Erection of Home Extension at the fourth floor level, front and rear infill Home Extensions, external alterations and revisions to existing entrance onto Railway Place.
Our Response

The Trust objects very strongly to this application on the basis of harm to the setting of multiple significant listed buildings, to the conservation area and the World Heritage Site. Whilst we support the sustainable principle of refurbishing buildings rather than demolish and rebuild, 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 WHS is neutral in effect. The proposals will have a negative effect on the WHS and are the opposite of sensitive adaptation (HE.1); they will therefore not maintain the significance, integrity and authenticity of the WHS. The reasons for this are:

• The adding of an extra storey to the building results in a scale of building that dominates over and intrudes upon the setting of multiple heritage assets, including the Grade II* Brunel Railway Station, Royal Hotel, Argyle Hotel, Bayntun’s Bookshop and Ralph Allen House. These assets form an historic grouping around the station and part of their significance derives from their association with it. An intervention into this grouping should be sensitively scaled and designed to assimilate and complement not to overpower the historic context.

• The building is situated in an important gateway location to the WHS and as such should be a building of exemplary design and comfortably, contextually scaled so as to complement and enhance the qualities of the WHS, not detract from them.

• The ‘boxing in’ of elevations creates a lack of articulation to the elevations and the roofscape, and results in a bland, barren 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 WHS.

• The 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 the lights are blazing well into the night in an historic city where low light levels are the norm. We assume there will be ecological issues relating to this as well.

• We do not see the increase in the height of 20 Manvers Street should act as a precedent for other insensitive and inappropriate development as this will also cause cumulative harm to the character and appearance of the conservation area and the OUV of the WHS.

• We believe the LVIA’s show the level of harm this building will have on important long views into and out of the city. In particular it eats into and erodes 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.

We strongly urge the case officer to consider the issue of the increased height of the building, the extent of glazing and the light pollution created. We would recommend the building is reduced in height by one storey at the very least.
The proposed scheme would neither preserve nor enhance the special interest of the adjacent listed buildings nor their setting, it would harm 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, policies B1, B2, B4, and CP6 of the B&NES Core Strategy and policies CP6, D2, D5, HE1, D8, B.4, B.2 and BD1 of the Placemaking Plan. We would therefore recommend the application be withdrawn or refused.

Application Number: 18/04248/FUL
Application Date: 25/10/2018
Closing Date: 25/10/2018
Address: 4-5 Railway Place, City Centre
Our Submission Status: Object