The developer has destroyed important trees on this site and must pay for theirreplacement and must pay compensation for damage to the local environment.If reparations for the damage caused are not enforced then it will demonstrate Bristol's disregardfor a greener city with lower pollution.It is possible to have new buildings with a good local environment if Bristol City Council actuallygives a damn.

 Information on the local Car Club scheme and contact details.

 Information on the health benefits of walking and cycling.

 Travel vouchers to the value of £500 (with option for a further £500 which would be welcomed) per dwelling to assist the purchase of sustainable travel modes such bus or train travel and/or cycle acquisition.

The pack will promote www. travelwest.info and the Travel Plan Co-ordinator when appointed plans to join the Bristol Workplace Travel Network and Cycle Champion Scheme. To do this they will need to email their contact details to city.transport@bristol.gov.uk Cycle maps can be downloaded or ordered from www.betterbybike.info/maps/cycle-maps. For examples of Travel Information Packs please see www.travelwest.info/movhome/new-housing-developments The pack should also include links to:

 National Rail Enquiries

 Falcon (Stagecoach) Service

 National Express

 Megabus

 Taxi

 Cycle repair shops

 Supermarket Deliveries We would request that the developer sends us the Travel Welcome Pack as evidence within 3 months of occupation and we would also need to see the results of the monitoring. When the Travel Plan Co-ordinator has been appointed their contact details including telephone and email must be provided along with the final Travel Plan Statement and a site location map to travelplans@bristol.gov.uk. For any further information please contact James Morvan - Travel Plan Officer on 0117 3576228. Footway Reinstatement / Vehicle Access Point / Parking Bays The revised ground floor plan Ref. P201 Revision A proposes to stop up the existing two vehicle access points and to reinstate the footway to full kerb height. Whilst this is acceptable the existing tactile paving must be removed and concrete kerbs replaced with pennant stone. Instead a new access 4.8m wide point is proposed, which will encompass a sliding entrance gate, with a vehicle crossover and dropped kerbs. The revised ground floor plan has reduced the number of proposed on-street parking bays to 3no. each of which has 45˚ splays. This is the same number of bays that are present on the existing frontage, although the site accesses do appear to have been used as unofficial parking bays in the past. The site plan indicates visibility splays of 2.4m x 25m (based on a speed of 20mph) and pedestrian visibility splays of 2m x 2m. While the splay is encroached by a parking bay and street tree, these will not fully obscure the visibility splay and it is considered acceptable. A Section 278 Agreement will be required to undertake the works as well as a Section 171 Licence. Traffic Regulation Order

The site plan submitted proposes to alter the existing waiting restrictions in the form of double yellow lines by removing them in front of the proposed parking bays and extending them either side of the proposed access point. The cost of these measures and the associated Traffic Regulation Order (TRO) (£5395) will be met by the applicant. Side Lane The application proposes to widen the existing lane that offers a pedestrian/cycle link from Gordon Road through to Lower Ashley Road that measure’s between 2.475m to 2.850m. This is acceptable providing the additional part is constructed to meet Bristol City Councils Engineering Standard Details and the route is appropriately signposted. The additional land can be dedicated for adoption and ongoing maintenance at public expense via the required Section 278 Agreement. Layout The site plan submitted proposes a 4.8m wide access point to enable 2 vehicles to pass each other. This will be set back 6m from the edge of the carriageway, which is sufficient to allow a vehicle to be able to fully pull clear of the adopted highway and avoid it becoming an obstruction to oncoming traffic. It will feature a gate and 45˚ visibility splays, all of which are acceptable. A small 0.3m to 0.5m buffer should be provided either side to prevent it being struck by vehicles manoeuvring in and out of the undercroft car park. Swept path analysis has been provided for the one of the spaces at the far end of the car park to demonstrate that vehicles can safely and easily use them. The parking spaces proposed will measure 2.4m wide x 4.8m long, separated by a 6m wide gap. The space for disabled residents/visitors features a side and rear hatched area 1.2m wide. Four access points to the property are proposed from Ashley Down Road: from the undercroft car park, and three pedestrian accesses. In addition there is an access path along the west side of the building to give access to a cycle store and garden space at the rear of the building with gates at both ends. These gates as well as all those within the site will be access controlled which is acceptable providing they are constructed to Secured by Design standards. The footpath should be suitably illuminated. Car Parking / Cycle Parking The Bristol Local Plan: Site Allocations and Development Management Policies (adopted July 2014) (SA&DMP) details the following parking standard for the proposed use of the site: Cycles, 1 space per 1 bed unit, and 2 spaces per 2/3 bed unit; car parking 1 space per 1 bed unit, 1.25 spaces per 2 bed unit, 1.5 spaces per 3 bed unit; spaces for disabled people 5% and; one electric vehicle charging point should be provided for every five spaces. Please note: vehicular parking provision is a maximum; cycle parking provision is a minimum. The application proposes 13 parking spaces of which one will be for disabled people and three will include Electric Vehicle Charging Points, as well as one space for motorcycles which is acceptable. In respect of cycle storage the site plan submitted proposes four fully enclosed stores that will be able to accommodate 43 cycles. This will permit storage of 43 cycles for residents and 4 for visitors, which is acceptable.

