9th September – 30th September 2013      –      Weeks 37–40  
Our Response


13/03056/LBA - 6-7 Old Bond Street, City Centre, Bath BA1 1BW

Internal and external alterations including redecoration of shop front and replacement awning

OBJECT Bath Preservation Trust views this application as having been a] brand-driven project with no thought or appreciation given to the historic fabric or surroundings. The design for the awning and other signs is overly dominant, the gloss paint is inappropriate, and a new hanging sign in a sensitive area without a precedent for projecting signs is unacceptable. The materials proposed for these elements are also unacceptable; all signs should be of timber and traditionally sign-written, and the replacement of a stone step with black marble is out of context in Bath. The material for the awning is not specified, therefore, a proper assessment of its impact upon the listed building is difficult. The material used should be specified prior to any permission and not by way of condition.

However, these details of the application which are deemed inappropriate come second to the reprehensible fact that these works have already been completed. Unauthorised works to a listed building are a criminal offence and should be condemned. This application should be denoted as retrospective and we would ask the LPA to begin enforcement against the applicant. If no enforcement is pursued this will set a harmful and reductive precedent across the conservation area and world heritage site of Bath as it is truly reprehensible to undertake works to a listed building without consent. The listing process allows for the appropriate management of change and if ignored serves only top highlight the deficiency of the applicant in their understanding of the sensitive approach required as custodians of a listed building. Bath Preservation Trust has drawn this application to the attention of the enforcement team.

For the reasons given above we strongly object to this application as it contravenes S16 and S72 of the Planning (Listed Buildings & Conservation Areas) Act 1990, Section 12 ‘Conserving & Enhancing the Historic Environment’ of the NPPF and Local Plan Policies BH.2, BH.6 andBH.17 and should be REFUSED.


13/03560/REG04 & 13/03561/REG13 - 26 Stall Street, City Centre, Bath BA1 1QF

Internal alterations to facilitate the Change of Use from Class A2 (Financial) to Class A3 (Restaurant).

COMMENT Bath Preservation Trust regrets this application on several fronts: the lack of comprehensive information required for the full assessment of the proposal, the lack of historic building appraisal and, although outside our remit, the proposed change to A3 use.

The application omits detail we would expect to be required to change premises to facilitate A3 use. For example, no mention is made of kitchen fume extraction and thus the necessary assessment of the position, type and duct routes of such a system cannot be made, nor is the impact on the listed building deducible.

We are surprised at the poor quality of this application. It is our experience that a householder or business owner presenting an application for a listed building would be expected to provide a thorough application with a historical impact assessment, an exploration of significance and a thorough design and access statement. The fact that is a Council owned building does not mean that need for high quality investigation and supporting evidence is diminished – indeed the Council should be setting a high standard of application as it is the body which judges others.


13/02964/LBA - 11 Gay Street, City Centre, Bath BA1 2PH

Internal and external alterations to increase and create safe access to the loft area, safe  access to the gutter and provision of roof lights

COMMENT Bath Preservation Trust is disappointed to see that there is no historical assessment of the roof. This application proposes works to a GI listed, John Wood the Elder townhouse and therefore the application should be well considered, informative and illustrate the significance and impact of the works.  More detail is needed on the existing ceilings and roof and there are no details on the proposed style of rooflight, therefore, until proven appropriate by a full historical assessment, we feel that the number of loft access points and new roof lights are inappropriate due to the likely loss of historic fabric. However, we do appreciate that the increased access to the roof interiors and external gutters may, if used to facilitate regular maintenance and gutter clearance, result in less likelihood of water ingress which will ensure the house is better protected from decay.


13/03663/LBA - 13 Broad Street City Centre, Bath BA1 5LJ

External alterations to include work to the roof, dormer, central valley and parapet gutter, removing paint from the front elevation of the building and carrying out minor stone repairs to both the front and rear of the property.

COMMENT Bath Preservation Trust is disappointed to see another application for works to a listed building which provides no historical assessment or information. Without a discussion of the significance of a building and the impact of any proposed works on that significance it is not possible to determine with any certainty.

