Flat 1 Basement, 33 Green Park, Kingsmead, Bath

Internal works including the provision of a specialist waterproof cavity drainage system to the walls of the vaults.
Our Response

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 previously responded to application 21/02414/LBA, which included proposals for the use of the under-pavement vaults as a gym and store. We previously considered that this would be acceptable as an ancillary use to the main building. However, it was indicated as part of proposals that “if any damp needs to be managed as part of this conversion, then a lime plaster on the internal wall surfaces would be used. This would ensure the protection of the historic fabric and significance of the vaults, in accordance with the guidance of the Bath Preservation Trust.”

We are therefore highly concerned by new proposals for the installation of a waterproof cavity drainage system to the internal wall of the vaults. This approach would be significantly more intrusive and result in the complete obscuration of the historic ashlar stone finish of the vaults’ interior.

We continue to reiterate 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 intrusive waterproofing and damp mitigation works in future, as evidenced by the submission of this application, with resulting detriment to the vaults’ special architectural and historic interest.

The internal subdivision works to create a bathroom would result in further harm to the plan form, appearance, and character of the vaults.

We do not consider that previous works to convert the basement floor into further residential space (cited as 02/02059/FUL & 02/02042/LBA) should be considered a suitable precedent for further erosion of the distinctive vaults character of this listed building. In this instance, claiming that the “damage has already been done” does not suitably justify further harm.

BPT therefore maintains that this would result in harm to the character and appearance of the listed building where this has been retained relatively unaltered. We consider that natural methods of damp control, such as passive ventilation via the permitted reopening of the windows or the internal application of limewash to the stonework should be prioritised ahead of more unsympathetic solutions. As yet there is no justification as to the need for a waterproof membrane system, or appropriate demonstration that installation would deliver adequate public benefit to outweigh harm to the heritage asset.

Application Number: 22/02636/LBA
Application Date: 30/06/2022
Closing Date: 18/08/2022
Address: Flat 1 Basement, 33 Green Park, Kingsmead, Bath
Our Submission Status: Comment