Cont/d..

2

These mitigation measures shall be fully implemented prior to occupation and subsequently in accordance with the scheme’s timing/phasing arrangement. The measures detailed above shall be retained and maintained thereafter throughout the lifetime of the development. Reason To reduce the risk and impact of flooding to the proposed development and future occupants. Condition The development hereby permitted shall not be commenced until such time as scheme for provision of flood barrier/gate on the entrance to the basement car park has been submitted to, and approved in writing by, the Local Planning Authority in consultation with the Environment Agency. This shall provide effective flood protection up to a level of 9.8m AOD. The scheme shall include details of how the barrier will be operated and maintained over the lifetime of the development. The barrier shall be available for use prior to first occupation, and maintained thereafter for the lifetime of the development. Reason To reduce the impact of flooding to the proposed development and future occupants. Condition The development hereby permitted shall not be commenced until such time as details of the flood resilience and resistance measures to be utilised in the construction of the development have been submitted to and approved in writing by the Local Planning Authority in consultation with the Environment Agency. This shall include details of all flood barriers/doors and a plan outlining details of how the barriers will be stored, operated and maintained over the lifetime of the development. The development shall thereafter be implemented and operated in accordance with the approved details. Reason To reduce the impact of flooding to the proposed development and future occupants. General guidance to local planning authority We do not comment on or approve the adequacy of flood emergency response procedures accompanying development proposals, as we do not carry out these roles during a flood. Our involvement with this development during an emergency will be limited to delivering flood warnings to occupants/ users covered by our flood warning network. The planning practice guidance (PPG) to the National Planning Policy Framework states that, in determining whether a development is safe, the ability of residents and users to safely access and exit a building during a design flood and to evacuate before an extreme flood needs to be considered. One of the key considerations to ensure that any new development is safe is whether adequate flood warnings would be available to people using the development. In all circumstances where warning and emergency response is fundamental to managing flood risk, we advise local planning authorities to formally consider the emergency planning and rescue implications of new development in making their decisions. As such, we recommend you consult with your emergency planners and the emergency services to determine whether the proposals are safe in accordance with the guiding principles of the PPG.

Cont/d..

3

This does not mean we consider that the access is safe, or the proposals acceptable in this regard. We remind you to consult with your emergency planners and the emergency services to confirm the adequacy of the evacuation proposals. 2) Groundwater and Contaminated Land The previous uses of the proposed development site and surrounding land and results of desk study detailed in Geotechnical and Geo-Environmental Desk Study Report (Arup, 21 December 2018) submitted in support of the application indicate that contamination including metals, PAH, TPH and PFAS contaminants could be present at the site that could pose a risk of pollution to controlled waters. Controlled waters are particularly sensitive in this location because the proposed development site overlies Redcliffe Sandstone classified as secondary A aquifer and is close to the Bristol Frome Floating Harbour surface water body. We welcome the general recommendation for intrusive investigation proposed in the Desk Study Report in order to characterise the groundwater regime and contamination status of the site. We advise that site specific remedial target concentrations are determined for contaminants of concern against which the results of the investigation be compared and appropriate action taken if these are exceeded to ensure the risk to controlled ground and surface waters is acceptable. It is understood from the Desk Study Report that piled foundations may be required for the development. Piling using penetrative methods can result in risks to groundwater and dependent surface water quality from, for example, pollution / turbidity, risk of mobilising contamination, drilling through different aquifers and creating preferential pathways. Any piling or other penetrative ground works should be risk assessed to ensure the risks to controlled waters are acceptable. There is a risk that contamination previously identified in the soils at the site could be mobilised by surface water infiltration should certain sustainable drainage system (SuDS) components be employed that could lead to pollution of controlled waters. The location of any infiltration areas should be appropriately located based on the results of the ground investigation to ensure the risk of pollution is acceptable. The Desk Study Report submitted in support of this planning application provides us with confidence that it will be possible to suitably manage the risk posed to controlled waters by this development. Further detailed information will however be required before built development is undertaken. It is our opinion that it would place an unreasonable burden on the developer to ask for more detailed information prior to the granting of planning permission but respect that this is a decision for the Local Planning Authority. In light of the above, the proposed development will be acceptable if planning conditions are included requiring the submission of a remediation strategy, verification report and proposals for any sustainable drainage schemes or piled foundations, carried out by a competent person in line with paragraph 178 of the National Planning Policy Framework (NPPF). Without these conditions we would object to the proposal in line with paragraph 170 of the NPPF because it cannot be guaranteed that the development will not contribute to, be put at unacceptable risk from, or be adversely affected by, unacceptable levels of water pollution. Condition

Cont/d..

4

No development approved by this planning permission shall commence until a remediation strategy to deal with the risks associated with contamination of the site has been submitted to, and approved in writing by, the Local Planning Authority. This strategy will include the following components: 1. A preliminary risk assessment which has identified:

 all previous uses;  potential contaminants associated with those uses;  a conceptual model of the site indicating sources, pathways and receptors; and  potentially unacceptable risks arising from contamination at the site. 2. A site

investigation scheme, based on (1) to provide information for a detailed assessment of the risk to all receptors that may be affected, including those off site. 3. The results of the site investigation and the detailed risk assessment referred to in (2) and, based on these, an options appraisal and remediation strategy giving full details of the remediation measures required and how they are to be undertaken. 4. A verification plan providing details of the data that will be collected in order to demonstrate that the works set out in the remediation strategy in (3) are complete and identifying any requirements for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action. Any changes to these components require the written consent of the local planning authority. The scheme shall be implemented as approved

Reason To ensure that the development does not contribute to, is not put at unacceptable risk from, or adversely affected by, unacceptable levels of water pollution in line with paragraph 170 of the National Planning Policy Framework. Condition Prior to any part of the permitted development being occupied a verification report demonstrating the completion of works set out in the approved remediation strategy and the effectiveness of the remediation shall be submitted to, and approved in writing, by the local planning authority. The report shall include results of sampling and monitoring carried out in accordance with the approved verification plan to demonstrate that the site remediation criteria have been met. Reasons To ensure that the site does not pose any further risk to human health or the water environment by demonstrating that the requirements of the approved verification plan have been met and that remediation of the site is complete. This is in line with paragraph 170 of the National Planning Policy Framework. Condition If, during development, contamination not previously identified is found to be present at the site then no further development (unless otherwise agreed in writing with the Local Planning Authority) shall be carried out until a remediation strategy detailing how this contamination will be dealt with has been submitted to and approved in writing by the Local Planning Authority. The remediation strategy shall be implemented as approved. Reasons To ensure that the development does not contribute to, or is not put at unacceptable risk from, or adversely affected by, unacceptable levels of water pollution from previously unidentified contamination sources at the development site in line with paragraph 170 of

Cont/d..

5

the National Planning Policy Framework. Condition No infiltration of surface water drainage into the ground is permitted other than with the written consent of the Local Planning Authority. The development shall be carried out in accordance with the approved details. Reasons To ensure that the development does not contribute to, or is not put at unacceptable risk from, or adversely affected by, unacceptable levels of water pollution caused by mobilised contaminants in line with paragraph 170 of the National Planning Policy Framework. Condition Piling using penetrative methods shall not be carried out other than with the written consent of the local planning authority. The development shall be carried out in accordance with the approved details. Reason To ensure that the proposed development does not harm groundwater quality or resources in line with paragraph 170 of the National Planning Policy Framework. General guidance to developer We recommend that developers should: 1. Follow the risk management framework provided in Land Contamination: Risk Management page on GOV.UK (replaces CLR11, Model Procedures for the Management of Land Contamination), when dealing with land affected by contamination. 2. Refer to the Environment Agency Guiding principles for land contamination for the type of information that we required in order to assess risks to controlled waters from the site. The Local Authority can advise on risk to other receptors, such as human health. 3. Consider using the National Quality Mark Scheme for Land Contamination Management which involves the use of competent persons to ensure that land contamination risks are appropriately managed. 4. Refer to the contaminated land pages on GOV.UK for more information. We note from the Desk Study Report that dewatering may be required to enable some of the deeper excavations proposed during development. Construction dewatering now falls within the abstraction licensing regime and therefore a licence may be required from the Environment Agency to cover such works if they cannot comply with certain exemptions. Further details of the exemptions and requirement for licences is available on our Water management: abstract or impound water web page https://www.gov.uk/guidance/water-management-abstract-or-impound-water . Note to local planning authority In accordance with the Planning Practice Guidance (Reference ID: 7-043-20140306), please notify us by email within 2 weeks of a decision being made or application withdrawn. Please provide us with a URL of the decision notice, or an electronic copy of the decision notice or outcome. A copy of this letter has been forwarded to the agent. Please do not hesitate to contact the undersigned direct should you have any queries.

End

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Yours sincerely Mark Willitts Sustainable Places - Planning Specialist Direct dial 0203 025 0253 e-mail nwx.sp@environment-agency.gov.uk cc Avison Young Ltd

Dear Mr Westbury

It is noted from the Planning Committee meeting held on the 4th September 2019 that theBedminster Green development proposal Item 1. 19/00267/F Former Pring and St Hill Ltd MalagoRoad which had been recommended for 'refusal' by the Planning Officer was subsequentlyrejected by 7-3 (with the Planning Officers decision being upheld) by the Planning Committeemembers.

The Planning Officers primary reason behind the refusal is outlined below;Item 1. 19/00267/F Former Pring and St Hill Ltd Malago RoadRecommendation; RefusalReasonFor Refusal1. Height, scale and massing and overall design quality would be unacceptable indesign terms contrary to;Section 12 of the National Planning Framework (Feb 19)Policy BCS 21 ofthe Bristol Core Strategy (June 2011)DM 26, DM 27, DM 28, DM 29 of the Site Allocations andDevelopment Management Policies (July 2014)Urban SPD (Nov 2018)End of extract

In relation to 'Fire Station Development Proposal' there is the additional matter of the RedcliffeConservation area and concerns raised in relation to the Grade II listed and Scheduled MonumentTemple Church site and the Grade II listed Generator Building, amongst others, as stated byseveral Government and Civil Bodies.

This therefore also raises concerns regarding the 'NPPF paragraph 194 in respect of harm to

heritage assets' and compliance with the advice of 'Historic England' that;

'In determining this application you should bear in mind the statutory duty of section 66(1) of thePlanning (Listed Buildings and Conservation Areas) Act 1990 to have special regard to thedesirability of preserving listed buildings or their setting or any features of special architectural orhistoric interest which they possess, and the statutory duty of section 72(1) of the Planning (ListedBuildings and Conservation Areas) Act 1990 to pay special attention to the desirability ofpreserving or enhancing the character or appearance of conservation areas.

'Your authority should take these representations into account and seek amendments, safeguardsor further information as set out in our advice. If there are any material changes to the proposals,or you would like further advice, please contact us'

End of Extract

In consideration of the 'Malago Road' decision and the additional aspect of 'Conservation' relevantto the Redcliffe area there is no rationale for the Fire Station Plans to be recommended forapproval or approved, in there present form, if there is to be any form of consistency from eitherthe Planning Officers office or the Planning Committee in dealing with these high rise and intrusiveapplications.

Appreciate the opportunity that has been given to comment.

Kind Regards

Laurence Parkman

ADDENDUM DAYLIGHT & SUNLIGHT SELF TEST REPORT - Posted 2 September2019

This addendum sets out "slight" improvement to the daylight levels in the development followingthe recent (29 July) revisions to the plans (Conclusions 9.2)

It has compared light levels in similar developments elsewhere in Bristol, and concludes that thelikely light levels in the development are not considered to be "out of the ordinary" (Conclusions9.3).To be only as good as others, which may have resulted in below BRE recommended light levelsdoes not seem to be consistent with the "design led" approach that is extensively cited in theDesign and access statement and the Urban living SPD design response.

It again describes "mitigation considerations" for the light levels, which are in fact backgroundjustifications and not "mitigations" in the normal sense of the word (Conclusions 9.4).The only real mitigations which this report acknowledges have only made a slight improvement tolight levels (see Conclusions 9.2) are the small reductions in massing in the 29 July revised plans.

I fully support the comments made in the URBAN DESIGN response of 29 August about themassing of the planned development. Changes to the plans to fully respond to the Urban Designcomments would make real and meaningful mitigations to the reduced daylight levels in thedevelopment and surrounding buildings including Templebridge Apartments

Elements of this building remain much too tall, spoiling the carefully-preservedhomogeneity of height of the area as seen from across the river, e.g. from Castle Park. The extraheight is really unnecessary.

In its present form the project is opposed by experts truly concerned with the city and with itsviews (Historic England, Bristol Civic Society etc) who correctly feel that no development shouldexceed the height of the Generator Building. It is supported by local commercial interests with ashort-term focus on footfall for their businesses (ignoring the fact that the same footfall couldbenefit other business elsewhere if densities were more evenly distributed around the city) and bypartisan architectural industry bodies (the Bristol Urban Design Forum) whose objectivity, despitetheir status, is highly questionable.

As local campaigners stress, the height of the tower "would totally distort the skyline andnegatively impact on the Grade 2 listed buildings, (Generator Building and Temple Church etc),and the whole of the Redcliffe Conservation Area."

Bristol needs to preserve its status as a city which attracts talent because of its character andcharm. Increasingly, young professionals are rejecting high-rise islands like the docklands, whichthey experience as dull and uninspiring, as a recent report by then consultants Colliers haspointed out. They are more attracted to classic 19th century cities like Bristol, which can offer themthe kind of lifestyle they hanker after, with a relaxed ambiance, vibrant street life and cafes, and apleasing visual variety. Bristol needs to treasure its uniqueness. We have a unique selling point

(USP) - our "Bristolness" - and to make the city centre a forest of high rises like Leeds or Panamawill trash that USP, as so many other cities have done (and now regret their lack of foresight).

The way forward is mid-rise spaces like Wapping Wharf, as Cubex itself have realised in theirnearby developments. However the "open sesame" encouragement of high rise planningpermissions under the current administration is irresistible to any developer with an eye on thebottom line. Cubex is a developer which has previously done good work, but this sort of generichigh-rise is highly damaging to the character of the city.

CDG Comments Date of assessment: 22/08/2019 Scheme: Avon Fire And Rescue Service Headquarters

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Email response on 12th July Thank you for the meeting on Tuesday and once again my apologies for having to leave early. Further to our discussions we appreciate your concerns about how to move the scheme to a successful resolution. I understand it was agreed CDG would come back to you with a further response. A comprehensive assessment of the full planning application was provided by CDG on the 21st June 2019. CDG would very much like to provide support for comprehensive redevelopment of the site, however a number of outstanding issues remain that have been detailed in our comments. It is not appropriate for CDG to provide prescriptive advice on how these issues should be addressed. Certainly it would not be appropriate, as we touched on in our meeting, to place simplistic requirements on single issues like removing storeys, which have not been tested or the wider implications for the scheme understood. In order to provide meaningful feedback we need to see revised proposals, with commensurate level of detail, to understand the scheme’s impact in that revised form. The key issues, which we have detailed in our comments, comprise the scale, form, massing and grain of development. These are contained in the Height, Scale, Massing and Architecture section of our assessment, and views T3, 4, 5, 11, 12 of the submitted LVIA illustrate our concerns of the proposal’s uncomfortable fit within the local townscape. A review of the LVIA will help guide further design development towards an appropriate response to the context. The locality has a number of landmarks and orientation points including the Former Tramway Generating Station, Lead Shot Tower, Castle Park and 1 Redcliff Street. These are set within a strong and coherent townscape of relatively uniform building heights, massing and grain and we believe the scheme as a whole must relate more sympathetically to that context. The merits of a taller landmark in what is considered to be a secondary location have not yet been justified. While there may be a case for a marginally taller building marking the corner, and whilst the proposed tower element does have some merit, it is not considered to be of outstanding or innovative design and the rationale for an explicitly tall building remains unconvincing in urban design terms. In addressing the concerns above and the fundamental issue of overdevelopment we recommend the design team also find opportunities for better liveability in line with Council Policies and Urban Living SPD. The CDG assessment has drawn attention to a number of areas that need further consideration, particularly in terms of the proportion of single-aspect flats, the provision of private amenity space appropriate for the unit type proposed, the aspect and outlook of flats facing into the inner courtyard, and the quality of communal amenity spaces for all tenure types. I hope this email provides further clarity and guidance on the issues we believe need to be addressed and we would be happy to comment on revised information once available.

CDG Comments Date of assessment: 22/08/2019 Scheme: Avon Fire And Rescue Service Headquarters

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CITY DESIGN GROUP Combined Response

Application No: 19/01255/F Address: Avon Fire And Rescue Service Headquarters Temple Back

Bristol BS1 6EU Description: Demolition of existing buildings to facilitate mixed use office

(Use class B 1) and residential (318 Units Use class C3) redevelopment including amenity space and cycle and car provision, with vehicular access, servicing arrangements, public realm works and landscaping.

Case Officer: Peter Westbury Date: 24/06/2019 Comments From: Martin Deaville, David Martyn, Peter Insole, Nitin Bhasin

No Objection - NOOBJECT No Objection subject to Conditions described below - CONDITION Not acceptable in the current form. See comments suggestions below - NAICF Object, Please see comments below - OBJECT

Summary: CDG supports the development on the site in principle. The current proposal however gives rise to a number of significant concerns and does not address a number of policy considerations. The key issues include the significant impact on heritage assets; the building scale, form, massing and grain of development; long corridors with single aspects units; sub-par liveability and amenity arrangements. The issues are intrinsically linked and query the contextual, design and policy positions informing the design of the scheme and warrant comprehensive reconsideration. City Design Group objects to the current proposal and seeks substantial changes to the design of the scheme. It should also be noted that the issues have been raised by the BUDF as well.

Impact on Heritage Assets The site is within Redcliffe Conservation Area and forms a part of settings for number of listed buildings, most notable amongst these are Grade II* listed Temple Church (also a Scheduled Ancient Monument) and Former Tramway Generating Station; Grade II listed Lead Shot Tower as well as listed and locally listed buildings along Victoria Street amongst others. We are required to place great planning weight in the conservation of designated heritage assets and their settings. As confirmed by the LVIA and drawings, the proposed development presents a significant increase in massing and has an extreme, adverse, and overbearing impact on the setting of Heritage Assets in a number of views (most notably V1, V3, V5, V6, V11, V12 and V19 amongst the views that are provided - Please see Appendix for review of LVIA assessment). The proposals greatly exceed the prevailing building heights in the Conservation Area, particularly the scale of the historic fabric, and the intended architectural and material qualities respond poorly to the designated assets. The proposal will cause significant harm to the character and settings of the heritage assets and their significance while the public benefits presented by the proposed development are limited, with enhancement to the public realm and an affordable housing component, but principally represent private benefits of the developer; we do not accept that

CDG Comments Date of assessment: 22/08/2019 Scheme: Avon Fire And Rescue Service Headquarters

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benefits are adequate to outweigh the harm posed. The level of harm could be significantly reduced and minimised whilst still ensuring an appropriate level of public benefit ensues from development. There is some opportunity to improve the design quality of the proposal but the opportunity for tweaks is relatively small and very limited compared to the scope and scale of issues that are outstanding. Recent developments such as Finzel’s Reach, Samson Court and Wapping Wharf have demonstrated an optimum approach to development in the context with medium rise development although some improvements as per the recently adopted Urban Living SPD need to be accommodated. Height, Scale, Massing and Architecture The scale of the development is a cause of substantial concern. The proposal presents a noticeable increase of approximately 2-4 stories throughout the development block set against prevalent scale which has remained relatively consistent through various eras and phases of development in the area. In addition, the taller tower element presents further increase in building heights of 8-10 stories and corresponding impact on the surroundings. There is strong urban design scale and grain in the area which needs to be reinforced by the proposed scheme. The current proposal does not present an appropriate design massing and design solution within the given context. The locality has recognised character of a conservation area with a number of noted and listed heritage assets such as Former Tramway Generating Station, Lead Shot Tower, Castle Park, 1 Redcliff Street etc. serving a notable landmarks and orientation points. There are a number of recognised landmarks and the merits of another taller landmark in the location appear unwarranted, and neither the justification has been presented. Consequently the significant increase in the building height cannot be justified and supported. The proposed development appears coarser in grain and massing than the design solution needed on site. While the larger format post war and recent development set against finer grain of historic townscape is noted, the proposed grain and massing along with additional building height and stepping out of building line presents an unresolved juxtaposition between the townscape, heritage assets and the proposed built form. In addition to the review of the scale of proposed development covered above, a review of the grain and massing of the development should also be undertaken to address this issue. While the detailed design does have some merit this does not overcome fundamental concerns regarding overdevelopment and the uncomfortable height and scale of within the immediate locality. Liveability considerations The proposed development comprises almost in entirety of single aspects residential apartments with long central corridors. Based on case studies, the Urban Living SPD recommends against this approach and seeks smaller cluster of dual aspect apartments. Formative decision to develop apartment blocks with smaller core and smaller cluster of flats are critical to address the issue. Private Rental Sector schemes should meet the National Space Standards as set out in the policy. It should be noted that a large number of flats in and around the city centre are occupied on a rental basis which is comparable to the Private Rental Sector. As confirmed by the sunlight and daylight assessment, many of the residential units fail to meet the minimum standards required by BRE with a significant proportion affordable units experiencing extremely low natural light. Further, the recent developments in the area are shown to perform significantly better than the proposed scheme. It should be noted that the difficulties faced by the residents of the comparable

CDG Comments Date of assessment: 22/08/2019 Scheme: Avon Fire And Rescue Service Headquarters

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schemes was one of the key factors for Urban Living SPD and liveability considerations to be emphasised in planning decision making. Rational presented to further lower the liveability considerations are wholly unacceptable. The separation distance between facades facing the inner courtyard is very low and a major cause of concern. Though retrospective measures as privacy screen on office windows can be employed to mitigate direct overlooking, the aspect and view out of some of the apartments remain unacceptably enclosed and overbearing. The amenity spaces on the ground level appear to be of tight dimensions and constrained location either within enclosed and overshadowed courtyard surrounded by access and servicing requirements or tightly helmed within public realm. The design and usability of the spaces will be problematic and offer limited value. Further, experience has shown that such spaces tend to get squeezed as the design evolves through detailed stages with technical, safety and management requirements. The amenity provision on the roof level will be of some benefit for the residents but not appear to be accessible to residents of affordable units. In addition to the planning policy considerations, this issue has already been reported as a particular cause of concern in Finzel’s Reach and schemes elsewhere which have highlighted in national headlines. Please see review for Urban Living assessment for further liveability considerations. Interface of development CDG supports the ambitious approach to design a pedestrian centric public realm in principle and support BUDF’s recommendation. CDG is keen to understand the feedback from transport department in relation to the vehicular and public realm arrangements as the considerations can have a significant impact on the design, delivery and management of the space. CDG seeks to be actively involved in further discussions on this front. Further discussion and clarity is needed to resolve the interface between the development and the public realm especially considering the resolution of the public realm and stepping forward of the building line causing unusual relation requiring greater scrutiny. The access to the affordable units is poorly located with entrance to the car park for office, entrance to the residential car parking, residential cycle parking, bin storage, substations for office and residential units and other servicing rooms surrounding it. Although some improvement have been made in the recent revisions Further improvement to the design, arrangement and the public realm is recommended. Clarity and resolution is needed on the interface of the development with the recently developed fire station premises. The proposed arrangement appears to be dominated by blank wall at eye level which appears overbearing, awkward and unresolved. Further, there are concerns about the relation of the residential units with fire station premises and training tower. We will be keen to understand the liaison undertaken on this front and feedback from the concerned liaison officer. Provision of Public Art The project presents good opportunity for inclusion of public art. It is disappointing that no such provision has been made while the scheme is at an advanced design stage. Further there very little opportunity for inclusion of public art as the public realm area appears to be tightly defined and constrained.

CDG Comments Date of assessment: 22/08/2019 Scheme: Avon Fire And Rescue Service Headquarters

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As a potential option, it may be possible to commission the public art provision in the vicinity where prominent public spaces such as Castle Park offer opportunity for the provision. Archaeology Recent archaeological evaluation on the site has established that the creation of the fire station complex has significantly impacted the archaeological potential on the site. However, in one discreet area archaeological remains were found to survive. Should the proposed development prove to have an impact on this archaeology it will be necessary to ensure that it is recorded prior to its loss. This can be secured through attaching appropriate pre-commencement and pre-occupation conditions for a programme of works to include archaeological excavation and watching brief as required.

Closing comments CDG supports the development in principle and supports the principle for a pedestrian centric public realm scheme. But the proposed scheme gives rise to significant concerns relating to the Conservation, its visual impact, liveability, public realm and public art considerations. CDG objects to the current proposal and seeks substantial revisions to the design of the scheme to address the issues outlined above.

Review of LVIA Assessment by BCC Officers Date of assessment: 21/06/2019 Scheme: Avon Fire And Rescue Service Headquarters

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Review of LVIA Assessment The brief comments below highlight the key areas of differences where City Design Group assessment differs from the one presented to support the planning application. V1 - Significant Adverse impact

V2 - No view has been identified or provided, yet it is listed and assessment has been made. V3

- Listed Former Tramway Generating Station and Lead Shot Tower serve as a focal building. - Medium susceptibility as forms part of leisure route - Moderate Adverse impact

V4 - Locally Listed Façade - Medium Susceptibility - Medium Sensitivity - Public realm enhancements will be negatively affected by the overbearing scale of

development and loss of light - Moderate Adverse Impact

V5 - Magnitude of Impact – High Medium scale - Lacks Sensitivity, grain and interest - Significant Adverse Impact

V6 - Listed buildings in foreground - Medium Susceptibility` - Medium Sensitivity - High magnitude of effect - Significant Adverse impact due to scale, grain and poor relation of lower level façade

V7 - Medium Susceptibility - Medium Sensitivity - Moderate magnitude of effect - Neutral/Minor negative due to frontage provided by office building but the overbearing

appearance of office building. Further the residential block looming over the skyline appears awkward and unresolved.

V10 - No view has been identified or provided, yet it is listed and assessment has been made. V11 - High Susceptibility

- High Sensitivity - Moderate magnitude of effect - Significant Adverse impact due to scale, grain and poor relation of lower level façade - Moderate Adverse impact as the proposal upsets the well-defined predominant scale of

development in the area and negatively affects the skyline. The proposal draws attention away from the designated heritage assets.

V12 - Medium Susceptibility - Medium Sensitivity due to heritage assets - Significant Adverse impact on the setting of heritage assets and townscape.

V13 - No view has been identified or provided, yet it is listed and assessment has been made. V14 - No view has been identified or provided, yet it is listed and assessment has been made. V15 - New neutral… nature of change

- Neutral impact. Question if a new landscape building is needed and consider the quality of design to be average.

V16 - No view has been identified or provided, yet it is listed and assessment has been made. V17 - No view has been identified or provided, yet it is listed and assessment has been made.

Review of LVIA Assessment by BCC Officers Date of assessment: 21/06/2019 Scheme: Avon Fire And Rescue Service Headquarters

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V18 - No view has been identified or provided, yet it is listed and assessment has been made. V19 - Nature of change – no rational for the new distinctive element within urban settings can be

seen. The proposal detracts from the townscape features and Heritage Assets. - Moderate magnitude of effect due to changes to the skyline. - Medium scale of Moderate Adverse impact. Question if a new landscape building is needed

and consider the quality of design to be average.

Urban Living SPD: Assessment by BCC Officers Scheme: Avon Fire And Rescue Service Headquarters Date of assessment: 21/06/2019

Notes: • Red elements identify aspects of proposals that need to be changed and where the scheme design at the time of assessment fails to respond to the question positively. • Amber is used where there is clear evidence of local constraints on the scheme, beyond the control of the design team, prevent it from achieving a green. • Green shows the design of the scheme has responded positively to the questions. There may still be room for improvement which should be highlighted.

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Urban Living Assessment Questions Assessment Observations

DAS ref

Additional information required by BCC

Part 1 Major Developments

City

Q1.1 Has the scheme adopted an approach to urban intensification which is broadly consistent with its setting?

Red

- Acknowledge that the area has potential for modest change. - The scale and massing is 2 – 4 floor higher than the prevailing height of the urban context - The taller element is significantly higher than the context and affects the setting of a number

of heritage assets. - The density of the propose scheme exceeds the parameter expressed in Page 12 of the Urban

Living SPD and fails to properly balance positive response to context, place making and liveability considerations.

- Limited evidence of design-led capacity study - We consider 581 dph is over intensification which is far in excess, almost three times the

optimum density recommended in the Urban Living SPD guidance

1. Demonstrate consideration of alternative development forms and layouts

2. Assessment of existing townscape

3. An appropriate 3D response

Neighbourhood

Q1.2 Does the scheme contribute towards creating a vibrant and equitable neighbourhood?

+ Evidence of community involvement within the Statement of Community involvement. - The variety of the accommodation is fairly limited. + Mix of uses, with communal provision at ground floor for BtR with office and housing

provision. + It is a sustainable location close to the city centre. - Access to children’s play facilities, Under 5’s, children’s play space and neighbourhood

playable space. - Development doesn’t provide a broad range of accommodation, sizes or types to welcome a

vibrant, mixed and balanced residential community

Q1.3 Does the scheme

- The scale and massing of the built form fails recognise the spatial hierarchy of the existing heritage landmark buildings within the immediate cityscape.

