Internal and external alterations for the erection of rear roof extension to convert the attic floor into three new rooms with minor internal alterations.
Our Response

3 Abbey Green is a Grade II listed house, now hotel, situated within the Bath conservation area and World Heritage site. It forms part of the Abbey Green townscape, the centre of which is recognised as a Scheduled Monument. 3 Abbey Green dates to 1700, with some later 18th century alterations, and is therefore highly significant in terms of its architectural and historic rarity in a city of largely early to mid-18th century construction. It additionally complements the unusual streetscape of Abbey Green around which survives a cluster of several Grade II and Grade II* late 17th and early 18th century buildings. We would therefore emphasise the greater aesthetic, architectural, and historic significance of 3 Abbey Green, both individually and within its historic context, which should be suitably understood and reflected in any material alterations or additions made to the building.

The Trust cannot support this application due to the inadequate documentation provided as part of the application, and concerns with the height and design of the proposal.

In principle, we cannot support applications that do not meet the requirements of the NPPF section 189, which requires an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. The relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary. We are unsure as to why the LPA validated this application without requiring an acceptable analysis of the building's history and development, and a clearly demonstrated understanding of its significance both in its own right and within its built context.

This application fails to suitably demonstrate an understanding of the building’s history, any material changes over time, and its visual contribution to the wider conservation area. Therefore, the proposed changes to the building’s roofline cannot be suitably assessed with regards to how this might either enhance or impact the building’s special architectural or historic interest.

We question the D&A Statement which claims that “there is no evidence to suggest that the new attic floor and roof extension will represent any harm to the inherent values of the house”. No information has been provided regarding the age of the existing roof, which the Trust suspects to be a late 20th century replacement, or the plan form, height, and design of the original roof as contemporary to the rest of the building structure. Should a roof extension be consented, we would expect 3 Abbey Green’s previous roof profile(s), as documented in available plans and photographs, to be considered throughout the design process so that any alterations to the building’s exterior are made with a full understanding of the impact and degree of harm to the building’s special historic and architectural interest.

We would emphasise that considering 3 Abbey Green’s comparative historic rarity within Bath, additional care needs to be taken to prevent the irreparable loss of either historic fabric or aesthetics which is otherwise not strongly represented within the conservation area and World Heritage site. We do not feel that this application appropriately highlights 3 Abbey Green’s specific and unusual significance at all.

With regard to the current proposal, we feel that the proposed M-type roof is of an excessive height and pitch, particularly in comparison with its neighbours as visible in the Proposed Roof Perspectives provided. We would strongly recommend that any roof extension should be recessive in its scale and sit comfortably below the ridge line of the principal front-facing roof.

We additionally feel that the current orientation and height of the M-type roof is over-dominant due to the proposed roof line sitting over the rear chimney stack. Following some consideration of the existing roofscape of the Abbey Green area, we would ask whether a different roof orientation had been considered in which a single ridge runs parallel with the existing roof ridge to create an internal valley gutter so as to better align with the rear chimney stack, although we would continue to emphasise that the suitability of this design is dependent on whether this would be a restoration of 3 Abbey Green’s traditional form.

Finally, we are concerned regarding the insertion of multiple slimline double-glazed windows in the exterior of a listed building, principally the 3-by-3 sash dormer window in the elevation facing onto Abbey Green. Whilst we acknowledge the position of the dormer window is fairly discreet and has little visual impact on the collective appearance of windows in this house and terrace, we would question the proposed glazing bar profile and thickness in relation to the building’s existing windows, and consequently the overall visual character of the windows. We would therefore require detailed measurements of existing windows to be submitted to enable the LPA to assess the historic compatibility and visual impact of the proposed window profiles.

Therefore, the Trust maintains a strong objection to the scheme on the grounds of insufficient documentation in support of the application. Without a proper understanding of the special architectural and historic interest of 3 Abbey Green, an assessment of the impact on the significance of the listed building cannot be made and therefore risks causing substantial harm to the heritage asset. Notwithstanding this serious absence, we would maintain that the proposed roof alteration would by virtue of its inappropriate and over dominant size and design harm the architectural and aesthetic interest of the listed building. Any roof alterations should be suitably subservient to the current form and appearance of the building, and should sit well below the principal ridge line. 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, D5, and HE1 of the Core Strategy and Placemaking Plan, and should therefore be withdrawn until a suitable Heritage Statement that assesses the historic and architectural significance of the site is provided. The Trust will respond in further detail when the adequate analysis has been provided.

Application Number: 20/00885/LBA
Application Date: 03/03/2020
Closing Date: 09/04/2020
Address: 3 Abbey Green, City Centre
Our Submission Status: Object