Waste The application proposes three internal waste stores. These must be independently ventilated with 1.5m wide doors. Whilst the stores are at the front of the building, the maximum distance that Bristol Waste operatives can manoeuvre 1,100ltr bins is 5m and for 180ltr 15m. As a result the bins will need to be left on the footway for collection and be brought is as soon as they have been emptied. Construction Management The Construction Management Plan submitted is welcomed; however the exact details of the temporary traffic management will be subject to agreement with Network Management. TDM would advise the applicant that the proposed timber hoarding to the east of the site is likely to obstruct visibility to and from the pedestrian crossing and will need to be amended. Once a principle contractor is appointed and prior to commencement of the development the plan will need to be updated with site contact details and submitted for approval to the LPA. A Temporary Traffic Regulation Order (£1,860) will be required as well as a Hoarding Licence and a Section 178 Mobile Crane Licence. Recommendation Subject to the above, TDM have no objection to this development. B. Pre commencement conditions B1A Highway works Prior to commencement of development general arrangement plan(s) indicating the following works to the highway shall be submitted and approved in writing by the Local Planning Authority.

 Remove existing two vehicle access points on Lower Ashley Road and to reinstate the footway to full kerb height.

 Creation of a new vehicle access point on Lower Ashley Road and 3no. parking bays

 Dedication of land adjacent to path between Gordon Road and Lower Ashley Road as highway

 Associated ancillary works including but not limited to lighting, signing, lining, drainage, resurfacing and street furniture.

 Alter the existing waiting restrictions Indicating proposals for: • Threshold levels of the finished highway and building levels • Alterations to waiting restrictions or other Traffic Regulation Orders to enable the works • Locations of lighting, signing, street furniture, street trees and pits • Structures on or adjacent to the highway • Extents of any stopping up or dedication of new highway These works shall then be completed prior to first occupation of the development to the satisfaction of the Local Highway Authority and as approved in writing by the Local Planning Authority.

Reason: In the interests of public safety and to ensure that all road works associated with the proposed development are planned and approved in good time to include any statutory processes, are undertaken to a standard approved by the Local Planning Authority, and are completed before occupation. NB: Planning permission is not permission to work in the highway. A Highway Agreement under Section 278 of the Highways Act 1980 must be completed, the bond secured and the City Council’s technical approval and inspection fees paid before any drawings are considered and approved and formal technical approval is necessary prior to any works being permitted.

B3 Construction management plan C. Pre occupation conditions C5 Implementation/Installation of Refuse Storage and Recycling Facilities – Shown C7 Completion of Vehicular Access – Shown C8 Completion of Pedestrians/Cyclists Access – Shown C12 Completion and Maintenance of Car/Vehicle Parking – Shown C13 Completion and Maintenance of Cycle Provision – Shown Car parking, access and highway safety D21 Retention of Garage/Car Parking Space(s) Travel plans D34 Travel Plans – Submitted Advices I021) Alterations to Vehicular Access I024) Works on the Public Highway I026) Traffic Regulation Order (TRO) I043) Impact on the highway network during construction I045) Restriction of parking permits – future controlled parking zone

- The distinction between the land ownership flush and seamless with no railing or wall separating the two. Deeper window reveals, planters, balconies etc. can be used to maintain privacy.