Whilst we regret the loss of painted signage as it adds to the distinctiveness of the street scene, conservation area and world heritage site, we do appreciate that the paint on this elevation is causing damage to the historic stonework to the building. We would ask that a photographic record be made of the signage, which is all the more important as its provenance has not been explored within the application. Related to this we are concerned that whilst the ‘paint removal statement’ proposes to use Peel away 1 and 7, the ‘schedule of works’ mentions Peelaway, DOFF and TORC without specifying which is to be used. This should be rectified prior to any consent especially as the TORC method in particular would likely constitute an overtreatment, removing all patina of age.


13/03567/FUL - The Salvation Army, Green Park Road, City Centre, Bath

Renewal of partially stripped lead roof coverings with new Single Ply coverings to Main Worship Hall roof

COMMENT The Trust would prefer the proposed replacement roof covering to be lead, as the roof of the Worship Hall can be seen from listed buildings such as Green Park Station, thus affecting their setting. However, we acknowledge the problems of metal theft currently being experienced by property owners and understand the necessity for selecting an alternative. However, we consider terne coated steel a more appropriate material to be used than the proposed synthetic membrane. Terne coated steel has a more similar appearance to lead and is a durable, cost effective alternative solution which will be better suited to the character of the conservation area.


13/03769/FUL & 13/03770/LBA - Francis Hote, 6 - 11 Queen Square, City Centre, Bath

Alterations to external areas including proposed dwarf wall with railings to existing car park entrance, proposed hard and soft landscaping to the existing garden, courtyard and rear hotel entrance with replacement lighting, and bin store screens.

OBJECT Bath Preservation Trust Objects to this application on the basis that the new signage element of the proposal constitutes an unsympathetic treatment to the external appearance of the hotel and the front canopy. The Font in particular does not sit comfortably alongside the ornate design of the canopy and fills the space awkwardly. Furthermore, it is not made clear in the application if the current lettering on the side faces of the canopy is to retained removed or replaced with the new scheme. We feel the current lettering is more than adequate and more in keeping. We also object to illumination within the conservation area and regret the proposal to illuminate the canopy with an LED lighting strip. This application is considered contrary to Section 12 ‘Conserving and Enhancing the Historic Environment’ and local plan policy BH.2 and should be REFUSED.


13/03795/FUL - 3 Victoria Buildings, Twerton, Bath BA2 3EH

Installation of new shop front

OBJECT The Trust is disappointed by the quality of this application which is entirely lacking in detail; no recognition is given to the listing of the building, no historical assessment of the shopfront has been made, no consideration has been given to the impact of the proposals on the significance of the building and the drawings provided are of minimal quality.  The materials proposed are inappropriate on a listed building and any replacement shopfront must afford an enhancement over the existing. As such The Trust feels that the replacement to this building should be in timber and should not be in too starker contrast with the shop fronts it sits next to. The current scheme would negatively impact on the street scene, the listed building and the setting of those adjacent to it and does not represent an opportunity to enhance the local distinctiveness of the World Heritage site. As such this application is considered contrary to Section 12 ‘Conserving and Enhancing the Historic Environment’ and local plan policies BH.2, BH.3, BH.6, BH.19 and BH.20 should be REFUSED.


13/03873/AR - Toast, 7 Bartlett Street, City Centre, Bath

Display of 1no. externally illuminated projecting sign

OBJECT Bath Preservation Trust will continue to object to illumination in the conservation area and as such finds this element of these proposals to be unacceptable. Whilst the building in question is not listed, it does have a traditional shopfront and is located in an area of the world heritage site and conservation area which has its own distinct ambiance, and as such any proposals should look to preserve this special character. Therefore, we must object to the fascia mounted projecting sign. This design does not sit comfortably on the traditional shopfront and a traditionally signpainted, timber hanging sign would be far more appropriate for the location. Linked to this the enamel material proposed for the sign is deemed inappropriate for the setting and harmful to the visual amenity of the street scene as Bartlett Street is deserving of a more traditional finish. There does not seem to be any specification for the fabric for the new awning and this should be provided prior to any permission, not secured by way of condition.

