Unit 1-4, Wells Road, Lyncombe, Bath
The proposed site of this development is currently occupied by occupied and trading commercial units situated on the edge of the Widcombe character area of the Bath City-Wide Conservation Area and World Heritage Site. The building as existing is a low profile, two storey metal-clad structure of contemporary origin situated on the south-north slope overlooking the Bath city centre. The building likely formed part of the 1960s works for the redevelopment of the Wells Road area to clear buildings identified as “ruin” and create a new roundabout linking up the A36.
The existing building’s its scale, form, profile, and materiality are clearly at odds with the established architectural character and appearance of the surrounding built environment. However, its low height and flat-roofed profile help to recess the building visually back and down from the streetscape approach into the city centre. The low height of development is particularly important given that a number of significant panoramic views are identified within the Character Appraisal from and above Wells Road across the city centre towards Lansdown and Bathwick Hill, which are especially obvious in the winter months. Additional views are noted from Holloway “looking east to Bathwick Fields and, lower down, north to the railway viaduct (a vista much loved by train spotters) and across the City.”
Previous application 22/02399/FUL for a 5-storey co-living block was withdrawn following a number of concerns raised, including an objection by the conservation officer on the following grounds: “The proposal is unacceptable in terms of its harmful impact on the setting of a number of designated heritage assets and within the context of this part of the World Heritage Site and conservation area. The design, scale, height, and massing of the proposal would lead to less than substantial harm to these heritage assets […].”
Height, Scale, Massing & Design:
We reiterate an in-principle objection to the proposed height, scale, and massing of development where this would result in harm to the appearance and character of the Bath City-Wide Conservation Area, the green wooded setting of the Grade II* St James’ Viaduct, and the immediate landscape setting of the World Heritage Site.
Whilst we acknowledge that efforts have been made to reduce the perceived height of the building from 5 storeys to 4 storeys, this has not successfully addressed our previous concerns where development would remain at a 5 storey height – description as a 4 storey building is not felt to be accurate. The articulation of the roofscape with a faux pitched roof profile would seek to reduce high-level massing but would ultimately not significantly reduce the building’s overall height.
We re-state that the development proposals would be contrary to the recommendations made within the Bath Building Heights Strategy, that the “building or shoulder height along streets should not be less than or exceed the prevailing cornice height of nearby Georgian buildings […] The overall height should not be less than or exceed the overall prevailing height of nearby Georgian buildings.” The proposed building would be substantially larger than, and consequently at odds with, the established 2-3 storey height of its contextual Grade II terraced streetscape, and its placement within the conservation area and World Heritage Site.
We continue to have strong concerns with the assessment provided within the Landscape Visual Impact Assessment (LVIA). The LVIA claims that “the site does not offer any benefit in landscape character terms,” completely overlooking the existing benefits of the low-profile height and scale of the building which enables it to blend unobtrusively into its landscape setting and permits unobscured views of the wooded hillside. This is clearly illustrated in the images provided in the LVIA appendices in which the existing building is shown to be completely hidden by tree planting in November (though this doesn’t account for later winter months when the tree canopy has thinned further).
We do not agree with the general assessment that development would have a slight adverse to slight/moderately beneficial effect on the Wider Georgian City of Bath WHS, where we do not consider that the value of the area, and as a result the degree of harm, has been properly realised. The Widcombe and the Kennet and Avon Canal Character Appraisal emphasises the prevalent character of this area in views from the south of Bath, in which “most of Widcombe nestles in the wooded combes and dividing hillsides which finger their way almost into the City Centre,” as well as outlining the “splendid panorama looking west, north and east from Abbey View and Abbey View Gardens.” Within this context, we maintain that development would have a clear, adverse impact on the landscape setting of the conservation area and World Heritage Site, introducing an unwelcome and prominent built element into the otherwise visually undeveloped hillside setting south of the city. The minor reduction in height and alterations to the design have not sufficiently addressed nor justified this proposed harm to the landscape setting of multiple heritage assets.
Development would continue to loom over the adjacent Grade II* viaduct to the north. Part of the intentional design of the Grade II* viaduct is the use of picturesque principles, blending the railway into its landscape setting, which “informed [Brunel’s] selection of the route and the design of structures along it” (Historic England). The scale, massing, and prominence of development would therefore irreversibly unbalance the viaduct’s sensitive relationship with its retained landscape setting and intrude into gateway views that continue to be experienced by trains coming into Bath, which further has not been reflected in the LVIA where the effect on rail has been summarised as moderate beneficial.