1. Heritage Assessment influence on the

Urban Living SPD: Assessment by BCC Officers Scheme: Avon Fire And Rescue Service Headquarters Date of assessment: 21/06/2019

Notes: • Red elements identify aspects of proposals that need to be changed and where the scheme design at the time of assessment fails to respond to the question positively. • Amber is used where there is clear evidence of local constraints on the scheme, beyond the control of the design team, prevent it from achieving a green. • Green shows the design of the scheme has responded positively to the questions. There may still be room for improvement which should be highlighted.

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respond positively to either the existing context, or in areas undergoing significant change, an emerging context?

- The justification of the 16 storeys height in the DAS is not satisfactory. - The scale and configuration of the perimeter block does not respond positively to the context. + Identification of key views and further analysis and impact assessment from the conservation

area have been submitted Room for improvement: • Relevant and convincing justification for exceeding the height

design to be more clearly represented in the DAS.

Block & Street

Q1.4 Does the scheme provide people-friendly streets and spaces?

+ Proposed footpath widths accommodate the increase in footfall delivered through the density increase.

- Provision of community green space is lacking, concern is raised about the location of ‘pocket park’. The definition of the ‘pocket park’ is felt to be misleading as it a wider verge with some seating.

- Proportion of building to the Temple Back creates overshadowing and undermines the microclimate within this street.

+ Creation of a double height treatment of the ground floor that gives prominence and legibility to the main entrance of the building onto the street frontage to Counterslip,

- Legibility of the entrance to the affordable housing along Temple street needs further consideration and improvement.

1. Confirmation of SuDs/ rain attenuation strategy.

Q1.5 Does the scheme deliver a comfortable micro-climate for its occupants, neighbours and passers-by?

- The layout does not respond to orientation, placing office space on the sunny side of the perimeter block and residential on the overshadowed part of the perimeter block.

- Daylight/sunlight assessment shows unacceptable living conditions for many of the residential units.

- No indication of integrated solar shading, wind deflectors for the office facade - Building configuration results in internalised corridors which do not benefit from natural light

or ventilation. - The majority of all of the units are single aspect

1. Wind study /

microclimate assessment

2. Sustainability Team to confirm Shading performance

Q1.6 Has access, car parking and servicing

Car parking + Integrated parking within internal courtyard and at basement level

Urban Living SPD: Assessment by BCC Officers Scheme: Avon Fire And Rescue Service Headquarters Date of assessment: 21/06/2019

Notes: • Red elements identify aspects of proposals that need to be changed and where the scheme design at the time of assessment fails to respond to the question positively. • Amber is used where there is clear evidence of local constraints on the scheme, beyond the control of the design team, prevent it from achieving a green. • Green shows the design of the scheme has responded positively to the questions. There may still be room for improvement which should be highlighted.

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been efficiently and creatively integrated into the scheme?

+ On-street loading bays and car club provision Cycle storage + All provision located within the courtyard space Servicing + Bin store areas screen from the public realm on the ground floor Room for improvement: • Providing cycle store areas at ground floor level comprises the communal courtyard • Access to the affordable houses needs substantial improvement.

Part 2 – Residential Developments Shared access and internal spaces

Q2.1 Does the scheme make building entrances welcoming, attractive and easy to use?

+ Creation of a double height treatment of the ground floor that gives prominence and legibility to the main entrance of the building onto the street frontage to Counterslip,

- Legibility of the entrance to the affordable housing along Temple street is compromised. - Segregation of entrances to the affordable and PRS units. These should be tenure blind. The

affordable housing entrance is significantly less generous than the PRS units entrance. + Entrance provided directly from the public realm. - Large number of units from single entrance and core. Room for improvement: • Reduce the number of units from a single core • Create more entrances to the buildings

Q2.2 Are the scheme’s internal spaces convivial, comfortable and user-friendly?

- Internal corridors with no natural light or ventilation - No provision of communal storage areas - Cores serve more than six units per floor, up to 11. - Broad range of amenities for PRS and affordable housing has not been provided, such as large

communal areas and areas for social interaction. Roof terraces present limited appeal and usability benefits.

- No children’s spaces has been provided within the scheme

Urban Living SPD: Assessment by BCC Officers Scheme: Avon Fire And Rescue Service Headquarters Date of assessment: 21/06/2019

Notes: • Red elements identify aspects of proposals that need to be changed and where the scheme design at the time of assessment fails to respond to the question positively. • Amber is used where there is clear evidence of local constraints on the scheme, beyond the control of the design team, prevent it from achieving a green. • Green shows the design of the scheme has responded positively to the questions. There may still be room for improvement which should be highlighted.

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- No provision for storage of bulk items Room for improvement: • Address the above •

HERE Private outdoor

space

Q2.3 Does the scheme provide sufficient private outdoor space?

• Applicant needs to calculate the amount of open space required in accordance with the Urban Living SPD using the minimum and child yield calculations.

• The applicant must in sure that the provision of outdoor space caters for family living as outlined in the Urban Living SPD.

Room for improvement:

1. Schedule of open communal space and private space, including typical size of balcony space and proportion of units with access to private space.

Q2.4 Does the scheme create attractive, well designed and well maintained private outdoor spaces?

- The provision of communal and private outdoor space is very limited and the quality of the amenity is questioned:

- Due to constrained dimension of the communal open space and the overshadowing, as well as safety and other technical requirements.

- Private open space is provided as mainly private balconies, a large percentage of which are north facing.

- No communal outdoor space for the affordable housing Room for improvement: • Further consideration of the approach to communal and private outdoor space to address

issues above.

1. Overshadowing assessment is required to demonstrate how much direct light the communal space will recieve

Q2.5 Does the scheme creatively integrate children’s play?

Child Yield Calculator - No indication of child yield calculation or provision on site or suitable offsite provision/

enhancement where appropriate - The provision of a pocket park along Temple Back and Temple Street is not appropriate as a

children’s play area due to safety concerns. - For the PRS it is unclear if the communal spaces on ground level and roof terrace has any

children’s play facilities included.

Child yield calculation using online tool.

Urban Living SPD: Assessment by BCC Officers Scheme: Avon Fire And Rescue Service Headquarters Date of assessment: 21/06/2019

Notes: • Red elements identify aspects of proposals that need to be changed and where the scheme design at the time of assessment fails to respond to the question positively. • Amber is used where there is clear evidence of local constraints on the scheme, beyond the control of the design team, prevent it from achieving a green. • Green shows the design of the scheme has responded positively to the questions. There may still be room for improvement which should be highlighted.

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Room for improvement: • Play facilities shall be creatively integrated, taking into account noise outbreak

Individual homes

Q2.6 Are internal layouts ergonomic and adaptable?

+ The internal layout of the Apartments is acceptable + Flexible open plan layouts provided to maximise living space. + Ceiling height of over 2.5m is proposed - PRS does not meet the space standards

Q2.7 Does the scheme safeguard privacy and minimise noise transfer between homes?

- Privacy distances between the facades is unacceptably limited + Privacy by design - careful placement of windows and balcony spaces

Q2.8 Does the scheme maximise opportunities for daylight and sunlight of internal spaces; avoiding single aspect homes?

- The scheme does not meet the BRE recommended standards for daylight/sunlight - Further the scheme preforms worse than recent schemes in the area which themselves

were identified as negative examples in the SPD - The scheme designed to deliver predominantly single aspect units. - Notable number of north facing single aspect units. Room for improvement: • Reducing the amount of single aspect flats • Maximising the amount of dual aspect units • Allowing natural cross ventilation

1. Reduction of amount of single aspect flats is required

2. Maximising amount of dual aspect units

Part 3 – Tall Buildings

Visual quality

• The area does not benefit from a spatial strategy so the applicants are required to propose rational for merits of a tall building.

Urban Living SPD: Assessment by BCC Officers Scheme: Avon Fire And Rescue Service Headquarters Date of assessment: 21/06/2019

Notes: • Red elements identify aspects of proposals that need to be changed and where the scheme design at the time of assessment fails to respond to the question positively. • Amber is used where there is clear evidence of local constraints on the scheme, beyond the control of the design team, prevent it from achieving a green. • Green shows the design of the scheme has responded positively to the questions. There may still be room for improvement which should be highlighted.

14 of 14

Q3.1 Is the tall building well located?

+ The site is well located with city centre shopping, employment and public transport provision in close vicinity.

- The principle of a tall building has not been established. The prior consultation noted the northern corner may be most conducive for increased scale of development; the rational for tall building is not presented or established.

- The proposal will have a negative impact on the setting of a number of heritage assets. Room for improvement: • Justification to support merits of a tall building in the given location remains to be established

Q3.2 Does the scheme make a positive contribution to the long-range, mid-range and immediate views to it?

+ Proposal appears relatively neutral in long distance views. - The proposal has a negative impact in mid-range and immediate view. - The proposal has a significant negative impact on the settings of a number of designated

heritage Assets. - Both the predominant scale of the development form and the tall building Room for improvement: • Revision of the scale of the parameter block and the tower is needed.

Q3.3 Does the scheme demonstrate design excellence?

- The tall building is of average design quality. It lacks fully resolution of district hierarchy (base, middle and top). The approach is appropriate for a medium scale block or elements that are slightly taller than the predominant scale. The proposal does not portray design excellence that will be needed to justify its scale and impact within the given context.

- It was a missed opportunity when the independent design review by the BUDF did not adequately discuss the design excellence of the proposal.

Functional quality

Q3.4 Does the scheme ensure the safety of

Not enough information to assess. • The applicant’s comments on the fire assessment are noted. However it is unclear if and to

Urban Living SPD: Assessment by BCC Officers Scheme: Avon Fire And Rescue Service Headquarters Date of assessment: 21/06/2019

Notes: • Red elements identify aspects of proposals that need to be changed and where the scheme design at the time of assessment fails to respond to the question positively. • Amber is used where there is clear evidence of local constraints on the scheme, beyond the control of the design team, prevent it from achieving a green. • Green shows the design of the scheme has responded positively to the questions. There may still be room for improvement which should be highlighted.

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occupants and passers-by?

what extent the assessment covers the public realm and the fire station site. • Further special consideration needs to be given to relation of the site with fire station and its

practice tower needs to be fully assessed in consultation with the fire department.

Q3.5 Does the scheme interfere with aviation, navigation or telecommunication, and does it have a detrimental effect on solar energy generation on adjoining buildings?

Not enough information to assess • The applicant’s comments are noted. • However it is unclear if any assessment has been undertaken. • The statement proposing post planning assessment of any impact on the Solar Energy

Generation on adjoining buildings is not acceptable in principle as the application seeks to agree the form and massing of the proposal along with all its impact.

Q3.6 Has the scheme’s future servicing, maintenance and management been well

considered?

Please seek comments from the sustainability team regarding the full lifecycle assessment of the proposed scheme which includes consideration for construction, running and decommissioning of the proposed scheme.

Environmental quality

Q3.7 Does the scheme create a pleasant, healthy environment for future occupants?

+ The proposal presents some benefits of communal entrance and roof terraces. - However the primarily single aspect development form, long corridors with small number of

circulation cores is a cause for concern. - Many of the flats have disappointingly low level of daylight/sunlight - Communal facilities and spaces are limited in dimensions and usability. There is no provision

for children play.

Q3.8 Is the scheme sustainably designed?

- The PRS scheme does not comply with National Space Standards. This will restrict future adaptability.

Urban Living SPD: Assessment by BCC Officers Scheme: Avon Fire And Rescue Service Headquarters Date of assessment: 21/06/2019

Notes: • Red elements identify aspects of proposals that need to be changed and where the scheme design at the time of assessment fails to respond to the question positively. • Amber is used where there is clear evidence of local constraints on the scheme, beyond the control of the design team, prevent it from achieving a green. • Green shows the design of the scheme has responded positively to the questions. There may still be room for improvement which should be highlighted.

16 of 14

Please seek comments from the sustainability team regarding sustainability credentials of the

scheme.

Q3.9 Will the scheme be neighbourly, both at the construction phase and

following occupation?

- There are concerns about overshadowing, wind and other microclimate considerations on surrounding public realm which needs further assessment.

+ The impact of proposal on adjoining residential properties has been assessed but it’s unclear if any further assessment is carried out for other users.

The Redcliffe Residents Action Group and Neighbourhood Forum is the recognisedNeighbourhood Planning Group for Redcliffe. We write to update our response following a meetingwith the developer and their resubmission of their proposal.

The changes made by the developer amount to minor tweaking of the proposals and do notsubstantively address the issues raised. We therefore, write to re-iterate our objection to thedevelopment as it currently stands and the development should not be allowed to go forward in itscurrent form.

------------

While the redevelopment of the former fire station site is to be welcomed, we write with concernand to object to the current proposals.

There are a number of failings with the current proposals, including most critically:

- The failure to restore a proper urban grain and character to this important conservation area. Inparticular, the scale, height and massing of the blocks are inappropriate to the area, which aregenerally between 5-9 storeys.

- The failure to create an urban texture and permeability is particularly disappointing, with nothrough access provided through the site and very miserly provision of amenity and green space.The lack of a public route through the site goes against SPD3, The Future of Redcliffe.

- The impact of the scale and height of the building will be unacceptably negative on neighbouringbuildings - both surrounding residents in terms of loss of light and overshadowing, and on theGrade II* Listed Generator Building by dominating it. The over-bearing nature of the buildings willalso negatively hinder creating a positive and welcoming streetscape atmosphere for pedestrians.

- The design combines being over-bearing (due to its scale) with being bland and characterless.The development will do little to build place-making value in the area.

There are good examples of developments that combine density with humane scale, characterfuldevelopment. The Government's Building Better Building Beautiful Commission - just published -urges council to reject low quality developments and ensure places, not just housing units, aredeveloped. Bristol can and should demand better from this important development site.

In my previous submission of 22 May on the alignment of the present plans with theUrban living SPD Question 3.9, I raised concern around the wind effects close to the tower blockat street level

The localised high winds at the base of tall buildings has caused the City of London authority torevise their planning guidance, and now require developers to undertake more detailedassessments of the effects.This has been reported in the Architects Journalhttps://www.architectsjournal.co.uk/news/city-of-london-cracks-down-on-skyscraper-wind-effects/10044118.articleAnd also in the Guardian on 20 Augusthttps://www.theguardian.com/uk-news/2019/aug/20/city-of-london-tightens-rules-on-skyscrapers-over-wind-tunnel-fears-cyclist-pedetriansThe Guardian article links to one reporting on serious physical injuries caused by wind effects inLeedshttps://www.theguardian.com/artanddesign/architecture-design-blog/2014/aug/14/killer-towers-how-architects-are-battling-hazardous-high-risesthe rather exaggerated language in the title of the second article is unfortunate.

From personal and frequent experience of the present amplified wind along Temple Back andacross Passage Street Bridge, I have concern that the tower block and the perimeter block natureof the rest of the development will contribute to even higher speed winds locally

I hope this potential issue will be taken into consideration in the assessment of the current plans

Dear Mr Westbury

Further to my original submission would comment further on perceived shortfalls in the notificationprocedure on this development

As previously stated despite our residence, The Milliners, being in direct proximity to the proposeddevelopment we were excluded from the original notice distribution in December 2018.

Now we see that revised plans were submitted by the Developer on 30th July 2019 with a deadlinefor comment 3 weeks later and the Developer Cubex openly stating that they plan to put thematter before the Planning Committee on 4th Sept 2019.

How can such a notification period be applicable for such a massively impactful development?Why is such haste being applied in what is clearly a holiday period? What attempt was made tocontact other Redcliffe Community members apart from those already registered as interested andaffected parties?

In recognition of time constraints being applied urgent representations were made by RedcliffeResidents Action Group/Neighbourhood Forum (RRAG/NF) for the revised plans to be presentedat their monthly meeting which the Developer was pursued to attend on 5th Aug 2019 despiteshowing a preference to attend the following meeting on 2nd Sept 2019 which would have beentoo late for this body to make any further submission on the matter as it would have been beyond

the Planning Officers deadline for comment i.e. 21st Aug 2019.

At the meeting the Developer Representations (CEO Gavin Bridge and Avison Youngs Jo Davies)presented minor adjustments to the plans and stated the tower element (the main point ofcontention) would remain in a slightly reduced 'width' form.

It was stated by the Developer that the need for housing outweighed all other considerationsdespite the concerns of specialist organisations on the impact on this highly historic area of Bristoland the welfare of existing and future residents.

The Developer was unable to give answers on key issues such as detail on a Road Safety Audittherefore it is unclear if the proposed highway works are safe in highway safety terms. This is butone area of developmental detail which appears to be missing from the documents submitted.

We believe that to apply a 3 week notice period for comment is unreasonable during the holidaymonth of August and prejudicial if the matter it to be put before the Planning Committee on 4thSept 2019

We are therefore of the opinion that this process is flawed and that the proposal should not be putbefore the Planning Committee on 4th Sept 2019.

Final thought is that when a final analysis of the public participation process is carried out it is tobe hoped the correct recognition will be given to the comments of professional bodies (HistoricEngland etc) and the recognised community body and neighbourhood planning group for Redcliffe(RRAG/NF) when compared to those with narrow business interests who do not live in theRedcliffe area.

We appreciate the opportunity given to comment.

Claire Parkman

As owners of 17 Temple Bridge Apartments, immediately adjacent to this developmentsite, we wish to object to this revised application as the changes do not materially address any ofour objection points previously raised.

Overall, the proposed development's height is excessive and will have a major impact in terms ofoverlooking, loss of privacy, loss of outlook, increased sense of enclosure, as well asovershadowing. The scale of development will seriously impact on the amount of daylight into the2 bedrooms in our apartment, and the main living room. The tower element of this development inparticular would have a major detrimental impact as it is immediately opposite our apartment andwill block light into those rooms to a serious extent. This will impact on quality of living and healthas well diminishing the value of the property. The tower element, even if it were to be approved,should be required to be placed at the other end of the site where it would only impact oncommercial space not residential. Our apartment has 3 windows facing the development all ofwhich will be severely impacted. For two of those rooms (the bedrooms) there is only the onewindow so the impact will be very severe and arguing that bedrooms are of lesser importance interms of daylight ignores modern living - our apartment is rented and our tenants are sharing souse their bedrooms as private living and study space, not just for sleeping. For the third room (theliving room / kitchen) the impact will also be significant, although at least that room has anadditional window.

Whilst a reduction in the overall massing of the proposed development is welcome, in reality therevised plans do nothing to mitigate the overall impact on the existing area, current residents and

community. the positioning of the tower element is key to this and unless moved to the other endof the development (where it would not impact on residential apartments) should be rejected.

In addition, we would like to point out that the new Daylight Sunlight Analysis Addendum Reportconfirms that overall conclusions remain unchanged and of the 30 windows analysed inTemplebridge Apartments, only 6 would meet BRE criteria, all of which face over Counterslip.Every window analysed that overlooks Temple Back fails to meet BRE criteria in both the originaland new proposal and this is an unacceptable impact on our property.

We also believe the height of this development overall is inappropriate for this area. The proposeddevelopment by reason of its siting and scale would constitute a prominent and inappropriate over-development of the site, unsympathetic to the scale and proportions of the surrounding streetscene and to the detriment of the visual amenities of the area - it should be in keeping with otherrecent developments as it is very near the waterside amenity that is part of Bristol's touristattraction - this type of development will adversely affect the character of the area to the detrimentof lifestyle, external amenity and tourist income for local businesses.

We also object to the extremely low level of car parking allowed for in the development - this willlead to serious congestion in terms of on street parking and traffic driving round looking for placesto park, impacting on air quality and safety.

We also believe that this scale of residential accommodation in this area is simply not supportedby the infrastructure - e.g. schools, doctors, dental surgeries, child care, etc. We would ask thatplanning permission for this development be denied for the above reasons

Concern over potential hazard to life from restricted road width of Temple Back, andpossible delay to fire appliances getting to emergencies

Drawing NPA 11039 402 P04: TEMPLE BACK AND TEMPLE STREET SECTION, posted on theplanning portal 29 July 2019, shows Temple Back restricted to a single vehicle width with railingsone side and bollards on the other.

As this will be one of the route for fire appliances to access Counterslip, then giving access on toroutes to the city centre and to Temple Way and Old Market, I am concerned that the restrictedwidth of the road can easily be blocked by a single vehicle parking to make deliveries to the officeon Temple Back, and especially to the new development because of the single layby beingprovided for the development on Temple Back.

A reasonable estimate of the likely number of deliveries to the development is given in an earliercomment posted on 31 July.This was:"I don't believe any impact assessment has been done on this, so I've been trying to envisage theamount of traffic we can expect idling underneath our living room windows, at all times, inservicing over 200 dwellings. We can expect this include: Taxis Supermarket delivery vansAmazon/Yodel/Hermes etc. deliveries Takeaway deliveries. Hypothetically, let look at supermarketdeliveries (with no residents having cars, in Cubex's ideal scenario) for just 200 dwellings having 1delivery a week. With all residents being young professionals, delivery slots are likely to be most

popular between 5pm-10pm, Monday to Friday and 8am-8pm Saturday & Sunday. That's 49available slots a week, making a mean average of just over 4 deliveries an hour. However, someslots are likely to be more popular that others (e.g. 6pm-8pm, Monday to Friday). And withnumerous supermarkets offering deliveries (Asda, Sainsburys, Tesco, Waitrose, Ocado) we couldbe seeing up to 5 different vans competing for space in the loading bay at peak times. Then welook takeaway delivery services, more popular at the anti-social end of the clock, Thursday, Fridayand Saturday nights 8pm-1am. Again, with the target residents being young professionals, we canexpect usage of this to be pretty high. Hypothetically you have just 100 dwellings ordering 1takeaway a week, evenly spread over 7 days this would be approx. 3 an hour, on top of the 4supermarket deliveries an hour. But in reality, it's more likely to be closer to 7 per hour at peaktimes. And now start thinking about all of the online shopping delivery drivers, 200 dwellingsmaking at least 1 online purchase per week. These deliveries can arrive at any time of day, 7 daysa week"

I hope that the width restriction will be revisited to ensure that fire appliances can move alongTemple Back without delay and potential hazard to life.

I have been recently informed, by my neighbours, about proposed development in placeof the former fire station. I would like to object to the proposals made by the developer. First of allwe have never had any consultations with the developer.

My main concern is the height of the proposed building, which in average is twice as high asTemplebridge Apartments. As a result of that our apartment will be in constant shade, which willaffect our health and wellbeing. I am also concern about our privacy during construction and afterimplementing the proposals as the new building is just across the street. I am also sure thatpotential residents of that building will have similar concerns.

As a mum of a 2 month old baby I am concern about noise and dust during demolition andconstruction of the proposed buildng. I would like to suggest to undertake demolition of the formerfire station during autumn and winter when we keep our windows closed to avoid noise and dust inour apartments. Actually the developer put a fence and started demolition process withoutpermission. As a result of that it is very noisy in our flat. I also wouldn't like them to work duringweekends and bank holidays and avoid making noise outside normal working hours by parking alorry with an engine on just outside our windows.

I also would like to see more trees and greenery on our street. It is now very grey, full of concreteand tarmac. I think the proposed landscape is not sufficient for this place.

In summary I am against the proposed development and if it gets permission I will have no choice,

but to move elsewhere.

Dear Mr Westbury

We note the revised plans which clearly make only token attempt at addressing the concernsraised in our previous submission, and those made by others, in regards to impact and design.

This was confirmed at a meeting with the Developer Cubex (CEO Gavin Bridge) called by theRedcliffe Residents Action Group/Neighbourhood Forum (RRAG/NF) on the 5th August 2019.

At this meeting Mr Bridge made it very apparent that his company was of the opinion that provisionof housing was the primary consideration and that this outweighed all concerns such as impact onHistoric monuments (including the scheduled monument 'Temple Church' which is considered ofthe highest possible historical importance and registered as being of 'national importance'), densityand impact on living standards and community welfare.

Clearly these revised plans are not fit for submission to the Planning Committee in September.

We believe as Case Officer you have an enshrined duty and obligation to the people of Bristol toreject these proposals on the following grounds;

1. Conservation - You have of a duty of care to protect this important Conservation Area andensure that short-term developer aspirations and gains do not override the need to protect'Historic Bristol'. Extract from Historic England submission dated 13th August 2019 (as follow up to

their original submission of 15th April 2019) reads;

'These concerns have not been addressed by the submitted amendments. The 15 storey towerremains at the same height, and will still cause a serious adverse impact on the setting of the II*listed generator building. The upper levels of the proposed development would still adverselyaffect the setting of Temple Church tower in key views from Victoria Street, and the proposeddevelopment's unrelieved elevational treatment still runs the risk of appearing an unfortunateamorphous and ill-designed mass behind the tower of this highly-graded church.

In respect of this latter point, amendments could be made to the design without reducing thequantum of development proposed. It follows, therefore, that the justification for harming thesetting of the church tower lacks the "clear and convincing justification that is required by NPPFparagraph 194 in respect of harm to heritage assets. Further revisions are therefore necessary toavoid or reduce the harm to the setting of the scheduled church tower.

Avoiding harm to the setting of the generator building will clearly require a reduction in height tothe 15-storey tower. We recommend that the tower is reduced in height by around 4 storeys,which should bring it below the ridgeline of the Generator building in views from St Philips Bridge,thus allowing the Generator building to retain its visual primacy as the bridgehead.

We have previously suggested that we meet with the applicant to discuss our concerns and howthey might be addressed further. It is disappointing that this offer has not been taken up. Weremain keen to discuss modifications that could reduce the damaging effect that the proposeddevelopment would have on Bristol's townscape, but are compelled to register our strongconcerns at the proposals as they currently stand.

In respect of this latter point, amendments could be made to the design without reducing thequantum of development proposed. It follows, therefore, that the justification for harming thesetting of the church tower lacks the "clear and convincing"

Recommendation

Historic England has concerns regarding the application on heritage grounds, and the advice setout in our original letter of 15 April 2019 still stands.

In determining this application you should bear in mind the statutory duty of section 66(1) of thePlanning (Listed Buildings and Conservation Areas) Act 1990 to have special regard to thedesirability of preserving listed buildings or their setting or any features of special architectural orhistoric interest which they possess, and the statutory duty of section 72(1) of the Planning (ListedBuildings and Conservation Areas) Act 1990 to pay special attention to the desirability ofpreserving or enhancing the character or appearance of conservation areas.

Your authority should take these representations into account and seek amendments, safeguardsor further information as set out in our advice. If there are any material changes to the proposals,or you would like further advice, please contact us.

End of Extract

2. Community Representative Body Opinion - You have a duty to take into account the commentsof Redcliffe Residents Action Group/Neighbourhood Forum (the officially recognisedNeighbourhood Planning Group for Redcliffe) and act on their recommendations which include(extract from submission 12th July 2019 relates ;

'There are a number of failings with the current proposals, including most critically:

- The failure to restore a proper urban grain and character to this important conservation area. Inparticular, the scale, height and massing of the blocks are inappropriate to the area, which aregenerally between 5-9 storeys.

- The failure to create an urban texture and permeability is particularly disappointing, with nothrough access provided through the site and very miserly provision of amenity and green space.The lack of a public route through the site goes against SPD3, The Future of Redcliffe.

- The impact of the scale and height of the building will be unacceptably negative on neighbouringbuildings - both surrounding residents in terms of loss of light and overshadowing, and on theGrade II* Listed Generator Building by dominating it. The over-bearing nature of the buildings willalso negatively hinder creating a positive and welcoming streetscape atmosphere for pedestrians

- The design combines being over-bearing (due to its scale) with being bland and characterless.The development will do little to build place-making value in the area.

There are good examples of developments that combine density with humane scale, characterfuldevelopment. The Government's Building Better Building Beautiful Commission - just publishedurges council to reject low quality developments and ensure places, not just housing units, aredeveloped. Bristol can and should demand better from this important development site.'

End Of Extract

3. Welfare - You would be neglecting your duties if you accept proposals which negatively impacton existing Residential Properties (overshadowing), result in increased pollution beyond what islegally acceptable (as you know pollution levels in this area are already well above GovernmentStandards) and put further strain on existing infrastructure which cannot cope with presentvolumes (there remain serious unanswered questions on such fundamentals as effect on road

infrastructure).

All professional advisory bodies (Civic Socity, Conservation Advisory Panel and Historic England)and the recognised community planning advisory body of Redcliffe (RRAG/NF) have spoken andare united in their belief that these plans are inappropriate and must be rejected in their currentform.

You therefore have no alternative other than to carry out your duty to the people of Bristol bysending these plans back to the Developer for further revision.

We appreciate the opportunity given to comment.

Kind Regards

Claire and Laurence ParkmanThe Milliners, St Thomas St, Bristol (Redcliffe Conversation Area Residents)

I am generally happy with the development of the former fire station however the currentproposals are absolutely not acceptable:

Land Use:The proposed development lacks of cultural & social opportunities. There's been plenty ofresidential and office buildings and introducing another 300 apartments will only increase themonotony. Why not trying to convert the existing building and propose sport facilities (the existingtower could be a great climbing wall), outdoor/indoor gym, swimming pool, space for culturalevents etc.