By virtue of the inappropriate proposal of illumination in the conservation area, and due to the ill designed projecting sign, this application is thought to contravene Section 12 ‘Conserving and Enhancing the Historic Environment’ of the NPPF and Local Plan policies BH.6 and BH.17 and should be REFUSED.


13/03888/REG13 - Pump Room & Roman Baths, Abbey Church Yard, City Centre, Bath BA1 1LZ

External alterations to include proposed replacement of inappropriate asbestos tile roof covering with natural slate tile finish.

SUPPORT Bath Preservation trust is pleased to see this application come forward as the proposed replacement natural slate tile roof will constitute a vast improvement on the current, inappropriate tiles. The intention to use sheep wool insulation is also to be commended as this is a sustainable alternative to less environmentally friendly insulation materials. The reinstatement of a natural slate roof on one of the most recognisable buildings in Bath and will set a commendable precedent for others to follow.


13/03931/AR - 1 - 4 New Bond Street, City Centre, Bath BA1 1BE

Display of 1no. non illuminated fascia sign, 1no. non illuminated hanging sign and 3no. window vinyls

OBJECT The Trust applauds the applicant for omitting any illumination from their proposals, however, must object to the fascia mounted projecting sign. This design does not sit comfortably on the listed building and a traditionally signpainted, timber hanging sign would be far more appropriate for the location. If the officer is minded to consent we would urge that they ask for this element of the proposals to be revisited. Whilst we appreciate that this sign is likely of a house style, this building is within the historic heart of the conservation area and world heritage site, where only one other historic, traditional timber hanging sign is cited, therefore it is only appropriate that this applicant be asked to follow this precedent. Linked to this, the steel and brass materials proposed for the projecting sign are deemed inappropriate for the setting and harmful to the visual amenity of the street scene.

Due to the inappropriate projecting sign this application is thought to contravene Section 12 ‘Conserving and Enhancing the Historic Environment’ of the NPPF and Local Plan policies BH.2, BH.6 and BH.17 and should be REFUSED


13/03952/FUL & 13/03953/LBA - Upton House, Bathwick Hill, Bathwick

Internal and external alterations including the demolition of attached greenhouse and detached garage to facilitate the erection of single storey extension and detached double garage with associated works.

OBJECT We regret that the applicant is seeking to remove this charming and historic conservatory in favour of the proposed extension which does not sit well alongside the listed building. The conservatory is included within the listing of the property and as such we consider it to be of equal significance to the house proper. Furthermore, the historical building report provides such a thorough assessment that the provenance for the conservatory is clearly defined, the suggestion being that it was built as part of a group of buildings (largely now removed) which facilitated the work of horticulturist, Solomon Tredwell. He has some local significance due to his father’s association with Brunel and more importantly for his history as an exhibitor at county wide flower shows. That this was his conservatory is the likely conclusion and as such it would be a shame to lose that piece of local history and also for the house to lose the last vestige of this period of its history.

Quite apart from the historic significance of the conservatory, the proposed lantern to the extension  clumsily disrupts he first floor fenestration of the North Western elevation.

Lastly, we hold reservations about the alteration to the central French window on the South Western elevation; although it is suggested that the doorway was originally lower at the threshold, the existing French window matches the other two, and the proposed loss of symmetry and design is unfortunate.

By virtue of the removal of a historic element of this building and the resulting loss of historic fabric and significance this application is considered contrary to Section 12 ‘Conserving and Enhancing the Historic Environment’ of the NPPF and Local Plan policies D.2, D.4, BH.2, BH.3 and BH.6 and should be REFUSED


13/03846/FUL & 13/03847/LBA - Estate Outbuildings, Kelston Park, Kelston Road, Kelston, Bath

Conversion to form estate staff offices and accommodation

SUPPORT The Trust is impressed with the extensive information and discussion provided within the application, and commend the applicant and agent for their thorough approach and conservation led design. The background report is a very impressive piece of work, with all the implications of restoring a semi-ruin in the Green belt very carefully considered and thought through. The final concept, a modern insertion of interiors whilst retaining, without re-building, all the historic fabric, seems admirable, particularly combining  the sensitive use of traditional roof tiles, oak trusses, and stone walls for the “garage” with modern materials elsewhere. Keeping the roof at a traditional pitch is welcomed, since anything else would jar visually, and “floating” the roof to make the distinction between the historic building and modern interventions is a laudable approach.

