Erection of extension at the fourth floor level, front and rear infill extensions, external alterations and revisions to existing entrance onto Railway Place (Resubmission).
Our Response

4-5 Railway Place is an unlisted, late 20th century office building situated within the core of the Bath conservation area and WHS. It is located opposite the Grade II* Bath Spa Station, and adjacent to numerous Grade II buildings including the Ralph Allen House, the Royal Hotel, Bayntun’s Bookshop, and the Argyle Hotel. Therefore, the visual impact on both the conservation area and setting of listed buildings must be considered with any proposed changes to this sensitively-situated site.

The Trust maintains its objection to this proposal on the basis of harm to the setting of multiple significant listed buildings, to the conservation area and the WHS. Whilst we support the sustainable principle of refurbishing buildings rather than demolition and rebuilding, in this case the proposed result of refurbishment will introduce a building of unacceptable height, scale, design and materiality into this part of the cityscape.

Whilst there is certainly scope to upgrade this building, the visual contribution it currently makes to the conservation area is neutral in effect. Therefore, whilst we appreciate changes have been made to this scheme with the intention to reduce the building’s height and lessen its aesthetic impact, we maintain that this proposal will detract from the character and appearance of the conservation area and have a negative effect on the special qualities of the WHS. Therefore, this design is contrary to Policies B4 and HE1 of the Core Strategy and Placemaking Plan for the following reasons:

The addition of an extra storey to the building results in a scale of building that dominates and visually intrudes upon the setting of multiple heritage assets, including the Grade II* Bath Spa Station and Grade II assets including the Royal Hotel, the Argyle Hotel, Bayntun’s Bookshop and the Ralph Allen House. These assets form a historic grouping around the station and part of their significance derives from their association with it. Any intervention into this grouping should be sensitively scaled and designed to assimilate and complement, not to overpower, the historic context. Despite the reduction of the proposed roof height by 1.5m, this still entails a significant visual increase in the building’s massing that conflicts with the low and varied roof height of the surrounding historic landscape.

Furthermore, the ‘boxing in’ of elevations creates a lack of roofscape articulation that results in a bland, monolithic design which does not add interest to the cityscape either at street level or at long views level. In particular the proposed flat roof results in an intrusive, expansive form in long views; the current building roofscape is broken down which reduces its impact and helps it assimilate with the overall roofscape character of the conservation area and WHS. The existing, variegated height of the roofline is more in keeping with lower-level historic streetscape in this region of Bath; therefore, the planned roofline uniformity of this application remains a direct detriment to the architectural diversity of the Bath conservation area and WHS.

The continued use of extensive glazing with intrusively lit internal space is harmful both in long and short views, especially as this level would be visible from many vantage points across the city. The visual harm caused by the glazed top floor of 20 Manvers Street is now apparent to all, and is especially exacerbated when brightly lit at night in an historic city where low light levels are the norm. We appreciate that attempts have been made to reduce glazing through the insertion of stone panels between the panes of glass, and the setback of the fourth storey from the parapet to limit the dominant, top-heavy impact of the glazing as negatively seen at 20 Manvers Street. However, the lack of proposed night-time CGIs provided within the application demonstrates a continued lack of understanding as to the potential light pollution affects the setting of listed buildings, potentially Bath Abbey in some views, the character and appearance and views of the conservation area, and the authenticity, integrity, and value of the WHS.

We uphold the belief that the LVIAs show the level of harm this building will have on important long views into and out of the city. In particular it risks intruding into the important green views of Beechen Cliff when viewed from points such as South Parade. Views into the city from Beechen Cliff show the impact of the building, dominating the sensitive historic context, neither visually contextual nor respectful but over-domineering and therefore harmful.

Therefore, whilst we appreciate that changes to the proposal have been made on the basis of our previous concerns, the similarity of design, the infill of the roofline, the over-dominating use of glazing, and increased roof height will continue to harm the special interest of the adjacent listed buildings and their setting, would neither preserve nor enhance the character and appearance of the conservation area and would detract from the special qualities of the WHS. The scheme would be contrary to Section 16 (Conserving and Enhancing the Historic Environment) of the NPPF, and Policies B1, B2, B4, CP6, D2, D5, HE1, D8, and BD1 of the Core Strategy and Placemaking Plan. We would therefore recommend this application be withdrawn or refused.

Application Number: 19/04462/FUL
Application Date: 15/10/2019
Closing Date: 21/11/2019
Address: 4-5 Railway Place, City Centre
Our Submission Status: Object