Scale & Massing:The proposed development to be double the height of surrounding buildings with addition of 15-storey tower which will dominate in the city skyline. It will completely block the sunlight toTemplebridge Apartments. The development also fills the plot not giving space for landscape.

Heritage:The proposed development will ruin setting of listed buildings: Former Tramway Central powerstation and Holy Cross church in the Temple Gardens.

Landscape:The proposed landscape available to general public consists of 2-4m wide strip of so called raingarden and 4No. trees. This is a joke. When we lost a mature plane tree in 2016 to build the new

fire station we were promised that more landscape, including street trees will be introduced withthe new development. In addition to that due to the height of the proposed building, the proposedtrees will be in constant shade, not giving them chance to grow properly.

Environment:Due to the scale of the proposed development it is logic that Wind & Microclimate Analysis isnecessary, however this document is missing in the developer's submission. The funneling effectalong Temple Back is present currently, especially Autumns/Winters and with the proposeddevelopment it will increase massively.

Also, the existing former fire station building acts as a birds habitat including disabled one-leggedsea gull, so potential demolition could only take place outside birds nesting season and when thesea gulls migrate inland.

Transport:The proposed one-way system + pedestrian crossing may be a good way for traffic calming, buthuge increase of journeys due to proposed 300 apartments + office will not help to achieve that.

Demolition of the existing building (If it get permission):Due to noise and dust to commence during Autumn/Winter season (November to March),weekdays only (Mondays to Fridays, excluding Bank Holidays, between 9AM and 6PM.

Additional:We never had any consultations with the developer.

Summary:The proposed development gives no respect to the surrounding environment and neighbours. Italso gives no respect to the potential future residents who will suffer from the lack of sunshine,lack of landscape, wind turbulence, noise and pollution. Therefore the planning application shouldbe rejected and the developer's plans revised.

Lack of consultation by the developer with established authoritative bodies

During development of the present plans, there has been very limited consultation with HistoricEngland and the Conservation Advisory PanelFrom what consultation has taken place, nothing has been done to address the concernsexpressed by Historic England and the Conservation Advisory Panel on the detrimental impact ofthe tower block on the presence of the Grade II listed Generator BuildingThis is in addition to the bare minimum consultation with affected neighbours as described in myearlier objection posted on the planning portal on 25 June 2019.

From the objections posted by Historic England and the Conservation Advisory Panel:

Historic England 15 April 2019In their assessment of the impact of the tower block opposite the Generator Building stated:"In views from St Philip's Bridge, the 15-storey tower element of the proposed development wouldundermine the landmark status of the Generator building. We acknowledge that there is scope fora building of some height at this location, but in order to maintain the bridgehead role of theGenerator building we recommend that the proposed tall building is reduced in scale so that inviews from the bridge it does not rise above the roofline of the Generator building."

Conservation Advisory Panel 17 May 2019"The Panel understands that the current proposals have not been amended in accordance with

the pre-application advice. The pre-application proposal had also not been presented to CAP.It is considered that this is not an appropriate location for such a tall building. The 16 storey towerwould have an adverse effect on the listed Generator Building both in terms of scale andovershadowing. It would also dwarf other important local buildings such as Temple Church and theShot Tower.The entrance would be better located in the southern corner where it would be visible from thebridge and would complement the Generator Building. The building was a dull brick box whichmust be of a much higher quality of design and materials in this location."

Historic England 13 August 2019They again state their concern about the detrimental impact of the tower block on the presence ofthe Grade II listed Generator Building, and describe the consultation that has taken place:"We have previously suggested that we meet with the applicant to discuss our concerns and howthey might be addressed further. It is disappointing that this offer has not been taken up. Weremain keen to discuss modifications that could reduce the damaging effect that the proposeddevelopment would have on Bristol's townscape, but are compelled to register our strongconcerns at the proposals as they currently stand."

I hope that this repeated lack of consultation will be taken into account in the advice from theplanning officers to the Development Control Committee

I had previously raised concern about direct sunlight/daylight (being on first floor itimpacts us most) that has not changed in new plan.

Other concerns as raised previously include

- amenities to support additional people

- traffic and parking issues

Other concerns which I had missed previously, which I would like to add are:

Nuisance that will be caused due to the massive number of dwellings proposed in the small area

I had attended meeting held with Cubex Developers to address concerns by neighbours. Theimpression I got was they have proposed the plan and nothing is going to change unless councilobjects.

Therefore I request the application to be refused and design to be altered to mitigate abovementioned issues.

addresses our concerns. This is simply not the case. It is true that Rapleys met with a small group of residents, however their notes do not indicate that there was any discussion as to how the impact of the development could be mitigated. At a prior meeting, at which the Cubex Chief Executive was present the developer stated that whilst they were happy to listen to our concerns they were simply not prepared to modify the proposal to deal with them. As such, the proposed modification was not undertaken in response to consultation with the residents and does not in any meaningful way address the loss of daylight issue. Rapleys’ have also restated the view that purchasers of properties within Temple Bridge apartments should have anticipated the redevelopment of the adjacent site and the resulting loss of daylight that would ensue. Whilst the residents welcome the redevelopment of the site, I along with others, assumed that any such development would be along the lines of the surrounding buildings that have also been built subsequent to Temple Bridge apartments and certainly not, in this post Grenfell era, the construction of a 16 storey tower block. The developers have attempted to portray this as an extension to the Finzels Reach development. However the most cursory comparison reveals that the architectural style and density are completely different to the rest of Finzels Reach. As regards the Temple Bridge apartments, Rapleys’ report concludes with the following statement in relation to the loss of daylight: “This reinforces the conclusion drawn from the cutback analysis contained within the previous report that the part of the proposal lost would be significant in order to strictly meet the guideline figures, blighting development potential.” To put this another way, the developer is asking the council to waive the guidelines and sacrifice the quality of living within Temple Bridge Apartments so that the developer can make a profit out of the development. I respectfully suggest that the council does not give in to such pressure and that the profitability of the development is purely a matter for the developer and its shareholders. I commend the planners for the Finzels Reach development and the manner in which the old and new elements have been blended together to provide an urban environment for which Bristol can be proud. I can only hope that as the planning authority you are able to ensure that this development is also worthy of Bristol and its heritage. Yours sincerely, Katherine Ogden

Comparison of Daylight Distribution Contours Light green shading highlights the area of improved daylight compared to the original application

Light green shading highlights the area of improved daylight compared to the original application

I'd like to start this objection by underlining that I understand the huge need for newhousing in Bristol. I also believe that the current Finzels Reach site has improved the local areaconsiderably, and has done so in a way that benefits both existing and new residents. I am alsofully behind redeveloping the Fire Station site.

However, I cannot support the current plans due to the detrimental effect they will have on bothTemplebridge Apartments residents and the existing historical structures in the area.

While my neighbours have voiced our reasons in far more eloquent terms, to reiterate:

- I'm extremely concerned about the impact that will be caused by the introduction of a raisedzebra crossing on Counterslip to the east of the Temple Back junction. The noise from cars, HGVsand buses driving across St Phillips Bridge 24 hours a day is already incredibly loud. Adding araised table will push the noise and vibration to an unacceptable level. This will affect all residentson the bridge side of the building, most significantly during the night when the noise will disruptsleep. Speaking as an individual with a medical condition who requires interrupted sleep to staywell, this increase in noise will have a substantial affect on my health. Adding a zebra crossing willalso cause an increase in stationary traffic on Counterslip and St Phillips Bridge (particularlyduring rush hour), similar to how the crossing on Victoria Street near Bristol Bridge causestailbacks. This goes against the city's aim to reduce pollution caused by traffic; it will actuallyincrease it.

- The height and positioning of the residential tower will cause an unacceptable reduction insunlight for residents facing Temple Back (as per the Daylight Sunlight Analysis Addendum ReportSection 10) which will have an impact on wellbeing and drive an increase in energy usage(something that we should be actively avoiding).

- The positioning of the entrance to the residential tower block and layby (currently on the corner ofTemple Back and Counterslip) has the potential to affect Templebridge residents due to anincrease in noise of people entering and leaving the property (particularly at night) and vehiclescoming and going.

- The adverse impact the residential building will have on the Generator building (as per HistoricEngland and the Bristol Civic Society's comments).

It's clear to me that repositioning the residential tower (perhaps to the corner of Temple Street andCounterslip as proposed by the Bristol Civic Society, or to the centre of Counterslip) and having amore considerate approach in the plans for the public realm and roads, will alleviate many of theseissues listed above.

Concern over potential hazard to life from restricted road width of Temple Back, andpossible delay to fire appliances getting to emergencies

Drawing NPA 11039 402 P04: TEMPLE BACK AND TEMPLE STREET SECTION, posted on theplanning portal 29 July 2019, shows Temple Back restricted to a single vehicle width with railingsone side and bollards on the other.

As this will be one of the route for fire appliances to access Counterslip, then giving access on toroutes to the city centre and to Temple Way and Old Market, I am concerned that the restrictedwidth of the road can easily be blocked by a single vehicle parking to make deliveries to the officeon Temple Back, and especially to the new development because of the single layby beingprovided for the development on Temple Back.

A reasonable estimate of the likely number of deliveries to the development is given in an earliercomment posted on 31 July.This was:"I don't believe any impact assessment has been done on this, so I've been trying to envisage theamount of traffic we can expect idling underneath our living room windows, at all times, inservicing over 200 dwellings. We can expect this include: Taxis Supermarket delivery vansAmazon/Yodel/Hermes etc. deliveries Takeaway deliveries. Hypothetically, let look at supermarketdeliveries (with no residents having cars, in Cubex's ideal scenario) for just 200 dwellings having 1delivery a week. With all residents being young professionals, delivery slots are likely to be most

popular between 5pm-10pm, Monday to Friday and 8am-8pm Saturday & Sunday. That's 49available slots a week, making a mean average of just over 4 deliveries an hour. However, someslots are likely to be more popular that others (e.g. 6pm-8pm, Monday to Friday). And withnumerous supermarkets offering deliveries (Asda, Sainsburys, Tesco, Waitrose, Ocado) we couldbe seeing up to 5 different vans competing for space in the loading bay at peak times. Then welook takeaway delivery services, more popular at the anti-social end of the clock, Thursday, Fridayand Saturday nights 8pm-1am. Again, with the target residents being young professionals, we canexpect usage of this to be pretty high. Hypothetically you have just 100 dwellings ordering 1takeaway a week, evenly spread over 7 days this would be approx. 3 an hour, on top of the 4supermarket deliveries an hour. But in reality, it's more likely to be closer to 7 per hour at peaktimes. And now start thinking about all of the online shopping delivery drivers, 200 dwellingsmaking at least 1 online purchase per week. These deliveries can arrive at any time of day, 7 daysa week"

I hope that the width restriction will be revisited to ensure that fire appliances can move alongTemple Back without delay and potential hazard to life.

*Resubmitted due to error in previous comment*

I'd like to start this objection by underlining that I understand the huge need for new housing inBristol. I also believe that the current Finzels Reach site has improved the local area considerably,and has done so in a way that benefits both existing and new residents. I am also fully behindredeveloping the Fire Station site.

However, I cannot support the current plans due to the detrimental effect they will have on bothTemplebridge Apartments residents and the existing historical structures in the area.

While my neighbours have voiced our reasons in far more eloquent terms, to reiterate:

- I'm extremely concerned about the impact that will be caused by the introduction of a raisedzebra crossing on Counterslip to the east of the Temple Back junction. The noise from cars, HGVsand buses driving across St Phillips Bridge 24 hours a day is already incredibly loud. Adding araised table will push the noise and vibration to an unacceptable level. This will affect all residentson the bridge side of the building, most significantly during the night when the noise will disruptsleep. Speaking as an individual with a medical condition who requires uninterrupted sleep to staywell, this increase in noise will have a substantial affect on my health. Adding a zebra crossing willalso cause an increase in stationary traffic on Counterslip and St Phillips Bridge (particularlyduring rush hour), similar to how the crossing on Victoria Street near Bristol Bridge causestailbacks. This goes against the city's aim to reduce pollution caused by traffic; it will actually

increase it.

- The height and positioning of the residential tower will cause an unacceptable reduction insunlight for residents facing Temple Back (as per the Daylight Sunlight Analysis Addendum ReportSection 10) which will have an impact on wellbeing and drive an increase in energy usage(something that we should be actively avoiding).

- The positioning of the entrance to the residential tower block and layby (currently on the corner ofTemple Back and Counterslip) has the potential to affect Templebridge residents due to anincrease in noise of people entering and leaving the property (particularly at night) and vehiclescoming and going.

- The adverse impact the residential building will have on the Generator building (as per HistoricEngland and the Bristol Civic Society's comments).

It's clear to me that repositioning the residential tower (perhaps to the corner of Temple Street andCounterslip as proposed by the Bristol Civic Society, or to the centre of Counterslip) and having amore considerate approach in the plans for the public realm and roads, will alleviate many of theseissues listed above.

The revised plans do nothing to:Reduce the overshadowing that will put the flats in permanent shadow from October to March andreduce daylight in the flats below national guidelines - in some cases more than 70% loss ofdaylightGet rid of the nuisance and disturbance that will be caused to people in the flats by having thesingle entrance for around 500 people exactly opposite Templebridge Apartments - people comingand going and the noise that goes with that especially late in the evening after the bars closeGet rid of the nuisance and disturbance that will be caused to people in the flats by having thesingle layby exactly opposite Templebridge Apartments with a conservative estimate of vehiclemovements at the end of this email

I firmly believe the present plans, including the revisions will:- not deliver a successful community that the Urban Living SPD promotes,- severely detract from the presence of the Generator Building (cause harm in planning terms)- cause great nuisance to the residents of Templebridge Apartments, which is the only residentialbuilding on Temple Back or Counterslip by siting the residential units along Temple Back.The harm done to the Generator Building and the nuisance we will experience could both bemitigated by swapping the office building to the corner of Temple Back and Counterslip andmoving the residential tower and some of the lower level residential building to Counterslip andTemple Street. We have previously (in May) suggested this to Cubex, but this has not beenadopted in the revised plans.

Let me restate, I recognise the need for housing in Bristol, and the old fire station site needs to beredeveloped. What I cannot support are the present plans, even including the revisions posted on29 and 30 July.

The revised plans do nothing to address my earlier objections about:1. The nuisance from the single entrance exactly opposite Templebridge Apartments and thelayby. The entrance will have around 500 people using it every day throughout the day and lateinto the evening, with the associated noise, and traffic.The layby will be used by vehicles picking up and dropping off people, and all their associateddeliveries from on-line supermarket deliveries (possibly 5 per hour), Amazon/Hermes/Yodel/DPD(possibly 3 per hour), take away food (possibly 7 per hour - mainly in evenings). Possibly 15

deliveries per hour wanting to use one layby exactly opposite the bedrooms and living rooms ofTemplebridge ApartmentsNeighbourliness in the terms of the Urban living SPD might mean that this aspect would beaddressed.2. Fair and equitable share of sunlight and daylight between existing occupants and neighbouringbuildings.Because of the height of the development - 11 and 16 storeys on Temple Back - TemplebridgeApartments will be in continuous shadow from October to March each year.Neighbourliness in the terms of the Urban living SPD might mean that this aspect would beaddressed.The height reduction and narrowing of the tower block as reported by Cubex in their response tothe Urban living SPD that was posted on 29 July only mentions daylight benefit to residents in thenew development on the fire station site (Q3.1 page 26). It is still acknowledged in the DaylightSunlight Analysis Addendum Report Section 10 that there will be no benefit to TemplebridgeApartments.3. The overbearing presence of a 16 storey tower block exactly opposite the Grade II GeneratorBuilding is contrary to the views of The Redcliffe Residents Action Group & NeighbourhoodForum, The Conservation Advisory Panel, and Historic England All these groups conclude that thearea of the proposed development on the corner of Temple Back and Counterslip should be nohigher than the existing Generator Building.There is nothing in the Redcliffe Conservation area SPD (3) that encourages such a tower blockHistorically there is no precedent for a building above about 6 to 8 storeys (including the groundfloor, which Cubex do not count as a storey).Respect for the heritage of the area as aspired to by the Redcliffe Conservation area SPD and theviews of several recognised bodies might suggest that a tower block is inappropriate for this areaof North Redcliffe.The Redcliffe SPD does set out Townscape Policy Guidance (page 31) that acknowledges that inNorth Redcliffe the predominant context is buildings of 3 to 6 storeys, and it aspires to seedevelopment that is on a human scale.It is acknowledged that the plans do address some of the aspirations set out on page 46 of theSPD.

My concern about the likely success of the scheme in its present form is from the density of thedevelopment. This is presently 345 dwellings per hectare (dph). The Urban living SPD citesWapping Wharf as a successful development with a density of 200 dph in a city centre site.Reducing the major part of the residential development (that is the tower block and the centralblock on Temple Back) to eight storeys would bring the number of dwellings to around 253. Thiswould give a density of 275 dph. Closer to what is recommended as likely to be successful in theUrban living SPD.A combination of overall height reduction, and resiting the presently planned Temple Backresidential units to the Temple Street and Counterslip would enhance the likelihood of building asuccessful community as well as mitigate the harm that the present plans will bring to residents of

Templebridge Apartments

29 QUEEN SQUARE BRISTOL BS1 4ND

Telephone 0117 975 1308 HistoricEngland.org.uk

Historic England is subject to both the Freedom of Information Act (2000) and Environmental Information Regulations (2004). Any Information held by the organisation can be requested for release under this legislation.

justification that is required by NPPF paragraph 194 in respect of harm to heritage assets. Further revisions are therefore necessary to avoid or reduce the harm to the setting of the scheduled church tower. Avoiding harm to the setting of the generator building will clearly require a reduction in height to the 15-storey tower. We recommend that the tower is reduced in height by around 4 storeys, which should bring it below the ridgeline of the Generator building in views from St Philips Bridge, thus allowing the Generator building to retain its visual primacy as the bridgehead. We have previously suggested that we meet with the applicant to discuss our concerns and how they might be addressed further. It is disappointing that this offer has not been taken up. We remain keen to discuss modifications that could reduce the damaging effect that the proposed development would have on Bristol's townscape, but are compelled to register our strong concerns at the proposals as they currently stand. Recommendation Historic England has concerns regarding the application on heritage grounds, and the advice set out in our original letter of 15 April 2019 still stands. In determining this application you should bear in mind the statutory duty of section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 to have special regard to the desirability of preserving listed buildings or their setting or any features of special architectural or historic interest which they possess, and the statutory duty of section 72(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 to pay special attention to the desirability of preserving or enhancing the character or appearance of conservation areas. Your authority should take these representations into account and seek amendments, safeguards or further information as set out in our advice. If there are any material changes to the proposals, or you would like further advice, please contact us. Yours sincerely

Simon Hickman Principal Inspector of Historic Buildings and Areas

Dear Sirs,

The following Addendum to my initial objection to the proposed redevelopment of the formerTemple fire station site has been prepared having considered the Technical Note prepared byKTC which responds to the observations made by Bristol City Council's (BCC) TransportDevelopment Management (TDM) team

This addendum uses the same notation as the KTC technical note which explains why Paragraph1 - Introduction has been excluded from this document

2.1 Passenger TransportWhilst acknowledging that the number of off-street car parking spaces proposed by the applicantfor both the proposed residential and office uses are BCC 'Policy Compliant', the actual numbersare minimal, therefore the development is heavily reliant on future occupiers travelling bysustainable means of transport other than the private motor car, such as walking, pedal cycle andpublic transport

I am therefore somewhat surprised that BCC Officers have only identified a single bus stop whichrequires improvement which will be funded by a financial contribution secured from the developer

It is noted that the applicant proposes to install Real Time Information (RTI) screens within thebuilding, which is welcomed

3.1 Travel PlanningIt is noted that the Travel Plan will be monitored for a five-year period - will this be from: firstoccupation; 50% occupation; or of full occupation of the residential element of the scheme? Giventhat the flats are for rent only, the turnover of future occupiers is likely to be high - how will theapplicant ensure that each new occupier will be supplied with a copy of the 'Travel Plan'?

4.1 Cycle Parking - B1 Office UseGiven that the applicant is proposing absolute minimum off-street car parking provision for theoffice accommodation, I am dismayed that TDM has requested that the number of off-street carparking spaces be further reduced in order to secure 221 secure cycle parking spaces, a requestwhich the applicant has taken on board

There are countless examples of development across the city where inadequate off-street, carparking provision continues to cause significant issues for existing residents, the flats at thecountry cricket ground and the redevelopment of Ashton Gate stadium spring to mind immediately

More locally, and speaking from experience, the number of employees who drive to number 10Temple Back exceeds the number of off-street, car parking spaces available on a daily basisresulting in them parking on-street and 'feeding the meter', thereby reducing the number of on-street spaces available to others. I note that the applicant still intends to reduce the existing levelof on-street, car parking stock by narrowing the existing carriageway which will make the matterworse

A further observation is that a number of existing local residents own more cars than the numberof off-street, car parking space(s) which have been allocated to/available to them. This results inthem utilising the existing on-street pay and display spaces, often displaying a residents parkingpermit

It should be noted that a number of local businesses and hotels rely upon the existing on-street,car parking provision and these will be severely affected by the proposed reduction in the existinglevel of on-street, car parking stock

5.1 and 5.2 Cycle Parking - ResidentialIt is noted that two-thirds of residents will have access to surface level secure cycle parkingfacilities and that the cycle parking will be sub-divided into smaller blocks as recommended byBCC's Urban Living SPD

6.1 'Tiger Crossing'I note that the applicant proposes a 'Tiger' crossing at the junction to Counterslip and TempleStreet to replace the existing traffic signal-controlled crossing point in order to allow westboundcyclists to safety re-join the carriageway

Whilst acknowledging that some pedestrians will cross against a red man, I have observed thatthe majority will wait until the pedestrian aspect displays a green man before crossing in platoons.Replacing the existing traffic signals with a 'Tiger' crossing will mean that pedestrians will bepermitted to cross at any time, which will cause east and westbound vehicular traffic to form astationary queue at the crossing point more frequently that they are currently required to do so atthe traffic signals

Whilst this has the potential to cause inconvenience to westbound drivers who may be required tostop on the approach to a green signal at the traffic signal-controlled junction of Victoria Street andCounterslip, the effect on eastbound traffic has the potential to be more significant

Continued use of the 'Tiger' crossing by platoons of pedestrians will quickly lead to a stationaryqueue of vehicular traffic towards, and potentially through, the traffic signal-controlled junction ofVictoria Street and Counterslip. This has the very real potential to interrupt the free flow of northand southbound traffic on Victoria Street and is considered to be to the detriment of highwaysafety

I would urge BCC Officers to observe the platoons of pedestrians who cross Counterslip at thislocation, especially on a Friday when the food market is located on Old Temple Street

I would suggest that a 'Tiger' crossing is not a suitable solution and that the applicant should beencouraged to upgrade the existing traffic signal installation to a 'Toucan' crossing

6.2 and 6.3 Extended Cycle LaneI look forward to seeing the plans to extend the proposed cycle lane eastwards over St PhilipsBridge towards Temple Way. However, I am still concerned that removing the advisory cycle laneson both sides of Counterslip and Passage Street, both of which are very well used, and combiningpedestrians and cyclists within a segregated facility has the potential to introduce conflict betweenthese two types of vulnerable road users

7.1 Crossing TreatmentAgree that the crossing point at Counterslip and Temple Street should be traffic signalled-controlled (Toucan) without the provision of a raised table.

I do not consider that raised zebra crossings are appropriate on Counterslip as constant use byplatoons of pedestrians will cause vehicular traffic to stop and form a stationary queue more oftenthan at the existing traffic signal-controlled crossing at Temple Street and the central pedestrianrefuges at Temple Back, to the detriment of air quality and road safety

They will also become a maintenance liability for the Local Highway Authority

7.2 Raised Zebra Temple BackIntroducing a raised zebra crossing on Counterslip, east of its junction with Temple Back, in placeof the existing central pedestrian refuge island is unacceptable. Counterslip and Passage Streetregularly act as two-way route for buses and heavy goods vehicles (HGCs) and the noise andvibration caused by these vehicle types negotiating the proposed raised table will be unacceptableto the existing residents of Templebridge Apartments

There is also the possibility that the vibration caused by these vehicles negotiating the proposedraised table could cause structural damage to Templebridge Apartments. Should the proposedraised table be given permission, I will insist that the applicant be required to fund a full structuralsurvey of Templebridge Apartments in order that the effect of any raised feature can be monitored

7.3 Courtesy Crossing(s)I look forward to seeing plans which indicate the final design of courtesy crossing(s)

8.1 and 8.2 Continuous Crossings (Side Roads)I am not convinced that continuous crossings are necessarily a good idea. They tend to givepedestrians and cyclists the impression that they somehow have priority over emerging vehiculartraffic and, when used in isolation, can cause confusion, especially for visually impaired users ofthe footway. I look forward to seeing the detailed design of all proposed continuous crossing andBCC keeping me up to date with regards to the findings of their proposed trials

Perhaps the swept path analysis referred to could be uploaded to the BCC planning portal andlocal residents advised when the plans are available for consideration and comment

8.3 Meeting with Avion Fire and RescueI look forward to seeing the minutes of any meeting between TDM, BCC road safety and Avon Fireand Rescue being uploaded to BCC's planning portal for inspection. To date I have noted that ithas not been possible to secure minutes of meetings between BCC and the applicant from whichwe as local residents have been excluded

9.1 Width of CounterslipI note that the width of Counterslip will be retained at a minimum of 6.5-metres, however, it isdifficult to see how speed tables of a minimum length of 14-metres can safely be accommodated

9.2 BollardsI would hope that street furniture other than traditional bollards could be used to encouragemotorists not to park on the footway

9.3 Footway WidthI would suggest that a minimum footway width of two metres be provided along the whole sitefrontage in accordance with the guidance provided by Manual for Streets (MfS)

9.4 Approach to Victoria StreetI would suggest that a 'Toucan' traffic signal-controlled crossing point would be the mostappropriate solution for reasons summarises earlier in this document

9.5 SignalsI am surprised that the 'signals have been removed' and have yet to have sight of any Road SafetyAudit (RSA). The lack of an RSA was brought to the attention of Gavin Bridge of Cubex at theMonday 5th August 2019 meeting of the Redcliffe Residents Action Group (RRAG)

10.1 Planting and BenchesWhilst the contains of planters do brighten an area up, in reality all they do it attract litter. They,together with proposed benches, should be located such that they do not represent a hazard tocyclists or visually and/or mobility impaired users of the footway/cycleway

10.3 Temple Street/Water Lane(10.2 appears to relate to a TDM observation) hopefully the revised arrangement will be subject toan RSA

11.1 Temple Back Contra-Flow Cycle LaneI note that a contra-flow cycle lane is now proposed for Temple Back. The design must be suchthat it does not encourage westbound vehicles crossing St Philips Bridge to turn left into TempleBack against the proposed 'No Entry'. Temporary 'New Road Layout Ahead' highway signage willassist in this regard

11.2 Play Park/Amenity AreaPlease clarify the position with regards to the principle of a 'play park/amenity area'

11.3 Water LaneThe Water Lane bell-mouth should be the subject of an RSA

12.1 On-Street, Car ParkingCan I please request that the total number of existing and proposed on-street, car parking spaceson Counterslip, Temple Street, Water Lane and Temple Back be confirmed together withinformation as to where lost on-street, car parking spaces will be relocated. I would also like tounderstand if the proposed development results in a net increase or loss of existing on-street, carparking provision in the area

13.1 Traffic Regulation Orders/Temporary Traffic Regulation OrdersNote observations relating to Traffic Regulation Orders (TROs) and Temporary Traffic RegulationOrders (TTROs)

14.1 Planting, Materials, Flood Risk and Commuted SumsNo observations

15.1 Flood Risk Management (FRM Team)No observations

16.1 StructuresNo observations

17.1 Street LightingLook forward to seeing a plan and specification for improvements to the existing street lightingprovision. Presumably LED lanterns will be required together with replacement columns?

18.1 Way ForwardNo observations, however, I would like to be kept up to date with future communications betweenthe applicant and TDM

Having received formal written notification from Bristol City Council, I have reviewed therevised plans uploaded to the authority's Planning Portal by the applicant on 29th and 30th July2019

Whilst I note that the amended plans 'slim down' the proposed tower and reduce the height of theblock running along the western side of Temple Back, neither the revised plans nor thepresentation to the Redcliffe Residents Action Group (RRAG) given by Gavin Bridge and JoDavies on Monday 5th August 2019 adequately address the material planning considerationsummarised in the initial letter of objection, as uploaded to the Planning Portal on 6th April 2019

I am therefore left with no alternative but to repeat my initial objection in full below for theavoidance of any doubt

I would like to take this opportunity to express both my surprise and disappointment that theapplicant has failed to take account of feedback provided by both local residents and otherinterested stakeholders when revising the plans

Dear Sirs,As a resident of Templebridge Apartments and a Director of the Templebridge Apartments (Bristol)Management Company, I would take this opportunity to provide the following observations andobjections following the submission of the above planning application to Bristol City Council(BCC).

Introduction

May I begin by stating that I fully support the principle of the redevelopment of the former Templefire station site, just not in the form displayed at the public consultation event, held on Tuesday11th December 2018, nor indeed as shown by the plans submitted in support of the planningapplication.

