Basement Flat, 33 Green Park, Kingsmead, Bath

33 Green Park forms part of a Grade II late 18th century terrace of townhouses by John Palmer, situated within the Bath conservation area and World Heritage Site. It forms part of the indicative setting of the Grade II early 19th century former coach houses to the rear at 33-34 Green Park Mews. The terrace presents a well-balance and uniform façade in Bath stone ashlar with a rusticated ground floor, although the eaves line does step up towards the southern end with greater detailing around the first floor window reveals. The terrace retains an elevated position overlooking Green Park, with connected vaults that run underneath the road and terminate in a buttressed ashlar wall visible in short to mid-range views across the park and from Green Park Road. A variety of openings in this elevation suggest a more utilitarian function divorced from the formal articulation of the principal terrace façade, with a number of windows, grilles, and coal chutes indicating the original ancillary function of the vaults.

BPT maintains that this application does not provide a level of detail appropriate to the Grade II designation of the building, and we are surprised that the application was validated despite being incomplete. We note that no existing or proposed elevations have been provided of the south elevation of the vaults as viewed from Green Park, and therefore it is currently difficult to ascertain the proposed changes and their impact on the appearance of a listed building. Currently, the external wall is covered in vegetation growth and therefore the current appearance of the elevation is unclear. We therefore strongly recommend that the wall is cleared and surveyed as to its current appearance, condition, and relationship to the wider context of the listed terrace for the benefit of the case officer.

Whilst we maintain that there is currently not enough information to make a fully-informed assessment as to the suitability of proposals, we do have some initial concerns regarding the proposed insertion of sash windows of a distinctly formal and ‘domestic’ profile, within an elevation that has otherwise retained a predominantly utilitarian appearance. We strongly recommend that the proposed window design, profile, and finish should sit sympathetically within its historic setting and reflect the existing characteristics of its context; in this instance, a more utilitarian window design may be more appropriate, or a black painted finish to the sash windows to better blend in.

There are additionally some practical considerations regarding security due to the accessibility of the elevation from Green Park and whether the use of sash windows is practical in this setting. A number of adjacent window openings feature metal grilles and bars; this may be a necessary consideration for this application, behind which could be fitted a window of a simpler design.

It remains unclear as to how the proposed windows would sit in the reinstated openings. We maintain a flush finish would not be appropriate.

This application may offer a positive opportunity for the introduction of a more traditional form of passive ventilation, and consequently the removal of the existing vent grilles which are currently unsympathetic additions to the frontage of a listed building.

We recommend that existing and proposed sections may be necessary to account for a possible variation in ground level between the vaults and Green Park. Whilst the historic openings can be seen in full from within the vaults as shown in the D&A/Heritage Statement, an increased external ground level would complicate how these would be reopened without additional ground works.

We emphasise the unsuitability of vaults for residential use due to naturally damp conditions and poor air quality, with vaults being better suited to ancillary facilities or storage space instead. The use of vaults for a directly domestic function would not be suitable, either for the comfort of human usage or the alteration of historic fabric to meet modern standards of utility, and would place increased pressure on further invasive waterproofing and damp mitigation works in future with resulting detriment to the vaults’ special architectural and historic interest.

We therefore maintain that the proposed gym use could be acceptable as an ancillary use. However, this is pending further details regarding the internal treatment of the vaults to the floors and walls to manage damp ingress. The current application does not provide sufficient detail on how ongoing, future damp would be managed sensitively with minimal impact on historic fabric and character.

We have some concerns regarding the increased depth of the rear extension which significantly steps out from the established extension line of the terrace rear. Whilst the replacement of the 1990s uPVC conservatory is positive, we strongly recommend consideration of a design that is more harmonious with the established special architectural and historic interest of the listed building, utilising either a traditional or more lightweight design. We note that no design reference or justification is provided for the insertion of Crittal doors within this context.

This application does not provide sufficient detail to enable an appropriate assessment of the suitability of proposals, and is therefore contrary to the Planning (Listed Buildings and Conservation Areas) Act 1990, Section 16 of the NPPF, and Policies B1, BD1, CP6, D1, D2 D3, D5, and HE1 of the Core Strategy and Placemaking Plan. We consider that this application should not be granted consent without the relevant details as outlined above.