Internal and external alterations to include refurbishment and amendments to floor layouts to existing flats, replacement of staircase accessing third floor and changes to fenestration.
Our Response

101 Sydney Place forms part of a Grade I series of eleven terraced townhouses situated within the Bath Conservation Area and World Heritage Site. The terrace was constructed in 1808-1809, designed by John Pinch the Elder, and forms part of the unfinished vision of Sir William Johnstone Pulteney for the residential setting of Sydney Gardens, flanking the junction to Great Pulteney Street. The terrace is noted for its uniform, palatial façade punctuated with three pavilion style dwellings set forward at each end and at the terrace centre. Unusually, the attic storey is included as a separate storey within the body of the building, rather than being set back into the mansard slope. 93-103 Sydney Place forms the last section of terrace to be built surrounding Sydney Gardens and is consequently a significant indicator of an unfinished, speculative plan for the further expansion of Georgian Bath to the east and forms part of the Georgian Town Planning and Georgian Architecture OUV of the World Heritage Site.

Together with 99 and 100 Sydney Place, 101 Sydney Place was acquired by the then Bath Council and was used to provide student accommodation and classrooms for the Bath Arts Secondary School from 1952 up until 1997, when consent was given to convert 101 Sydney Place back into residential use as two dwellings. It is believed that 99-101 Sydney Place have largely survived subdivision into apartment-style accommodation and are rare examples of the terrace’s original townhouse plan form. The building is currently subdivided into a 3-bed basement flat and a maisonette across the ground-third floors.

BPT previously objected to application 21/00404/LBA for similar proposals to subdivide the building to create a self-contained maisonette at ground floor and lower ground floor level. We objected on the following grounds:

- We had concerns regarding the proposed further residential conversion of the lower ground floor vaults to create an additional bedroom and ensuite in place of the existing ‘snug’ and utility. These spaces are typically dark, damp, and poorly ventilated as part of their original character and as such do not lend themselves to being converted to a more ‘immediate’ residential use without increased pressure for invasive works such as damp-proofing.
- The proposed insertion of a staircase between the lower ground and ground floors in the rear hall would result in an unjustified loss of historic fabric, which would not be outweighed by any demonstrated public benefit.
- The proposed creation of a passage through the historic spine wall and chimney breast would result in the loss of original historic fabric and associated harm to the to the plan form of the building and how the principal rooms on the ground floor are accessed and experienced.
- We highlighted ongoing concerns regarding the lack of documentation of potential changes to the first floor ‘piano nobile’, and ambiguity as to how this floor would be integrated within the scheme. This floor is of particular significance as the main reception rooms for entertaining and consequently more ornately decorated with high ceilings and the tallest windows; as such, it remains the most sensitive to change with regards to its plan form, access from the main staircase, and internal detailing and plasterwork. (It was later clarified that the first floor would be retained in use as part of the ground/lower ground floor maisonette and would be accessed via the main staircase with no material interventions.)

We are therefore pleased to see that certain aspects of the previous 2021 application have been omitted, including the proposed ground-lower ground floor staircase and works to the under-pavement vaults. It is also proposed that the rear wine cellar vaults would be retained in their existing form where it was originally proposed to re-format this space.

The proposed third floor plans appear to be missing from this application and should be submitted to enable a proper assessment of potential impact. However, we maintain concerns about the proposed reconfiguration of the space to further subdivide 101 Sydney Place into two maisonettes between the ground-lower ground floors and the first-third floors, with continued proposals for intrusive material alterations to the ground floor in particular.

The interior photographs in the Heritage Statement show that despite the previous conversions, the interior is largely intact, and further subdivision would therefore result in clear harm to the special architectural interest of a Grade I building which remains unusually intact, in a terrace where the majority of townhouses have already been subdivided into individual apartments.

The insertion of a “mirrored or smoked glass partition” would impact the original plan form and flow of the building, closing off the front of the building from the rear. To allow movement between the ground and lower ground floors, access would be rerouted through the existing blind door into the sitting room; it is indicated that the blind door is a historic feature intended to symmetrically match the functional door into the principal ground floor room. As such, it remains a feature indicative of the Georgian focus on architectural symmetry both externally and internally. Whilst the Heritage Statement asserts that it was used as a functioning door in the mid-19th century, there is otherwise little evidence for this beyond the reference to the potential ‘piecing in’ of stone skirting in the outer lobby (see Fig 57, Heritage Statement) and we do not consider that this aspect of the works is sufficiently justified to outweigh resulting harm.

The proposed creation of a passage through the historic spine wall between the front and rear of the building, to enable access to the dining room from the rear hall, would result in a significant loss of historic fabric, including what is indicated to be part of the chimney breast and the fireplace in the utility room, and a fundamental alteration to the plan form of the building and how the principal rooms on the ground floor are accessed and experienced. The passage would curve awkwardly to avoid the fireplace in the rear hall and provide a narrow, concealed access completely out of character with the grand, double depth floor plan of the ground floor front rooms.

In accordance with the NPPF, where a proposed development will result in harm to the special interest of a listed building or associated loss of significance, it should be demonstrated that the harm can be outweighed by identified public benefit, and in the case of less than substantial harm, securing the optimum viable use of the building. At present, the building already forms two viable dwellings, with the basement flat having been occupied up until recently. It is therefore uncertain as to why subdivision would be considered to secure the “optimum viable use” of the building beyond increasing the market/rental value of the maisonette across the lower floors.

The reason given for the recent vacancy is due to safety issues associated with the steepness of the front lightwell steps. The proposed scheme therefore does offer some public benefit in the creation of a new and improved access route to the basement flat, but this must be given limited weight due to it being demonstrated that the basement flat remains a viable residential space that up until recently was still occupied. The external lightwell staircase is indicated to have been added c.1997 and there is a clear opportunity for works to this area to improve accessibility and provide associated public benefit by addressing issues with current access to the lower ground floor apartment. This work could allow the building to safely function as two units and negate the need for a large number of the other alterations. However, no works at all are proposed in this area as part of this scheme. Therefore, we do not consider that the proposed public benefits would be sufficient to outweigh the harm resulting from the loss of historic fabric and plan form.

This proposal therefore continues to risk causing unjustified harm to a Grade I building without being sufficiently outweighed by the demonstrated public benefits, and would harm the building’s contribution to the Georgian Architecture OUV of the World Heritage Site through harm to the plan form of what is considered one of John Pinch’s finest creations. This application is therefore contrary to the Planning (Listed Buildings and Conservation Areas) Act 1990, Section 16 of the NPPF, and Policies B1, B4, BD1, CP6, D1, D2, and HE1 of the Core Strategy and Placemaking Plan and should be refused or withdrawn.

Application Number: 22/04233/LBA
Application Date: 19/10/2022
Closing Date: 25/11/2022
Address: 101 Sydney Place, Bathwick, Bath
Our Submission Status: Object