The proposals represent a massive over development of an unsuitable site in terms of its areawhich is also unsustainable in terms of local community facilities such as retail, leisure, healthcare, child care and education.

When I purchased my apartment in March 2009, I did so in the knowledge that the mixed-usedevelopment known as 'Finzels Reach' was under construction, and that the height of thebuildings fronting Counterslip would not exceed that of the existing adjacent buildings, includingTemplebridge Apartments.I proceeded with the purchase of my property in the knowledge that some natural light would belost upon the completion of the Premier Inn hotel and the Aurora office block.

ObjectionI formally object to the proposed development as a resident of Templebridge Apartments and onbehalf of all the existing owners and occupiers of Templebridge Apartments in my role as aDirector of the management company.

My main objection is to the height and density of the proposed development which will significantlyreduce the existing levels of natural light from which habitable rooms within TemplebridgeApartments currently benefit from. The justification that these rooms currently benefit from "toomuch natural light" is simply outrageous and laughable. A more detailed review of theDaylight/Sunlight Analysis submitted in support of the application is provided later in thedocument.

I also have grave concerns with regards to the proposed highway works and a more detailedreview of the Transport Statement submitted in support of the planning application is includedbelow.

During a recent meeting with a representative of Cubex, we suggested moving the 'tower' elementof the proposed development to the corner of Counterslip and Temple Street thereby relocatingthe proposed office use to the Temple Back frontage, a suggestion we repeated to arepresentative of the Bristol Civic Society and Councillor Smith and Councillor Dudd when we metthem on Saturday 6th April 2019. We currently await a response from the developer.

BackgroundMore recently the residents of Templebridge Apartments were consulted on a previous pre-

application enquiry submitted to BCC for the redevelopment of the former Temple fire station site.The plans and information submitted in support of the pre-application enquiry indicated adevelopment of six-storeys together with the re-establishment of the road through the site, therebyincreasing its permeability. The current proposals do not include the re-establishment of the roadwhich I consider to be a missed opportunity.

The residents of Templebridge Apartments were recently invited to attend a public consultationevent at which the proposals for the redevelopment of the former Temple fire station site werepresented. We noted that the developer will be seeking planning permission for a mixed-usedevelopment delivering 150,000 square feet of office floorspace together with 310 dwelling units,in accordance with BCAP47 of the Bristol Central Area plan, which is reproduced below for theavoidance of doubt:

Policy BCAP47: The Approach to Redcliffe9.14.2 In north Redcliffe, outside of the Redcliffe Way area, the key to major change lies in theregeneration of a small number of major development sites that are presently underused, vacantor derelict, including the former Courage Brewery, the Redcliffe Village site and the Temple Backfire station. The mixed-use redevelopment of these areas has the potential to significantlytransform the economy and appearance of the Redcliffe neighbourhood and deliver significantlyupon the vision, objectives and detailed proposals of SPD3 The Future of Redcliffe, which wasprepared in 2006 with the support of Redcliffe Futures.

9.14.3 In south and west Redcliffe, development opportunities are generally smaller and scarcer,with the exception of the former Bristol General Hospital site. Much of the area is an establishedresidential community supported by a range of local services including convenience shopping. Theapproach to south and west Redcliffe therefore focuses on protecting local services and improvingpedestrian routes across the area rather than delivering major change.

The planning applicant which has been submitted to BCC differs slightly in that is seekspermission for 15,472 square feet of office use together with 318 residential units. During thepublic consultation event, I was told that one of the aims was to expand the 'Finzels Reach''community', however, I note that the application does not include any community facilities.

It was during the public consultation event that we first learned of the ambition of the developer toconstruct a sixteen-storey building directly opposite our homes.

The above policy does not encourage the redevelopment of the former Temple fire station site toinclude a 'high rise' building and I can find no other BCC policy which has been formally adoptedby the elected local Members which encourages 'high rise' development in central Bristol. I wastold at the public consultation event that the height of the proposed building is being driven by oneof BCC's planning officers, a claim that was repeated when we met a representative ofConversation PR and Cubex on the evening on Monday 25th March 2019. Surely the height of a

proposed development cannot be determined by a single city council officer? Surely no individualcity council officer has sufficient delegated powers to encourage a 'high rise' development in suchan unsuitable, unsustainable location?

When planning permission was granted for Templebridge Apartments, it is clear that the developerwas told that the height of the development should not exceed that of the existing adjacentbuildings, including the Grade II* Listed 'Generator Building'. I would like to know when BCC'splanning policy for this area of Temple changed to encourage 'high rise' developments and beprovided a link to the associated policy which has been adopted by the local elected Members.

I would also be keen to view a copy of the adopted BCC criteria that a site needs to meet to bedeemed suitable for a 'high rise' development.

Observations Made at Public Consultation EventThere are several observations which I made at the public consultation event, which I considerneed to be formally raised and recorded.

The 'Emerging Context' exhibition board confirmed that BCC has granted planning permission forseveral 'high rise' development near the former Temple fire station site:- Former Central Ambulance Station (17/04267/FUL) - height ranging between 4 and 24-storeys;- The Assembly (16/06195/FUL) - height ranging between 5 and 12-storeys; and- Redcliff Quarter (16/02349/FUL) - height ranging between 8 and 22-storeys.

I note that none of the sites 'allocated' for 'high rise' development overlooks existing residentialdwellings. During the public consultation event, I enquired as the results of the light and shadowsurvey and was told that one had not been undertaken, a response which I found to be incredible.How can you possibly consult existing local residents without being fully aware of the effect thatthe construction of a sixteen-storey building will have on the levels of natural light from which theycurrently benefit?

When the light and shadow survey is undertaken, it will clearly demonstrate that most of thenatural light currently being enjoyed by the residents of Templebridge Apartments will be lost, tothe detriment of their physical and mental health and well-being. Should the proposals be takenforward to a full planning application, this will surely prompt BCC officers to recommend refusal ofthe proposed development.

The proposed development will also have a negative effect on the value of our properties asnobody will be interested in purchasing an apartment which is continually in shade.The proposed sixteen-storey will also overshadow the 'Generator Building', a Grade II* listedstructure, which first opened in 1899 and remains one of Bristol's iconic buildings which will bedominated by the proposed works.

During the public consultation event, I was told that the proposed development is essentially acontinuation of 'Finzels Reach' to create a community, however, the developer is not proposing toprovide any community facilities which is surely an oversight on their part?

The representative of Cubex also stated that the main entrance to the residential units was chosenas being on the corner of Counterslip and Temple Back as this is 'thought' to be the point at whichoccupiers would arrive. However, the developer is proposing to provide only 15 off-street carparking spaces, meaning that the majority of future occupiers will be expected to arrive by publictransport and walk to the development from either Bristol Temple Meads railway station or Bristolbus station, suggesting that the main entrance is not ideally located to receive them.

Assuming that the main entrance provides access to all the proposed 310 residential dwellings, itis fair to assume that around 620 future occupiers will use the main entrance which will causenoise and disruption to existing residents where currently none exists.

I appreciate that BCC's adopted car parking standards are a maximum, however, the provision of15 off-street car parking spaces is most definitely an insufficient number, as it represents a singlespace per 20 flats. The proposed development will generate a significant number of vehicular tripswhich will lead to drivers circulating the area in search of an on-street car parking space, to thedetriment of local air quality.

I also note that the developer proposes to remove several existing well used on-street car parkingspaces which will be to the detriment of local business.

I assume that, as with Templebridge Apartments, future occupiers of the proposed residential unitsand the office space will not be eligible to apply to BCC for parking permits, which will lead to anincrease in illegal waiting activities.

Bristol City Council - Urban Living SPD Making Successful Places at Higher Density

Part 3 of this document provides 'Guidance for Tall Buildings' and the introduction highlights that:

- A poorly located, poorly designed tall building can have a detrimental impact on the historictownscape of a city like Bristol; and- Tall buildings can put a strain on local transport and social infrastructure.

I completely agree that the proposed development will have a detrimental impact on the historiclandscape of the local area as well as putting a strain on local transport and social infrastructure.

The document continues to state that: "Tall buildings can be poor neighbours, overshadowingsurrounding development and open spaces and putting a strain on local transport and socialinfrastructure" - something I also complete agree with as it is particularly relevant to habitable

rooms within Templebridge Apartments as well as the local transport and social infrastructure.

Question 3.1 - 'Is the tall building well located?' recommends:

- C. The impact of tall buildings proposed in sensitive locations should be given particularconsideration. Such areas might include conservation areas, listed buildings and their settings,scheduled monuments and registered historic parks and gardens;- E. Generally speaking, larger sites (2ha and over) offer the greater potential for taller buildings,as these sites are more able to set their own context than smaller sites. Larger sites provide theopportunity to site tall buildings away from existing buildings, and thus protect them from over-shadowing and adverse wind effects;- G. Tall buildings will generally be discouraged on physically constrained sites within existing builtup areas, where a tall building is likely to have a negative impact on the daylight and sunlightpenetration into the habitable rooms of existing buildings, or onto well used parts of the publicrealm; and- H. Stand-alone tall buildings (i.e. buildings that do not form part of a block and street structure)will also be discouraged.

Whilst all of the above points are relevant to the proposed development, points G and H areespecially salient and I would draw your attention to these.

Question 3.2 - 'Does the scheme make a positive contribution to the long range, mid-range andimmediate views to it?' recommends:

- When siting a tall building, it will be important early on to test out a range of long-range, mediumrange and local viewpoints to understand the suitability of a site to accommodate a tall building.This should be undertaken in line with guidance from both Historic England and the LandscapeInstitute.

There is no evidence that the developer has undertaken the tests recommended by the SPD.

Figure 12 - Locational Criteria states that "a tall building should not be located where":

- It hides or masks the topography of the city;- It harms valued views from key vantage-points;- It has a detrimental impact on the city's historic environment;- It has a significant negative impact on the amenity of nearby occupiers or on the public realm;- It has a negative impact on existing nearby renewable energy systems; and- There is insufficient transport, utilities or community infrastructure to support a more intensiveform of development.

Again, whilst all of the above are relevant to the proposed development, I would particularly draw

your attention to bullet points 4 and 6 which are especially salient.

Question 3.4 - 'Does the scheme ensure the safety of occupants and passers-by?' includes anumber of recommendations, the most salient of which are included below:

- B. Careful consideration of public realm and landscape design around the base of tall buildings toensure access by emergency vehicles and easy evacuation and muster points; and- C. The preparation of a Fire Statements/strategy produced by a third-party independent suitablyqualified competent professional for consideration by Building Control or should therecommendations of the Hackitt Review be adopted, by the Joint Combined Authority (JCA).

There is no evidence that the developer has complied with these salient recommendations.

I would respectfully request that the developer has to comply with all of the recommendationscontained within this BCC documents, especially those which are particularly salient to the effecton Templebridge Apartments and the local transport and social infrastructure.

Future of Redcliffe - Supplementary Planning DocumentThis document has been guided by a ground-breaking initiative between BCC and the localcommunity of Redcliffe working together on how the area should be developed. Redcliffe Futuresbrings together local residents, businesses, developers and other agencies in a partnership whereeveryone can have a say about the changes happening in the area.

'Townscape Policy Guidance' T5 is specific in that: "Building heights should respond to thepredominant existing context of 3-6 storeys and should relate to the site's context, surroundingdevelopment and urban design considerations. Redcliffe is not generally considered anappropriate location for tall buildings." The proposed development is contrary to one of the statedobjectives of the Supplementary Planning Document (SPD).

'Movement Policy Guidance' M1 states: "All significant proposals ("major" planning applicationsmust include a Transport Assessment to establish impacts of proposals and identify appropriatemitigation measures." The planning application being considered by BCC is supported by aTransport Statement and not a Transport Assessment as required and is therefore contrary to oneof the stated objectives of the SPD.

'Parking' M17 confirms: "No further residents' parking permits will be issued within the ControlledParking Zone, that are directly linked to new developments, albeit dispensation should be madefor spaces to accommodate disabled individuals, car club initiatives or equivalent."

Paragraph 5.31 of the 'Social Profile and Community' confirms that: "There are presently nodoctor's surgeries in Redcliffe and the two closest surgeries are full. The South West Primary CareTrust believe there is a demand for surgery for two doctors to serve the growing population." This

highlights that there are insufficient existing health care facilities to accommodate future occupiersof the proposed residential units.

The proposed development fails to address points 3 and 7 of the aspirations for theredevelopment of the Temple area:

- 3. Create a new pedestrian link from Victoria Street past the Cornubia Pub, across TempleStreet, through the Fire station site and on to reconnect into a new section of the riverside walk.This will better reconnect the pub into the urban fabric, as this is currently a hidden and poorlyconnected building. The permeability of the area will also be improved; and- 7. Develop the Fire Station site with a perimeter building. Establish pedestrian ways through thissite to allow ease of permeability as well as vehicle access ways to service the site.

The proposed development fails to consider point 5 of the 'Former Brewery Site', which states: "5.New buildings should respond to the scale of the Generator Building which must be maintained asthe dominant landmark building within the site." The SPD also identifies the view of the 'GeneratorBuilding' as being one which needs to be preserved. The proposed development will dwarf thisGrade II* Listed building such that it will no longer be the dominant landmark building.

Paragraph 7.12 of the 'Planning Applications' section requires major planning applications toinclude a 'Design Statement' which demonstrates how proposals respond to the overall vision forRedcliffe. The integration of townscape, movement, social and economic benefits must be clearlyset out and how the integration of these factors has been addressed. I am not convinced that theapplicant has provided such a document.

Paragraph 7.13. Major applications should provide context drawings and images illustrating theproposed development within the existing surrounding environment, demonstrating how adevelopment has responded to the issues and recommendations contained within this SPD.Again, I am not convinced that the applicant has provided suitable drawings and images.

Paragraph 7.14 requires major planning applications (i.e. large buildings in excess of 1,000 squaremetres, and developments of 10 houses or more) submitted for development within Redcliffe areexpected to include the following information:- Planning Statement (including proposal package of SPD4 obligations);- Sustainable Development Profile;- Transport Assessment;- Travel Plan;- Urban Design Statement;- Landscape Strategy;- Conservation Plan if proposals include an historic building within the Conservation Area and/or alisted building;- Public Art Plan;

- Assessment of the impact of the proposals in the light of the findings of a desk-basedarchaeological assessment and evaluation;- Ground Investigation Report; and- A Statement of Community Involvement, including details of involvement events, the issuesraised by the community and how those issues have been addressed within the developmentproposals.

The planning application is not supported by all of the documents requested above and istherefore contrary to the to one of the stated objectives of the SPD.

I would be grateful if the applicant can confirm that they have formally consulted with 'RedcliffeFutures' as their response is not currently available on BCC's Planning Portal.

Consistent Bristol City Council Officer AdviceDuring January 2018, a planning application was made to BCC relating to number 21 St ThomasStreet, Redcliffe, reference 18/04911/F. Under a previous planning application, permission wasgranted for the erection of a nine-storey block of 387 student bed spaces and 270 square metresof commercial space.Planning application reference 18/04911/F sought to increase the height of the previous approvedbuilding from nine-storeys to a maximum of fourteen-storeys providing over 400 student flats.

BCC officers recommended that the application be refused for five reasons, with the officer'sreport highlighting that by extending the building by five additional storeys it would create adevelopment which is "out of step with the surrounding area and creating harm to the RedcliffeConservation Area."The report continued: "It is further considered by extending the building by five storeys, a greaterdegree of less than substantial harm would be attributed to the setting of the surrounding heritageassets, including a number of Grade II* and Grade II Listed Building."

As the former Temple fire station site is also located within the Redcliffe Conservation Area, wewould expect officers to provide members of the planning committee with consistent advice withregards to the harm the proposed development will create to the Redcliffe Conservation Area.

We would also expect officers to make members of the planning committee aware of the harm thatthe proposed development will have on the existing Grade II* Listed 'Former Tramway GeneratingStation' on Counterslip together with the 'Central Electric Lighting Station' on Temple Back.

It is also noted that the proposed development of the 13-storey building would also badly affect theview from Temple Church.It is imperative that BCC officers provide members of the planning committee with consistentadvice with regards to two planning application sites, both of which are located within the RedcliffeConservation Area.

The following sections provide observations on the various documents submitted in support of theplanning application.

General ObservationsThe elevation section indicates that the 'tower' element of the proposed development will bebenefit from balconies fronting onto Temple Back, use of which have the real potential to causenoise and disruption directly opposite existing habitable rooms and bedrooms within TemplebridgeApartments.

Material planning considerationsMaterial planning considerations can include, but are not limited to, the following:- Overlooking/loss of privacy- Loss of daylight/sunlight or overshadowing- Scale and dominance- Layout and density of buildings- Appearance and design of development and materials proposed- Disabled persons' access- Highway safety- Traffic and parking issues- Drainage and flood risk- Noise, dust, fumes etc- Impact on character or appearance of area- Effect on listed buildings and conservation areas- Effect on trees and wildlife/nature conservation- Impact on the community and other services- Economic impact and sustainability- Government policy- Proposals in the Local Development Plan- Previous planning decisions (including appeal decisions)

Whilst all of the above are relevant to the planning application currently being considered by BCC,I consider that points 1, 2, 3, 4 7, 8, 10, 11 , 12 and 14 are especially salient.

Daylight/Sunlight AnalysisThe following section summarises observations made having reviewed the Daylight/SunlightAnalysis undertaken by Rapleys dated March 2019, which is significantly AFTER the publicconsultation event, referencing their paragraph numbers:- Paragraph 1.6 - the author focuses on 'around' five living rooms, failing to identify that five loungewindows also exists on the western elevation of Templebridge Apartments all of which will beimpacted by the development. I fail to see how the author can focus on 'around' five living rooms -surely there are either 5 living rooms, or there are not;

- Paragraph 1.6 - appears to conclude that the reduction in the existing level of natural lightTemplebridge Apartments currently benefits from is acceptable given that the developmentcurrently benefits from 'good or well over and above the average levels' which is simplyoutrageous. How can a professional person possibly justify reducing the existing level of naturallight from which Templebridge Apartments benefits from to a level below the minimum levelsrecommended by BRE on the basis that the existing residential block benefits from 'good or wellover and above the average levels'? This statement simply leaves me lost for words given that theimpact on habitable rooms within Templebridge Apartments will be to the detriment of the physicaland mental health and well-being of existing and future occupiers;- Paragraph 1.6 - confirms that Templebridge Apartments is 'likely' to be impacted on by theproposed development. Surely the results of the of the analysis will indicate whether TemplebridgeApartments will or will not be impacted. Why has the author concluded that TemplebridgeApartments is 'likely' to be impacted - either it will be, or it will not be;- Paragraph 1.6 - when planning permission was granted to the erection of TemplebridgeApartments, during the construction phase and post-construction, Temple fire station wasoperational, comprising a combination of fire appliances and administration staff. There was noindication that the fire station would become available for redevelopment, therefore how can theauthor possibly make continued reference to the developer of Templebridge Apartments, togetherwith the occupiers, designer and the local authority "must have taken into account the likelihood ofa neighbouring development" when the neighbouring building was an operation fire station?- Paragraph 1.6 - as referred to earlier in this document, the residents of Templebridge Apartmentswere consulted on a previous pre-application enquiry relating to the proposed redevelopment ofthe former Temple fire station site. The submitted plans indicated the height of the proposedbuildings being a maximum of six-storeys which is in keeping with the existing structures. Howcould any of the occupiers possibly anticipate a neighbouring development of sixteen-storeyscoming forward?- Paragraph 1.9 - please can the author provide a clear and concise justification for arriving at theconclusion that: "We therefore recommend that the impact 'likely' to be experienced withTemplebridge Apartments should be deemed acceptable 'in this instance' and the proposeddevelopment itself will benefit from acceptable levels of Daylight and Sunlight, given the context ofits location";- Paragraph 1.9 - could the author please expand on why the impact 'likely' to be experienced withTemplebridge apartments should be deemed acceptable 'in this instance';- Paragraph 1.9 - could the author please provide a clear and concise justification for plunging fiveexisting, habitable rooms within Templebridge Apartments, which have been occupied for tenyears, into permanent shadow? Occupiers will become reliant on artificial light to the to thedetriment of their physical and mental health and well-being; and- Paragraph 1.9 - I believe that the author has failed to identify a further five habitable rooms onthe western elevation of Templebridge Apartments which will be impacted by the proposeddevelopment.

The catastrophic extent to which the existing level of natural light currently being experienced by

habitable rooms within Templebridge Apartments is clearly demonstrated by the extract below,which has been reproduced from a document that is publicly available on BCC's Planning Portal:

The observations summarised above are made with regards to the effect of the proposeddevelopment on the Daylight and Sunlight on Templebridge Apartments included within the'Executive Summary' of the Rapleys report. I would very much hope that the summary would ringalarm bells with both BCC officers and elected Members to the extent that the proposeddevelopment should be recommended for refusal given its forecast detrimental effect on aminimum number of five habitable rooms within Templebridge Apartments in so far as it reducesthe existing level of natural light below the minimum recommended by BRE

The following observation are made having reviewed the main body of the Rapleys report:- Paragraph 3.14 - the first floor and sixth floor plans of Templebridge Apartments (undated) onwhich the analysis is based were found via on-line research. What level of confidence does theauthor have that these plans are an accurate representation of Templebridge Apartments 'as-built'? Why have plans for the second to fifth floors inclusive not been included in the analysis?- Paragraph 4.4 - Policy DM27 of The Site Allocations and Development Management PoliciesLocal Plan states: "Sunlight and daylight studies may be required for schemes where there isdoubt over the acceptability of their impact on the amenity of existing development." The analysisleaves us in no doubt that the proposed development will have an unacceptable impact on thelevel of natural light from which a number of habitable rooms within Templebridge Apartmentscurrently benefit;- Paragraph 4.4 - the proposed development appears to be contrary to Policy DM27 of The SiteAllocations and Development Management Policies Local Plan, which states: "Proposals for newbuildings will be expected to ensure that existing and proposed development achieve appropriatelevels of privacy, outlook and daylight." The analysis clearly concludes that the proposeddevelopment will reduce the level of natural light from which Templebridge Apartments currentlybenefits to a level below the minimum recommended by BRE - this is simply unacceptable;- Paragraph 4.5 - it appears as if the proposed development is contrary to the 'Tall Buildings inBristol City Centre' policy, which states: "Tall buildings are those that are significantly taller thantheir neighbours and/or significantly change the skyline. Within the city centre, backgroundbuildings tend to be 4-6 storeys high and a tall building would therefore be in the region of 9 ormore storeys. Due to their impact over a wide area, proposals for tall buildings require carefulassessment against Policy BCS21 of the Core Strategy and Policies DM26, DM27, DM29 andDM30 of The Site Allocations and Development Management Polices." I can find no evidence thatthe proposed development conforms with the policies summarised above;- Paragraph 4.6 - agree that the former Temple fire station site is included in the in the BristolCentral Area Plan (2015);- Paragraph 4.7 - SPD3 outlines the 'Vision for Redcliffe': "A sustainable neighbourhood ofcompact, mixed-use development that is human-scale, accessibility to all and respectful of thearea's history and character." There is simply no way that the developer has demonstrate that theproposed development is in any way respectful of the area's history and character;

- Paragraph 8.3 - why did the author not take the opportunity of determining the use of rooms onthe sixth and seventh floors of Templebridge Apartments which are referenced in the report as'unknown'. There are habitable rooms at least on the sixth floor which will be impacted by theproposed development and not including these in the analysis makes me question if the report isfit for purpose given that it does not demonstrate the effect that the proposed development willhave on Templebridge Apartments as a whole;- Paragraph 10.14 - perhaps the author would be kind enough to outline the circumstances underwhich the BRE guidelines would not be strictly applied?- Paragraph 12.1 (7) - the majority of affected rooms within Templebridge Apartments arebedrooms with the BRE Report states are 'less important' than other habitable rooms - I reiteratemy earlier point that I believe the author has failed to identify habitable lounge room windows onthe western elevation of Templebridge Apartments which will be impacted by the proposeddevelopment; and- Paragraph 12.1 (7) - A number of existing occupiers of Templebridge Apartments use the 'spare'bedroom as a study, a point that the analysis fails to identify. I also consider that the constructionof the proposed 'tower' will impact upon the levels of natural from which habitable lounge roomsfronting the north elevation of the building will benefit from, something that has not been identifiedby the analysis.

I am somewhat at a loss to understand why the author makes repeated reference to thehypothetical scenario of Templebridge Apartments being constructed post the redevelopment ofthe former Temple fire station site, as this is not a material concern. Templebridge Apartmentshave been occupied since March 2009 and the analysis really does need to focus on thesignificant impact the proposed development will have on the level of natural light habitable roomswithin Templebridge Apartments benefit from, to the detriment of the physical and mental healthand well-being of existing and future occupiers.

Continued reference to whether Templebridge Apartments would have been designed differently ifthe block had been constructed post-redevelopment of the former Temple fire station site appearsto have no relevance to the planning application currently being determined by BCC.In summary, the Daylight and Sunlight Analysis concludes that a number of habitable rooms withinTemplebridge Apartments will be impacted by the proposed development, reducing natural lightinglevels below the minimum recommended by BRE. The justification for this is that the existingresidential block currently benefits from 'good or well over and above the average levels' which issimply outrageous.

The reduction in the level of natural light to habitable rooms within Templebridge Apartments willbe to the detrimental physical and mental health and well-being of existing and future occupiers.

I consider that the Daylight and Sunlight Analysis fails to identify existing lounge windows on thewestern elevation of Templebridge Apartments and does not consider the effect on these rooms ofthe forecast reduction in the level of natural light. I also consider that the report fails to identify the

effect the reduction in natural lighting levels will have on habitable rooms which front the northernelevation of Templebridge Apartments.I would respectively suggest that the justification of the forecast impact on the natural lightinglevels from which habitable rooms within Templebridge Apartments currently benefit, together withthe numerous omissions from the report, are suitable grounds on which the application beingdetermined by BCC should be recommended for refusal.