We do feel that this development should be defined as ancillary accommodation, by way of condition, so as to mitigate against these buildings being cut off as a separate property at any point in the future. The Trust does not often look to support development in the green belt, however, we accept that as these buildings exist and as we would rather see them re-used to preserve their historical significance and the gains that re-use allows in terms of sustainability, and therefore feel that together these comprise ‘very special circumstances’  outweighing any harm.


13/03892/LBA - 1 Partis College, Partis Way, Lower Weston, Bath

External alterations to include removal of existing roof to the external courtyard of plot 1, to be replaced with a new roof and associated internal works. Removal of existing porch and gate to the rear of plot 1, new gate to be installed in similar location. Removal of existing greenhouse, outbuilding and low wall to the parking courtyard to the rear of plots 8 and 9.

COMMENT Bath Preservation Trust applauds the intention of the applicant to remove many of the inappropriate accretions form the site, such as the corrugated plastic sheet roofing over the courtyard, the impermeable wall finishes and re-tiling the outbuilding which is to be retained in natural slate. These repairs will bring these separate built elements in line with the standard of materials and finishes associated with a G1 listed building, and visually the improvement will be great. However, we do hold some concern over the removal of the outbuilding to provide parking. The design and access statement states that the outbuilding originated from the mid 19th century, as evidenced by the 1888 OS plan, and as such may be a feature of the original construction of the college. It is then suggested that as they are uniform across the college site they are probably original to the design. As such we think it would be inappropriate for this outbuilding to be removed and may set an unhelpful precedent for the future.


13/03967/AR - 30 Milsom Street, City Centre, Bath BA1 1DG

Display of 1no. externally illuminated fascia sign

OBJECT The Trust will continue to object to illuminated signs on listed buildings and within the conservation area and in the World Heritage Site. The sign, by virtue of its materials (fold silver and acrylic lettering with applied vinyl) and illumination by trough lighting would damage the visual amenity of the street scene, would harm the architectural and historic significance of the listed building, and would detract from the setting of the adjacent listed buildings and the outstanding universal value of the World Heritage Site. The Trust encourages traditional approaches to signage in the Bath conservation area and in this instance would consider that a painted fascia sign would be more appropriate. The proposal is contrary to Section 12 ‘Conserving & Enhancing the Historic Environment’ of the NPPF and Local Plan Policies BH2, BH6 and BH17 and should be refused.


13/03986/LBA - 26 Upper Borough Walls, City Centre, Bath BA1 1RH

Internal and external alterations to convert 2no. existing retail units into 1no. retail unit for the basement of 26 Upper Borough Walls and the ground floor of 26 Upper Borough Walls and 12 -13 Union Street

OBJECT Bath Preservation Trust objects to this application due to the poor quality of the documentation provided. The design and access statement is confused and vague and we believe some of the historic information provided to be questionable. The application contains a lot of presumptions and relies on previous planning drawings for evidence, when it is not clear to what extent these works were carried out.

We do appreciate that the architect and applicant have taken on board some of our suggestions and that there is a desire on their behalf to get these works right. Unfortunately, whilst they seem to understand the existing plan form and state of the building this has not been communicated so as outside parties can understand it, nor has the evidence and information required to assess the proposals been provided. For example, the plans of the existing and proposed basement do not match in the areas where no work is proposed and the proposed new door opening in the basement is proposed in a wall which does not seem to have been properly plotted or structurally analysed.

Lastly, as the proposals alter the plan form of the historic buildings the application must provide adequate justification for the works. The commercial desire for a larger unit in not an acceptable justification for the works to the ground floor and a the protection of a listed building is not over-ridden bythe commercial aspirations of an occupier.

The works, by virtue of the unclear documentation, the questionable assessment of historic fabric and the lack of justification are considered to be detrimental to the special architectural and historic interest and character of the listed buildings contrary to S16 of the Planning (Listed Buildings & Conservation Areas) Act 1990, and contrary to Section 12 “Conserving & Enhancing the Historic Environment” of the NPPF and Local Plan Policy BH.2 and should be REFUSED.