- It’s unfortunate that the south facing frontage addressing Lower Ashley Road cannot animated with balconies and private amenity spaces due to air quality issues.

- There is however an opportunity to provide private balconies and amenity space on the North facing elevation in addition to the communal provision being proposed.

- It is unclear why the communal amenity space has been subdivided into two parts. Joining these as a single space will allow for more efficient use.

It is requested that the applicant look towards revising the scheme to address these concerns, with further consultation with CDG undertaken once revised plans have been received.

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BCS 13 Climate change

All new development should be designed with the future climate in mind through climate change mitigation &

adaptation techniques. Mitigation and adaptation measures must be integrated into the design.

Mitigation

Energy use – see comments under BCS14 below

Electric Vehicles – The proposed EV charging spaces are supported in line with policy

Cycle parking – The proposed cycle parking is supported in line with policy

Adaptation

Insufficient information has been provided on climate change adaptation measures.

The proposal conserve water through water efficiency measures and limit water use to 105l/p/d is noted and

supported. However further information should be provided to demonstrate how the development will meet

the following points;

 The layout of the site should be designed to mitigate extreme temperatures brought about by climate

change. Orientation, form, massing and planting for shade should be carefully considered so that both

internal and external spaces are comfortable in hot weather.

 The building design should mitigate extreme temperatures and risk of overheating brought about by

climate change. This should include good thermal mass, living walls and roofs, open able windows,

canopies, and external shading, and avoiding single aspect units. This is particularly important for rooms

on S and SW sides of the building. South facing elevations will receive more direct solar radiation around

midday when the sun is high in the sky. South-west facing elevations will receive solar gains when ambient

external temperature is at its highest, making the rooms on both South and South West elevations more

prone to overheating. The extent of glazing to the W facing rooms should be carefully considered as these

may receive unwanted solar gains from low level sun in the evenings. We’d recommend that overheating

risk analysis (e.g. following CIBSE TM59/TM52 guidance/other as appropriate) is carried out based on

dynamic thermal modelling in order to understand the implications of future projected temperatures (e.g.

in 2030 and 2050) on the development in order to mitigate the risks appropriately and ensure a

comfortable internal environment is provided without the need for energy consuming cooling equipment.

Further guidance produced by the NHBC foundation/zero carbon hub on understanding overheating and

design options for mitigation can be found here. Assessments using the steady state conditions SAP

compliance tool are not appropriate for the purpose of demonstrating compliance with the policy

requirement (i.e. for site layouts and approaches to design and construction which provide resilience to

climate change) because this tool does not factor in future climate impacts.

 Development should minimise flooding through the use of sustainable drainage systems – please refer to

comments from flood risk manager.

 Development should include blue & green infrastructure to both mitigate the urban heat island and

reduce surface water runoff. DM15 requires that new GI assets are designed to be multifunctional, and

expects the provision of additional and/or improved management of existing trees as part of new

development. Minimal green infrastructure is proposed. Further greening is required for example through

provision of a green/ green-blue roof with a deep substrate and minimal/no sedum blanket areas.

 Development should avoid responses to future climate impacts leading to increases in energy use (e.g. air

conditioning systems).

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BCS 14 Sustainable energy

Calculation methodology

The calculation methodology (SAP12) is in line with policy, however the baseline energy calculation is not

policy compliant. This needs to include a policy compliant heating system, not electric heating as currently

included as this results in high baseline emissions compared to other policy compliant heating systems. The

calculations must be revised and a revised energy statement and table submitted

Energy Efficiency

The energy efficiency measures proposed are acceptable.

