Landscaped Area Between Abbey Church House And 22 Westgate Buildings, City Centre

Construction of two-storey office building with associated works including removal of existing railing, public bin, and public bench.
Our Response

The proposed site of development is situated between Abbey Church House, a Grade II 16th century house, and 22 Westgate Buildings, a Grade II Georgian house and shop, within the core of the Bath conservation area and World Heritage site. The site itself is a Scheduled Monument due to its close proximity to the Roman Baths and the location of the Beau Street Hoard discovery in 2007. The site was previously occupied by a pre-war two-storey commercial building that was almost completely destroyed by war damage in 1942; it has since been left undeveloped, and has formed a positive green contribution to the public realm of St James Rampire.

Whilst we appreciate there has been a precedent established on the site for development, we cannot support this application due to the low quality and local distinctiveness of the design which will neither preserve nor enhance the appearance of the conservation area, and the lack of appropriate archaeological understanding of the site.

Following consideration of this application, we do not feel that the precedent for development on the site suitably justifies the proposed design or the resulting visual harm to the conservation area and World Heritage site. The proposed design, form, and use of materials do not complement either the adjacent listed buildings, or the wider conservation area; the ground floor does not align with the platband of either building, creating an irregular, wonky ground floor level out of character with the uniformity of Georgian building proportions. We additionally feel that the proposed building sits too far forward, and is not suitably recessive or ‘light touch’ in its positioning between two listed buildings.

We would emphasise that the empty or negative space within a conservation area is also highly significant in terms of how this presents or enhances the setting of an area’s built heritage. This space can affect how a historic building might be located or viewed within a streetscape, and how it architecturally interacts with other surrounding buildings. At present, this site positively provides a verdant break within the streetscape that exposes the gable end of Abbey Church House and the end terrace wall of 22 Westgate Buildings, contributing an aspect of visual interest that is usually relegated to backland streets and areas. This proposal neither appreciates the benefits of negative space, nor incorporates the unusual aesthetic benefit of the site into its design, therefore emphasising its lack of local distinctiveness or a bespoke approach to its setting.

We do not feel that the materials or form proposed are of the quality expected within the Bath World Heritage site. This building could not only offer an opportunity to harmonise with its setting, but to become a ‘little gem’ in its own right that could contribute to the architectural interest of the conservation area. Unfortunately, the current design does not suitably preserve or enhance the setting of two Grade II buildings or the wider conservation area, and we consequently cannot support this application in its current iteration.

Considering the Scheduled Monument status of the site, we feel that the assumption presented in the D&A Statement that any archaeological evidence in situ was “either destroyed or severely compromised” by bomb damage and associated clearance in 1942 is highly inadequate, and does not display a full understanding of the existing condition of the site.

We do not consider these assumptions to be appropriate justification for the proposed development, and would ask why there is no provision of either an Archaeological DBA, or evidenced consultation with a relevant planning archaeologist. No evidence is provided to indicate that the site is of “low potential”, and instead we feel that a full archaeological excavation and documentation of the site should be incorporated into the application, rather than as a Condition should the proposal be consented.

This application is therefore contrary to the Planning (Listed Buildings and Conservation Areas) Act 1990, the Ancient Monuments and Archaeological Areas Act 1979, Section 16 of the NPPF, and Policies B1, B4, BD1, CP6, D1, D2, D3, D4, D5, D7, and HE1 of the Core Strategy and Placemaking Plan, and should be refused or withdrawn.

Application Number: 20/01064/LBA
Application Date: 14/03/2020
Closing Date: 07/05/2020
Address: Landscaped Area Between Abbey Church House And 22 Westgate Buildings, City Centre
Our Submission Status: Object