Transport StatementThe following observations are made having reviewed the Transport Statement (TS) prepared byKey Transport Consultants referencing their paragraph numbers:

- Paragraph 1.1 - given the scale of the proposed redevelopment, I am somewhat surprised thatBCC highway officers consider it appropriate that the application is supported by a TransportStatement (TS) rather than a full Transport Assessment (TA). I would have thought that therequirement for a full TA which considers the effect of additional vehicular trips generated by theproposed development would have on an already saturated local highway network would havewould have been communicated to the applicant during the pre-application enquiry stage;- Paragraph 1.2 - indicates that the proposed office use will be split over eight floors, however, itfails to identify the number of floors over which the proposed residential use will be split;- Paragraph 1.2 - it is noted that 43 off-street car parking spaces will be provided for the proposedoffice use, at a ratio of one space per 33m2, and that 15 off-street car parking spaces will beprovided for the proposed residential use, which includes the provision of six spaces for thededicated use of blue badge holders. It is noted from paragraphs 8.4 and 8.6 that the proposednumber of off-street car parking spaces for both the office and residential uses are below themaximum standard required by BCC's adopted parking standards, however, the reason why thedeveloper considers the proposed number off-street to be satisfactory is unclear;- Paragraph 1.2 - the TS provides no information on whether the proposed off-street car parkingspaces for both the office and residential will be available on a first-come-first-served basis, orwhether they will be allocated, which is a really important point. If they are available on a first-come-first served basis, drivers who arrive at the proposed development site after the car park isfull will trawl the local area in search of a vacant on-street car parking space to the detriment of airquality. This conflicts with the stated aims of BCC to improve air quality in central Bristol, to theextent that the authority is in the early stages of designing and implementing a Clean Air Zone(CAZ) whereby polluting vehicles will be charged to enter the CAZ zone;- Paragraph 1.2 - allocating the proposed off-street spaces for both the office and residential useswill not prevent more vehicles arriving at the proposed application site than can be accommodatedwithin the car park, again to the detriment of local air quality;- Paragraph 1.2 - assuming that the proposed off-street car parking provided for the residential useis allocated, the TS provides no indication as to where parking activities associated with theremaining 303 residential units will be accommodated. There is limited on-street car parkingcapacity in the vicinity of the application site and I note that the applicant actually proposes toreduce the existing number of on-street car parking provision in order to provide a three-metre

wide segregated cycleway along the north side of Counterslip, between its junctions with TempleStreet and Temple Back;- Paragraph 1.2 - the TS makes no reference to the fact that future occupiers will not be eligible toapply to BCC for on-street parking permits and there is very limited publicly available off-street carparking available within a comfortable walking distance of the application site;- Paragraph 2.1 - identifies that the area is predominately occupied by commercial offices, butbuildings have a number of other ground floor uses. The TS fails tom identify that there are anumber of residential buildings in the area, including Templebridge Apartments;- Paragraph 2.2 - it is unclear why the applicant proposes to reduce the existing 70 basement carparking spaces to a total of 58;- Paragraph 2.26 - are any highway improvements proposed at the Water Lane / Temple Backjunction where a cluster of collisions involving cyclists has been identified?- Paragraph 2.29 - are any highway improvements proposed at the St Thomas Lane East / VictoriaStreet junction where a cluster of six collisions in 36-months has been identified?- Paragraph 3.17 - the existing traffic signal-controlled crossing across Counterslip is a Toucancrossing not a Puffin;- Paragraph 3.17 - states that the existing signal-controlled crossing will be relocated onto a speedtable proposed to be constructed for the whole of the Counterslip / Temple Street junction. Thereason for the proposed raised speed table has not been stated and suggests that there is anexisting problem with the speed of vehicles using Counterslip, however, the recorded 85thpercentile speed is not included within the TS. I am interested in the design of the proposed raisedspeed table as constructing it to the top of the existing full-height kerbline will place vulnerableroad users in direct conflict with motor vehicles;- Paragraph 3.17 - I would also be interested to understand if BCC officers support theconstruction of the proposed raised speed table, including assuming responsibility for its futuremaintenance;- Paragraph 3.17 - Counterslip is a strategic route for the emergency services and vertical trafficmeasures have the potential to exacerbate injuries to patients being transported to hospital byambulance, especially those with spinal injuries and have the potential to have a detrimentalimpact on the response times of the emergency services. When local service bus routes are eitherblocked or closed, Counterslip provides a temporary public transport route and there is evidencethat vertical traffic calming measures cause injury to bus drivers and passengers, especially thoseon the top deck of a double-decker vehicle;- Paragraph 3.5 - should be expanded to confirm if the off-street car parking spaces associatedwith the proposed office use will be available on a first-come-first-served basis or if they will beallocated;- Paragraph 3.7 - as with paragraph 1.2, this paragraph fails to identify the number of floors overwhich the residential units will be split;- Paragraph 3.8 - confirms that the 'Build to Rent' residential units will be served by a singlepedestrian access from Counterslip which has the real potential to cause noise and disruption toexisting residents at all times of the day and night where none currently exists. I would beinterested to see the observation of Avon and Somerset fire brigade with regards to a single point

of access serving 252 residential units;- Paragraph 3.8 - I would also be interested to understand any concerns raised by Avon andSomerset fire brigade with regards to a single point of pedestrian access serving the proposed 66affordable residential units;- Paragraph 3.10 - should be expanded to confirm if the off-street car parking spaces associatedwith the proposed residential use will be available on a first-come-first-served basis or if they willbe allocated;- Paragraphs 3.12 to 3.24 inclusive provide a summary of proposed highway works; however, theplanning application is not supported by a Stage 1 Road Safety Audit in accordance with GG119or a 'Response Report' produced by designer. How can a combination of BCC elected Membersand officers provide comment on the suitability of the proposed highway works withoutunderstanding their potential impact on highway safety?- Paragraphs 3.12 to 3.24 inclusive - should BCC elected Members be minded to grant planningpermission subject to the construction of the proposed highway works being a Condition attachedto the planning permission, there is a real possibility that the checking of the detailed designpackage will identify problems with the proposed highway works which mean that the applicanthas secured planning permission that they are unable to implement;- Paragraphs 3.12 to 3.24 inclusive - has any micro-simulation modelling been undertaken whichdemonstrates the effect of the proposed highway works on the operation of the local highwaynetwork. Is it not unusual to see traffic using Counterslip and Passage Street stationary in bothdirections for the full length of both roads, especially during the pm peak period when VictoriaStreet and Temple Way are heavily congested. This also occurs when the M32 motorway is eithervery busy or closed;- Paragraphs 3.12 to 3.24 inclusive - reducing the width of Temple Back and making it one-waynorthbound removes the ability for a fire engine responding to an emergency call to pass anobstruction in the carriageway, be it a parked vehicle or a vehicle which has broken down, whichhas the potential to have a detrimental effect on response times, endangering lives and property- Paragraph 3.13 - the proposed segregated cycleway along the north side of Counterslip,between its junctions with Temple Street and Temple Back, is located to the rear of three maturetrees and across the existing vehicular access to 'Finzels Reach' underground car park. The 'treepits' are constructed from loose material which increases the risk of cyclists becoming unseatedresulting in injury and the presence of the existing vehicular access places vulnerable road users(pedestrians and cyclists) in direct conflict with motor vehicles;- Paragraph 3.14 - is the proposed retained carriageway width of six-metres sufficient to safelyaccommodate opposing vehicles given that Counterslip is a popular route for heavy goodsvehicles, coaches accessing the various hotels in the area and buses when their scheduled routeis closed?- Paragraph 3.17 - the location of the existing Toucan crossing on Counterslip, east of its junctionwith Temple Street, is contrary to national advice and the proposal to make Temple Street one-way southbound rather conveniently addresses this point;- Paragraph 3.19 - I assume that the proposed Zebra crossing will replace the existing centralpedestrian refuse island which has been the cause of a number of collisions. Can the applicant

demonstrate that they are able to achieve the required Stopping Site Distance to the proposedZebra crossing in both directions given the vertical alignment of the carriageway?- Paragraph 3.19 - The TS does not include proposed measures to prevent light spillage from theflashing Belisha Beacons which will be required at the proposed Zebra from causing a nuisance tohabitable rooms on the northern elevation of Templebridge Apartments;- Construction Phasing - it is imperative, should BCC elected Members be minded to grantplanning permission, that all construction activities be accommodated with boundary of the site.During the construction of the Premier Inn hotel and the Aurora office building, heavy goodsvehicles used the east side of Temple Back as a marshalling yard.

Templebridge Apartments residents regularly woke to fine several heavy goods vehicles waitingon the east side of Temple Back with their diesel engines running which prevented us fromopening our windows, which was especially inconvenient during the summer months. Theresidents of Templebridge Apartments reported this to BCC planning enforcement on severaloccasions only to be told that there was nothing they could do, which was simply unacceptable;- Construction Phasing - should BCC elected Members be minded to grant planning permission, Iwould expect one of the Conditions to request a detailed Construction Management Plan (CMP)which must take account of the application site being in close proximity to a number of residentialunits and insist that the applicant abide by the CMP;- Paragraph 4.10 - agree that paragraph 109 of the National Planning Policy Framework February2019 states that "Development should only be prevented or refused on highway grounds if therewould be an unacceptable impact on highway safety, or the residual cumulative impacts on theroad network would be severe." Vehicles trawling the area in search of on-street car park as aresult of the lack of proposed off-street car parking, no Road Safety Audit and no modelling of theeffect of the proposed highway improvements mean that, as things stand, the applicant is unableto demonstrate the effect that the proposed works will have on the local highway network and Iconsider that there are material grounds for officers to refuse the application on highway safetygrounds;- 5. Accessibility to Homes, Shops and Services - this section of the TS fails to identifyaccessibility to local health care, child care or education facilities or that the applicant has been intouch with local providers to determine that they have sufficient spare capacity to accommodatefuture occupiers of the proposed residential units;- Paragraph 6.3 - as predicted when I met Councillor Smith and Councillor Dudd, the applicant hasused TRICS to precure trips rates based upon the number of car parking spaces rather than thearea of the proposed office use and the number of residential units. I have undertaken my ownTRICS assessment on the basis of the area of the proposed office use and the number ofresidential units which is reproduced below:- The TRICS summary above demonstrates that the number of arrivals and departures forecastare significantly more than those forecast by the TS and I therefore question if trip rates based onthe proposed number of off-street spaces is appropriate;- Templebridge Apartments is a prime example where the 22 apartments generate significantlymore vehicular trips during the am peak period, pm peak period and on a daily basis than the 12

off-street car parking spaces provided. This is due to the occupiers of the one-bed apartmentsowning at least one car, despite not being allocated an off-street car parking space, together withoccupiers of a number of the two-bedroomed apartments owning more than one car;- This observation applies to a number of existing office and residential uses in the vicinity of theapplication site;- Paragraph 7.4 - a loading bay is proposed to be constructed on the west side of Temple Back toaccommodate 'day-to-day deliveries', however, the proposed location is directly opposite theexisting pedestrian access to Templebridge Apartments and has the potential to cause nuisanceto existing residents. Given the existing loading only bays to be retained on Counterslip, is theproposed loading bay on Temple Back actually necessary? If it is, could the proposed location bereconsidered?- 8. Parking - I have set out my observations with regards to the proposed off-street car parkingprovision earlier in this section

In conclusion, I consider that there are a number of points which the TS does not adequatelyaddress, which I why I raise an objection to the proposed development on highway safetygrounds. A copy of this letter of objection will be copied to the applicant, the elected Members whorepresent the Temple ward and the local Member of Parliament.

SummaryIn summary, I formally object to the proposed development as a resident of TemplebridgeApartments and on behalf of all the existing owners and occupiers of Templebridge Apartments inmy role as a Director of the management company.

My main objection is to the height and density of the proposed development which will significantlyreduce the existing levels of natural light from which habitable rooms within TemplebridgeApartments currently benefit from. The justification that these rooms currently benefit from "toomuch natural light" is simply outrageous and laughable.

I would respectfully request that the developer has to comply with all of the recommendationscontained within the 'Bristol City Council Urban Living SPD Making Successful Places at HigherDensity' document, especially those which are particularly salient to the effect on TemplebridgeApartments and the local transport and social infrastructure

The planning application is contrary to a number of stated aims and objectives of the 'Future ofRedcliffe - Supplementary Planning Document'.

BCC officer advice in respect of planning application reference 18/04911/F relating to number 21St Thomas Street, Redcliffe was that the proposed increase in the height of the building which hadplanning permission would create a development which is "out of step with the surrounding areaand creating harm to the Redcliffe Conservation Area."

The report continued: "It is further considered by extending the building by five storeys, a greaterdegree of less than substantial harm would be attributed to the setting of the surrounding heritageassets, including a number of Grade II* and Grade II Listed Building."

As the former Temple fire station site is also located within the Redcliffe Conservation Area, wewould expect officers to provide members of the planning committee with consistent advice withregards to the harm the proposed development will create to the Redcliffe Conservation Area.

We would also expect officers to make members of the planning committee aware of the harm thatthe proposed development will have on the existing Grade II* Listed 'Former Tramway GeneratingStation' on Counterslip together with the 'Central Electric Lighting Station' on Temple Back.

It is imperative that BCC officers provide members of the planning committee with consistentadvice with regards to two planning application sites, both of which are located within the RedcliffeConservation Area.

The Daylight/Sunlight Analysis concludes that the construction of the proposed development willreduce the level of natural light from which the five identified habitable rooms within TemplebridgeApartments will benefit from will be below the minimum levels recommended by BRE. This willresult in existing and future occupiers relying on artificial light all day every day to the detriment oftheir physical and mental health and well-being. This is simply unacceptable.

The Daylight/Sunlight Analysis fails to identify existing lounge windows on the western elevation ofTemplebridge Apartments and therefore does not consider the effect that the reduced level ofnatural light will have on these habitable rooms.

The Daylight/Sunlight Analysis does not identify the use of rooms on either the sixth or seventhfloor of Templebridge Apartments therefore it does not consider the effect on the reduced level ofnatural light will have on these habitable rooms.In short, the Daylight/Sunlight Analysis is essentially incomplete and does not demonstrate howTemplebridge Apartments as a whole will be impacted by the significantly reduced levels of naturallight. I would respectfully suggest that the Daylight/Sunlight Analysis provides insufficientinformation to allow BCC elected Members and officers to make an informed decision and that theapplication should be refused as it will have a severely detrimental effect on existing residents.

The level of proposed off-street car parking spaces for both the office and residential use is simplyinsufficient and the TS acknowledges that the proposed provision for both uses is below standard.This, coupled with the proposed reduction in the existing number of on-street car parking spacesin the vicinity of the application site, will result in cars trawling the local area to the detriment oflocal air quality. This appears to conflict with the stated aims of BCC to improve air quality incentral Bristol, to the extent that the authority is in the early stages of designing and implementinga Clean Air Zone (CAZ) whereby polluting vehicles will be charged to enter the CAZ zone

The planning application is not supported by a Stage 1 Road Safety Audit, in accordance withGG119, which demonstrates that the proposed highway works are safe. A 'Response Report'prepared by the designer has not been provided.

No micro-simulation modelling has been undertaken to identify what effect the proposed highway'improvements' will have on the safe operation of the adopted public highway.

Forecast traffic generation is based on trip rates derived from the proposed number of off-streetcar parking spaces and not from a combination of the area of the proposed office use and thenumber of proposed residential units. The forecast traffic generation is low when compared to myown assessment and there is no evidence that the existing congested local highway network hassufficient spare capacity to safely accommodate the predicted number of additional vehicle trips.

In short, I consider that the TS submitted in support of the planning application does not providesufficient information to allow BCC elected Members and officers to make an informed decisionand that the application should be refused as it has not been demonstrated that the proposeddevelopment will not result in an unacceptable impact on highway safety, or that the residualcumulative impacts on the road network will not be severe.

Having received formal written notification from Bristol City Council, I have reviewed therevised plans uploaded to the authority's Planning Portal by the applicant on 29th and 30th July2019

Whilst I note that the amended plans 'slim down' the proposed tower and reduce the height of theblock running along the western side of Temple Back, neither the revised plans nor thepresentation to the Redcliffe Residents Action Group (RRAG) given by Gavin Bridge and JoDavies on Monday 5th August 2019 adequately address the material planning considerationsummarised in the addendum to my initial letter of objection, as uploaded to the Planning Portal on6th April 2019

I am therefore left with no alternative but to repeat the addendum to my initial objection in fullbelow for the avoidance of any doubt

I would like to take this opportunity to express both my surprise and disappointment that theapplicant has failed to take account of feedback provided by both local residents and otherinterested stakeholders when revising the plans

Dear Sirs,Since uploading my initial letter of objection to the Bristol City Council (BCC) planning portal, myattention has been drawn to previous planning application reference 18/01890/F, which relates to'The Bell' Public House, 7 Prewett Street Bristol BS1 6PB.

The application sought permission for the demolition of existing buildings to provide residentialdwellings (Use class C3), commercial retail space (Use Class A1) and community facilities (UseClasses D1/D2) with associated landscaping and works.The planning case officer recommended that the application was recommended for refusal, asfollows:

REASONS FOR REFUSAL:

1. Urban DesignThe proposed development, by reason of its siting, scale, massing, urban form and architecturaldetailing fails to contribute positively to the urban character and identity of the area and as suchfails to create or reinforce local distinctiveness. The proposed development is therefore contrary topolicies BCS2, BCS20 and BCS21 of the Core Strategy (2011); policies DM26, DM27 and DM29of the Site Allocations and Development Management Policies (2014); policy BCAP47 of theBristol Central Area Plan (2015) and the provisions of the National Planning Policy Framework.

2. Heritage AssetsThe proposed development, by reason of its siting, scale, massing, urban-form, detailed designand architectural detailing represents harm to both designated and non-designated heritageassets. This includes the Grade I listed St Mary Redcliffe Church, Grade II listed assetssurrounding St Mary Redcliffe, including those on Colston Parade and Redcliffe Parade, and thecharacter and appearance of the City Docks Conservation Area. The non-designated assetsharmed by this development include the Redcliffe Estate and the complete loss of the Bell publichouse. There is a lack of robust justification for the proposed works, or evidence suggesting thatwider public benefits will be secured such that would outweigh the identified harm to the heritageassets identified above. The application is subsequently contrary to guidance contained withinSections 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990; Section16 of the National Planning Policy Framework (2018); policy BCS2, BCS22 of the Core Strategy(2011); and policy DM31 of the Site Allocations and Development Management Policies (2014).

3. Landscaping and loss of treesThe proposed development includes the provision of a substandard landscaping scheme whichwould result in a public realm of reduced quality. The development also includes the loss ofmature trees that currently make a significant contribution to the character and appearance of thearea. As such the proposals are contrary to policies BCS9 and BCS21 of the Core Strategy(2011); and policies DM15, DM17 and DM28 of the Site Allocations and DevelopmentManagement Policies (2014).

4. Residential AmenityThe proposed development, by reason of its siting, scale, massing and urban form would prejudicethe levels of daylight currently experienced by the existing residents of both Corinthian Court and

Magdalena Court. In addition, the proposed development would appear as an overbearing,oppressive structure for these residents. As such the proposals would materially harm theamenities of existing residents contrary to policy BCS21 of the Core Strategy (2011); policiesDM27 and DM29 and the provisions of the National Planning Policy Framework.5. Living ConditionsThe proposed development, by reason of its design to incorporate large numbers of single aspectdwellings, in addition to creating a number of dwellings that fail to meet BRE daylight standards,has failed to provide adequate living conditions for future residents. As such the proposals arecontrary to policy BCS21 of the Core Strategy (2011); policies DM29 of the Site Allocations andDevelopment Management Policies (2014) and the provisions of the National Planning PolicyFramework.

6. Dwelling MixThe proposed development consists entirely of one and two bedroom flats and in so doing fails toprovide any family sized homes. As such the proposals are contrary to policy BCS18 of the CoreStrategy (2011); and policy BCAP3 of the Bristol Central Area Plan (2015).

7. Transport and MovementThe proposed development is unacceptable for the following reasons:

The proposal does not include improved facilities for the bus stop on Somerset Street and itconflicts with the proposed loading bay;- No effective waste collection facilities are provided;- The cycle parking proposals are inadequate;- The loading and servicing facilities are inadequate;- The facilities provided for pedestrians and cyclists are inadequate and would not create anacceptable public realm- The travel plan has not been approved; and- There is no disabled parking on site. 6 disabled bays are required.

For these reasons the proposals are contrary to policies BCS10 and BCS13 of the Core Strategy(2011); and policies DM23 of the Site Allocations and Development Management Policies (2014).

8. Nature ConservationIn the absence of an up-to-date bat survey, the proposed development fails to comply with policyDM19 of the Site Allocations and Development Management Policies (2014) which requires thatdevelopment likely to have any impact upon habitat, species or features which contribute to natureconservation is expected to be informed by an appropriate survey and assessment of impacts

The planning application was refused permission.Whilst not all of the reasons for refusal are applicable to the planning application currently beingconsidered by BCC officers, officers recognised that the "The proposed development, by reason of

its siting, scale, massing and urban form would prejudice the levels of daylight currentlyexperienced by the existing residents of both Corinthian Court and Magdalena Court. In additionthe proposed development would appear as an overbearing, oppressive structure for theseresidents. As such the proposals would materially harm the amenities of existing residentscontrary to policy BCS21 of the Core Strategy (2011); policies DM27 and DM29 and the provisionsof the National Planning Policy Framework."

As per my initial letter of objection, I would ask that BCC officers provide consistent advice whendetermining the planning application for the redevelopment of the former Temple fire station.

I think redeveloping the area is a great idea. As a finzels reach resident I am concernedabout the road capacity - I walk and cycle everywhere and the road network in this area is alreadybusy with aggressive drivers especially at rush hour. Also, please do everything you can to buildthe space around pedestrians and cyclists! Also I think a focus on green space and nature wouldbe of benefit for the area, especially for encouraging a more diverse range of residents (e.g.families). The Finzels Reach buildings have a large number of flats owned by companies whichrent them out through Airbnb for holidays. This massively limits the community atmosphere andhas caused issues with noise. I don't know enough about the legality to know if there is a way tolimit this but if this is possible I think this would massively improve the community feeling in thearea. I recognise the handy location for the station is appealing to tourists and tourists generateincome for the city, but I think the balance is poor in the current Finzels Reach buildings.

The Society responded on the 19th April 2019 to the original planning application. Wehave considered the revisions; our original response remains unrevised.None of the revisions affect our original response. The tower on the corner of Counterslip withTemple Back would overshadow the Templebridge Apartments. The revisions do not mitigate thedisruption that the tower block entrance and layby would cause to the Templebridge Apartmentsresidents.The revisions do not change our view about the impact of the tower rising on two sides from theback of the pavement, its poor relationship with Counterslip and Temple Back and its impact onthe setting of the Grade II* Generator House. Our view remains that if the Council accepts this siteas suitable for a tall building a better site would be on the Counterslip/Temple Street corner whichwould overcome the understandable objections of the Templebridge House residents, would notoverbear the Grade II* listed building and would mitigate its impact from the view from St. Philip'sBridge.

I think the proposal is forward thinking, innovative and just what the area needs, and willfit in with a exciting developing area between thd station and Cabot Circus. It makes provision forwalkers, cyclists etc and is inkeepi ng with the area. ie Finzels Reach etc.

I fully support this thoughtful application as we need new ideas in Bristol. It will benefit the area, iemore customers for local shops, markets etc and bring life to area.

Regards

Tom

This is just a brief note to say that the amendments to the application in July do nothingto address the original grounds of my objection, and those of my neighbours.

As an independent local street food business which takes part in the weekly foodmarket at Finzels Reach we are in support of this development. We have seen a marked increasein sales as the site at Finzels has been developed and this has had a large impact on our owngrowth as a business. From our perspective the development of a brownfield site into a thrivingbusiness and residential area will undoubtedly have a positive effect on our business as well asothers who trade at the weekly market.

I use this statement to reiterate all points in my original objection,(https://planningonline.bristol.gov.uk/online-applications/files/F0FE3382FE101BB8E27A657230B1E130/pdf/19_01255_F-16_TEMPLEBRIDGE_APARTMENTS__TEMPLE_BACK__BRISTOL_BS1_6FS-OBJECTS_FULL_-2072879.pdf) none of which appear to have been mitigated by the revisedproposals.

Whilst a reduction in the overall massing of the proposed development is welcome, in reality therevised plans do nothing to mitigate the overall impact on the existing area, current residents andcommunity.

In addition to my original objection, I wish to add the following.

OVERSHADOWING

The new Daylight Sunlight Analysis Addendum Report itself confirms this position within point 1.2'The results confirm an improvement in comparison with the previous proposals although ouroverall conclusions remain unchanged'. Just to clarify the level of 'improvement' being talkedabout. In the original analysis, the impact on my apartment was:

4th Floor R4 Residential Living Room

Existing Lit Area 100%Original Lit Area Proposed 31%New Lit Area Proposed 37%Meets BRE Criteria NO

4th Floor R4 Residential BedroomExisting Lit Area 88%Original Lit Area Proposed 54%New Lit Area Proposed 54%Meets BRE Criteria NO

In fact, of the 30 windows analysed in Templebridge Apartments, only 6 continue to BRE criteria,all of which face over Counterslip. Every window analysed that overlooks Temple Back fails tomeet BRE criteria in both the original and new proposal.

As well as impacting on the wellbeing and mental health of residents, this also has an environmentimpact. Currently we need to use very little heating in winter, due to the amount of solar gain wehave. We are also able to rely heavily on air drying clothes in doors. The reduction in sunlight willneed us all to use more heating, and electrical drying of clothes.

It's also clear the whilst the revisions to the plans do nothing for the existing community, theyappear to instead be benefiting the proposed development. I refer to the Urban Living SPD DesignResponse, in particular Q3.1

"The 'scoop-outs' along the south eastern and north eastern elevations have been designed toallow light into the central courtyard that serves the development""The design proposed seeks to bring in the morning/midday sun to the development"

IMPACT ON THE LOCAL AREA, EXISTING HISTORIC BUILDINGS & REDCLIFFECONSERVATION AREA

Again, as well as my original objection, I also back the objections and comments made by:

The Redcliffe Residents Action Group & Neighbourhood ForumThe Conservation Advisory PanelHistoric England

All these groups conclude that the area of the proposed development on the corner of TempleBack and Counterslip should be no higher than the existing Generator Building.

I would point out that their comments directly contradict the conclusions in Q3.1 of the Urban

Living SPD Design Response where it states:

"In heritage terms, early pre-application advice from City Design and Historic England indicatedthat siting the tallest element on the corner of Temple Back and Counterslip was the appropriatedesign response""The impressive architectural design of the scheme was considered to sit harmoniously with theGenerator Building."

Also, the 3d modelling used in new Daylight Sunlight Analysis Addendum Report appears to showthat the tower on the corner of Temple Back and Counterslip has increased in size. The originalplans showed this as being 62.07, and the new plans as being 62.93.

LOADING BAY AND NARROWING OF TEMPLE BACK

As noted in my original objection, the narrowing of Temple Back brings the whole developmentcloser to Templebridge Apartments. This combined with the location of a loading bay and mainresidential address causes concern.

Both the loading bay proposed on Temple Back and main building reception are directly oppositethe main living areas for all flats on this side of Templebridge Apartments.

I don't believe any impact assessment has been done on this, so I've been trying to envisage theamount of traffic we can expect idling underneath our living room windows, at all times, inservicing over 200 dwellings. We can expect this include:

TaxisSupermarket delivery vansAmazon/Yodel/Hermes etc. deliveriesTakeaway deliveries.

Hypothetically, let look at supermarket deliveries (with no residents having cars, in Cubex's idealscenario) for just 200 dwellings having 1 delivery a week. With all residents being youngprofessionals, delivery slots are likely to be most popular between 5pm-10pm, Monday to Fridayand 8am-8pm Saturday & Sunday. That's 49 available slots a week, making a mean average ofjust over 4 deliveries an hour. However, some slots are likely to be more popular that others (e.g.6pm-8pm, Monday to Friday). And with numerous supermarkets offering deliveries (Asda,Sainsburys, Tesco, Waitrose, Ocado) we could be seeing up to 5 different vans competing forspace in the loading bay at peak times.

Then we look takeaway delivery services, more popular at the anti-social end of the clock,Thursday, Friday and Saturday nights 8pm-1am. Again, with the target residents being young

professionals, we can expect usage of this to be pretty high. Hypothetically you have just 100dwellings ordering 1 takeaway a week, evenly spread over 7 days this would be approx. 3 an hour,on top of the 4 supermarket deliveries an hour. But in reality, it's more likely to be closer to 7 perhour at peak times.

And now start thinking about all of the online shopping delivery drivers, 200 dwellings making atleast 1 online purchase per week. These deliveries can arrive at any time of day, 7 days a week.

Again, I need to point out that, as currently proposed, all of this activity is taking place directlyopposite and underneath the main living areas for residents of Templebridge Apartments on thisside of the building. Now as well as reducing the daylight in the flats to well below recommendedlevels, residents also have to keep all windows closed to keep out the noise and fumes from allthis additional traffic.

I fully support the need to redevelop this site, and the inclusion of more affordable residentialproperty as being beneficial to the wider area. However, as it stands, the current proposal is toodamaging to the directly affected local community. I would look to BCC to either engage Cubex inwholly reducing the scale of the development in line with the existing Finzels Reach site, or tomoving the larger scale elements to the Temple Street side of the development, away from anyimmediately impacted residential buildings.

Kind regards

Sarah Surridge

I use this statement to reiterate all points in my original objection,(https://planningonline.bristol.gov.uk/online-applications/files/F0FE3382FE101BB8E27A657230B1E130/pdf/19_01255_F-16_TEMPLEBRIDGE_APARTMENTS__TEMPLE_BACK__BRISTOL_BS1_6FS-OBJECTS_FULL_-2072879.pdf) none of which appear to have been mitigated by the revisedproposals.

Whilst a reduction in the overall massing of the proposed development is welcome, in reality therevised plans do nothing to mitigate the overall impact on the existing area, current residents andcommunity.

In addition to my original objection, I wish to add the following.

OVERSHADOWING

The new Daylight Sunlight Analysis Addendum Report itself confirms this position within point 1.2'The results confirm an improvement in comparison with the previous proposals although ouroverall conclusions remain unchanged'. Just to clarify the level of 'improvement' being talkedabout. In the original analysis, the impact on my apartment was:

4th Floor R4 Residential Living Room

Existing Lit Area 100%Original Lit Area Proposed 31%New Lit Area Proposed 37%Meets BRE Criteria NO

4th Floor R4 Residential BedroomExisting Lit Area 88%Original Lit Area Proposed 54%New Lit Area Proposed 54%Meets BRE Criteria NO

In fact, of the 30 windows analysed in Templebridge Apartments, only 6 continue to BRE criteria,all of which face over Counterslip. Every window analysed that overlooks Temple Back fails tomeet BRE criteria in both the original and new proposal.

As well as impacting on the wellbeing and mental health of residents, this also has an environmentimpact. Currently we need to use very little heating in winter, due to the amount of solar gain wehave. We are also able to rely heavily on air drying clothes in doors. The reduction in sunlight willneed us all to use more heating, and electrical drying of clothes.

It's also clear the whilst the revisions to the plans do nothing for the existing community, theyappear to instead be benefiting the proposed development. I refer to the Urban Living SPD DesignResponse, in particular Q3.1

"The 'scoop-outs' along the south eastern and north eastern elevations have been designed toallow light into the central courtyard that serves the development""The design proposed seeks to bring in the morning/midday sun to the development"

IMPACT ON THE LOCAL AREA, EXISTING HISTORIC BUILDINGS & REDCLIFFECONSERVATION AREA

Again, as well as my original objection, I also back the objections and comments made by:

The Redcliffe Residents Action Group & Neighbourhood ForumThe Conservation Advisory PanelHistoric England

All these groups conclude that the area of the proposed development on the corner of TempleBack and Counterslip should be no higher than the existing Generator Building.

I would point out that their comments directly contradict the conclusions in Q3.1 of the Urban

Living SPD Design Response where it states:

"In heritage terms, early pre-application advice from City Design and Historic England indicatedthat siting the tallest element on the corner of Temple Back and Counterslip was the appropriatedesign response""The impressive architectural design of the scheme was considered to sit harmoniously with theGenerator Building."