Heating systems – Heat Hierarchy

The heating system proposed (electric heating) does not comply with the BCS14 heat hierarchy. The site is

within the heat priority area and nearby to an emerging heat network in the St Pauls area and is therefore

required to incorporate infrastructure to enable connection to forthcoming networks in the future. i.e a wet

communal heating system.

In accordance with the heat hierarchy, the preference is for this to be served by a renewable heating system

such as air source heat pumps. These could be located at roof level.

The applicant should provide a revised energy statement setting out how the BCS14 heat hierarchy will be

met through provision of a policy compliant heating source.

Renewable Energy

The proposal for PV is supported and this will meet the 20% reduction in CO2 below residual emissions

requirement.

BCS 15 Sustainable construction

Waste & recycling

The proposals set out in the sustainability statement do not set specific targets for construction waste

reduction/diversion from landfill. A Site Waste Management Plan should be conditioned to include these

targets.

The storage for bins and recycling should be provided in line with Bristol Waste’s recycling planning guidance.

– see comments from Bristol Waste on the proposal.

Water

The water efficiency proposals are acceptable. Further consideration of the use of rainwater harvesting is

encouraged.

Materials

The proposal for the use of A and A+ -rated BRE Guide materials in 80% of the major building elements as set

out in the sustainability statement is supported.

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Biodiversity

There do not appear to be proposals to enhance biodiversity or green infrastructure on site.

In addition to BS15 requirements about enhancing biodiversity, the Site Allocations and Development

Management Plan also links to biodiversity (DM15 and DM29).

Biodiversity enhancement options could include; sustainable drainage systems such as green roofs, brown

roofs, living walls, tree pits, swales, attenuation ponds to reduce surface run off and improve water quality,

wildlife areas, the inclusion of bird and bat boxes and the planting of fruit/ nut bearing trees. Green roofs

should be specified with deep substrate depths to support a greater variety of species, hold significantly more

rainfall, have a greater thermal mass and have greater evapotranspiration properties.

Revised proposals setting out proposals to enhance biodiversity should be submitted

Information & communications technology

The broadband statement submitted is for a different site. A revised assessment is required providing evidence

of the provision of high-speed broadband access and enabled provision of ‘Next Generation’ broadband.

Further guidance on demonstrating this policy requirement has been met can be found in the broadband

connectivity practice note March 2018

BCS 16 Flood risk & water management

This policy requires Flood resilience and surface water management. Please see comments from the flood risk

team

of the findings must be produced. The results of this investigation shall be considered along withthe Remediation Verification Report prepared by SLR consulting, dated October 2004 (Ref4B/321/008). The written report of the findings shall be submitted to an approved in writing by theLocal Planning Authority prior to any works (except demolition) in connection with thedevelopment, hereby approved, commencing on site. This investigation and report must beconducted and produced in accordance with DEFRA and the Environment Agencys ModelProcedures for the Management of Land Contamination, CLR 11.

Reason: To ensure that risks from land contamination to the future users of the land andneighbouring land are minimised, together with those to controlled waters, property and ecologicalsystems, and toensure that the development can be carried out safely without unacceptable risks to workers,neighbours and other off site receptors.

SF-031

There should be a suitable presentation point adjacent to the highway where containers can be

placed for collection by a resident or building manager on the relevant collection day.

The dimensions of the relevant containers are listed below:

Container Volume (litres) Width (mm) Depth (mm) Height (mm)

Refuse bin 240 570 740 1070

Green recycling box 55 585 390 350

Black recycling box 45 585 390 285

Food waste bin 23 320 400 405

We would urge at this stage of the planning process that the developers refer to the Planning

Guidance for Waste and Recycling produced by Bristol Waste Company. When considering the

layout, access and the design of the bins stores, this guide contains a wealth of information

regarding the bin volumes, requirements etc. http://www.bristolwastecompany.co.uk/resources/

I hope that this has provided sufficient feedback with regards to the areas of concern should this

development progress from application status as proposed.

Please note that the above comments are made on the basis and the quality of the information

received to date and as such, they are made without prejudice to any further pre-application or

application proposals which may raise further detailed questions or matters that are not currently

considered within this response.

