Waterworks Cottage, Charlcombe Way, Fairfield Park, Bath

Demolition of dwellinghouse (Waterworks Cottage).
Our Response

Waterworks Cottage is an unlisted mid-19th century cottage situated within the World Heritage Site, and the indicative townscape setting of the Bath conservation area. The north boundary of the site directly overlooks the Green Belt and the Cotswold AONB, and forms part of the green landscape buffer between the city’s residential fringe and open, undeveloped countryside. In 2017 it was recognised as a Non-Designated Heritage Asset (NDHA) of local historic and social significance relating to the original site of the Charlcombe Water Works Company Ltd (B&NES Pre-Application Report 2017). As part of the dismissed appeal for application 20/04067/FUL, the inspector agreed that the cottage could be identified as a NDHA and concluded that “its significance is derived, in part, from its vernacular style, traditional local materials and historic associations.”

The August article by Kirsty Elliot in Local Look Magazine has highlighted that the original lease to William Powney in 1846 included “the erection of a steam engine, engine house, cottage and reservoir”, indicating the cottage to be part of the original waterworks infrastructure. It later appeared in the 1844-1888 OS map (attributed to 1882-1888). It is noted that the historic engine house is retained to the west of the site, although in what appears to be a derelict condition.

The cottage and its spacious garden setting positively contribute to the character and appearance of Charlcombe Way and the wider Fairfield Park character area. Part of Bath’s rural periphery, this area is characterised as primarily residential in which “the special relationship between the city and its surrounding hillsides is abundantly clear” (Bath City-wide Character Appraisal). Development on the higher slopes retains an open visual character with views out to the surrounding hills, particularly to the north as the land rises. The immediate setting of Waterworks Cottage constitutes early 20th century and interwar mid-density development, typically detached or semi-detached two-storey dwellings with generous front and rear private garden spaces that form a green visual buffer along Charlcombe Way.

Consequently, Waterworks Cottage constitutes a standalone remainder of traditional architectural and material vernacular within this localised suburban portion of the city’s periphery which, whilst undergoing some 20th century extensions and remedial works, has retained its historic core. The inspector concluded the following in relation to the site’s contribution to the wider area: “When also factoring in the inherently rural composition of the neighbouring open lands to the north, the site and its immediate surroundings can be observed to exhibit a green and semi-rural character and appearance.”

This application follows previous refusal of prior approval applications 22/01884/DEM and 22/02297/DEM, to which BPT objected on grounds of the unjustified total loss of a NDHA and the continued, insufficient provision of documentation associated with the demolition.

We maintain that demolition would continue to result in the complete and irreversible loss of a recognised NDHA contrary to Section 16 of the NPPF and Policies HE1 and CP6 of the Core Strategy and Placemaking Plan.

Harm to a Non-Designated Heritage Asset:

We recognise that as a prior approval application, permitted development rights pertaining to demolition are unfortunately not restricted by heritage considerations in this instance. However, we wish to take the opportunity to reiterate our previous comments regarding the heritage impact of proposals and strongly request the applicant to reconsider the proposed demolition of a NDHA with notable historic and aesthetic contributions to the local area.

We maintain strong resistance to the principle of the unjustified demolition of a NDHA with strong connections to the history, appearance, and distinctive rural character of the local area. The cottage is attributed greater significance as the apparent, final remainder of the Charlcombe Water Works considering the demolition of other related built features such as the reservoir.

In accordance with paragraph 197 of the NPPF, “the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that directly or indirectly affect non-designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset.” As such, the demolition of the cottage would constitute substantial harm and the total loss of significance of the heritage asset.

Local Policy CP6 states that “the Council will protect, conserve and seek opportunities to enhance the historic environment including the character and setting of designated and other heritage assets.” Emphasis is placed on the “sensitive reuse and adaptation of historic buildings and spaces”. As part of previous application 20/04067/FUL, it was proposed to retain, refurbish, and extend the cottage, clearly demonstrating that it was at least considered materially possible to upgrade the cottage to meet modern living standards. NO reasons have been provided as part of this application as to why it cannot be retained. Unless proven to be otherwise, it seems apparent that the cottage is of an adequate standard to be reused and demolition is therefore entirely unjustified.

Local Policy HE1 sets out that “development that has an impact upon a heritage asset, whether designated or non-designated, will be expected to enhance or better reveal its significance and/or setting, and make a positive contribution to its character and appearance.” The demolition would result in the complete and irreversible loss of a heritage asset and as such would therefore fail to enhance or better reveal its significance, instead resulting in identified harm to the localised heritage significance of the area.

We previously maintained that the development of three new-build dwellings on the site would not appropriately outweigh the demolition and associated harm to the cottage. We note the continued developmental pressures felt by this site following the dismissal of application 20/04067/FUL and highlight that the proposed demolition is likely part of land clearance works to try and remove planning obstacles for the next application to be submitted. However, on the principle of considering an application on its own merits, there would be NO identified public benefits or advantages that would be considered to adequately balance the loss of an attractive 19th century cottage in its entirety.

In accordance with paragraph 203 of the NPPF, “a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset.” However, demolition would result in total harm to a NDHA, with subsequent harm to local distinctiveness and townscape character, without identification of appropriate public benefit or optimum viable use to appropriately outweigh harm.


Paragraph 10 of the NPPF highlights that there is “a presumption in favour of sustainable development”, a sentiment matched by Policy SD1 of the Core Strategy and Placemaking Plan. In achieving sustainable development, the NPPF highlights the need to fulfil three key objectives including “c) an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change”. Paragraph 152 of the NPPF states that “the planning system should support the transition to a low carbon future in a changing climate […] It should help to: […] encourage the reuse of existing resources, including the conversion of existing buildings”.

In light of the Climate Emergency, we continue to strongly emphasise the value of retaining and reusing our built housing stock, where possible, to minimise unnecessary and wasteful demolition, the generation of debris (a proportion of which would likely end up in landfill), and the release of embodied carbon from the original construction of the building.


We continue to strongly oppose the unjustified demolition of a NDHA, contrary to Sections 2 and 16 of the NPPF, and Policies B1, DW1, SD1, CP6, HE1, NE3, and NE5 of the Core Strategy and Placemaking Plan. We continue to emphasise the benefits of this building as a positive feature in its local townscape and landscape context. We strongly recommend that the cottage is retained, updated and reinstated as a family home, and hope that the applicants will withdraw from the irreversible and total loss of a NDHA where this could easily be avoided.

Otherwise we recommend consideration of the removal of permitted development rights through an immediate Article 4 Direction.

Application Number: 22/03249/DEM
Application Date: 12/08/2022
Closing Date: 05/09/2022
Address: Waterworks Cottage, Charlcombe Way, Fairfield Park, Bath
Our Submission Status: Object