Also, the 3d modelling used in new Daylight Sunlight Analysis Addendum Report appears to showthat the tower on the corner of Temple Back and Counterslip has increased in size. The originalplans showed this as being 62.07, and the new plans as being 62.93.

LOADING BAY AND NARROWING OF TEMPLE BACK

As noted in my original objection, the narrowing of Temple Back brings the whole developmentcloser to Templebridge Apartments. This combined with the location of a loading bay and mainresidential address causes concern.

Both the loading bay proposed on Temple Back and main building reception are directly oppositethe main living areas for all flats on this side of Templebridge Apartments.

I don't believe any impact assessment has been done on this, so I've been trying to envisage theamount of traffic we can expect idling underneath our living room windows, at all times, inservicing over 200 dwellings. We can expect this include:

TaxisSupermarket delivery vansAmazon/Yodel/Hermes etc. deliveriesTakeaway deliveries.

Hypothetically, let look at supermarket deliveries (with no residents having cars, in Cubex's idealscenario) for just 200 dwellings having 1 delivery a week. With all residents being youngprofessionals, delivery slots are likely to be most popular between 5pm-10pm, Monday to Fridayand 8am-8pm Saturday & Sunday. That's 49 available slots a week, making a mean average ofjust over 4 deliveries an hour. However, some slots are likely to be more popular that others (e.g.6pm-8pm, Monday to Friday). And with numerous supermarkets offering deliveries (Asda,Sainsburys, Tesco, Waitrose, Ocado) we could be seeing up to 5 different vans competing forspace in the loading bay at peak times.

Then we look takeaway delivery services, more popular at the anti-social end of the clock,Thursday, Friday and Saturday nights 8pm-1am. Again, with the target residents being young

professionals, we can expect usage of this to be pretty high. Hypothetically you have just 100dwellings ordering 1 takeaway a week, evenly spread over 7 days this would be approx. 3 an hour,on top of the 4 supermarket deliveries an hour. But in reality, it's more likely to be closer to 7 perhour at peak times.

And now start thinking about all of the online shopping delivery drivers, 200 dwellings making atleast 1 online purchase per week. These deliveries can arrive at any time of day, 7 days a week.

Again, I need to point out that, as currently proposed, all of this activity is taking place directlyopposite and underneath the main living areas for residents of Templebridge Apartments on thisside of the building. Now as well as reducing the daylight in the flats to well below recommendedlevels, residents also have to keep all windows closed to keep out the noise and fumes from allthis additional traffic.

I fully support the need to redevelop this site, and the inclusion of more affordable residentialproperty as being beneficial to the wider area. However, as it stands, the current proposal is toodamaging to the directly affected local community. I would look to BCC to either engage Cubex inwholly reducing the scale of the development in line with the existing Finzels Reach site, or tomoving the larger scale elements to the Temple Street side of the development, away from anyimmediately impacted residential buildings.

Kind regards

Sarah Surridge

As a local business owner I fully support the planning application. The development ofthis area has already opened many local business opportunities and greatly improved the area inevery way.

Some of the reasons to approve the application;

- Redevelop a brownfield site, currently a local eyesore;318 new homes - including 21 per cent (66) high-quality affordable apartments, all with balconies;- High-quality market rented apartments, with secure, long-term tenancies available, owned andmanaged by a single, professional company;£2.6M investment in public spaces, including 'pocket parks' for existing and new residents;- Prioritising people over cars: the first works to be undertaken will include: reducing Temple Backto one way traffic, making it safer and cleaner; improvements to cycle and pedestrian routes;reduced car parking levels and providing lots of secure bike storage spaces;- Rooftop terraces and shared social/work spaces for residents, to help support wellbeing andsocial integration;- A 116,000 sq. ft, high-quality, energy-efficient office providing more jobs for local people.

I am in full support for the proposed re-development of the Old fire station. Currently thelocation looks derelict and the new development would not only bring additional jobs to the area,but also help the traders around the location (me being one of them).

As an ex-pat Bristolian, it's this kind of development and it's densification of centralBristol which is likely to draw me back to my home city. The developer has good form in theadjacent finzel's reach development and can obviously be trusted to create a high qualitydevelopment here. It's height and massing are commensurate with its central city location and itoffers a vast improvement on the wasteland that I grew up with in this part of Bristol. As part of thecoherent plan for Redcliffe that is now(finally after all these years) funded and being brought tofruition, we can finally start to imagine a future where central Bristol is returned to its pre SecondWorld War levels of activity. It's been a long wait; don't dither, approve!

The proposed mix of uses will obviously be a significant improvement for the use of thecurrent site and will bring much needed affordable housing to this key, central Bristol area.

The landscaping and public realm works will contribute positively to the area and add to thealready great sense of community that Finzels Reach brings.

Cubex have a strong track record in Bristol - they're continuing to support the localcommunity and should be supported with this application.

In total support of this development.

1. Importantly will get the site developed. There are too many stalled sites due to minor issuesaround Bristol which need to be kickstarted & refinanced etc which is always difficult meaningthere's a danger of sites becoming "Castle Park"-esque.2. Will provide much needed housing in Central Bristol.3. Finally a scheme thats not only for Students.4. Jobs being created as its a Mixed use development.5. Development, Noice, traffic etc although potentially annoying is in the nature of fast moving andgrowing cities. What were you expecting???6. If we bypass these opportunities to build higher/denser schemes to provide more space then wewill have no option but to start building on Greenbelt land which we have unfortunately alreadystarted to do. :-(7. Bristols skyline could do with a lot more height, especially in Central areas. I mean Its not likethey're building a 50 story tower, although I would welcome that too... ;-)8. Cubix have a decent track record of delivering projects in Bristol and I believe they have takenon some complex sites including Finzels Reach area which is encouraging.9. I want to live in one of the Apartments once they're built! :-)

For Clarity... I'll be able to see parts of this development from where I live but also I work onVictoria Street so walk/ride past this site 4 times a week. It desperately needs to be developed likemany other sites in Bristol.

Planning Application: 19/01255/F - Redevelopment of Former Temple Fire Station

The Redcliffe Residents Action Group and Neighbourhood Forum is the recognisedNeighbourhood Planning Group for Redcliffe.

While the redevelopment of the former fire station site is to be welcomed, we write with concernand to object to the current proposals.

There are a number of failings with the current proposals, including most critically:

- The failure to restore a proper urban grain and character to this important conservation area. Inparticular, the scale, height and massing of the blocks are inappropriate to the area, which aregenerally between 5-9 storeys.

- The failure to create an urban texture and permeability is particularly disappointing, with nothrough access provided through the site and very miserly provision of amenity and green space.The lack of a public route through the site goes against SPD3, The Future of Redcliffe.

- The impact of the scale and height of the building will be unacceptably negative on neighbouringbuildings - both surrounding residents in terms of loss of light and overshadowing, and on theGrade II* Listed Generator Building by dominating it. The over-bearing nature of the buildings willalso negatively hinder creating a positive and welcoming streetscape atmosphere for pedestrians.

- The design combines being over-bearing (due to its scale) with being bland and characterless.The development will do little to build place-making value in the area.

There are good examples of developments that combine density with humane scale, characterfuldevelopment. The Government's Building Better Building Beautiful Commission - just published -urges council to reject low quality developments and ensure places, not just housing units, aredeveloped. Bristol can and should demand better from this important development site.

Yours sincerely,

Yvonne LongChairRedcliffe Residents Action Group & Neighbourhood Forum

Redevelop a brownfield site for all the community and visitors to enjoy.

I am very concerned about the consultation undertaken by Cubex in the development ofthe plans for this site. From information I have had from a representative of Cubex, it would bebest described as "token" consultation, and certainly no effective consultation with the localcommunity affected by the current application.

I have had confirmation in an email sent on 4 July at 0903 from Andrew Smith, the PR manengaged by Cubex to interface with residents of Templebridge Apartments, that Cubex onlycarried out what to me seems the absolute bare minimum of public consultation.He has confirmed that Cubex carried out as public consultation:1. one open public consultation event on 11 December 2018 in Finzels Reach

In addition to that we as "neighbours" of the site have had1. one meeting with Andrew Smith and Elgan Jones of Cubex (believed to be a director) on March25 20192. one with other representatives of Cubex on 16 May, which was summed up by Gavin Bridge ashaving found "no common ground"3. one with a representative of the Daylight/Sunlight report authors on 14 June 2019.

The first time we knew of any proposed development of the site was in June 2018 from generalpublicity in the local press that showed a very different scheme from the one in the presentapplication (see links below).

This consultation would not seem to meet the recommendation in the Urban Living SPD raisedfrom Question 1.2: "Does the scheme contribute towards creating a vibrant and equitableneighbourhood?"The recommendation is:"We recommend a) Early and sustained community consultation to establish local aspirations,needs and priorities for the area, using this information to inform the brief for the scheme, and itsdesign evolution. Such an approach can build community support for a more intense form ofdevelopment, if time is taken to show the wider benefits, and dispel fears about higher densities(Gainsborough Square in Lockleaze being a good example)"

I hope this information helps to explain why we so strongly oppose this present scheme

Link to press release:From Bristol 24/7 July 2018https://www.bristol247.com/news-and-features/news/136m-scheme-planned-for-former-fire-service-hq-in-bristol/Palmer Capital press release June 2018https://www.palmercapital.co.uk/investment/cubex-buys-former-fire-station-headquarters-site-in-bristol-for-mixed-use-scheme/

Collectively the residents of Templebridge Apartments have engaged a professionalDaylight/Sunlight specialist to review the Daylight/Sunlight report submitted by the developer aspart of the application. The results of that review have been provided to the Planning Case Officerand are below:

THE FORMER AVON FIRE AND RESCUE SITE, BRISTOL BS1 6EU - 19/01255/FI have been instructed by the residents of Templebridge Apartments to review the potential impactof the proposed development at the above site upon the daylight and sunlight amenity currentlyenjoyed by their properties.I have reviewed the technical analysis carried out by Rapleys, for Cubex Land Limited in March2019 and compared the results with the relevant planning policy outlined by Bristol City Counciland set out my findings as follows:Rapleys Technical analysisWe have not carried out technical analysis of our own. I have relied upon the results of theanalysis carried out by Rapleys. I have been supplied with typical floor layouts of the of theTemplebridge Apartments and note that the Rapleys assessment is mostly correct, however it hasexcluded the kitchens to the rear of the R5 on each floor. If the rooms were assessed correctly,with the full extent of the rooms included, the daylight distribution results would be greatly reduced.I have included a plan of the rooms with this letter. (Unable to include here)The results of the technical study clearly indicate an impact upon the daylight and sunlight amenitywithin the building that it is beyond what would be considered acceptable when considered in linewith the guidance set out by the BRE guide, that is used as a reference within the report.

Daylight - Vertical Sky Component and Daylight DistributionOn each floor within the building, all rooms and windows which face the site will experiencereductions in VSC and DD significantly beyond the levels set out in the BRE guide.For VSC, the BRE states within its guidance that:"If the VSC, with the new development in place, is both less than 27% and less than 0.8 times itsformer value, occupants within the existing building will notice the reduction in the amount ofskylight. The area lit by the window is likely to appear more gloomy and electrical lighting will beneeded more of the time."The report shows that of the windows facing the site, ALL will experience reductions in VSC levelsof between 39% to 88%, significantly beyond the maximum 20% recommended in the BREguidance. Many of the larger reductions occur on the upper floors to the kitchen/living room areas,which have a greater expectation of natural light, as set out in the BRE.All the windows which fail the analysis (with the exception of two) will be left with VSC values ofless than 15%, which according to s2.1.6 of the BRE guide will leave the room with light levels thatwill be "very difficult to provide adequate daylight...".In terms of daylight distribution, the BRE also states its recommendations as:"If, following the construction of a new development, the no sky line moves so that the area of theexisting room, which does receive direct skylight, is reduced to less than 0.8 times its formervalue, this will appear noticeable to the occupants, and more of the room will appear poorly lit."As can be seen from the results in the report, the impact upon all the rooms facing the site will failthis test, in most cases, quite severely - one room, at sixth floor level, will experience an 87%reduction in the visible sky line area with the proposed development in place. None of the singleaspect rooms facing the site will enjoy DD levels above 55% - significantly below the 80% targetrecommended by the BRE.I acknowledge that the BRE suggests that the guidelines must be applied flexibly, but it is clearfrom these results that the impact upon Templebridge Apartments is beyond that which could beconsidered "satisfactory" or "deemed acceptable", as stated within the Rapleys report. Clearlythere will be reductions in the amenity currently enjoyed by the residents within the building that,we suggest, are not in keeping with flexibility suggested in the BRE guide, nor with the LocalPlanning policy.Furthermore, the BRE guidance also sets out methods of setting alternative methods of targetvalues in Appendix F of the guide, for situations such as this, none of which have been explored.Whilst we have not carried out any additional analysis, I would suggest that the overbearingmassing of the scheme, which is directly in front of one of the few residential areas surroundingthe site, would not meet any of them. In particular the 'mirrored massing' study, or the AverageDaylight Factor assessment, which takes into account the room layouts and sizes (and has beencarried out within the proposed scheme).The Templebridge Apartments, being relatively recently constructed, have clearly been designedwith the daylight and sunlight amenity to its future residents in mind. The impact upon this from theproposed development at the Former Avon Fire and Rescue Site is, in our view, beyond that whichcould be considered acceptable when considered against Local Authority policy.I hope the above is clear. Should you have any queries, please do not hesitate to contact me.

Yours sincerely

Richard Howard MScAssociateWatts Group Limited

This is a great idea , will create so many residential and office opportunities within thecity centre. Help the community grow and make use of wasted space.

While the idea of more housing and office space I am aligned with, I object to thisdevelopment on the grounds that a 15 story building is far too excessive.

The area around this development is already reasonably sunlight challenged, and a massive 15stories would make this significantly worse.

In addition, this area is already very strained from a parking and traffic perspective and thisdevelopment will take the area far beyond the breaking point.

The communication with local residents, as brought up in other objections, has also beensignificantly lacking. Which seems to be ticking the minimum amount of boxes rather than actuallytrying to understand the local area to improve it with this development, rather than making themost amount of profit.

It is a shame, as the previous development next door by Cubex fits into the area much better, andI would fully support a development of a similar calibre as this.

I am the founder of Finzels Reach Street Food Market and have been working on thesite at Finzels Reach on a weekly basis for over 2 years. I have seen the development grow frombeing a building site to a vibrant, bustling and community focused destination. This transformationhas been predominantly down to the efforts of the developers Cubex who have passionately seenthrough their vision often putting the community and residents first over their return on investment.I have full confidence that their plans to develop the Avon Fire And Rescue Service Headquarterson Temple Back will be another successful and carefully thought out development.I'd also like to make the point that having more people on site due to the new proposed flats andoffices will generate more footfall to our weekly market and therefore will financially support all thelocal businesses involved in the market. Most of our traders are very small businesses who's soleincome is generated by the sales they make at local markets and therefore are dependent on thesuccess of the market to survive.

Cont/d..

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The 1 in 200 year 2110 modelled flood level from the Central Area Flood Risk Assessment model is 10.2 mAOD. In the FRA it states ‘These values combine a 1:200 year tidal level with a 1:10 year fluvial level in both the River Frome and River Avon, and are therefore considered to have an in-built level of freeboard above the tidal 1:200 year level’. Freeboard for uncertainty also needs to be considered as current model levels are to 2110 not 2119 (100 year lifetime) and do not reflect the full suite of climate change allowances: https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances The FRA states that resilience and resistance measures will be considered where floor levels are not planned to be raised further to provide active frontages. In view of the potential flood risks in this locality, we would advise that any developer of this site gives consideration to the use of flood resilient construction practices and materials in the design and build phase. Choice of materials and simple design modifications can make the development more resistant to flooding in the first place, or limit the damage and reduce rehabilitation time in the event of future inundation. Detailed information on flood proofing and mitigation can be found by referring to the CLG free publication 'Improving the Flood Performance of New Buildings'. See the link below: http://www.planningportal.gov.uk/uploads/br/flood_performance.pdf. Page 9 outlines that above 0.6m buildings should be designed to flood. Therefore a combination of resilience and floor level raising needs to be considered. Overcoming our objection It may be possible for the applicant to overcome our objection by submitting information to the local planning authority, which addresses the matters raised in this letter to our satisfaction. We first need to understand whether the Local Planning Authority are willing to accept a 75 year design life for the “More Vulnerable” elements of the scheme. This should be confirmed to the Agency in writng. The FRA should be revisited and a combination of finished floor levels and resistance and resilience measures utilised to mitigate flood risk to 2079 (commercial) and 2119 level (residential). The layout of the residential units on the ground floor should be reconsidered. This could include the provision Maisonettes e.g. relocating some of the two bedroom units down to a lower floor and creating duplex accommodation with no sleeping accommodation at ground floor. Or the relocating of all ground floor units to a higher floor. We advise information addressing the above points should be submitted directly by the agent to the local planning authority. We will provide bespoke comments within 21 days of receiving your formal re-consultation. Note to Local Planning Authority We advise that Bristol City Council, as the Lead Local Flood Authority, should be consulted on the surface water drainage requirements for the proposed development. The Local Authority Emergency Planner should be consulted on a Flood Warning and Evacuation Plan for the proposed development. If you are minded to approve the application contrary to this advice, we request that you contact us to allow further discussion and/ or representations from us in line with the Town and Country Planning (Consultation) (England) Direction 2009. A copy of this letter has been forwarded to the agent.

End

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Please do not hesitate to contact the undersigned direct should you have any queries. Yours sincerely Mark Willitts Sustainable Places - Planning Advisor cc Avison Young Ltd

This looks like a brilliant development and should be encouraged.

The mixed use element is exactly what the area needs and looks very well designed to fit in withthe surrounding area.

In Bristol City Council "URBAN LIVING SPD Making successful places at higherdensities" there is a recommendation in Question 1.2: "Does the scheme contribute towardscreating a vibrant and equitable neighbourhood? ". This states:"We recommend a) Early and sustained community consultation to establish local aspirations,needs and priorities for the area, using this information to inform the brief for the scheme, and itsdesign evolution. Such an approach can build community support for a more intense form ofdevelopment, if time is taken to show the wider benefits, and dispel fears about higher densities(Gainsborough Square in Lockleaze being a good example)"There has been very little consultation known to me. What is known to me would not meet areasonable reading of the recommendation for "Early and sustained community consultation".

Part 2 of the Design & Access statement posted in the BCC Planning portal for this developmentshows a time line, and the only public consultation shown is on Page 35 as the single publicconsultation on 11 December 2018.All other consultations are with specialist bodies; not the community in what would seem thenormal meaning of that word.Other community consultation may be listed in the documents submitted by the developer, but Ihave not been able to find them, and the developer has not provided further details despite arequest to their nominated contact

The only consultation known to me is:11 December 2018 - public consultation

25 March 2019 - Andrew Smith & Elgan Jones of Cubex - first direct contact with residents ofTemplebridge Apartments, although the Daylight/Sunlight report was initiated in March 2018, andthe effect on Templebridge Apartments must have been obvious from then16 May 2019 - Residents of Templebridge Apartments met with representatives of Cubex14 June 2019 - Residents of Templebridge Apartments and Milliners Court met with Mr D Tapscottof Rapley, the consultants who wrote the Daylight/Sunlight report submitted by the developer

- Traffic at peak times is already an issue. There hasn't been any mitigating solutionsprovided in our vicinity. Metro bus been a failure and adding more cars/people into an alreadybusy area doesn't seem like a prudent idea. The assumption that city centre dwellers do not own acar is not accurate.

- In our development (Finzels Reach) we have already been living on a building site for the last 2-3years with dust, noise and disruption, so the thought of this extending for another 3-5 years is veryconcerning. Cubex track record is poor, they haven't hit any of their deadlines on our developmentand provided a sub-standard build quality to residents. So whatever they are suggesting for thisnew venture should be taken with a commercial dump truck pinch of salt.

I welcome any further discussion on these points through the details I have provided and lookforward to hearing from you.

I've not got anything about development on the site, but I don't want for the builders tobe given dispensation to work evenings and weekends.

There has been a lot of building work around Finzels Reach for the last few years and the counciloften granted site access in antisocial hours (bank holidays and weekends, starting early, finishinglate).

I just want for the construction to be considerate of the neighbors who live right next door.

As long as the impact will not effect access to the main routes to motorway by car thena new affordable central flag complex is a good idea. Carless flats is a great idea

There is already too much building work happening in this area which has beendisrupting the residents and has gone on for much longer than initially promised.As it stands there is not enough parking spaces and I believed it will become overcrowded withfurther construction.

As follow up to my previous comment on the public participation process would updateas below following an email exchange with Andrew Smith at ConversationPR;

The Milliners consists of 109 residential units in very close proximity to the proposed developmentand I find it totally unacceptable that the 'distribution agents' apparently gave up when they wereunable to gain access to distribute notifications of the participation process. For information aManaging Agent sign is clearly displayed at our main entrance with FULL contact details. We havereceived previous mail notifications for less impactful development proposals (e.g. 21 St ThomasSt and Temple Meads Campus) so why was more effort not made on this occasion?

For the record The Milliners is not included in documents relating to this proposal on the BristolCity Council (BCC) website documents 'Neighbour Notification List' (posted 18th March 2019) and'Statement Of Community Involvement prepared by Avison Young Section 3 Public ConsultationEvent 3.2 Diagram' (posted 12th March 2019) which shows The Milliners outside of the area forleaflet distribution.

We have seen a GPS document of proposed drop zone which includes The Milliners but is of littlerelevance as it appears the delivery agents did not make anything beyond a token effort to fulfil the'obligation'.

On the matter of public participation we now feel that the 'horse has bolted' as we were not notified

of the 'Public Exhibition' and were effectively excluded from the subsequent discussions until weheard about the proposal via a news bulletin from our local Councillor on June 2nd 2019.

At present I am of the firm belief that the public participation process applied is seriously flawedand am acutely aware that the matter goes before BCC for a decision on the 10th July.

Whilst I support the redevelopment of the buildings in principle, the proposed structureis out of keeping with the surrounding area, is of poor aesthetic value and is overbearing andimposing in its size. Such a development would not improve the character of the area, making itfeel more harsh, generic, darker and more enclosed.

Objection and suggested mitigationI feel that the plans do not make any attempt to meet the expectation in the Urban Living SPDpage 30 Section 1.5This asks:Does the scheme deliver a comfortable micro-climate for its occupants, neighbours, and passersby?B Providing a fair and equitable share of sunlight and daylight between existing occupants andneighbouring buildings & the future occupants of the scheme (see Appendix B)

The plans show concern for a fair and equitable distribution of light into the court yard within thedevelopment by reducing the building height on the Water Lane elevation to "allow increased lightinto the shared courtyard space" - see Page 51 of Part 2 of the Design and Access Statement.

However, the current plans show no concern for the severe reduction in light that will beexperienced by the Temple Back elevation of Templebridge Apartments.

A meaningful mitigation consistent with the normal use of the word; "the action of reducing theseverity, seriousness, or painfulness of something", would be to apply a similar reduction inbuilding height opposite Templebridge Apartments as applied to the Water Lane elevation tobenefit the daylight in the courtyard of the development. This would improve the daylight reachingTemplebridge Apartments

Review of the Daylight/Sunlight analysisThe Daylight/Sunlight analysis produced in March 2019 (DAYLIGHT SUNLIGHT ANALYSISREPORT - PART 1 on the planning portal for this development) in Section 8 states the number ofwindows meeting BRE guidelines, but the corollary is that the others won't.

Considering those that won't meet BRE guidelines, shows that:30 out of 37 windows fall below the Vertical Sky Component values24 out of 31 windows fall below the Daylight Distribution valuesThe first four floors of 6 habitable floors will experience an unquantified impact on sunlight amenity(Annual Probable Sunlight Hours)

The report offers in mitigation of this that:The site upon which Templebridge Apartments was constructed, along with the fire station, wasincluded within SPD3 Future of Redcliffe, published in 2006 as 'Development Opportunities'While this is accepted as probably an accurate statement of the 2006 SPD, this was an aspirationrather than a commitment, and the fire station continued in active use until about 2016/7. Inaddition, at that time, the SPD expected that development in the Redcliffe Conservation Areawould be consistent with its stated vision of "human scale" development. In the currently availableversion this is:Vision - "A sustainable neighbourhood of compact, mixed-use development that is human-scale,accessible to all and respectful of the area's history and character"Human scale is defined on Page 72 of the SPD as ""the use within the development of elements,which relate well in size to an individual human being, and their assembly in a way which makespeople feel comfortable rather than overwhelmed."In 2006, most development in Bristol city centre was between 6 and 8 storeys.The present plans for 11 storeys and a tower block of 16 storeys is not consistent with that.

This leaves the impression that the report is selective in the criteria it chooses to apply.

A senior representative of the company who signed the report admitted during a site meeting thathe had been approached casually during work in the area around 2008/9 by a member of the Fireand Rescue service who enquired if he knew of any organisation looking for a development site.This may or may not have influenced the choice of this "mitigation".

The 12 listed "mitigations" in Section 12 of the report do not reduce the severity, seriousness orseriousness of the daylight loss to Templebridge Apartments and at best seem to be justificationsof the acceptability of the loss to support the report

Amazing developer, will make an eye sore into an amazing building that is needed!(From a local restaurant owner)

I own a property in the Milliners facing Victoria Street. The proposed tower is higherthan 1 Redcliffe St which an internet search indicates is 60m. The 'width' of the tower structure isestimated at 26m and the 12 storey office block structure will also be prominent on the skyline fornearly all Milliners properties facing Victoria Street. The scale of the development is totallyinappropriate for this location in a Conservation Area particularly when there is already so muchdevelopment happening. I would like to object to the proposed plans.

I fully object to this building due to the sheer size of it and all the knock on issues thatwill cause. Its already extremely congested with cars around this area and there is very limitedstreet parking as it is. The development of Redcliffe quarter will have already added to that, so ifthis goes ahead it will be even worse. The height of the building will block out sunlight for so manyapartments around and have a seriously detrimental affect on the quality of living in this area. Itwont be affordable family housing, or the type of living to attract a range of different people andages. Instead it will probably be young office workers who will soon move on to bigger houses andhave no interest in the community or engaging with the area. It also goes so against the otherbuildings in the area and does not even try to fit in with the surroundings. There seems to havebeen very little public consultation (we only heard about this from another resident in our building)and i can only see businesses benefitting from this building, and they are not the ones living hereday to day.

Object to this proposal not only for the reasons outlined in my husbands previoussubmission but due to the additional fact that as owners at The Milliners we did not receive formalnotification of the intended development.

We therefore have been excluded from various stages of the public participation process (this isconfirmed in the 'Statement Of Community Involvement' produced by Avison Young in March 2019under section 3 'Public Consultation Event' where under section 3.2 The Milliners is set outside ofthe 'flyer distribution area' in the graphic despite The Milliners comprising a 109 residential unitswhich will be negatively impacted by the proposal being in direct line of vision and less than 100meters from the proposed development site). This exclusion of The Milliners is also noted in thedocuments listing attached to this link.

This is contrary to good practice and other recent applications such as the student accommodationSt Thomas St and even the proposed campus at Temple Meads (both of which, despite being lessimpactful on The Milliners owners, gave full postal notification including the opportunity to attend aworkshop).

I would suggest that the lack of notification invalidates the application as ALL owners at TheMilliners will be affected by such a major development on the Fire Station site particularly thosefacing Victoria Street, upwards of 50 units, whose views and daylight will be negatively impacted.

I therefore object to the proposal, in its present format, and would suggest the Developer revisit

the plans decreasing height/density, respecting the needs of existing residents, giving furtherattention to the Redcliffe Conservation Area guidelines (with reference to the Bristol City CouncilRedcliffe Conservation Area 19 Character Appraisal adopted in 2008) and the views of entitiessuch as Historic England.

The amended proposal should then be subject to a new comprehensive public participationprocess involving ALL interested and affected parties.

Appreciate the opportunity I have been given to comment.

We believe that proposal in its present form is totally inappropriate for the followingreasons;

1. Standard set in this area of North Redcliffe is for between 6 and 8 floors (not 11 to 16) asadhered to by adjoining properties such as Finzels Reach and Paragon. It is noted that RedcliffeQuater Development has reduced requested number of floors to comply with this requirement.2. Such a high rise development will negatively impact on the visibility of historic structures suchas the Generator Building and Temple Church.3. The development will disturb the views, privacy and access to light of adjoining properties in thearea including, but not restricted to, Finzels Reach, Templebridge Apartments and The Milliners.4. The density created by multiple offices and 318 residential units will cause major congestionand disruption in an area of North Redcliffe where the transport network and infrastructure isalready stressed with existing volumes.

Therefore the application should be rejected and Developer told to submit a proposal whichreflects other existing Developments in the area (Finzels Reach, Aurora Building, The Millinersetc) and which is more sensitive to this specific section of the Redcliffe conservation area.

We therefore formally object to the application in its present form.

We appreciate the opportunity we have been given to comment and would wish to be registeredas an interested and affected party to be kept fully informed on the progress of this application.

