2 Cleveland Place East, Walcot, Bath, Bath and North-East Somerset, BA1 5DJ

Proposal Internal and external alterations to convert basement accommodation to create flat (Use Class C3) at 2-3 Cleveland Place East.
Our Response

For clarity, with reference to the Heritage, Design and Access Statement (D&A), comments are limited to ‘wall finishes’ (inc. insulation), mechanical ventilation and windows (glazing).

2 Cleveland Place East (No. 2) is included on the National Heritage List for England at Grade II. List entry reference number: 1394636. The proposal site is located within the City of Bath World Heritage Site (WHS) and the Bath-city wide conservation area (CA).

It is noted that No. 2 has been subject to several applications relating to the basement level since 2020, with various outcomes. It appears that the subject scheme has not been the topic of pre-application advice from the Local Planning Authority (LPA).

Drawing 697-P-03 (existing and proposed floor plan) (10/09/24) includes the text “All windows to be thoroughly repaired and made to work. All repairs to be undertaken on a like for like basis.” The D&A states “Windows will generally be repaired and restored and made to work…As part of these works and in order to improve thermal efficiency…the opportunity will be taken to change the glazing from single glazing to slim profile vacuum glazing. Draught proofing will also be installed” (para. 4.8). Heritage, Design and Access Statements or similar, are not typically subject to being ‘approved documents’; however, given the above, what is proposed in ambiguous.

If it is proposed that the glazing is to be replaced, whilst it is acknowledged that the officer will benefit from the opportunity of a site visit, the submission should make clear as to what, if any, contribution the subject windows and their glazing makes to the significance of the listed building. At present, unfortunately this is lacking. Reference should be made to paragraph 200 of the National Planning Policy Framework (December 2023) (NPPF).

With reference to the proposed wall insulation (Bedroom 2). It should be noted that intervention of this nature is not without risks to the proper function of natural materials and that the best intentions can have unforeseen consequences. If the LPA permits the application and a condition relating to the specific approach is attached to the decision notice, then perhaps reference could be made via an informative to the guidance note, Energy Efficiency and Historic Buildings: insulating solid walls (Historic England: April 2016).

With regard to the proposed extraction, serving the bathroom and kitchen respectively, this is acceptable in principle. Subject to specific details of the design and location(s) of the external terminal(s).

It is noted that the D&A concludes that the proposed scheme will lead to less than substantial harm to the significance of No. 2 (para. 5.0). If the officer comes to the same conclusion, then the ‘balancing exercise’ as per the provisions of section 16 of the NPPF will need to be undertaken.

Application Number: 24/03422/FUL & 24/03423/LBA
Application Date: 10/09/2024
Closing Date: 10/10/2024
Address: 2 Cleveland Place East, Walcot, Bath, Bath and North-East Somerset, BA1 5DJ
Our Submission Status: Comment