The absence of any large built form protruding above the line of the Grade II* viaduct is an attractive feature of the wider setting of the viaduct and the conservation area which should be sustained.
Where we note that revisions have been made to the design in an attempt to address previous objections, such as the use of Bath stone ashlar rather than a buff brick, we remain somewhat disappointed that the design largely remains the same. The most significant change that has been made is the proposed pitched roof profile and gabling across the side elevations, though it appears this has been introduced more to reduce the perceived height and massing rather than referencing or drawing from its contextual setting. The roof profile is disingenuous where it would only be a façade screening the roof terrace and amenity space at fourth floor level. There is an opportunity for a more responsive design drawing on local examples or a more contemporary design, though this would still be expected to address continued issues with the excessive height, scale, and massing of current proposals.
Amenity & Affordable Housing:
We maintain our continued concerns regarding principle of the proposed co-living model and how this would ensure adequate levels of private and communal amenity space for future occupiers, as well as the apparent lack of affordable housing.
The claim is made that the development would be exempt from affordable housing requirements on grounds that the proposed co-living model would come under ‘Sui generis’ use and as such be exempt from Policy CP9. Previous schemes for co-living accommodation within Bath (see 20/03166/FUL at Regency Laundry on Lower Bristol Road) have been considered eligible for affordable housing provision by B&NES Council. Considering the site’s location within an area of 30% affordable housing provision requirement as set out in Policy CP9, we strongly emphasise the need for a genuinely affordable housing offer.
Where the applicant cites reports that “co living is often around 20% cheaper in terms of all-in cost of living in comparison to other private rental accommodation,” this in itself does not guarantee that co-living would be an affordable option for its target market of young professionals. A standard co-living unit offered by Scape in Guildford would cost upwards of £1,335 p/m for a 24m2 studio room (it’s worth also noting that Scape are providers of student accommodation). Co-living prices in London typically start from around £1,000 p/m for a studio room, but can average £1,200 at the cheaper end of the market. We continue to reiterate that this simply isn’t affordable for 20-30 year olds looking to live in Bath.
Where the application indicates a lack of comparison with HMOs due to “the amenities that come with the co living package”, this does not account for the intrinsic appeal of HMOs due to the private use of amenity space between much smaller groups of residents (average 3-4 per dwelling) as well as other benefits such as access to a private garden and parking, often at a much lower price point. The further claim that provision of affordable housing would not be able to be sustained due to the shared use of amenities is not convincing – affordable housing should be tenure blind and provide access to the same facilities and standard of accommodation.
We therefore consider that the provision of a financial contribution would be insufficient, and highlight the current need for the delivery of affordable housing now on the limited available sites within Bath.
We reiterate our concerns with the quality of internal space provision and inadequate residential amenity for future occupiers. The standard studio room sizes vary between 22.7m2 and 25.5m2 (though the average is around 24m2), with the exception of one accessible studio per floor at 31.9m2. There would be a total of 91m2 amenity space per floor, to be shared between 24 residents. Discounting the amenity space provided at ground floor level, which is given to ancillary storage (eg. bins, bikes), mail room, and employment space intended to serve the entire building, it is estimated that each resident (excluding the resident of the accessible studio) would have access to a total of 26.8-27.8m2. A total provision of 446m2 of internal amenity space (excluding the ground floor employment space and ancillary facilities, as well as the roof terrace) would equate to an average of 5.8m2 of amenity space per resident, and access to a minimum total of 27.8m2 combined private/communal amenity space, falling short of the national space standard of 37m2.
We continue to be uneasy with the provision of a single type of residential use and housing mix, contrary to Policy CP10 and Section 8 of the NPPF. We maintain that the proposed accommodation type is more suited to short-term, temporary lets, drawing from existing models of student accommodation and tenancy periods, rather than providing much-needed longer-term city centre lets with appropriate levels of private amenity space.
The proposed height, scale, massing, and design of development would continue to fail to respond positively to local townscape character and constitute overdevelopment, and would have an adverse impact on the landscape setting of the World Heritage Site, would fail to preserve or enhance the character or appearance of the Bath conservation area, and would result in less than substantial harm to the grouped setting of multiple listed buildings. The development would be result in cumulative, adverse impact on the setting of multiple heritage assets and failure to reflect local distinctiveness and townscape character, and would not be adequately outweighed by public benefit. This application is contrary to the Planning (Listed Buildings & Conservation Areas) Act 1990, Section 16 of the NPPF, and Policies B1, B4, BD1, CP6, D1, D2, D3, D4, D5, D6, HE1, NE2, and NE2a of the Core Strategy and Placemaking Plan and should be refused or withdrawn.