Proposed conversion/Change of Use of the upper storage/facilities to provide 3 no. single bedroom flats with the ground floor retained as business use, together with the Replacement/Extension of rear 3-storey…
Our Response

11 London Street is part of a Grade II Victorian terrace within the Bath conservation area and World Heritage site. It retains its original 19th century shopfront which remains a strong feature of merit within the streetscape despite previous poor maintenance.

BPT recognises the suitability of this neglected site for restoration and redevelopment which could better enhance Bath’s architectural character whilst preserving its valuable historic setting. We further encourage the proposed mixed-use of commercial and residential space to ensure the building’s sustainable future function, and support the provision of much-needed accommodation within the city centre, whilst retaining the property’s original shopfront and associated character.

However, we regret that we cannot make a fully informed assessment of the impact based on the information submitted. The Trust feels that the assumption that the extension is “not an original structure” due to its exclusion from the listing description is an inadequate justification. In accordance with section 16 of the NPPF, the applicant must describe the full significance of a site before the benefits can be weighed against prospective impacts on historic fabric and aesthetics. Therefore, we feel that a revised D&A Statement and Heritage Statement should be submitted including details of the current extension before this application is allowed to progress further.

BPT is additionally disappointed in the lack of sustainable or energy-efficient measures incorporated either into the core building or the proposed, contemporary extension. In light of the recently declared Climate Emergency, we advocate for the sensitive retrofit of listed buildings to adhere to higher standards of energy efficiency and lowered carbon emissions. We would further recommend the use of the ‘whole house approach’ which incorporates sustainable adaptations throughout the whole property, rather than solely the new extension, to ensure an efficiency of performance that remains sympathetic to historic fabrics and architectural features.

Whilst the Trust does not object to the proposed design and function of 11 London Street, we request that a suitable application in accordance with section 10 of the Planning (Listed Building and Conservation Areas) Act 1990, section 16 of the NPPF, and Core Strategy and Placemaking Plan Policies B1, B4, BD1, CP6, and HE2 be submitted before we can properly consider the suitability of the proposed development.

Application Number: 19/03998/LBA
Application Date: 19/09/2019
Closing Date: 25/10/2019
Address: Scott Antiques, 11 London Street
Our Submission Status: Comment