There is no information for the loss of daylight in the lounges of flats 1, 5, 9, 13 and 17The floor plans showing daylight penetration are in Part 2 of the Daylight and Sunlight AnalysisReport on pages 19 to 23 in Appendix 2 - NEIGHBOURING DAYLIGHT &SUNLIGHT VSC & APSH RESULTS.The listed flats all have a floor to ceiling window facing the fire station site. This is 1.2m wide by2.3m high. This window will be overshadowed by the development.To aid an accurate reassessment, I have provided to Cubex pictures from the sales brochure forthe block that show dimensioned floor plans for all flats with windows on the Temple Backelevation, as well an external view of the Temple Back elevation showing the windows on thatelevation.In addition I provided a dimensioned floor plan PDF drawing of these flats. This was provided tome by the Carillion agent for the flats while under their warranty.The pictures and floor plan can be if wanted by the Planning Officers.

Planning application 129/01255/F - redevelopment of the Temple Back Fire Station siteAssessment of the proposed application against Bristol City Council SPD "Urban living"

Please note that I have taken topics & accompanying guidance from the Urban living SPD andreviewed the proposed development against those that I feel it does not adequately address.For each topic, I have taken an extract from the SPD and copied it into this note to reduce theneed to continuously refer to the SPD.My comment follows each extract from the SPDI hope that my comments are relevant and infomative

SPD Introduction

SPD page 10 Section 0.1 "The need to optimise densities:This advocates creating "more mixed and balanced communities"Comment:The proposed model of shared communal space would seem likely to attract younger people as"starter" living. It would seem unlikely to attract families, or middle aged people seeking more livingspace. In addition if the "build to rent" model fails to attract the demographic the developer seemsto be seeking (young, working people), the dwellings would seem suitable for conversion tostudent accommodation"

SPD page 10 Section 0.2 How to measure density

SPD page 11 Section 0.3 Optimal density Supports retail and social needs of residentsComment:Presently the only shops close by open outside office hours are one Tesco Metro, one local Co-opand a café. Residents will have to travel, or rely on on- line orders being delivered. Deliveryvehicle movements for 318 dwellings is likely to be high to very high

SPD page 11 Allow sunlight to penetrate to street levelComment:The daylight assessment seen shows that Temple Back will be in shadow from October to March.Page 101 of Section 5 of the Design & Access Statement shows the overshadowing: location:https://planningonline.bristol.gov.uk/online-applications/files/095FBD70262B8118890A4CB914530E36/pdf/19_01255_F-DESIGN_AND_ACCESS_STATEMENT_PART_5-2054907.pdf

Counterslip will be substantially deprived of sunlight except around the middle of the dayThe tower block shadow will track over a substantial area, and deprive the 10 Templeback andAurora offices of most of their daylight. The effect on residents of the development is assessedlater

SPD page 11 Build a sense of communityComment:Given the low likelihood of frequent encounter in communal areas with the same few people thatwould enable the building of acquaintances that will occur with around 500-600 residents; theabsence of any shared interests related to the building & its facilities, this seems unlikely tohappenThe scale of the development would seem to militate against a community feeling beingestablished

SPD page 11 Departure from the prevailing characterComment:The present plans present a very uniform external appearance that departs from the prevailingcharacter, including new buildings on the other side of Counterslip built by Cubex

SPD page 11 Proposed development mixComment:The build to rent economic model and the comments above about the likely young, starterresidents above (section 0.1) would seem likely to result in a uniform development

SPD page 12 Section 0.5 Residential density and the Development Management processComment:The SPD sets out "learning from recent higher density developments) have demonstratedoptimum densities in new development schemes as 200 units/ha in a city centre setting (i.e.

Wapping Wharf)"In a meeting with residents of Templebridge Apartments on 16 May, the developer stated that thedensity in the current plans is 581 dwellings per hectare.The SPD continues to set out that "Recent research (Superdensity- HTA et al 2015) has shownthat very high density can challenge positive response to context, successful placemaking andliveability aspirations, sometimes resulting in poor quality development."The very high density of the development does not meet the expectations of the SPD

SPD page 13 Section 0.5 - "undertake effective pre-application community involvement throughadherence with Bristol's Statement of Community Involvement"Comment:The only engagement with the residents of Templebridge Apartments was at the publicconsultation on December 11, and then on 19 March. Subsequently there has been a meeting withrepresentatives of the developer on 16 MayThis does not seem to have been "effective pre-application" community involvement from theperspective of residents in Templebridge Apartments

City

SPD page 22 Section 1.1 Has the scheme adopted an approach to urban intensification which isbroadly consistent with its setting?Comment:The SPD sets out:"Some parts of the city offer opportunities for more significant increases in density. These areasare identified in the Local Plan and tend to be the more sustainably located areas such as thedistrict/town centres and transport hubs (see Fig 2), areas with fewer contextual constraints (seeFig 3) and the larger development sites (greater than 2ha) where there is potential for newdevelopment to define their own setting."The site is in an area shown in Fig 3 as possibly providing opportunities to diversify housing stock.The area around the site is already an area of predominantly small one or two person flatdwellings.The present plans emulate that profile, and is not likely to enhance the diversity of the housingstock or of the resident demographic.

Neighbourhood

SPD page 24 Section 1.2 Does the scheme contribute towards creating a vibrant and equitableneighbourhood?Comment:The SPD sets out the expectation: "a) Early and sustained community consultation to establishlocal aspirations, needs and priorities for the area, using this information to inform the brief for the

scheme, and its design evolution."Residents of Templebridge Apartments attended the public consultation event on 11 December2018 and gave the contact information requested by the hosts of the event. Our dismay about theplans was made know to the hosts, and believed to have been related to the developer. There wasthen no engagement with residents of Templebridge Apartments until 19/03/2019 21:27 when arepresentative of Cubex contacted a resident by email. By that time the application had beensubmittedOther community engagement is not knownConsultation with people adversely and severely affected by the development does not seem tohave been timely or effective

SPD page 24 Section 1.2 e) Creating vibrant, mixed and balanced neighbourhoodsComment:Please see the responses above for Introduction 0.1, and 0.3, and Question 1.1.The development would seem to be likely to attract a fairly homogeneous group of residents, whoare likely to echo the majority of the existing local residents. That is mainly young, office workersusing the location as a starter home, before moving to a larger dwelling

SPD page 24 Section 1.2 f) Designing buildings which can be easily adapted to accommodatenew uses over time.Comment:The building structure and the reduced size of living space in exchange for communal facilitieswould seem to militate against this aspiration as it would be likely extensive internal alterationswould be needed to facilitate adaptation

SPD page 24 Section 1.2 h) For larger developments, locating new facilities (if provided) wherethe greatest number of people can access them easilyComment:The application seems to be a large development as described in the SPD, with no new facilitiesoutside of the site being planned. This is likely to place increased demand on the few existingfacilities in the immediate neighbourhood.

SPD page 26 Section 1.3 Does the scheme respond positively to either the existing context, or inareas undergoing significant change, an emerging context? Areas of strong character and formoffer only limited opportunities for deviation.Comment:The area around the development is very uniform with building heights of about 6 to 8 storeys,including several that face the site across Counterslip built by the same developer, Cubex. Thesevery much echo the Grade 2 Listed Generator Building and do not overwhelm its presence andcharacter.The plans show a uniform building of 11 storeys, and a tower block exactly opposite the GeneratorBuilding of 16 storeys.

The uniform nature and the scale of the development is likely to cause it to dominate allsurrounding buildings, and it would not seem to respond positively to the existing context. Thepresent plans are very uniform and dominating of the area

SPD page 28 Section 1.4 d Does the scheme provide people-friendly streets and spaces?Remembering that the schemes occupants' and occupants of neighbouring buildings may want towalk through the development to get somewhere else, so carefully consider how a developmentcan contribute towards creating a more walkable neighbourhood, connecting places where peoplewant to go.Comment:The present plans show an almost completely enclosed "block" layout except for the vehicleentrance to the rear courtyard. The courtyard seems to be fully enclosed by the development andgives no means of traversing the development from Temple Street to Temple Back

SPD page 28 Section 1.4 I Providing regular building entrances to provide activity and visualinterest along the street.Comment:The developer's illustrations of the street views and the plans portray a very uniform exterior facingonto the street with only the main entrance for the tower block, the office building and an entrancefacing the Cornubia. This does not seem to provide any significant visual interest along the street

Block and street

SPD page 30 Section 1.5 b Does the scheme deliver a comfortable micro-climate for itsoccupants, neighbours, and passers by? Providing a fair and equitable share of sunlight anddaylight between existing occupants and neighbouring buildings & the future occupants of thescheme (see Appendix B)Comment:The daylight assessment seen shows that Temple Back, and in particular the habitable rooms inTemplebridge Apartments will be in shadow from October to March.Page 101 of Section 5 of the Design & Access Statement shows the overshadowinghttps://planningonline.bristol.gov.uk/online-applications/files/095FBD70262B8118890

SPD page 30 Section 1.5 g Locating active ground floor uses e.g. cafes and community facilities,where uses can spill out on to generously scaled pavements, and take advantage of direct sunlight(see Appendix B)Comment:The planned community use area in the entrance to the tower block is believed to be the only areathat might have such a possibility for active use, but the pavement onto Counterslip is probably notwhat is intended by "generously scaled" pavements. The pavement onto Temple Back is wider,but immediately opposite Templebridge Apartments, and by "spilling out" the ground floor use

would obstruct pavement space for passers by during the day and create noise nuisance for theresidents of Templebridge Apartments in the evenings. This would not seem to achieve the aim ofthe SPD easily without creating an obstruction or nuisance

SPD page 30 Section 1.5 k Thinking about the prevailing wind direction, ensuringthat......gathering spaces and balconies are designed to be sheltered from itComment:The planned community use area on the roof, will be exposed to winds from all directions all year,which is likely to limit its use and amenityThe planned balconies on the tower block above about 6 storeys will have no shelter fromprevailing winds depending on the wind direction and aspect of their elevationWind is likely to impose significant limitations on the use of the roof space and the balconies

SPD page 32 Section 1.6 l Rear parking courts or parking that is not overlooked as they offergreater opportunity for anti-social behaviour.Comment:The plans for the residential section of the development show an enclosed courtyard for extensivebicycle parking and a small number of cars. This seems to be overlooked by a few dwellings onthe southern part of the development but it would seem likely that by the time anyone reached thearea to intervene in any anti social behaviour, the persons causing the problem would havefled.The present plans may possibly meet the expectation but perhaps with little meaningfulopportunity for any effective intervention

SPD page 35 Section 1.6 Servicing - Ensuring that deliveries to any non-residential parts of thescheme can be received outside of peak hours and if necessary in the evening or night-timewithout causing unacceptable nuisance to residents.Comment:From the available plans, it is not clear where deliveries to the office building will be made.Deliveries to the residential part of the development are likely to predominantly be made to thetower block entrance on the corner of Counterslip and Temple Back, opposite the residentialbuilding, Templebridge Apartments.The pattern of deliveries such as on-line grocery will be in the control of individuals placing theorder; internet shopping (Amazon etc) and takeaway food (Deliveroo, Just eat etc) will be in thecontrol of the delivery organisation or driverThis means that disruption to residents of the planned development will be limited by their location,but with a knock on disruptive and adverse effect for the residents in Templebridge Apartments.The expectation is met for residents of the development, but not for its residential neighbours

Guidance for major residential developments2 ResidentialSPD page 38 Q2.1 f Providing entrances that serve as small a number of units as possible to helpfoster a sense of community and familiarity with neighbours. Encouraging frequent interaction with

the same few people to encourage acquaintance with close neighboursComment:The single entrance to the tower block that the developer advised in a meeting with residents ofTemplebridge Apartments will give access to 252 dwellings, there would seem to be a lowlikelihood of frequent encounter in communal areas with the same few people that would enablethe building of acquaintances. The 252 dwellings may have around 500-600 residentsBuilding a "community" by interaction in the communal entrance area and lifts seems unlikely

Guidance for tall buildings

49 Q3.1 Is the tall building well located?Comment:The location of the single entry to the tower block again, exactly opposite TemplebridgeApartments is likely to be a meeting place for people, and stopping point (illegally) for vehicles.Given the 252 dwellings using this entrance as confirmed by the developer, the arrival anddeparture of people is likely to start very early in the day and go on late into the night.Given the absence of local shops and the resulting reliance on on-line grocery and food orders,the number of delivery vehicles arriving at the one entrance is likely very high. One order per weekper dwelling (likely under estimate) would mean 45 per day. Given the likely working pattern ofresidents, most will be clustered in evenings and weekends

50 Q3.1 a proposals for tall buildings should come forward as part of a spatial strategy for thewider area,Comment:SPD 3 - Future of Redcliffe: Vision - "A sustainable neighbourhood of compact, mixed-usedevelopment that is human-scale, accessible to all and respectful of the area's history andcharacter"Human scale is defined on Page 72 of the SPD as ""the use within the development of elements,which relate well in size to an individual human being, and their assembly in a way which makespeople feel comfortable rather than overwhelmed.""Comment:The present proposals do not seem to be on a human scale, with the 16 storey tower block risingstraight from street levelHuman scale is also a criterion in Question 3.3 about design excellence - see below

50 Q3.1 b If no spatial strategy, then the developer is expected to undertake a thorough contextand urban design analysis that establishes the scheme meets the criteria set out in Fig 12.Comment:As the proposal is inconsistent with the present spatial strategy in SPD 3, a design analysis wouldbe expected

50 Q3.1 c impact in sensitive locations, including conservation areas the impact should be givenparticular considerationComment:The proposed tower block is in the Redcliffe conservation area, close to the Generator building,Temple church and the Listed façade of 10 Templeback offices. Historic England have respondedto the application with comments that are critical of the plans in their present form

50 Q3.1 d The capacity of an area to accommodate a tall building is heavily influenced by anarea's underlying character. This should be understood at the scale of the city, neighbourhood,and street. Often the greater the existing variety of character within an area, the greater capacityfor future change in terms of introducing higher densities, and new building typologies including tallbuildingsComment:The existing buildings in the area are in the 6 to 8 storey range, with several recent new buildingsof that scale by the same developer (Aurora, Premier Inn). There is nothing in the area above thatheight except for Temple ChurchThis seems to suggest that the area does not have the ""capacity"" to accept the tower block at 16storeys or the rest of the development at ~11 storeys

50 Q3.1 e generally speaking, larger sites (2ha and over) offer the greater potential for tallerbuildings, as these sites are more able to set their own context than smaller sites. Larger sitesprovide the opportunity to site tall buildings away from existing buildings, and thus protect themfrom over-shadowing and adverse wind effects Large site over 2ha offers better likelihood ofsetting its own context for a tall buildingComment:The fire station site at 0.9ha seems too small to accept such a large tower. Especially located atstreet side, and in close proximity to Templebridge Apartments which the developer's ownassessment shows will be completely overshadowed from October to March each year, withreduced daylight throughout the yearSee page 101 of Section 5 of the Design and access statement submitted by the developer andthe supporting Daylight & overshadowing assessments

50 Q3.1 f Tall buildings will be encouraged where they can be integrated into a wider developmentblock, with lower level buildings assisting the transition in scale from the tall building down to thesurrounding context (place-shielding)Lower level buildings assist the transition in scale from tall building to the surrounding contextComment:The surrounding area is all of 6 to 8 storey buildings, including several by the developer proposingthe present tower block.The planned ~11 storey adjacent buildings in the development will not provide any significanttransition, and present a very uniform street scene

50 Q3.1 g Tall buildings will generally be discouraged on physically constrained sites withinexisting built up areas, where a tall building is likely to have a negative impact on the daylight andsunlight penetration into the habitable rooms of existing buildings, or onto well used parts of thepublic realmTall buildings will not have a negative impact on the daylight and sunlight penetration intohabitable rooms of existing buildings, or onto well used parts of the public realmComment:The tower block is immediately to the West of, and in very close proximity to TemplebridgeApartments which the developer's own assessment concludes will be completely overshadowedfrom October to March each year, with reduced daylight through out the yearSee page 101 of Section 5 of the Design and access statement submitted by the developer andthe supporting Daylight & overshadowing assessments

50 Q3.1 h Stand-alone tall buildings (i.e. buildings that do not form part of a block and streetstructure) will also be discouraged. The tall building will be part of a block and street structureComment:The tower block is only part of its own block, which is very much of a uniform height at ~11storeys. This presents a uniform monolithic appearance that is not on a human scale and does notcontribute to the grain of the area. It is redolent of Soviet community era housing blocks

50 Q3.1 I Cluster of tall buildingsComment:Not considered as this is a single tower block with no others in it present vicinity N/A

50 Q3.2 Does the scheme make a positive contribution to the long-range, mid-range andimmediate views to it?When siting a tall building, it will be important early on to test out a range of long-range, medium-range and local viewpoints to understand the suitability of a site to accommodate a tall building.This should be undertaken in line with guidance from both Historic England and the LandscapeInstitute.Comment:Historic England have submitted a response to the planning application which is critical of thedevelopment for its effect on Temple Church in particular.The tower block is extremely close to the Grade II* listed Generator Building and the Grade II*listed façade of the municipal generating station on Temple Back. Both will be dwarfed by thedevelopment and, especially the Generator Building by the tower. The landmark nature of bothbuildings will be grossly diminished

52 Q3.3 Does the scheme demonstrate design excellence

Comment:The SPD includes extensive recommendations and supporting information that has not beencopied here - see Pages 52 and 53 of the SPDThe comments below address the Top, Middle and Base.

Comment:The key expectation for this proposal seems to be relevant to the base and its interaction withpeople:"key failing of tall buildings is the way they meet the ground and therefore how they are perceived/experienced at the short distance. Ultimately the aim should be to create a public realm with ahuman scale. Human scale need not necessarily be prejudiced by high buildings, provided thatthese are carefully located, and have regard to the effects on the microclimate. This often involvesthe following:""TOP:Comment:The application has a community space on the top floor. This is likely to be of very limited usebecause of high winds across the space. I have a balcony on the 4th floor. I get very limited use ofit because of wind across itThe high density of occupation and likely congregation of people on the roof late into a summerevening both increase the possibility of accidental or malicious dropping of items from height. Thiswould pose a severe hazard to pedestrians at ground level, with possible fatalitiesBASE:"to prevent the design failing, the following points need to be successfully addressed:"stepping down a large mass to its neighbours; ""ensuring that the ground level most relevant to the pedestrian experience is as active andinteresting as possible;"Comment:The massive appearance at street level of this development fails to satisfy the aspirations implicitbehind the failings above, and are similar to some of the reasons given for rejecting the 21 StThomas Street tower (18/04911/F). The issue of a podium was raised whereby the tower does notrise immediately from street level, as is presently planned for the Fire station site."mitigating against the adverse impacts a tall building can often make on the microclimate;"Comment:The plans seem to risk creating a wind funnelling through the canyon that will be formed by thedevelopment's bulk and the narrowing of Temple Back.

54 Q3.4 c, d, e, Does the scheme ensure the safety of occupants and passers-by?Fire safetyComment:The proposal shows long artificially lit corridors that give access to many flats, and a limitednumber of vertical cores; with only one in the tower block.This must be a matter of grave concern in the wake for the Grenfell Tower fire.

The criterion in the SPD is for a (c) third party assessment of the design for safety,(d) modelling of the critical access and movement points.(e) design of stair and lift cores for fire fighting & evacuation(f) designing lift and stair cores to allow natural lighting & ventilation.The single core in the tower and the long artificially lit corridors, with a believed single point ofaccess to the development on the corner of Temple Back & Counterslip would seem to suggestthat all these criteria need to be rigorously questioned and satisfactorily answered.Specialist assessment of the information in the application and its adequacy is needed .The assessment should take account of the Hackitt report as stated in the SPD and its interimfinding that "the current legislative system in relation to fire safety was not fit for purpose whenconsidering complex or high rise buildings (defined as 10 storeys and above)". The final reportrecommends that "the Local Planning Authority will need to consult with a new Joint CompetentAuthority (JCA) on fire safety matters"STRONGLY recommend independent review of all aspects of fire safety and adequate evacuationor rescue arrangements

54 Q3.4 c, d, e, Does the scheme ensure the safety of occupants and passers-by? Fire safety(continued)Comment:The number of dwellings suggests around 500 residents. The planned concierge control wouldprovide a means of knowing the number of people present in the development at any one time,enabling accurate roll call in the event of an emergency; the number of missing was a majorproblem for fire and rescue in Genfell Tower. However the need to log in and out may raiseprivacy issues, and date protection problems. The merits and possible implications raised wouldneed careful investigation Logging of people in the building would contribute to fire safety, but mayraise data protection issues

54 Q3.5 Does the scheme interfere with aviation, navigation or telecommunication, and how will itaffect the solar energy generation on adjoining buildings? c) effect on solar energy generationComment:The new Fire Station has solar panels on its roof, and any other local installation will be affectedby the over shadowing of the tower block, and the ~11 storey rest of the development.Any possibility of installing solar panels on the roof of Templebridge Apartments is now removedby the overshadowingOther aspects of this criterion will need specialist assessment to judge the compliance of theapplication

55 Q3.6 a Has the scheme's future servicing, maintenance and management been wellconsidered?a) Considering maintenance issues during the design process to facilitate the management of thelong term maintenance of the building with minimum disturbance to occupants and thesurrounding public realm.

Comment:There are large parts of the development with North facing walls, or ones in shadow.Experience from Templebridge Apartments is that organic growth readily takes place on suchwalls, and frequent cleaning is needed. For 6 storeys, this can be done by extended pole washingThe development has extensive elevations that face North or will be in shade. Provision for accessto enable routine cleaning would seem to be essential. Extended pole washing will not reachbeyond about 6 floors.There are no apparent arrangements in the plans for routine access equipment that wouldfacilitate external cleaning

56 Q3.7 b Minimising excess solar gain that could lead to overheating risk through use of externalshading and careful consideration of facade design.assessments should be prepared to show that the building will not overheatComment:The tower has many South and West facing flats, all of which will be exposed to solar gain(insolation), and there are no apparent mitigating measures in views of the outside of the building.Reliance on air conditioning would require significant energy usage, mitigating other energyefficiency measures in the structure.

56 Q3.7 d providing communal amenity spaces on the upper floors to enable all buildingoccupants to enjoy the views afforded by tall buildings, whenever possible, making areas alsoaccessible for the publicComment:The concierge service can enable public access, but control of access to other space from the liftswould need to be implemented Possibly, depending on the Concierge service

56 Q3.7 e That with good daylight and views, a higher proportion of single aspect dwellings maybe acceptable within the upper storeys of a tall building. Single aspect dwellings need gooddaylight and aspectComment:From the information reviewed at present, it is not clear how many single aspect dwellings arepresent on the North and East facing elevations of the tower.This should be reviewed as part of the planning assessment

57 Q3.8 Is the scheme sustainably designed?Q3.8 a tall buildings should be designed to be adaptable and flexible to ensure that these buildingsremain functional and capable of addressing any shifts in demographics and market demandsover the long term.Comment:Response to shifting demographics: The present offering of reduced dwelling space, believed tobe below the Nationally Defined Space Standards, with shared communal facilities would seem tobe aimed at a young, professional worker demographic.

As the population ages, it would seem that the reduced dwelling space would be less attractive,and the build to rent economic model, are not likely to appeal to an older demographic because offixed incomes and limited pensionsGiven the reduced dwelling space, the alternative demographic would seem to be studentsseeking accommodation. Increase in student accommodation in the Redcliffe area would not seemto meet the Urban living SPD criterion in Q1.2 ""Does the scheme contribute towards creating avibrant and equitable neighbourhood?"

58 Q3.9 Will the scheme be neighbourly, both at the construction phase and following occupation?

Q3.9 a Ensuring that a comfortable micro-climate is provided at the base of the building,recognising that as urban densities rise, the value of the public realm as somewhere to dwell alsoincreases.Comment:The shape of the tower as shown in the application suggests that it is likely to give rise todeleterious wind effects at street level, using the illustrations in "Issues" of Appendix D of theUrban Living SPD as illustrations of building shape and wind flow effects.The present plans show a monolithic structure rising straight from street level.It does not show any of the features in Appendix D that are suggested as possible mitigations toundesirable wind effects.The SPD expects that for towers of 14 to 20 Storeys Desk-Based Assessment + ComputationalFluid Dynamics Simulations will be done with possible wind tunnel testing required. It is not clearfrom the information reviewed that these studies have been satisfactorily completed.The developer has stated in an email of 19 May 2019 20:39 that ""No wind assessment isrequired, nor would be expected on a development of this scale"".The SPD continues to state that ""These guidelines need to be read in conjunction with prevailingbuilding heights; where the protruding building is more than twice the average height ofsurroundings then the risk of building related wind effects may be more pronounced.""The plans are for a 16 storey tower in an area of around 8 storey buildings.It also states that ""Public spaces at high levels (e.g. terraces) fall into the same guidelines asabove."", supporting concern about the design of the roof top space in Q3.7(d)

Page 58 Q3.9 b dispersion of air pollutionComment:The Counterslip side of the competed development will be facing a road that is presently heavilycongested at peak times, and even with the proposed width reduction, severe congestion wouldseem likely to persist.The height of the tower block and the presently positioned office building will create a canyoneffect that would seem likely to limit the dispersion of traffic fumes

Page 58 Q3.9 c Undertaking a sunlight and daylight assessment at the outset of the designprocess, in line with the guidance in Appendix B. By adopting a slender point form tower with

compact floor plates, the building will cast smaller, faster moving shadows, than a bulkier tower. Aslender tower can also improve access to sky view, and permit better views between buildings andthrough sites Neighbourly building with lesser effect from its shadow on the surroundings andbetter views of sky, between buildings and through the siteComment:As for Q3.1 (g) above, the tower and the Temple Back lower level (~11 storey) building will castthe Eastern side of Temple Back into shadow from October to March each year as shown in theshadow diagram on page 101 of Section 5 of the Design and access statement submitted by thedeveloper and the supporting Daylight & overshadowing assessments (Link in F7 above)This particularly affects Templebridge Apartments, as acknowledged in the Daylight survey withmany habitable rooms suffering severe reductions in daylight

Page 58 Q3.9 d Assessing likely wind turbulence at the base of the building in line with guidancein Appendix D. Wind turbulence will depend on the local grouping of buildings and their orientationto the prevailing wind. Seek to avoid bolt-on solutions post-completion to deal with negativeenvironmental impact e.g. wind effects.Planned reduction of wind turbulence in the vicinity of the tall buildingComment:The shape of the tower as shown in the application suggests that it is likely to give rise todeleterious wind effects at street level, using the illustrations in ""Issues"" of Appendix D of theUrban Living SPD as illustrations of building shape and wind flow effects.The present plans show a monolithic structure rising straight from street level.See further comment in response to Q3.9 (a) above

Page 58 Q3.9 f Preparing a Construction and Environmental Management Plan outlining thestrategy for dealing with the operational construction phase impacts such as air quality, dust,noise, vibration, traffic, water quality. This is particularly critical for constrained sites, where accessis limited and neighbours are close.Management of nuisance and impact of construction on neighboursComment:There are residential neighbours in very close proximity to the tower block location who will beaffected by all phases of the project, and during its lifetime.No management plan is presently (12 May 2019) available on the planning application in the BCCplanning portal

Page 58 Q3.9 g Considering the impacts on tunnels, sewers and settlement around the site, as atall building generally requires deep foundations. Consider also the impact on the loading ofadjacent foundations, including party walls, and how the settlement of the tower will affectsurrounding roads and buildings.Prevention of settlement in neighbouring buildings & structuresComment:

Between the development site and the harbour are the 10 Temple back offices, and the residentialTemplebridge Apartments. Both are built on bored piles in close proximity to the harbour and itscontaining walls. The walls containing the harbour are believed to be of concern to the CityCouncil due to their age and poor condition. Further excavation and piling works on thedevelopment site may introduce further hazard to the stability of the harbour walls, with thepotential for collapse. Beneath the offices on Temple Back is a car park below water level. Anyhazard to the harbour walls may result in risk of inundation with possible risk to columns in the carpark that support the above ground office building. Not presently know, but assessment wouldseem to be advisable

The Panel understands that the current proposals have not been amended inaccordance with the pre-application advice. The pre-application proposal had also not beenpresented to CAP.

It is considered that this is not an appropriate location for such a tall building. The 16 storey towerwould have an adverse effect on the listed Generator Building both in terms of scale andovershadowing. It would also dwarf other important local buildings such as Temple Church and theShot Tower.

The entrance would be better located in the southern corner where it would be visible from thebridge and would complement the Generator Building. The building was a dull brick box whichmust be of a much higher quality of design and materials in this location.

The archaeological study is inadequate in scope. It fails to reference the 2014 English Heritagestudy or to research the histories of individual properties on the site with plans where appropriate.

The panel endorses the views of Historic England on the application.

Once again I'm saddened to see developers thinking that the sky is the limit withmasssive developments in central Bristol! 15 Storeys in this location is an excessive andinsensitive impact to the history and cultural assets of the area like Temple Church, let alone to theexisting residents who have bought properties at Finzle's Reach that were more sensitive to thearea in their built height. Apart from height it does seem, although I have not found a good 3Ddrawing, to be rather blocky to - another sign is built density at over 300 apartments overridinggood design.

