Variation of condition 14 (Plans List) of application 21/05080/LBA (External and internal alterations to ground, first, second and third floors to provide 4 flats, and other external works).
Our Response

2 Bath Street forms part of a Grade I 1791-1794 terrace situated within the commercial core of the Bath conservation area and World Heritage Site. It sits opposite 9-16 Bath Street, which is also Grade I. Together, both terraces form part of the Bath Improvement Scheme of 1789 by Thomas Baldwin, and create a visual avenue between the Grade I 1783-4 Cross Bath and the Grade I 1788-9 colonnaded entrance to the Queen’s Bath. It consequently forms part of the 18th Century Town Planning and 18th Century Architecture OUV of the World Heritage Site. The ground floors have since been converted to commercial use with a lightweight, contemporary treatment, either utilising single panes of glazing or replicating traditional sash forms of fenestration.

BPT previously objected to listed building applications 20/04337/LBA, and later 21/05080/LBA on grounds of unjustified harm to historic fabric and the special architectural and historic interest of the listed building. Where these have been granted consent, we acknowledge that the principle of works has already been secured, but we take this opportunity to continue to highlight potential concerns in relation to proposed alterations to the principal Bath Street frontage, and the wider grouped special interest of the Grade I Bath Street assemblage.

Revisions to the scheme include the reduction of the width of the ground floor bin store, which would place greater emphasis on the glazed access to the upper floor apartments (in a similar style to that already existing). This change is welcomed and we feel that the redistribution of visual hierarchy towards the proposed residential access point is more appropriate.

However, we maintain that the proposed bin store access would continue to be an overtly ‘service’ addition to the principal elevation due to its use of ventilation louvres and obscured glazing, and remains better suited to Bath’s backland character. Within this context, the ‘utilitarian’ character of the proposed service door and ventilation grille on a the principal façade of a Grade I building would be highly inappropriate and would visually ‘deaden’ what is now a popular commercial street through the use of obscured glazing, and would neither preserve nor enhance the appearance of character of the conservation area.

We continue to highlight that the existing refuse collection and storage areas for use by the offices are highlighted as part of the plans, and ask why these could not be appropriately reused for residential refuse. Where the principle of a ground floor bin store on Bath Street has already been secured in application 21/05080/LBA, we highlight the need for appropriate refuse management to ensure that bins are promptly put away following a collection. There is a concern that bins may be left out beyond collection times and result in the cluttering of a high-significance historic street within the city centre, which would be of cumulative visual detriment to the setting of multiple heritage assets including a number of Grade I listed buildings, the Bath conservation area, and the World Heritage Site.

We maintain that the proposed frontage treatment would continue to constitute harm to the significance of a Grade I listed building without being outweighed by any substantial public benefit, would neither preserve nor enhance the appearance and character of the conservation area, and would harm the special interest and erode the 18th Century architecture value of the World Heritage Site. 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, D3, D4, D5, and HE1 of the Core Strategy and Placemaking Plan and should be refused or withdrawn.

Application Number: 22/04949/VAR
Application Date: 08/12/2022
Closing Date: 20/01/2023
Address: 2 Bath Street, City Centre, Bath
Our Submission Status: Object