Thank you,

Jennifer Fawcett-Thorne

Business Development Officer

jennifer.fawcett-thorne@bristolwastecompany.co.uk

While I welcome the proposal for more affordable housing in the area, as a very closeneighbour to the land where this application is being considered, I object to the application on thefollowing grounds:Loss of light and overshadowing to the rooms at the front of our house, especially downstairs - Ihave looked at the daylight and sunlight assessment. Gordon Road properties are not mentionedbut I can't see how buildings at the same end of Gordon Road as the development (as ours is)wouldn't be adversely affected. A three storey building would be much less of a concern.Adequacy of parking - since the introduction of permit only packing in the neighbouring areas of StPauls and Montpelier parking on and around the road we live on has become increasinglycramped and inadequate. There have been frequent occasions when it has been very difficult forlarge vehicles such as vans to access our road and nearby streets. For a fire engine/ambulanceresponding to an emergency this could lead to fatalities. Increasing the local population by building31 units would be very likely to exacerbate the already overstretched parking capacity in the area.I appreciate that some onsite parking is planned for but I feel it is very unlikely that the number ofpeople who would live in the new development would have fewer than this number of vehicles.Traffic generation - traffic in the immediate area is already frequently congested. Building aproperty with so many living units would inevitably create more traffic and more congestion.Loss of trees - at the moment there are several mature trees on Lower Ashley Road. Theproposed development will lead to these mature trees being cut down and small immaturesaplings being planted instead. These mature trees help to mitigate the air pollution from the busyroads nearby. To cut them down would be a loss.Nature conservation - I have seen bats flying very close to our house and in neighbouringgardens. I don't know where the bats live but their habitat should be considered.

 The entry into the under-croft parking is shown to have access control although the construction of the gate/barrier/shutter is not clear. We would advise that any barrier denies unauthorised entry and meets requirement of LPS 1175 SR 1 or STS 202 BR 1.

 There is a high level of graffiti in the immediate area, where elevations of the building lack defensible space e.g. rear of east elevation, then the use of a sacrificial coating should be considered.

The affordable housing element will have to satisfy the LPA’s Affordable Housing Practice Note (April 2018) which needs to meet the Housing Corporations ‘Design and Quality Standards (published April 2007). This states ‘ensure that the scheme design reflects advice obtained from local police architectural liaison officers/crime prevention design advisors prior to detailed planning stage’ and ‘obtain Secured by Design certification wherever possible’. As such we can provide advice from the outset www.securedbydesign.com If you have any questions then please feel free to contact me. Peter Wozniak Crime Prevention Design Advisor.

 Information on the health benefits of walking and cycling.

 Travel vouchers to the value of £500 (with option for a further £500 which would be welcomed) per dwelling to assist the purchase of sustainable travel modes such bus or train travel and/or cycle acquisition.

The pack will promote www. travelwest.info and the Travel Plan Co-ordinator when appointed plans to join the Bristol Workplace Travel Network and Cycle Champion Scheme. To do this they will need to email their contact details to city.transport@bristol.gov.uk Cycle maps can be downloaded or ordered from www.betterbybike.info/maps/cycle-maps. For examples of Travel Information Packs please see www.travelwest.info/movhome/new-housing-developments The pack should also include links to:

