Former Debenhams, 17 Southgate Place, City Centre

Repurposing of existing retail building to provide a mixed commerical (Class E) building, including roof extension, elevational alterations and associated works. (BPT’s full response including annotated images is available here.)
Our Response

The proposed site of development is the former Debenhams store, which forms part of the wider Southgate development completed in 2009. It is situated within the commercial/retail centre of the Bath City-Wide conservation area and World Heritage Site. The objective of the development was to achieve a mixed-use regeneration on the site of the deteriorating 1970s shopping centre and bus station, drawing on Georgian architectural principles to inform the site’s built form, scale, massing, and design. The Southgate site as a whole now marks a key transition point between the bus and train stations and the historic city centre, with the Dorchester Street frontage acting as a prominent gateway in both streetscape views and wider landscape views to the south (eg. Beechen Cliff).

The Debenhams store was closed in 2021 and remains vacant across all three floors.

BPT welcomed early engagement and the opportunity to have pre-application discussions with the design team, and we are pleased to see that a number of our initial comments have been taken into consideration as part of the submitted scheme. Our comments in response to the first design review are summarised as follows:

• In principle, we welcomed the opportunity for the refurbishment and reuse of a large, contemporary building within the city centre, to bring this back into long-term sustainable use with associated benefits for the economy and visual amenities of the streetscape. A mixed-use scheme with a retail ground floor is considered to be acceptable.
• We were supportive of opportunities for energy retrofit measures to be integrated into the design proposals, such as proposals for a roof-mounted solar array to maximise on-site ‘green’ energy generation.
• We had concerns that the proposed dropping of the second-floor window sills would compromise the composition of the façade by disrupting the established ‘order of proportion’ and the Georgian architectural integrity and character that the building originally endeavoured to incorporate. The windows would break through the cornice, resulting in incoherence with the original architectural design. We recommended that the cornice could be removed in favour of a slimmer stringcourse, to run as a continuous line along the proposed sill line of the second-floor windows.
• We recognised the opportunity to improve and reactivate public realm, but felt that the removal of the central columns from the colonnade would result in an unbalanced appearance in contrast with Dorchester Street’s uniform ground floor frontage treatment.
• We were generally supportive of opportunities for the activation of the roofscape, and highlighted some potential concerns with a perceived increase in light spill/reflectivity in wider landscape and cityscape views, and maintained that this aspect of the scheme should be subject to further assessment. We recommended that the proposed metal lining was removed from the internal face of the retained columns.
• We recommended the inclusion of a soft landscaping plan and maintenance strategy to fully embed the proposed roofscape greening works into the overall scheme.
• We raised concerns about the omission of the Manvers Street frontage from the scheme, particularly opportunities for improvement and activation works to the ground floor colonnade where there have been identified concerns with lack of public surveillance.
We therefore welcome the proposed improvements that have been made to the scheme in response to our townscape concerns, including the inclusion of the Manvers Street elevation within the scheme, the omission of the proposed metal linings from the colonnade columns, and the replacement of the existing cornice with a “shallower stringcourse”.

Proposed Second Floor Windows:

Measures that address the issues of poor natural light attributed to the deep floor plate of the building, such as the opening up of the central courtyard and the conversion of the lift shaft into a lightwell, are welcome interventions that help to address the future use, occupation and sustainability of the building. We note the importance of finding solutions to adapt the building in line with modern requirements and address previous design flaws to ensure its viable ongoing use. As part of the proposed refurbishment works, the enlargement of the second-floor windows is intended to achieve necessary standards of natural light and ventilation for future occupiers and meet the specified office space grading. The reuse of the building and provision of active city-centre office and retail space is therefore considered to be a public benefit which should be appropriately weighed against the potential visual impact on the wider conservation area and World Heritage Site as part of the planning balance.

