Basement Flat, 9 Sion Hill Place, Lansdown, Bath

Internal and external alterations for the installation of 2No. timber framed sliding sash window units within front Courtyard.
Our Response

BPT maintains some concerns regarding the scope of proposals and potential impact on historic fabric and the associated character and significance of a listed building. The application provides insufficient information regarding the original function and use of the “study” in relation to the main building. From the photographs provided, the distinctive curved form is indicative of originally being part of the vaults, having since been altered and converted to a more directly residential use as part of the basement flat. The existing plans similarly indicate the presence of what may be vault-specific features such as coal chutes in the southern wall.

We maintain an in-principle position that Bath’s vaults and cellars are of evidential significance, where these typically remain an area of least alteration within a listed building and indicative of how the original building was used and lived in. These spaces are not generally suited to ‘immediate’ residential use where levels of ventilation and natural light do not meet modern standards. Habitation of these spaces therefore results in increased pressure to meet these modern standards of living, resulting in harmful material interventions and alterations with resulting harm to surviving character and contribution to the overall special interest of a listed building.

We recognise that this area of vaults has already been subject to unspecified levels of internal alteration. However, as indicated in the provided photographs, the space retains its distinctive barrel-shaped roof characteristic throughout Bath. The insertion of windows would therefore remove a large section of historic fabric, cutting through the external wall and the intersection with the curved roof. There would be resulting harm to the otherwise retained form and envelope of the vault. We reiterate that vaults provide sub-standards of natural lighting and passive ventilation, making them ill-suited to residential use without intrusive alterations.

An assessment of the harm proposed is required, taking into consideration the existing condition of the vaulted space and its contribution to the overall significance of the building, to then be measured against the proposed “public benefits” of the scheme. We do not consider that this exercise has been suitably undertaken within the D&A/Heritage Statement as provided.

We therefore maintain that inadequate documentation has been provided to demonstrate that the proposed harm to a listed building has been suitably assessed against demonstrated public benefit, contrary to the Planning (Listed Buildings & Conservation Areas) Act 1990, Section 16 of the NPPF, and Policies B1, BD1, CP6, D1, D2, and HE1 of the Core Strategy and Placemaking Plan and should be refused or withdrawn

Application Number: 22/03776/LBA
Application Date: 20/09/2022
Closing Date: 10/11/2022
Address: 157 Church Road, Combe Down, Bath
Our Submission Status: Object