Internal and external alterations to ground, first, second and third floors to allow for change of use from office Class E (g)(i) to residential Class C3 (a).
Our Response

2 Bath Street forms part of a Grade I 1791-4 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 Georgian Town Planning 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.

The Trust does not oppose the residential conversion of the upper floors to provide much-needed residential accommodation within the city centre, although we emphasise our preference for accommodation to be tailored to suit long term occupation by local residents rather than short term holiday lets or seasonal student usage.

However, we object to the proposed elevational treatment regarding proposed apartment access and bin storage. The new access doors would result in the loss of a section of decorative frieze that runs around the north, north-east, and east elevations of the terrace and matches that surviving on 9-16 Bath Street. Its removal would constitute an irreversible, unmitigated loss of historic fabric and consequent substantial harm to a Grade I listed building without demonstrated public benefit, and would significantly unbalance the dual, symmetrical appearance of both terraces along Bath Street. Access to private apartments does not constitute a public benefit. This application would therefore propose harm to the special architectural and historic interest of a listed building and is contrary to the Planning (Listed Buildings and Conservation Areas) Act 1990 and Section 16 of the NPPF.

Furthermore, the proposed insertion of ventilation louvres and obscured glazing would constitute a ‘service’ treatment of a significant street elevation. This design is more in keeping with Bath’s backland character and could be deemed appropriate on a concealed rear elevation. However, Bath Street remains a fundamental example of monumental Georgian design and town improvement at the heart of the Bath conservation area and World Heritage Site. Within this context, the proposed access is 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 ask 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.

This application would constitute harm to the significance of a Grade I listed building, which is not 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 OUV 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: 20/04337/LBA
Application Date: 17/11/2020
Closing Date: 24/12/2020
Address: 2 Bath Street, City Centre, Bath
Our Submission Status: Object