36 Milsom Street, City Centre
We object to this application on the basis that the change of use is contrary to policy and no justification has been supplied to support the application. We are surprised that such a scant application should come from B&NES given that we feel the Council should be leading by example. Milsom Street is a primary shopping street and has a distinct character as such. This character is underpinned by the historic use of the street as a shopping centre and therefore the shopping use is part of its special historic interest. The proposal to include an A3 use is in our view inappropriate and unwanted and would harm the special historic interest detailed above. An A3 use could lead to legitimate but inappropriate food businesses within what is Bath’s most prestigious shopping street. In our view there is already a good mix of A3 offerings within the street with both cafes and restaurants (some that are empty) and losing another shop floor and frontage would be harmful to the shopping function of the centre (as per policy CR3) and result in an oversupply of A3 which could cumulatively harm the retail character of the street. Other secondary areas, including Kingsmead Square which is a café hub, are more appropriate for the balance towards A3 to be skewed. Moreover, following a change of use there would be no control over the type of food business to lease the space.
The lack of supporting information is disappointing; no business case or justification has been provided as to why A3 use is needed and consequently why A1 use is not viable. We would except to see some form of business case added to the application for any informed decision to be made.
The proposed scheme would neither preserve nor enhance the character and appearance of the conservation area, would harm the balance and vibrancy of the primary retail area and would detract from the special qualities of the WHS. The scheme would be contrary to the Town and Country Planning Act 1990 (Listed Buildings and Conservation Areas) sections 16, 66 and 72, Section 12 (Conserving and Enhancing the Historic Environment) of the NPPF, policies B1, B2, B4, and CP6 of the B&NES Core Strategy, policies HE1, B.2, CR3 of the Placemaking Plan and Saved Policy S.5 of the Local Plan. We would therefore strongly recommend the application be withdrawn or refused.