We recognise that improvements have been made to the appearance of the proposed second floor alterations. However, we maintain that the proposed interruption of the stringcourse running through the windows would continue to present an incongruous composition and junction at odds with its built context and the intended design reference of the building. Where stringcourses are used, these are typically intended to delineate the division between floors or are integrated into a continuous sill band that align with the bottom sills of the window openings. There is no informed, historic precedent for the interruption of the stringcourse with window openings, resulting in a jarring and discordant appearance. The cut-through of the stringcourse further emphasises the increased scale of the proposed windows which appear to be comparable to the size of the first-floor windows, at odds with the established hierarchy of proportion.

At pre-app stage, we highlighted the large floor to ceiling height of the second floor (4.6m) and suggested that the floor could be raised slightly (eg. 500mm) to allow for the depth of the window reveal to be reduced. This would then allow for the window openings to be enlarged to a sufficient degree, with all associated benefits, whilst remaining of a slightly smaller size in comparison with the first floor and allowing for the improved integration of the stringcourse as part of the proposed window sills, in accordance with established order and Georgian detailing visible elsewhere in the City.

There is insufficient justification for the proposed use of a metal lining within the second-floor window reveals. We express a strong preference for the use of a stone surround or architrave in keeping with the rest of the building to ensure a consistency of appearance across the external elevations, rather than an awkward split between traditional and contemporary approaches between floors. If a cornice or stringcourse is located at the base of the window then this negates the need for any deep reveal or lining.

Overall, we welcome the proposed amendments to the scheme; however, we consider that the revised approach to the windows would continue to have an adverse impact on the building’s design, integrity, and contribution to the streetscape character, within a prominent area of the conservation area and World Heritage Site. Considering the evidenced feasibility of making changes to the external elevation (as proposed), we therefore suggest that there is no reason why further amendments could not be incorporated to better address ongoing concerns.


We maintain that the proposed works to the ground floor colonnade have the potential to improve an area of the public realm which has not entirely been successful. Improved lighting works would help to address safety concerns, particularly in the Manvers Street section of colonnade, where the depth of columns has resulted in poor public surveillance and obscured lines of sight. We therefore acknowledge that these proposals can be attributed some public benefit in the activation of the streetscape and enhancement for pedestrian use.

The proposals for alterations to the colonnade are an improvement on those previously presented at pre-app, however we maintain ongoing concerns with the proposed disturbance to the regularity of the colonnade feature and its presence along Dorchester Street. Should this aspect of the scheme be considered acceptable by the case officer, this should not be considered a replicable precedent and maintain the importance of retaining historic examples of colonnades elsewhere in the City.


There is capacity for a more innovative approach to the use and activation of Bath’s contemporary roofscapes, where this sustains and enhances distinctive roofscape and townscape views from key locations into and across the World Heritage Site. The proposed third floor floorplate would be extended as part of the proposed works, resulting in a noticeable increase in roof massing along the Manvers Street elevation. There is a slight increase in height with the proposed roof access lobby and chimney projecting above the ridge height of the building (+42.800). We recommend that this increase in height is fully specified, and further contextual comparison is provided with surrounding buildings such as 20 Manvers Street to ensure this would be coherent with the established scale of the roofscape within this area. Shoulder heights of surrounding buildings must be requested in support of the application to allow for a proper assessment of the impact ahead of determination.

The D&A Statement indicates that “additional external lighting might be introduced to the roof terraces”. We maintain that further visual impact assessment is required regarding the potential for increased light spill at roof level and associated impact on the setting of significant heritage assets, landscape views and Bath’s night time character. This would require a coordinated consideration of increased illumination from both the interior of the proposed new roof-level floor plan as well as the external treatment of the roof terrace amenity space.

We would welcome further opportunities to engage with the development of proposals should there be any further negotiations with the LPA and revised drawings or details submitted.

Application Number: 22/04328/FUL
Application Date: 27/10/2022
Closing Date: 16/12/2022
Address: Former Debenhams, 17 Southgate Place, City Centre
Our Submission Status: Comment