13/03980/LBA  - Kilowatt House, North Road, Bathwick, Bath

Internal and external alterations for repairs to roof, external decoration and internal repair and redecoration

SUPPORT Bath Preservation Trust is saddened to see that this important building has fallen into a state of poor repair and as such we consider all the works proposed to be necessary and commendable. Repairs to the roof will halt water ingress and stop any further deterioration of the fabric of the building. Externally the decoration is supported with the hope that this will make the building more marketable as ultimately the building must be lived in order to be properly maintained.


13/03650/LBA - 106 Entry Hill, Combe Down, Bath, Bath And North East Somerset, BA2 5LS

Erection of dwelling attached to 112 Entry Hill

OBJECT This application is woefully lacking in detail, to the extent that we question why it has been registered. The design and access statement is not fit for purpose and the heritage statement offers no historic impact assessment. This is a site with a complex history with various extensions permitted and refused. Whilst we appreciate that permission is not required to demolish the existing artisan cottage, the replacement proposed does not afford an enhancement over the original, constitutes an overdevelopment of the site and will negatively impact the listed building and its setting. Furthermore, the submitted drawings are of such a low quality that any real assessment of the design is unachievable.

The works, by virtue of the unclear and lacking documentation, the lack of assessment of the impact on the heritage asset and due to the overdevelopment of this site, are considered to be detrimental to the character of the listed building and contrary to Section 12 “Conserving & Enhancing the Historic Environment” of the NPPF and Local Plan Policies D.2, D.4 and BH.2 and should be REFUSED.


13/03893/LBA - 4 Walcot Terrace, Walcot, Bath, Bath and North East Somerset, BA1 6AB

External works to include reinstatement of original sashes to ground floor window to front of house and removal of paint and restoration of the Bath Stone to the front elevation of the building from basement to first floor level.

COMMENT Bath Preservation Trust understands the desire of the applicant to reinstate a window into the front facade which matches the original sashes as this will unify the fenestration and enhance the appearance of the building. The opposing argument is that the window to be replaced is as much a part of the house’s history as those windows with glazing bars; however in this location we believe the new window will be an enhancement. However, as there is no historic assessment of the building or analysis the original sashes on the higher floors provided within the application, we would question how the applicant intends to demonstrate that the windows will match? There is no detail provided on the intended glazing or joinery, both of which are crucial to ensuring a unified appearance.

Linked to this lack of detail there is no specification for the stone cleaning therefore we cannot assess the method to be used and if it is appropriate and there is no evidence given that any one method has been investigated. Whilst we support the removal of paint from Bath stone, we would warn the applicant that once stone has been cleaned, as a result of the pores of the fabric made larger it can become stained more quickly. In such a traffic heavy location we hold some concern that this may mean the rate at which the building appears dirty would be accelerated.


13/03929/ERES - Western Riverside Development Area, Midland Road, Twerton, Bath

Approval of reserved matters with regard to outline application 06/01733/EOUT for the erection of 259 residential apartments within four buildings (blocks B11, B13, B15a andB15b) of four to seven storey height surrounding a central courtyard, which includes play space, gardens, landscaping and exterior lighting.

COMMENT Whilst we encourage high density development on this site so as to alleviate pressure on the green belt to provide housing, Bath Preservation Trust has long been concerned this should be at a height comparable to the city tradition. High density does not have to equate to high-rise; a point which we made in our objection to the outline planning application. As these matters were determined in the outline application we currently have no further comment to make.


13/04006/LBA - 15 St Mark's Road, Widcombe, Bath BA2 4PA

Internal alterations at ground floor level, including the removal of a section of wall between the living room and dining room to form a revised semi-open plan layout.

COMMENT The Trust does not have an in principle objection to this application, however, we would like to make the point that stating the precedent of a similar alteration having had permission at number 16 does not assure consent in this case. As there is no record or assessment of the joinery accompanying the application with which we can fully determine the impact of the proposal, and as there has already been a loss of historic plan form to the neighbouring listed building, arguably there is a case for not granting consent.

Application Number: Various
Application Date:
Closing Date:
Address: Various
Our Submission Status: Various