Rising Sun, 58 Lymore Avenue, Twerton, Bath

The Rising Sun is an unlisted former public house, situated within the World Heritage Site and the indicative townscape setting of the Bath conservation area. The building appears to date to the late 19th century and has retained its historic L-shaped form in Bath stone ashlar, albeit with substantial later (likely 20th century) additions to the southern elevation. Due to the pub’s 2 ½ storey form and prominent position along the north-west – south-east slope of Lymore Avenue, it positively contributes to the streetscape as a distinctive built feature. The pub has since been converted to residential use and currently operates as a 10-bed HMO, but retains notable features such as a hanging sign at first floor level that allude to its historic use.

The proposed development incorporates both the former pub building and the undeveloped site running down the slope adjacent to the roadside, previously in use by the pub to provide outdoor seating and limited parking. As existing, the streetscape is defined by the presence of modest two-storey turn-of-the-20th century terraced housing in a mix of Bath stone ashlar and red brick, with a stepped roofline that follows the slope of the roadside. Later additions to the north include 1930s terraced housing with elevated front gardens that therefore read as taller, although these are focused opposite the more significant gabled elevation of the former pub.

There is existing planning permission to develop the site to provide three detached four-bed dwellings (see 14/05259/FUL). Therefore, the principle of the residential redevelopment of this site has already been established as acceptable.

BPT is supportive of a proposed terraced layout, which would be more in keeping with the site’s immediate residential context.

However, we feel that this scheme as proposed would constitute overdevelopment of the site due to the excessive scale and height of the terrace, and floor area ratio which deprives the development of any meaningful amenity space or nature positive space. The immediate context of the site reads as modest and low-profile in scale, generally 2 storeys in height (Bath City-Wide Character Appraisal, 2005), with buildings of 2 1/2 – 3 storeys functioning as distinctive townscape landmarks. The proposed terrace reads as 3 storeys with the bays on the principal elevation running up to gabled dormers at roof level, resulting in a perceived increase in streetscape height by a storey. The rear elevation is visibly even taller at 3 ½ storeys due to the land gradient. The development would therefore be an over-dominant addition to the street scene out of keeping with the modest grain of its townscape setting. It would overshadow the adjacent terrace rather than complementing and contributing to the area’s established terraced form and distinctiveness.

The proposed footprint of development would push up against the southern elevation of the former pub building and result in a cramped, awkward intersection between the terrace and a detached, standalone feature of local interest, as well as significantly restricting the outdoor amenity space available for use by the future residents of the 6-bed HMO. The cumulative massing of the terrace would near-completely obscure the historic gable end of the former pub as viewed from the south up Lymore Avenue.

Furthermore, we have strong concerns regarding the future residential amenity of these dwellings. Considering each house is four-bed and would likely be occupied as a family home, the tiny, constricted rear courtyards overshadowed by three storey extension offshoots to the north and south would be completely inadequate. Policy D6 of the Core Strategy and Placemaking Plan specifies that “development must provide for appropriate levels of amenity”, including “provision of adequate and usable private or communal amenity space and defensible space.” Whilst the existing streetscape is of a tight terraced grain, terraces at Lymore Avenue, Lymore Gardens are provided with generous rear garden plots. Even streets such as Dartmouth Avenue with more restricted gardens have a greater volume of outdoor space than proposed in this scheme and good access to natural light.

We therefore maintain that the proposed scale and volume of development is immoderate in relation to the size of the site, and would sit poorly in its streetscape setting at detriment to local townscape character. It would fail to deliver acceptable amenity space and facilities for future residents. This application in its current form is inappropriate, and we strongly recommend the scale of the scheme is reduced to allow for a reduction in roof height and a more relaxed layout with increased amenity space. A reduced number of dwellings and/or a reduced number of bedrooms per dwelling could be considered.

The provided proposed General Arrangement Plans 1 & 2 appear to indicate that Bedroom 3 in a number of the dwellings would have no windows and therefore no access to natural ventilation or light, contrary to Policy D6 of the Core Strategy and Placemaking Plan. This would also likely fail to meet fire safety requirements in Section 2, Approved Document B of the Building Regulations 2010, and we therefore recommend that this is suitably amended.

We question the practicality of the proposed provision of 10 parking spaces using an underground docking system, and how these spaces will be maintained and secured to ensure their functionality. This type of parking system is better suited to staffed parking areas where malfunctions can be easily and quickly addressed. We consider that this proposed parking provision is an over-intensive use of the site and is indicative of the overdeveloped, cramped nature of the proposed development without adequate space for supporting facilities.

It is unclear as to whether the principal elevations would be clad in natural Bath stone ashlar, or reconstituted Bath stone; we express a strong preference for a natural Bath stone to materially echo the adjacent terrace. There are no further details regarding what is meant by ‘rangework’ proposed for the principal bays and the two storey extension to the former pub building, and how this would sit against the proposed Bath stone in construction, colour, and material finish. We have some concerns that this material type would be out of keeping with the material character of the area, and would sit oddly against the palette of Bath stone ashlar. We strongly recommend that further details regarding the proposed materials are supplied as part of this application, rather than being left to condition. A stone-coloured render rather than the proposed white render across the rear elevations may be more visually congruous with the defined appearance and character of the area.

In light of the declared Climate Emergency, we emphasise the need for high quality, sustainable housing that uses appropriate measures to minimise emissions, lower energy usage, and make use of sustainable materials where appropriate. We feel that this scheme could do more to ‘build in’ green energy production and microrenewables. We additionally note that in the Sustainable Construction Checklist, it is specified that “The SAP calculations for the proposal show how solar PV can be utilised to meet the policy requirements. The total PV systems would comprise of 26 no 250W panels, or other panels options available to meet site wide capacity shown below.” No panels are indicated on any of the proposed roof plans, and it is unclear as to whether this measure would be implemented as part of the scheme.

Considering the green, undeveloped character of the site as existing, appropriate ecological assessment may be required to assess any potential adverse loss of biodiversity as part of the proposed scheme.

This application would have an adverse impact on local distinctiveness and townscape character and would fail to positively respond to its context, contrary to Policies B1, BD1, CP6, D1, D2, D3, D4, D5, D6, and D7 of the Core Strategy and Placemaking Plan, and should be refused or withdrawn.