Victoria Hotel, Millmead Road, Twerton

Change of use from Public House (A4) to two 4-bedroom HMO properties (C4).
Our Response

The Victoria Hotel is a late 19th century public house situated in the Oldfield Park character area of the Bath World Heritage site, built at the turn of the century, and just outside of the boundary of the Bath conservation area. It remains a distinctive feature of the Millmead Road townscape due to its detached position, height, and distinctive gabled façade, and until 2018 provided an important community venue in a dense residential area of Bath. It seems to have been purpose-built as a public house, and is noted as such on a 1902 Ordnance Survey of Bath, and therefore it should be noted that the building’s communal function should be considered an integral aspect of its local historic and social significance.

BPT is not opposed to the principle of reusing historic buildings, and we would encourage vacant buildings to be repurposed to ensure their future sustainability and presence within Bath’s built environment.
However, we feel we cannot support this proposed change of use due to the unmitigated loss of a community asset, and the lack of justification regarding the public house’s current economic viability.

Considering the Victoria Hotel’s sensitive position within the local Oldfield Park community, we are surprised that the applicant has not sought a pre-application consultation with B&NES officers to discern possible alternative options for the public reuse of the building, aside from the previously withdrawn proposal to convert the building to D1 usage (see application 19/01447/FUL). There additionally appears to be no evidence of consultation with the local community regarding the potential future of the building, and how it could enhance the communal amenity of the local area. Based upon the large volume of objection comments from local residents, we would therefore request that the suitable documentation of public engagement be made available to ensure that any proposed change of use is tailored to meet the needs of the community whilst ensuring a consistent supply of recreational and communal facilities in accordance with sections 4 and 8 of the NPPF.

Ultimately, in accordance with Policy LCRA1A of the Core Strategy and Placemaking Plan, the development or change of use of a public house should “result in the provision of alternative facilities of equivalent or greater benefit to the local community.” Similarly, Policy LCR1 states that the loss of community facilities are only justified if other facilities of “equivalent community value” are provided, or if it can be demonstrated that there is an adequate provision of public local spaces within the area. Section 8 of the NPPF encourages development that “promotes social interaction” and provides necessary “social, recreational, and cultural facilities and services” to ensure the future sustainability and self-sufficiency of local communities and groups. We do not consider the conversion of a public house into private residential accommodation to constitute justifiable public benefit for the loss of a community venue. We would therefore strongly recommend that alternative uses for the building are considered that can provide “equivalent community value” to the residents of Oldfield Park.

Furthermore, we do not feel that suitable justification has been provided regarding the Victoria Hotel’s lack of economic viability. Whilst we appreciate that the public house has been on the market for a minimum period of six months in accordance with Policy LCR1A of the Core Strategy and Placemaking Plan, there has been no additional evidence supplied to suggest that the Victoria Hotel is not economically viable when in operation. We would encourage the submission of a Viability Report to enable the LPA to make a more informed decision as to whether the Victoria Hotel could continue to run successfully as a business, regardless of its current vacancy.

BPT therefore cannot support this application on the grounds of the loss of an important community asset without pre-application consultation with local residents, and the lack of documentation provided regarding the public house’s economic viability as a business. We would encourage the Victoria Hotel to retain some form of communal usage that will continue to enhance the residential amenity of the site, and its interconnected historic and social interest. This application is therefore contrary to section 2, 4, 6, 8, and 16 of the NPPF, and Policies D1, D2, D6, D7, HE1, H2, H3, LCR1, and LCR1A of the Core Strategy and Placemaking Plan, and we would recommend that it is withdrawn.

Application Number: 20/00967/FUL
Application Date: 17/03/2020
Closing Date: 09/04/2020
Address: Victoria Hotel, Millmead Road, Twerton
Our Submission Status: Object