The Beacon, Richmond Place, Beacon Hill, Bath

The proposed site of development is situated at the southernmost corner of Beacon Hill Common, within the Lower Lansdown and Camden Character Area of the Bath conservation area, and within the World Heritage Site. The existing property on the site is a “dormer bungalow” built in the 1930s that is deemed to be of a neutral architectural and historic value to the area. It is located adjacent to the Grade II listed Richmond Place, a significant late Georgian series of two-storey residential terraces that define a historic, architectural precedent of slate or clay pantile roofs, six over six timber sash windows, Bath stone ashlar, and a simple, symmetrical appearance. The dominant position of Beacon Hill Common establishes a distinctly verdant atmosphere connected with the surrounding wooded hillside overlooking the city, and the area’s low-density structure.

BPT previously objected to permitted application 19/04671/FUL. The latest proposals remain near-identical to the original 2019 scheme, as well as the earlier refused 2017 scheme (although the 2017 scheme was ultimately dismissed at appeal on grounds of the lack of an ecological impact mitigation strategy, rather than on the basis of design or harm to the conservation area and the setting of other heritage assets). It appears that the application has been resubmitted to renew the expired 2019 planning permission. We therefore maintain the main emphasis of our previous objection as follows:

BPT acknowledges the potential of this site for redevelopment that will positively contribute to the green setting of multiple listed buildings and the wider conservation area. Any development here should respond to its context and either utilise, respect, or complement the existing vernacular style of the area. We are not opposed to the sensitive or subtle use of sensitive contemporary design.

The proposed dwelling constitutes a significant increase in footprint, height, and massing. Consequently, it will have a heightened visual impact on its setting, whereas the existing dwelling is of a neutral aesthetic value that sits subservient to both its natural and architectural context. The new design’s use of striking contemporary forms and materials will be highly visible and consequently jarring in comparison with the area’s primary use of natural materials. Therefore, this application is contrary to the Planning (Listed Buildings and Conservation Areas) Act 1990 due to the proposed dwelling’s direct detriment to the appearance and associated character of the area. Whilst comparisons are drawn between the Beacon and The Birches in the D&A Statement, we emphasise the comparative invisibility of The Birches from the streetscape due to its low position, dense green screening at the front and rear, and its position well back from the road, criteria which the application for The Beacons unfortunately fails to meet.

Furthermore, this application intends to remove trees along its southern boundary, as demonstrated in the previously refused application. Concern has been drawn to the thinning of the woodland which would expose the southern face of the property and heighten its impact on the wider views into the city, especially when considering the high concentration of glazing along the building’s southern elevation. We are concerned that this amount of glazing and light spill will have a detrimental impact on the views from Alexandra Park, Smallcombe, Powlett Road, and Sham Castle. Bath’s World Heritage Site status is characterised by its “picturesque views” into which it is critical that new development contributes positive yet subtle visual interest that does not degrade the city’s harmonious landscape setting. In its current form the application does not give adequate assurance that this new dwelling will not be a visual detractor within the landscape the setting of the World Heritage Site and this valued, largely undeveloped, wooded hillside overlooking the city. We recommend further documentation of the potential visual impact of the new dwelling on the Bath skyline setting, in the form of a Landscape Visual Impact Assessment (LVIA) and encourage the applicant to publicly consider a scheme of tree replanting to ensure suitable, permanent screening along the southern edge of the site.

We are supportive of the inclusion of energy-efficient and micro-renewable features in response to the current Climate Emergency, and encourage the suitable incorporation of non-reflective solar panels. The adherence to established Passivehaus standards is also recommended through the use of solar shading and thermally-efficient materials. However, the claimed energy efficiency of the proposed dwelling does not account for the energy used in demolition, reconstruction, or the production of new materials that will be used. Furthermore, this application does not consider the embedded carbon value of the existing property, and the consequent embedded carbon cost of the new-build, nor the resulting generation of landfill waste and air pollution. In the interests of a truly energy-efficient dwelling, we would like to see designs that consider the positive retrofit and redevelopment of the existing property to minimise the damaging consequences of demolition in accordance with sections 2 and 14 of the NPPF, and Core Strategy and Placemaking Plan Policies CP1, CP2, CP3, and CP6.

Therefore, BPT maintains that due to the continuity in the proposed design, size, siting and materials, our heritage concerns regarding the potential harm to the setting of multiple listed buildings and the special vernacular and green character of this region of the Bath conservation area remains valid. The high density of glazing on the southern slope is harmful to the Outstanding Universal Value of Bath’s landscape setting due to its high light spill and architectural incongruity with its setting, a threat exacerbated by the removal of screening trees. The resulting harm from this scheme would not be demonstrably outweighed by public benefit. Consequently, this application is contrary to the Planning (Listed Buildings and Conservation Areas) Act 1990, section 16 of the NPPF, and Policies B1, B4, BD1, CP6, D1, D2, D3, HE1, NE2 and NE6 of the Core Strategy and Placemaking Plan and should be refused.”