Proposal
Internal alterations to convert the upper floors into 4no. residential units.
Our Response

BPT supports the opportunity for the residential conversion of the upper floors of this Grade II terraced building, with the existing commercial use of the ground floor to be retained as existing. We welcome proposals for the provision of much-needed residential accommodation within the city centre and consideration of a mixed-use sustainable use of a listed building, with resulting public benefits including its continued use and occupation and associated ongoing maintenance and repair.

It is proposed to insert a new external door in the ground floor shopfront to facilitate a separate residential access to the upper floors. It is noted that the shopfront at No. 18 is a later addition attributed to the latter end of the 20th century, replicating the design of the earlier 1911 shopfront at No. 17 (Historic England). Whilst the shop frontage is now considered as a whole due to the shared shop unit across the ground floors of Nos. 17 & 18, there is still a visible distinction between the two halves where the portion of glazing at No. 18 is considerably recessed to form the principal access into the shop. The addition of a new external door would therefore result in the loss of late 20th century glazing and there would be no loss of historic fabric. It is indicated that the positive architectural aspects of the shopfront, such as the regularly placed fluted columns with Corinthian capitals would not be affected by the proposed works, and the overall appearance and rhythm of the ground floor frontage retained. Works would therefore result in the lower end of less than substantial harm which would be outweighed by the public benefits of bringing the upper floors back into an active use.

We strongly recommend that further details are provided regarding the proposed design, appearance, and material finish of the new external door to ensure this would be coherent with and sympathetic to the special interest of a listed building and the existing appearance of the shopfront.

BPT is generally supportive of the energy efficiency upgrade of listed buildings, including measures such as secondary glazing and slimlite double glazing which form part of the proposals, so long as it can be demonstrated that works would be sympathetic to the appearance and associated special interest of the listed building. We encourage provision of relevant sections of the proposed secondary glazing and slimlite double glazed units in situ to ensure these would be of an appropriate thickness and profile consistent with the traditional fenestration style of the wider terrace.

We further recommend that if internal insulation is to be consider then a conditions survey should be submitted to mitigate and highlight any fabric risk and unintended consequences, along with details of the type of internal insulation to be used in the 19th century rear extension, as well as its proposed thickness and how it would interact with the internal space (we note the D&A Statement indicates a lack of surviving internal details or decorative finishes). BPT continues to be very interested in potential case studies for the implementation of internal insulation within Bath’s historic building stock which may be used to inform future proposals elsewhere in the City.

The internal subdivision of the proposed apartment within the rear extension at first floor level would be somewhat awkward due to following the octagonal form of the roof lantern, resulting in small constrained bedrooms as shown on the proposed floor plans. Further consideration of how the internal layout and space provision could be improved is encouraged.

The upper floors of No. 17 would be excluded from the scheme, where these are still accessed via a separate stair within the middle of the shop floor. There are understandable restrictions associated with No. 17 where potential residents would have to walk through the shop to access the existing stairwell. It is presumed that the upper floors of No. 17 would therefore remain associated with the commercial use of the ground floor (eg. stockroom storage), but we would encourage further consideration as to possible options for its refurbishment and reuse where this would be of benefit to the continued sustainable use of a listed building and its contribution to the vitality and amenity of the Bath City-Wide Conservation Area.

Application Number: 23/03108/LBA
Application Date: 21/08/2023
Closing Date: 29/09/2023
Address: 17-18 Milsom Street, City Centre
Our Submission Status: Support