External alterations for widening of existing opening in stone wall by 450mm and the positioning of a charging point for electric car.
Our Response

31 St Mark’s Road forms part of a pair of Grade II listed semi-detached mid-19th century dwellings, situated within the Bath conservation area and World Heritage Site. It forms part of the contextual street setting of a high concentration of Grade II early to mid-19th century terraced and semi-detached dwellings along St Mark’s Road, culminating in the Grade II early 19th century St Mark’s Church, now St Mark's Community Centre. The mid-19th century boundary wall with arched tracery and rounded stone piers is explicitly included within the building’s Grade II listing description as a subsidiary feature of interest; the wall forms a shared boundary treatment at 30 & 31 St Mark’s Road whilst matching similar design examples at 28 St Mark’s Road and 32 & 33 St Mark’s Road. This may be attributed to a shared design approach or architect as part of the burst of 1860s development along the north side of St Mark’s Road. It is noted that a high number of properties in this area have already converted their front gardens to provide off-street parking, including at 31 St Mark’s Road, and therefore the principle for this use has already been established.

It was previously proposed in application 21/04755/LBA to remove a 0.65m area of boundary wall. The proposed amount of fabric to be removed has been reduced and it is now proposed to remove 0.45m of boundary wall with a reduced material impact on historic fabric.

We are supportive of the opportunity to improve the integration of the driveway access with the historic boundary wall. It is indicated that the opening as existing is a later, likely 20th century intervention due to the balustrade tracery ending in a half-arch against the western gate pier. The removal of a small section of wall would therefore allow for a more symmetrical articulation of the wall and the intersecting vehicle access.

However, we recommend that further material details are provided as to how the stone tracery will be finished beside the pier which is to be moved.
Section 202 of the NPPF specifies that “where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use.” It is considered that the proposal would constitute less than substantial harm to a heritage asset due to a minor loss of historic fabric. This must be considered against the following identified public benefits as part of the planning balance:

- Repairs to the historic west pier, which has been progressively damaged through ongoing driveway use and the narrow width of the driveway entrance. It is noted that widening works would also ensure that future damage would be prevented by allowing for adequate passing space.
- The replacement of the existing tarmac hardstanding with pennant paving, a surface treatment more in keeping with the character and setting of the listed building.
- Improved access to existing off-street parking space would help to reduce ongoing and future pressures on on-street parking and associated impact on the visual amenities of the area.
- Opportunity for sustainability measures such as the installation of EV charging.

We therefore conclude that the cumulative weight of public benefit would therefore outweigh identified less than substantial harm.

We note that in the case officer’s Delegated Report for refused application 21/04755/LBA, concerns were highlighted that the granting of consent to increase the opening width would “set a precedent that would compromise the Local Planning Authority's ability to resist similar proposals in the future.” We emphasise that planning applications should be considered on their own merits and therefore maintain that the suitability of alteration or demolition works to a boundary wall remains to be determined on a case-by-case basis. In this case, we conclude that the marginal loss of 0.45m of boundary wall would be appropriately balanced by a series of identified public benefits including repairs to historic fabric as well as sustainability measures which would accord with the council’s environmental objectives.

Application Number: 22/01578/LBA
Application Date: 07/04/2022
Closing Date: 28/06/2022
Address: 31 St Mark's Road, Widcombe, Bath
Our Submission Status: Support