Combe Royal, Bathwick Hill, Bathwick, Bath

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Demolition of existing garage, swimming pool, pool house and sections of external walls, repair, upgrades and reinstatement works to existing buildings, erection of single-storey extensions to Combe Royal and Combe…

Our Response

Combe Royal is a Grade II mid-19th century villa house, situated within the Bathwick Hill character area of the Bath conservation area and World Heritage Site. The villa is situated in the surviving remnants of what used to be an extensive estate, incorporating woodland and gardens that ran down to the south along what is now Claverton Down Road. Whilst a large portion of the original estate has been separated from Combe Royal, and in some cases developed, the villa retains a generous garden setting indicative of its historic location and relationship with its landscape setting. It remains set back from the roadside but is visible in largely unobscured streetscape views from Copseland across the original walled garden. The site also includes the Grade II mid-19th century Combe Royal Lodge, which fronts the streetscape on the north-east boundary corner of the site, adjacent to the principal northern access to the estate.

Development Scale and Justification:

• We generally welcome the range of work across the site which maintains the occupation and use of buildings and high standards of maintenance and repair to support the conservation of the asset.
• However, we have the following concerns regarding the proposed scale and density of development across the remains of the historic estate, and how this would affect the hierarchy of buildings comprising of the estate, and garden setting of multiple listed buildings, in particular the central Combe Royal. It is appreciated that the provision of estate management facilities have limited heritage gains in ensuring the sustainable, long-term management of the heritage asset and its setting; however, there remains a lack of justification as to the proposed scale of built development across the garden site and how potential harm would be outweighed by public benefit (NPPF, para 202).
• It remains ambiguous as to how the proposed areas of development across the site relate to one another or the central Grade II villa and currently lacks a cohesive approach to the treatment of the historic estate grounds. We maintain that further contextual elevations and/or visual montages from key internal and external views across the site would help to better illustrate the proposed scale, massing, and density of development and resulting impact on the heritage asset.
• We have some heritage impact concerns regarding the visual impact of the proposed replacement of the pool house with a considerably larger 2-storey footprint, considering its close proximity to the west of Combe Royal. Whilst we recognise the opportunity to update the current structure, an appropriate hierarchical balance should be maintained between the prominence of the central villa dwelling and the ‘service’ function, appearance, and scale of its ancillary buildings. We recommend that existing and proposed views between Combe Royal and the pool site are considered, as it is currently unclear as to how well the land gradient mitigates visibility from the main house.
• The proposed development of the walled garden would result in the cumulative build-up of the Copseland streetscape. It is recognised that the walled garden has historically been developed until the late 20th century; however, the NPPF notes in relation to its definition of setting that “its extent is not fixed and may change as the asset and its surroundings evolve.” The current openness of the site allows for views of Combe Royal across the garden. As such, it maintains legibility as the focal point of the site, in contrast with the smaller scale, more modest and in some cases semi-permanent (the greenhouse) ancillary buildings. The proposed games room/estate office development would intrude into and partially obscure views of Combe Royal, and would therefore compete with the prominence of the villa in streetscape views. In particular, the twin gables would be overly dominant, appearing to define a new frontage rather than sitting more recessively within its historic setting. Cumulatively, the walled garden would signify a substantial increase in built density and resulting impact to the setting of multiple listed buildings. We encourage consideration of a reduction in height and a more subservient roof profile. Further montage views of the development from Copseland, particularly the south-eastern corner where the footprint of development is particularly large, would allow for improved assessment of the development in wider contextual views of the setting of Combe Royal and the wider conservation area.
• The proposed single storey extension to Combe Down Lodge sits somewhat awkwardly against the gabled form and articulation of the heritage asset. We recognise that the flat-roofed form sets the extension down below the boundary wall to minimise public views from Copseland. However, there does not appear to be adequate reference to the building’s own significance as an individually listed Grade II building with regards to its form, footprint, location, or use of materials.
• Further information regarding the proposed scale and volume of the subterranean parking unit is encouraged.


• The current Climate Emergency highlights the urgency to build in thermal and energy efficiency measures and green energy alternatives to meet net zero targets by 2050. Considering the scale of proposed development across the site, we emphasise the need to appropriately demonstrate how the resulting increases in operational and construction emissions, as well as embodied carbon in new building materials, would be appropriately offset or mitigated through the design process and into delivery.
• We would encourage and expect a refurbishment and rebuilding on this scale to be supported by a sustainability strategy and to be leading the way on retrofit and renewable energy. And for the public benefit of lowering net carbon emissions to be legible for the assessment and balance of harm.
• The submission of a Sustainable Construction Checklist is recommended to appropriately highlight how sustainability and energy efficiency would be considered as part of this scheme. We feel that the scale of new-build across the site should be considered an exceptional opportunity to integrate passive house principles and micro-renewables such as solar from the outset to appropriately meet the council’s environmental objectives and demonstrate best practice.
• It is proposed to install 6.7mm vacuum double glazing in Combe Royal. In light of the Climate Emergency, BPT is supportive of the principle of ‘slim’ double glazing installation where this is compatible with the special architectural and historic interest of a listed building, and material harm to historic fabric is appropriately limited or mitigated. We welcome further details regarding the proposed appearance of the vacuum glazing as some systems use internal pillars which can result in a ‘spotty’ appearance.
• The Heritage Statement indicates an approximate 50/50 mix of crown glass, presumed to date to the mid-19th century at the latest, and plate glass, suggested to be a mid- to late 20th century addition. We are not opposed to the retrofit of 20th century glazing where this would not constitute a loss of historic fabric. However, in reference to the existing crown glass, the estimated mid-19th century date would match the building’s original construction in 1855 and as such would be of higher historic and material significance to the building.
• The proposed elevations show the retention and replacement of only four metal casements on the west elevation; this does not match up with the Heritage Statement’s estimate of “circa 50%” of retained, possibly historic crown glazing. We therefore recommend further information is supplied to clarify the historic value of existing windows and glazing across the property and whether retrofit would result in loss of historic fabric and associated harm to the building. This would need to be appropriately outweighed by the proposed benefits of the scheme.
• The proposed through glazing bar details indicate the re-use/like-for-like replacement in a matching thickness and profile. However, section A proposes the use of an applied glazing bar which would be incongruous to the traditional detailing and finish of the building. We maintain that a through glazing bar should be used.

Application Number: 22/02232/LBA
Application Date: 31/05/2022
Closing Date: 21/07/2022
Address: Combe Royal, Bathwick Hill, Bathwick, Bath
Our Submission Status: Comment