore this degree of harm should be balanced against public benefit.
• We recognise that the less than substantial harm, and reversible installation would be outweighed by public benefit in this instance.

Proposed Interventions to Pavement Vaults:

• There is insufficient information regarding the existing condition, and proposed alterations to, the pavement vaults. It is proposed that these vaults would be used as cold storage, requiring an “internal waterproofing membrane” and the creation of a new barrel hoist opening through from the Milsom Street pavement.
• Figure 29 of the Heritage Statement indicates that a number of vaults retain metal safe doors, indicative of their original use as the bank vaults. However, it is unclear as to what extent these features survive and where, and how these would be affected by the proposed works. We suggest that this is clarified and could be highlighted on the existing floor plans, particularly in relation to the pavement vaults.
• We maintain that the current condition and value of the vaults should be summarised and appropriately balanced against the proposals. Whilst we recognise the need to make the vaults usable as part of the wider premises, BPT is typically resistant to the tanking or waterproofing of vaults where this would have a significant impact on their appearance and associated character as underground, ancillary spaces.

Proposed Installation of Orangery:

• We have some concerns regarding the proposed orangery structure in the rear courtyard. At this stage, the application does not provide sufficient information as to the contextual appearance and relationship of the proposed orangery with the main building, as well as the adjoining 25 Milsom Street with which the courtyard was historically affiliated. The specification drawings as provided are ambiguous and fail to illustrate how the new structure would relate to a Grade II listed building and its setting.
• We strongly recommend that existing and proposed elevations are provided of the orangery, as well as broader contextual elevations and cut-through sections that show the orangery within its setting. The proposals also include “new fabric covered walkway to orangery” which it would be helpful to include in external elevations.
• Considering the more permanent enclosure of the courtyard area, there may be an associated increase in activity and noise as part of the use of the main building, although there does not appear to be any indicated change in opening hours from previous. We trust that any potential amenity issues will be considered by the case officer.