Unit 1-4, Wells Road, Lyncombe, Bath

Demolition of existing commercial Units 1 & 2 (Designability) and Units 3 & 4 (The Great Wine Company) and erection of a new 5-storey building, comprising employment floorspace (Use Classes…
Our Response

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 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 building is located on the edge of the north-western boundary of the defined Widcombe and the Kennet and Avon Canal character area, and as such is considered to define one of the principal routes into and through the area along the eastern and southern approaches. Within the Character Appraisal, the building is directly referred to with reference to the site’s contribution to street planting and greening: “An area of grass, shrubs and trees, tall Lombardy Poplars and Silver Birch, inadequately screening a modern low commercial retail building adjacent to the main Wells Road.” Further reference is made to negative townscape features and buildings in the area, including “inappropriate infill buildings dating from the 1970s”, although the building is not directly marked as a negative townscape feature on the attached map (see Annexe 1).

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.”

In views from the city, the site is screened (especially in summer) by mature tree planting, and merges into views of the wooded hillside towards Alexandra Park, reinforcing Bath’s sustainable and compact form and the Green Setting OUV of the World Heritage Site.

The existing commercial building is situated close to a number of listed buildings. To the immediate west is a concentrated cluster of individually-listed Grade II early 19th century terraced buildings at 12-32 and 42-48 Wells Road, and the Grade II early 19th century terrace at 1-9 St Mary’s Building; cumulatively, these terraces establish a mixed streetscape of 2-3 storey height in Bath stone ashlar. Significantly, the commercial building borders the St James’ Viaduct, a significant Grade II* 1840 structure that forms an integral aspect of Isambard Kingdom Brunel’s vision for the Great Western Railway between London and Bristol via Bath. Whilst of high significance in its own right as a survival of Bath’s early railway infrastructure, it is also recognised as a significant landmark in the Widcombe landscape with strong positive contributions to the character and appearance of the conservation area.

Height, Scale, Massing & Design:

Within the Bath Building Heights Strategy, the site falls within Zone 1 (The Georgian City); the following recommendations are set out for the building heights of new development “to preserve and/or enhance the character and/or appearance of the Georgian City”:

o “Building or shoulder height along streets should not be less than or exceed the prevailing cornice height of nearby Georgian buildings.”
o “The overall height should not be less than or exceed the overall prevailing height of nearby Georgian buildings.”

The Character Appraisal explicitly identifies development of increasing height as one of the key threats to the conservation area: “Building height of new development exceeding the traditional limits within and around this part of the conservation area disrupting the hierarchy of public and private buildings.”

The proposed 5 storey height of development would therefore be over-dominant and out of keeping with the established grain and profile of its Georgian context. Despite reading as 4 storeys across the south elevation from Wells Road, this would still overshadow the prevailing 2-3 storey townscape context of the conservation area and World Heritage Site, and would detract from the setting of multiple listed buildings, including the low-rise Grade II terrace along Wells Road.

The D&A Statement asserts that the design draws from “the 18th century buildings typical of Bath […] to emulate the surrounding context.” However, the result fails to reference or respond to the varied and less formal 19th century terraced streetscape of Wells Road, including a mix of pitched and mansard roof profiles and fenestration styles. The proposed parapet and unbroken roofline would make the building appear taller and more visually imposing. The proposed form is more indicative of the height and density of terraces within the city centre and as such is an inappropriate design reference in this location which fails to respond to, reinforce, or contribute to its townscape setting or local distinctiveness.

The heavy, monolithic presence of the building is exacerbated by the unbroken roofline and massing without variation or use of finer detailing to break up the expanse of the façade. We consider that the scale of the building as proposed is severely oversized compared with the relatively constrained nature of the site and as such constitutes overdevelopment contrary to Policies D1, D2, and D3 of the Core Strategy and Placemaking Plan.

We consider that the submitted Landscape Visual Impact Assessment (LVIA) does not demonstrate the reality of the impact of the development in mid- and long-range views across the conservation area and World Heritage Site. There is no consideration of the visibility of the site in winter months when the tree canopy is substantially thinned. However, what the LVIA does clearly demonstrate is that the existing building sits seamlessly within its green wooded landscape setting in close and long-range views from the north; the extent of tree canopy in this area and the absence of any large built form protruding above the line of the viaduct is an attractive feature of the wider setting of the viaduct and the conservation area which should be sustained.

