Internal alterations to convert the existing 7 Bedroom HMO into an 8 Bedroom HMO.
Our Response

3 Hay Hill is a Grade II listed early 19th century terraced residential building, situated within the Bath conservation area and World Heritage Site. It forms part of the 18th century street between the Paragon (formerly identified as London Road) and Lansdown Road, and as such constitutes part of the contextual streetscape context of a high concentration of Grade II listed late 18th century buildings along Belmont and the Vineyards, as well as the other Grade II late 19th century buildings at 1-3 and 5-6 Hay Hill. The Hay Hill streetscape is of a varied form and height, although development of four storeys is largely concentrated to the eastern and western junction points, with the exception of 3 Hay Hill which is centrally placed despite its four-storey height. It otherwise reinforces the established Bath stone ashlar palette of the area with regular, centrally placed windows. The treatment of the ground floor with a timber fascia and offset front door position is indicative of a historic shopfront which has since been removed.

It is recognised that the building is already occupied as a 7-bed HMO.
BPT maintains concerns regarding the proposed conversion of the basement floor to provide new bedrooms to increase the building’s total capacity to 8 beds. It is indicated that “the lower ground suffers from poor ventilation and elevated levels of damp”; we highlight that this is indicative of Bath’s distinctive variety of basements and cellars which were originally ancillary (eg. storage) to the principal domestic use of the main building. It is not considered that the basement level is appropriate for any intensified residential use such as bedrooms, where this would be of inadequate residential amenity for residents whilst also placing the listed building under increased pressure to meet unachievable standards of modern performance.

We note that the scheme proposes to address identified damp issues by “[running] an industrial dehumidifier for one week to extract excessive moisture” and “[applying] tanking & latex finish to seal the floor surface.” No further information is provided as to the proposed type of tanking intervention to be used and potential impact on historic fabric. We do not encourage the implementation of possibly irreversible interventions to manage damp where this may not be compatible with the traditional permeable qualities of historic fabric, and could result in long-term problems or damage.

We therefore consider that proposals would fail to provide appropriate levels of residential amenity, contrary to Policy D6 of the Core Strategy and Placemaking Plan. We do not consider that the provision of an additional bedroom is adequate justification for proposals, with the existing 7-bed capacity of the building already being a high-density and intensive residential use.

Application Number: 22/02696/LBA
Application Date: 05/07/2022
Closing Date: 18/08/2022
Address: 3 Hay Hill, City Centre, Bath
Our Submission Status: Comment