 National Rail Enquiries

 Falcon (Stagecoach) Service

 National Express

 Megabus

 Taxi

 Cycle repair shops

 Supermarket Deliveries We would request that the developer sends us the Travel Welcome Pack as evidence within 3 months of occupation and we would also need to see the results of the monitoring. When the Travel Plan Co-ordinator has been appointed their contact details including telephone and email must be provided along with the final Travel Plan Statement and a site location map to travelplans@bristol.gov.uk. For any further information please contact James Morvan - Travel Plan Officer on 0117 3576228. Footway Reinstatement / Vehicle Access Point / Parking Bays The site plan submitted proposes to stop up the existing two vehicle access points and reinstate the footway to full kerb height. Whilst this is acceptable the existing tactile paving must be removed. Instead a new access 4.8m wide point is proposed, which will encompass a sliding entrance gate, with a vehicle crossover and dropped kerbs. The site plan indicates visibility splays of 2.4m x 25m (based on a speed of 20mph) and pedestrian visibility splays of 2m x 2m. The plan also proposes five on-street parking bays, each of which has 45˚ splays. Unfortunately the two parking bays closest to the vehicle access point (one on each side) would obscure visibility and would not be acceptable. A Section 278 Agreement will be required to undertake the works as well as a Section 171 Licence. Traffic Regulation Order The site plan submitted proposes to alter the existing waiting restrictions in the form of double yellow lines by removing them in front of the proposed dual parking bays and extending them either side of the proposed access point. The cost of these measures and the associated Traffic

Regulation Order (TRO) (£5395) will be met by the applicant. Side Lane The application proposes to widen the existing lane that offers a pedestrian/cycle link from Gordon Road through to Lower Ashley Road that measure’s between 2.475m to 2.850m. This is acceptable providing the additional part is constructed to meet Bristol City Councils Engineering Standard Details and the route is appropriately signposted. The additional land can be dedicated for adoption and ongoing maintenance at public expense via the required Section 278 Agreement. Layout The site plan submitted proposes a 4.8m wide access point to enable 2 vehicles to pass each other. This will be set back 6m from the edge of the carriageway, which is sufficient to allow a vehicle to be able to fully pull clear of the adopted highway and avoid it becoming an obstruction to oncoming traffic. It will feature a gate and 45˚ visibility splays, all of which are acceptable. A small 0.3m to 0.5m buffer should be provided either side to prevent it being struck by vehicles manoeuvring in and out of the undercroft car park. Swept path analysis has been provided for the one of the spaces at the far end of the car park to demonstrate that vehicles can safely and easily use them. The parking spaces proposed will measure 2.4m wide x 4.8m long, separated by a 6m wide gap. The space for disabled residents/visitors features a side and rear hatched area 1.2m wide. Four access points to the property are proposed from Ashley Down Road: from the undercroft car park, and three pedestrian accesses. In addition there is an access path along the west side of the building to give access to a cycle store and garden space at the rear of the building with gates at both ends. These gates as well as all those within the site will be access controlled which is acceptable providing they are constructed to Secured by Design standards. The footpath should be suitably illuminated. Car Parking / Cycle Parking The Bristol Local Plan: Site Allocations and Development Management Policies (adopted July 2014) (SA&DMP) details the following parking standard for the proposed use of the site: Cycles, 1 space per 1 bed unit, and 2 spaces per 2/3 bed unit; car parking 1 space per 1 bed unit, 1.25 spaces per 2 bed unit, 1.5 spaces per 3 bed unit; spaces for disabled people 5% and; one electric vehicle charging point should be provided for every five spaces. Please note: vehicular parking provision is a maximum; cycle parking provision is a minimum. The application proposes 13 parking spaces of which one will be for disabled people and three will include Electric Vehicle Charging Points, as well as one space for motorcycles which is acceptable. In respect of cycle storage the site plan submitted proposes four fully enclosed stores that will be able to accommodate 43 cycles. This will permit storage of 43 cycles for residents and 4 for visitors, which is acceptable.

Waste The application proposes three internal waste stores. These must be independently ventilated with 1.5m wide doors. Whilst the stores are at the front of the building, the maximum distance that Bristol Waste operatives can manoeuvre 1,100ltr bins is 5m and for 180ltr 15m. As a result the bins will need to be left on the footway for collection and be brought is as soon as they have been emptied. Construction Management The Construction Management Plan submitted is acceptable. A Temporary Traffic Regulation Order (£1,860) will be required as well as a Hoarding Licence and a Section 178 Mobile Crane Licence. Recommendation The parking bays proposed as part of the access proposals that are presented require modification in order to provide an acceptable visibility splay to and from the vehicle access point. In absence of any changes, highways would raise an objection on the grounds of highway safety.