The proposed visual montages supplied in the D&A Statement clearly demonstrate that the proposed building would have an adverse visual impact on the landscape setting of the conservation area and World Heritage Site, and would challenge the architectural prominence of the viaduct as a Grade II* structure and noted local landmark. The proposed block would loom over the viaduct, introducing an unwelcome and prominent built element into the otherwise visually undeveloped hillside setting south of the city.

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.

BPT maintains an in-principle objection to the height, scale, massing, and design of the proposed development, citing less than substantial harm to multiple heritage assets of high significance without demonstrating that this may be suitably outweighed by public benefit.


We feel that the use of brick is out of keeping with the established material and colour palette of the townscape. Inappropriate comparisons have been drawn with other developments in the D&A Statement such as Spring Wharf and the Aquila student accommodation block, where these development sites are located in a historically industrial area along the south of the river where there is a greater precedent for the use of brick.

In contrast, this development is set back from the river up the slope in an area characterised by low-rise Georgian and Victorian residential housing in a mix of natural Bath stone ashlar and blockwork, as well as some examples of coursed rubble stone on boundary walls and lesser elevations. This development would introduce a highly conspicuous use of brick ‘inland’ within the Widcombe character area and on a sensitive junction site that forms a visual ‘gateway’ into Bath, both along Wells Road and via the railway over the viaduct.

Proposals include the use of “engineering brick” at ground floor level to reflect the material treatment of the Grade II* viaduct. We remain unconvinced that the use of an industrial building material across the frontage of what is to be a residential building is in any way appropriate.

The D&A Statement maintains that the use of materials would “reflect[s] the characteristic material, colour and tones found within the buildings in the surrounding area and adjacent viaduct.” However, there is no historic or architectural reference or precedent for “buff” brick in this area. The proposed use of brick would be an over-dominant and uncharacteristic addition which would fail to reinforce local distinctiveness or to preserve or enhance the character and appearance of the conservation area. The use of brick would have an adverse impact on the material homogeneity of the city and the associated OUV of the World Heritage Site.

Further information is required as to the proposed planting mix for the green wall on the corners of the north and south elevations and how appropriate management and maintenance would be secured in the long-term. The effectiveness of the use of green walls is dependent on their health; where green walls are allowed to die due to poor management, the result is always woeful.

Amenity & Affordable Housing:

We have some concerns regarding the principle of the proposed co-living model and how this would ensure adequate levels of private and communal amenity space for future occupiers, in accordance with Policy D6 of the Core Strategy and Placemaking Plan.

The proposed studio room sizes are given at 23-24m2, with the exception of one accessible studio per floor at 33-34m2. 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 combined private/communal amenity space, falling short of the national space standard.

We are also concerned 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. Similarly, the provision of outdoor garden space for use by residents would be restricted to a terrace at roof level. Development would therefore be contrary to Policy D6.

In principle, BPT remains uneasy with development schemes that are restricted to a single type of residential use with inherent problems for future flexibility. The development would comprise solely one-bed studio rooms “especially aimed at retaining Bath’s graduates and young professionals”. This would be contrary to Section 8 of the NPPF, in which mixed-use developments are associated with “healthy and safe communities”, and Policy CP10 where new development is required to “provide for a variety of housing types and size to accommodate a range of different households, including families, single people and low income households”.

We note that the scheme proposes the provision of “much needed, affordable residential accommodation”, although it is unclear as to whether unit prices would meet the requirements (eg. discount market rent) to be considered truly affordable housing. Current examples of co-living prices in London typically start from around £1000 p/m for a studio room, which we do not consider to be affordable for the graduate and young professional market which this scheme would target.

Previous schemes for co-living accommodation within Bath (see 20/03166/FUL) 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 encourage that a genuine affordable housing offer is considered on this site.


The proposed height, scale, massing, and design of development would 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.

Application Number: 22/02399/FUL
Application Date: 01/07/2022
Closing Date: 07/08/2022
Address: Unit 1-4, Wells Road, Lyncombe, Bath
Our Submission Status: Object