Alteration of existing ground and basement floor flat and disused sub-basement floor to form 1No 1-bed ground floor flat and 1No 2-bed basement and sub-basement garden maisonette.
Our Response

19 The Paragon forms part of a Grade I late-18th century terrace of townhouses situated within the Bath conservation area and World Heritage Site. It is overlooked by the adjacent Grade II raised pavement and the Grade II late 18th century terraced townhouses at The Vineyards, whilst the steep slope to the east provides The Paragon with elevated views over Walcot Street to the rear as well as clear, unobscured views across the terrace’s backland elevation. The Paragon is one of Bath’s earliest ‘crescent’ constructions, pre-dating works on the Royal Crescent, and is therefore a significant evidential aspect of the Georgian Town Planning and Georgian Architecture OUV of the World Heritage Site. It possesses strong group value as part of a “monumental ensemble[s]” of interconnecting, grandly articulated terraces to the west via Lansdown Road. The building has since been subdivided into flats, likely around the post-war era, and the ground/basement floors currently function as a two-bed maisonette, but these works have not been extended to the sub-basement which, whilst described as “dilapidated”, retain its original, historic vaulted character and appearance without significant modern intervention.

We acknowledge there are some issues relating to damp penetration and encourage remedial works that target the root of the issue such as the improvement of drainage in the front-facing lightwell.

However, the Trust is resistant in principle to the conversion of historic basements, cellars, and vaults to provide residential or domestic spaces. Typically, these areas retain a largely unaltered appearance that is historically, architecturally, and evidentially significant and associated with the historic function and use of the main dwelling. BPT maintains that these areas, due to expected levels of damp and poor air quality, are not considered suitable for domestic usage, and should have an ancillary function only as a store room or utility space that requires minimal interventions into the historic fabric.

Therefore, we feel that the proposed residential function of the sub-basement and its vaults would be inappropriate in principle unless proven otherwise. The space is not suitable for modern standards of living, with poor outlook, natural light, and passive ventilation, without material intervention at the detriment to its largely unchanged historic appearance and atmosphere. In particular, the use of one of the vaults as a bathroom would have a notable impact on the humidity and temperature of this space, and a significant unbalance of the vault’s existing atmosphere could result in increased future damp or condensation issues that would require more intrusive damp proofing measures.

Whilst more sympathetic measures such as lime plaster application can reduce levels of damp, this does not guarantee that the basement would be a damp-free space suitable for human habitation and we remain concerned that conversion would prompt the use of more visually intrusive damp proofing measures.

The Trust is supportive of proposals for the repurposing of vacant historic buildings and spaces within the city centre to ensure their continued use and associated maintenance. However, we maintain that the sub-basement is not fit for residential conversion and would therefore encourage its use as an ancillary storage space. We suggest that the sub-basement floor could be used as a self-contained one-bed flat without needing to expand across another floor with resulting harm to the architectural and historic interest of a listed building.

This application 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, and HE1 of the Core Strategy and Placemaking Plan and should be refused or withdrawn.

Application Number: 20/04812/LBA
Application Date: 16/12/2020
Closing Date: 04/02/2021
Address: Flat 1, 19 The Paragon, Walcot
Our Submission Status: Object