I would take issue with Destination Bristol that this is a welcome development on this site - Bristolis a special city and the reason people want to live here is that it hasn't been ruined by proposalssuch as this, and when new residents take up a home in buildings that have been more sensitivelydesigned they don't expect a 15 story colossus to built opposite them that negates all of this gooddesign.

I would also take issue with the safety of terrace gardens with garden furniture on the 15th floor instorms and single stairwells to these apartments - it may be built next to a fire station, but thelessons of Grenfell Towers and the fact the Fire Service can only get to about the 8th floorexternally should be paramount in good design and fire exit redundancy, although perhaps theFire Service are more interested in property development now than being a Public Service?

The low level Old Temple Fire station acted as a relief to historic assets in this area and althoughnot a worthy building in it's own right it had an important function in not overwhelming historic

views and assets such as the lovely The Kings Head, Shakespeare 1636 (orig) and Cornubia pubscirca 1775 (already hidden away and now to be massively overshadowed), The TramwaysGenerator building and Temple Church let alone other buildings on Victoria street which are circa15th century. The DRG building, although accepted now, is a good looking but tall building,unlikethis one, but I'm sure we would not want substantially more of them in the locale when the streetview and Bristol's historic legacy is obscured - the History of The Knights Templars and Bristol istruly important and the tragedy of WWII and it's impact on the centre of Bristol should not beovershadowed by poor design that arguably does more damage to Bristol than the Luftwaffe did!

single largestore, as recommended in the cycle storage section of Bristol City Council's Urban Living SPD.CONTACTRichard Williams

The Bristol Civic Society response to planning enquiry - 19/01255/F - theredevelopment of the Avon Fire And Rescue Service Headquarters Temple Back

The proposalDemolition of existing buildings to redevelop mixed use office and 318 residential units includingamenity space and cycle and car provision, with vehicular access, servicing arrangements, publicrealm works and landscaping.

SummaryThe Society supports the demolition of the current buildings that are without architectural merit andthe redevelopment of the site. The proposed employment space will replace the employmentspace lost with the demolition of the current buildings. The Society supports the residentialdevelopment and the improvements to the surrounding public realm although we believe that thereis more that could be done to mitigate the damage caused by post-war redevelopment. Aresidential building of amplified height is appropriate for the site as recommended in the recentlyapproved planning advice in the Urban Living Special Planning Document (Urban Living). Theproposal does not make the case for a and tall building whose height and entrance would have asubstantially harmful effect on the amenities of Templebridge Apartments (Templebridge) and onthe setting of the Grade II* listed Generator Building and views along Counterslip.

The Urban Living Special Planning Document Urban Living) questions.

Q1.1 Has the scheme adopted an approach to urban intensification which is broadly consistentwith its setting?

On the 22nd June 2017, in response to an earlier scheme the Council's planning advice lettersaid, "........the urban design expectation was that the building heights along Counterslip wouldecho the height of the buildings that had been recently constructed as part of the Finzel's Reachdevelopment. ' This includes offices of 5+1, 6+1 and the hotel of 8. This establishes a city scalemedium rise context on the Counterslip elevation."

Although the Society understands that the tall building proposal has attracted support from otherswe prefer the original advice which was that a tall building rising from the back of the pavement inCounterslip and the narrower Temple Back would appear bulky, have a poor relationship with bothstreets and would conflict with the aspiration to narrow Counterslip to improve the urban grain.

The application fails to assess adequately the impact of the proposed tower on the setting of theGrade II* listed Generator Building which it significantly affects. The proximity of the listed buildingmeans that the site cannot be considered a landmark site despite its corner position close to theriver. The scale of the tower also has a harmful impact on the view into Counterslip from St.Philip's Bridge and from the Victoria Street direction. The scale of the proposed tower would harmthe conservation area.

Q1.2 Does the scheme contribute towards creating a vibrant and equitable neighbourhood?

The redevelopment of Counterslip has not produced an active street frontage so far. Although theproposed scheme would add ground-floor office use it is unlikely to achieve a substantialimprovement to street level activity which is inevitable, as there is no demand for retail space. Wenote that the Premier Inn already has two ground-floor café/restaurant areas. The Societysuggests a change in the scheme: to transfer the residential block from the St. Philip's Bridgecorner to the Temple Street corner of the development, with the entrance to the residential blockmid-way along Counterslip where it would stimulate more pedestrian activity.

Q1.3 Does the scheme respond positively to either the existing context, or in areas undergoingsignificant change, an emerging context? AndQ1.4 Does the scheme provide people-friendly streets and spaces?

The character of the area is dominated by large commercial buildings that do not create a humanscale street. The proposal would inevitably contribute to the area's anonymous character.

A tall building rising from the back of the pavement would accentuate the scale buildings thatframe Counterslip and Temple Back. This site gives no opportunity to mitigate the impact of the tallbuilding at street level by setting it behind a human street scale podium as recommended in UrbanLiving.

A significant urban design aspiration is to amend the area's urban grain, that post warredevelopment damaged. The Society supports the principle of a perimeter arrangement thatreinforces the street frontages notwithstanding that it would be desirable to reflect the scale ofTemple Street to create a more human scale and legible route between Victoria Street andFinzel's Reach.

The Society welcomes the use of trees and planting to green the edges of the development andreduce the impact of the street widths.

The two raised tables on Counterslip, narrowed roads on Counterslip, Temple Street and TempleBack are welcome street improvements. It is unfortunate that the entrance to the car park is to beon Temple Street. For pedestrians, the Counterslip improvements will be tempered by trafficqueues that use Counterslip as a rat-run through to Redcliffe Way.

The site offers the opportunity to achieve improvements to the historic line of Temple Street andthe setting of the listed Cornubia Public House. It is unfortunate that the entrance to the car park isto be on Temple Street. Can the developer discuss with the Council and neighbouring land ownersimprovements to integrate the remnants of historic fabric including the Cornubia and TempleChurch, into a better context for example, a pocket park outside the Cornubia? This issue wasraised by the Central Area Plan. The area is a small site with a high visual impact on the TempleMeads Finzel's Reach pedestrian route and is in the Redcliffe Conservation Area.

We note that the scheme does not meet the aspiration of 'The Future of Redcliffe -SPD3 toprovide a public route through the site.

Q1.5 Does the scheme deliver a comfortable microclimate for its occupants, neighbours andpassers-by?

We anticipate that the Council will verify the wind effect of a tall building on the surroundingstreets.

Q1.6 Has access, car parking and servicing been efficiently and creatively integrated into thescheme?

The Society has no comment other than the Council has established policies to assess theseaspects.

Q2.4 Does the scheme create attractive, well designed and well maintained private outdoorspaces?

This building would have a density that substantially exceeds the density of 200 dph that Urban

Living recommends for the centre of the city. The central courtyard would offer an inadequateprivate outdoor amenity space for this population. Private roof top spaces are superficiallyattractive, but their use is limited by their dependence on weather conditions, particularly windspeed.

Q2.5 Does the scheme creatively integrate children's play? Not applicable to this proposal.

Q3.1 Is the tall building well located?

The tower on the corner of Counterslip/Temple Back must be assessed against the requirementsof the Urban Living SPD. The Central Area Plan gives no specific advice for the site. Subsequentplanning advice has overtaken the Future of Redcliffe SPD. The developer must show that a tallbuilding is more appropriate for the site than a building of amplified height.

The scheme adopted must show an approach to urban intensification which is broadly consistentwith its setting. Previous planning advice considered the scale of an earlier scheme to be too greatand advised that at a lower level, more human scale should be adopted. At 16-floors the tower is astep-change above the surrounding buildings in Counterslip and Temple Back, not the 'amplifiedheight' that the Urban Living recommends as a starting point for city centre urban living. The senseof enclosure by the mass of formal commercial street elevations would not create the feeling of anew urban living quarter or a people welcoming sense of a place.

We shall not repeat the Templebridge response which is fully argued. There are reasonablegrounds to infer that when the proposal was considered earlier, those who supported the tallbuilding were not aware of the existence of the Templebridge residences. The developer's shadowillustration shows that the tall building would obstruct sunlight from reaching any part of theTemplebridge from October to March; a major loss of amenity. This aspect of the proposal mustbe assessed properly with a more developed sun path diagram.

We are sympathetic to the Templebridge objection to the location of the entrance to the residentialblock.

The suggestion to transfer the residential block from the St. Philip's Bridge corner to the TempleStreet corner of the development does not affect our comments on the height of the residentialbuilding.

Q3.2 Does the scheme make a positive contribution to the long-range, mid-range and immediateviews to it?

The Society's view is that the tall residential building rising on two sides from the back of thepavement would have a poor relationship with Counterslip and Temple Back. All the surroundingbuildings are of amplified height and a tall building in this closely built up area would feel

oppressive at street level.

A tall building close to the Generator House would overbear and draw attention away from theGrade II* listed building which would harm this character area of the Redcliffe Conservation Area.

We support the Templebridge proposal that the residential block be moved to theCounterslip/Temple Street corner. The advantages would be:- Templebridge would face only an amplified height building with a corresponding improvement toaccess to sunlight.- Only commercial buildings would border the residential block's entrance.- An entrance mid-way along Counterslip would generate greater footfall to animate the street.- An amplified height building would not overbear the setting of the Grade II* listed GeneratorHouse. If the curved double-height entrance is transferred to face St. Philip's Bridge, thoseapproaching Counterslip from the bridge would enjoy the view of the 'welcome area' into theinterior of the building which would be a planning gain.

Q3.3 Does the scheme demonstrate design excellence?

The Society supports Historic England's concerns set out in their response dated the 15th April2019 about the southern end of the development and its relation to Temple Church and the viewfrom Victoria Street.

Q3.4 Does the scheme ensure the safety of occupants and passers-by? AndQ3.5 Does the scheme interfere with aviation, navigation or telecommunication, and does it have adetrimental effect on solar energy generation on adjoining buildings? AndQ3.6 Has the scheme's future servicing, maintenance and management been well considered?

The Society has no comment other than the Council has established policies to assess theseaspects.

Q3.7 Does the scheme create a pleasant, healthy environment for future occupants?

Although a critical aspiration of Urban Living is to achieve a high-density residential developmentthat promotes stable tenure the Council may consider that a new form of build to rent model thatgives residents access to communal space and other facilities outweighs other factors. Acommunal living approach would add a new form of housing for residents in the expanding citycentre residential market albeit, one with a relatively high turnover of residents.

The Society appreciates the benefits of higher density level, but the ambitious density of thisproposal significantly exceeds the illustrative masterplan at page 31 of Urban Living thatdemonstrates design principles with a density of 250 dph. A design-led approach faces seriouschallenges managing this kind of density.

No private amenity space is provided there are not even inset or Juliet balconies. The Councilmust assess whether the internal public amenity space is adequate for the projected number ofapartments many of which will have two occupants. National Space Standards must apply to theprivate residential areas.

There are aspects of the scheme that conflict with Policy DM29 which applies to the design of newbuildings.- The apartments are arranged around a double stacked corridor. There would be little natural lightwithin communal circulation areas which would require continuous artificial light.- The corridor gives access to a high number of apartments. There is nationally accepted researchthat describes and quantifies the disadvantages of multi-flat access corridors to the sense ofneighbourliness, community and effective management.- The scheme contains a great number of north facing units or units that face into a narrowcourtyard which fail to deliver the required residential amenity advocated within Urban Living.

Q3.8 Is the scheme sustainably designed? AndQ3.9 Will the scheme be neighbourly, both at the construction phase and following occupation?

The Society has no comment other than the Council has established policies to assess theseaspects.

Failure to meet planning guidelines and Material Planning Considerations

I fully recognise that the site needs redevelopment and Bristol needs housing, but I feel that thecurrent plans are not good for the area, severely out of step with its character, and will not promotea sense of community that the developer has stated as its aim. It will increase the present severestrain on public services in the centre of Bristol, with no present plan to mitigate that. Thedeveloper recognises that it is hyper densely developed.

I believe that the present plans for the site do not meet many of the criteria in the Bristol CityCouncil Supplementary Planning Documents (SPD) on Urban living - "Making successful places athigher densities (November 2018)", is inconsistent with the Future of Redcliffe document (SPD no.3), as well as being unacceptable when judged against several of the Material PlanningConsideration criteria. I also believe that the plans show many similarities with those forapplications The Bell, 7 Prewett Street (18/01890/F) and 21 St Thomas Street (18/04911/F), bothof which did not gain approval.

I live on Temple Back, exactly opposite the proposed tower block in Templebridge Apartments.The developers shadow diagrams show that we will be overshadowed at midday all year round.Myself and other residents have suggested mitigations to the developer that would mitigate theeffect on us; move the tower block to another corner of the site, and reduce the height of theremaining buildings to 6 to 8, which would be consistent with the surroundings.Our suggested mitigations would not address the fundamental issue of not aligning with planning

guidance. They would merely make the plans more acceptable to us

The overshadowing is shown below and on Page 101 of Section 5 of the Design & AccessStatement

SPD 3 on the future of Redcliffe includes Townscape policy guidance that expects:T2 Development should be fine grain with strong vertical rhythm to ensure human scale.T3 In instances of the redevelopment of existing large floor plate sites, fine grain developmentshould be wrapped around the ground floor to create active frontages.T4 Developments should respond to the historic context of the area.T5 Building heights should respond to the predominant existing context of 3-6 storeys, and shouldrelate to the site's context, surrounding development and urban design considerations. Redcliffe isnot generally considered an appropriate location for tall buildings.T7 Important views must be maintained.T8 Development near to landmarks and listed buildings should preserve and enhance their setting.All buildings in the vicinity of historic landmarks to be a height which allows the existing landmarkto be dominant, both from near and from more distant views.

I do not believe that the present proposal meets any of these points of guidance. It cannot be saidto:- Be on a human scale - this will dominate all the streets and create canyons for pedestrians- Have an active frontage.- Respond to the historic context- Respond to the predominant existing context- Maintain important views - views of Temple Church & the Generator Building will be severelyaffected- Enhance the setting of the Grade II* listed Generator buildingThere is further guidance on other specific aspects that I can provide if you wish.Urban living SPD - Making successful places at higher densities (November 2018)Addressing specifically the tower block element of the plans located on the corner of Counterslipand Temple Back, I believe this is inconsistent with many of the questions and criteria that a well-designed tower should meet, and fails to fulfil many of the criteria

Visual qualityQ 3.1 & 3.2 - I do not feel that the tower is well located or that it makes a contribution to the long,mid-range, or immediate views.The locational criteria state that a tall building should not be located where:- it hides or masks the topography of the city- it harms valued views from key vantage-points- it has a detrimental impact on the city's historic environment (see Appendix C)- it has a significant negative impact on the amenity of nearby occupiers or on the public realmIt is too close to the Grade II* listed Generator Building and the Grade II* listed façade of the

municipal generating station on Temple Back. Both will be dwarfed by the development and,especially the Generator Building by the tower. The landmark nature of both buildings will begrossly diminished.Q3.3 - design excellenceThis identifies that a "key failing of tall buildings is the way they meet the ground and thereforehow they are perceived/ experienced at the short distance. Ultimately the aim should be to createa public realm with a human scale. Human scale need not necessarily be prejudiced by highbuildings, provided that these are carefully located, and have regard to the effects on themicroclimate. This often involves the following:"- "stepping down a large mass to its neighbours; "- "ensuring that the ground level most relevant to the pedestrian experience is as active andinteresting as possible;"I believe the massive appearance at street level of this development fails to satisfy the aspirationsimplicit behind the failings above, and are similar to some of the reasons given for rejecting the 21St Thomas Street tower.- "mitigating against the adverse impacts a tall building can often make on the microclimate;"the plans seem to risk creating a wind funnelling through the canyon that will be formed by thedevelopment's bulk and the narrowing of Temple Back.

Functional qualityQ3.4 - I feel that the plan for a roof terrace with such a high density of residents in thedevelopment will pose a hazard to passers-by from material that could be dropped from the roof,and the balconies on Temple Back. I believe that with the single entrance to the tower, and theone internal stair route, the fire safety of so many occupants (~250 dwellings) is at severe risk.

Environmental qualityQ3.7 a pleasant, healthy environment for future occupants?The plans show residential spaces opening out on to an internal court on the development createdby its enclosing, excluding layout. The lower levels, especially on the Water Lane end of thedevelopment will get no natural light at all.All of the living spaces facing Temple Back and the Counterslip side of the tower block (Northfacing) will have no direct natural daylightThis can cause mental health issues from living under artificial light. This was cited as a detrimentin the Prewett Street considerations.Similarly the development will remove virtually all of the natural light available to residents in myblock, Templebridge Apartments. This is acknowledged in the Daylight/Sunlight Analysis

The severe reduction of light seems to fail to comply with Q3.9 about the building beingneighbourly.The report rather states that Templebridge Apartments is 'likely' to be impacted on by theproposed development.

Q3.9 - will the scheme be neighbourly?As explained above, the apparent disregard of removing the majority of the natural light to ourhomes does not seem very neighbourly

I have other concerns about "neighbourliness" as the number of vehicle movements fromdeliveries, taxis and cars collecting & dropping off people, residents & visitors trawling for parking,removal lorries when flats are vacated and then occupied will I believe lead to vastly increasedtraffic at all hours of the day and night. This will be exacerbated by the location of the layby exactlyopposite Templebridge Apartments. Vehicles stopping & starting, and waiting with idling engineswill not be good for sleep during the summer months, and detrimental to air quality all year round.

The location of the single entry to the tower block again, exactly opposite TemplebridgeApartments gives me grave concern as it will be a meeting place for people, and stopping point(illegally) for vehicles. Given the ~250 dwellings, the arrival and departure of people is likely tostart very early in the day and go on late into the night.

Material planning considerationsI believe that the present plans do not adequately respond to several of the planningconsiderations, primarily:Material planning considerations can include (but are not limited to):- Overlooking/loss of privacy- Loss of daylight/sunlight or overshadowing- Scale and dominance- Layout and density of buildings- Appearance and design of development and materials proposed

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Prior to being badly damaged by bombing in 1940, Temple Church was one of the great churches of Bristol and for a long time was the second largest and finest church after St Mary Redcliffe. The Weavers' chapel in the church represents the first indication of a link between the Church and the merchants of Bristol. Despite the considerable damage caused by bombing the ruins of the church were considered too important to the city to lose, and the ruins were consolidated and taken into state care in 1958. Elements of the earlier circular church survive below ground, and contain archaeological information relating to the churches and the landscape in which they were constructed. The church is of great significance, with considerable evidential, aesthetic, historic and communal value. The setting of the church contributes to its significance. Its churchyard is now a well-used public amenity space, from within which the conserved ruins of the church can be appreciated as a powerful reminder of the damage wrought on the city in World War II and a place of quiet contemplation. Unremarkable postwar office blocks provide the immediate backdrop to the churchyard, some of which rise above the ruined walls of the church in views from within the churchyard but do not dominate. The church tower has a pronounced lean to the west which is thought to be the result of historic ground movement. Its tower remains prominent in views from Victoria Street, where it rises above a parade of well-preserved early 19th century domestic-scale buildings - a mixture of shops, pubs and townhouses - many of which are listed at Grade II. The church tower also forms an attractive composition with the Grade II listed 17th century Shakespeare Inn, an imposing double-fronted timber-framed building. Opposite the site of the proposed tall building on Counterslip is the Grade II*-listed Generator building, the former generating station for Bristol’s tramways. The building’s exuberant neo-Baroque style allows it to act as a bridgehead to traffic crossing the adjacent St Philip’s Bridge. Part of the building’s significance is in its landmark quality. Impact In views from St Philip’s Bridge, the 15-storey tower element of the proposed development would undermine the landmark status of the Generator building. We acknowledge that there is scope for a building of some height at this location, but in order to maintain the bridgehead role of the Generator building we recommend that the proposed tall building is reduced in scale so that in views from the bridge it does not rise above the roofline of the Generator building. We also have concerns regarding the impact of the proposed development on the setting of the tower of Temple Church, particularly in views from Victoria Street. As demonstrated in the applicant’s verified views (image 12), the proposed development

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would visually coalesce with the church tower, undermining its visual primacy in the historic townscape. It would also rise above the roof of the Grade II listed Shakespeare Inn, weakening this historic building’s eminence in the streetscape. This adverse effect is potentially exacerbated by the unrelieved elevational treatment of the proposed building, which runs the danger of the disparate elements of the proposals appearing as an unfortunate amorphous mass above the rooftops of this picturesque surviving piece of the townscape of old Redcliffe. Improvements to the elevational treatment of the proposed building, particularly reducing the expanse of unrelieved brickwork at its upper level, would also bring benefits in the context of views from Temple Churchyard, where the proposed buildings would rise above the ruins of the church. We acknowledge that the existing backdrop to the church is one of mediocre architectural quality, but would encourage the applicant to consider how the elevations of the proposed buildings which face the historic church could establish a more positive relationship with the churchyard. The current designs suggest the back of a building, whereas we believe they should be treated as a principal façade. This would also be of benefit to the character and appearance of Redcliffe Conservation Area, and accord with the wording of the site allocation in the Bristol Local Plan (Site reference SA 607) which states that development of the fire station site should take account of the Redcliffe Conservation Area. Under paragraph 193, the NPPF advices that when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the conservation of the asset - and the more important the asset, the greater the weight should be. This is irrespective of whether any potential harm amounts to substantial harm, total loss, or less than substantial harm to significance. The harm these proposals would cause less than substantial harm to the setting, and thus significance, of Temple Church and the Generator Building. But these are heritage assets of the highest significance. The proposals would also harm the setting of the Grade II listed Shakespeare pub, and the character and appearance of the Redcliffe Conservation Area. Under paragraph 194, the NPPF advises that any harm to the significance of a designated heritage asset requires clear and convincing justification. Paragraph 196 advises that where a development proposal will cause harm that is less than substantial, this harm should be weighed against the public benefits of the proposal. It is for your authority to assess the wider public benefits associated with the scheme. However, in terms of the “clear and convincing justification” your authority will need to be satisfied that the harm we have identified is necessary to deliver the scheme and any associated benefits it may bring. We believe that revisions are necessary to

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reduce or avoid the harm to the historic environment that this scheme would cause. Recommendation Historic England has concerns regarding the application on heritage grounds. We consider that the issues and safeguards outlined in our advice need to be addressed in order for the application to meet the requirements of paragraphs 193 & 194 of the NPPF. In determining this application you should bear in mind the statutory duty of section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 to have special regard to the desirability of preserving listed buildings or their setting or any features of special architectural or historic interest which they possess, and the statutory duty of section 72(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 to pay special attention to the desirability of preserving or enhancing the character or appearance of conservation areas. We would be happy to meet with yourselves and the applicant to discuss means by which our concerns could be addressed, if you would find that useful. Your authority should take these representations into account and seek amendments, safeguards or further information as set out in our advice. If there are any material changes to the proposals, or you would like further advice, please contact us. Yours sincerely

Simon Hickman Principal Inspector of Historic Buildings and Areas E-mail: simon.hickman@HistoricEngland.org.uk

The proposed plan significantly impacts direct sunlight/daylight, being on first floor thisimpacts us most; and can cause health issues.

Other reasons include- amenities to support additional people- traffic and parking issues

Therefore I request the application to be refused and design to be altered to mitigate abovementioned issues.

i object to the proposed development for the reasons listed below:Loss of daylight/sunlight or overshadowingScale and dominanceLayout and density of buildingsrHighway safetyTraffic and parking issuesImpact on character or appearance of areaImpact on the community and other servicesEconomic impact and sustainability

My property can be identified in the document Appendix 2 Neighbouring Daylight &Sunlight VSC & APSH Results as Templebridge Apartments Fourth Floor R4/W5 and R5/W6.

This is a 4th floor apartment looking directly over Temple Back, and the old Fire Station building.When I moved into this property the Fire Station was at that time operational from the building.

My property has only 2 windows, a small bedroom window facing down Temple Back towardsTemple Way, and a large (wall to wall, floor to ceiling) window in my combined living area &kitchen. So all my natural light (during day time hours) comes from this one window.

I've fully accepted that the Fire Station site was to be redeveloped at some point, and wasresigned to loosing some of my light if a building of up to 8 stories was built. This seemed areasonable assumption based on the height of all other buildings in the area be they:* Historical (Temple Church & the Generator Building);* Legacy (Crescent Centre & Water Lane Apartments); or* Newly developed (Bridgewater House, Finzels Reach & 10 Templeback).

So you can imagine my shock, dismay and upset when I went to the Cubex public consultationand was faced with a building of 10 stories at it's lowest and a 16 story tower right in front of myonly source of daylight.

The impact of this building will be devastating on my quality of life and mental health. The daylight

analysis itself acknowledges this, but then dismisses the issue by saying if you average my lightwith my neighbours who instead overlook the river, then this is fine. Well unfortunately myneighbours who overlook the river can't share their daylight with me. So this 'averaging' of daylightacross our entire building is a ridiculous theory, that doesn't resolve any issues in the real world.

As well as my flat, the shadow analysis for this development shows that all, or some ofTemplebridge Apartments will be in shadow at midday, all year round. The wider area around thisdevelopment also drastically suffers in the shadow analysis.

The height of the proposed tower, and building in general is just too much for the area to bear. It'sway out sync with the height of all existing buildings and will block views to the historic localelements (Temple Church, St Mary Redcliffe & the Generator Building).

I fully support the regeneration of this site and the local area. If I'd gone along to the Cubex publicconsultation, and seen a building of up to 8 stories (as I expected), I would not be objecting.

With some neighbours I have even met with a representative of Cubex (Elgan Jones) and theirmediator (Andrew Smith, Conversation PR) in the hope that some middle ground, or compromisecould be achieved.

I pointed out that they have chosen to put the largest part of their development directly oppositethe only immediately adjacent residential property. If they were to instead put the tower andresidential area on the other side of the site (Temple Street/Counterslip) this would then overlookonly commercial properties. However it became very clear that they are not interested in alteringor scaling their plans in anyway. In fact they intimated that it was Bristol City Council who askedthem to upscale their original plans. Poor old Cubex wanted to build something smaller but BCCare forcing them to put up a tower block!

I have recently seen that a proposed development at 21 St Thomas Street was refused permissionto extend from 9 stories to 14 stories (https://www.bristolpost.co.uk/news/bristol-news/14-storey-block-student-flats-2464582). It would seem to me the reasons for turning that down are the samethat apply to this developments, and I would ask that they also be applied in this case:* Creating harm to the Redcliffe Conservation Area* Out of step with the surrounding area* Substantial harm to the setting of the surrounding heritage assets, including Grade II & Grade IIListed buildings

Outside of the size, scale and positioning of this development my other concerns relate to the localarea/community as a whole.

The size of the residential element (approx. 250 dwellings) give me concerns with:Additional traffic, drop offs, pick ups and parking. With this number of people living in rented

accommodation the number of moving vans taking people in and out compared with the space thesite has allocated for this.

Also, without car parking, residents will inevitable rely on taxis, home shopping, supermarketdelivery vans, amazon deliveries, pizza & takeaway deliveries, yodel deliveries etc. Ok, that'spretty normal, but now imagine that for 250 homes (375 people) opposite your living room.

With the residential buildings main reception being located directly opposite TemplebridgeApartments, I can foresee all of these 'quick' drop offs, with engines idling on a near constantbasis.

I also have concerns on the impact to local amenities for example GPs and nursery places. Fromliving in the Redcliffe area for the past 19 years I can tell you the closest GP surgeries areBedminster Family Practice and Broadmead Medical Centre. The number of students alone nowliving in the centre of Bristol are pushing these services to the limit. It's completely irresponsible tocreate new residences, without the support infrastructure they will need (and are entitled to) inplace.

Again I reiterate, I am not against this development in principal, just the size and scale of thecurrent plans. To me the consultation process should be just that, a consultation and dialogue.However my experience with Cubex so far as been that they take it as tick box exercise. In fact,they use the feedback gleaned from the public consultation not to review their plans, but tomitigate for the arguments presented to them in their final planning documents. For them publicconsultation is fact finding, so they know what issues they'll have to defend their application from.

Should any member of the planning team wish to view the proposed site, from my living roomwindow please do contact me. I think the people involved in this decision really need to seedirectly the impact that it will have on real people, living actual lives, not the lovely happy drawingsof imagined people living perfect lives, in their proposed new development.

I thank you for your time.

Sarah Surridge

My reading is that the Temple Back side of Templebridge Apartments will be in shadowat Midday all year roundI want to register my objection to the present plans on the grounds of one or all of the followingmaterial planning considerations:

Material planning considerations can include (but are not limited to):Overlooking/loss of privacyLoss of daylight/sunlight or overshadowingScale and dominanceLayout and density of buildingsAppearance and design of development and materials proposedDisabled persons' accessHighway safetyTraffic and parking issuesDrainage and flood riskNoise, dust, fumes etcImpact on character or appearance of areaEffect on listed buildings and conservation areasEffect on trees and wildlife/nature conservationImpact on the community and other servicesEconomic impact and sustainabilityGovernment policy

Proposals in the Local Development PlanPrevious planning decisions (including appeal decisions)

In my role as Chief Executive of Destination Bristol, I am keen to support this newdevelopment.

I have been impressed with the creation of the Finzels Reach development, by this samedeveloper. This has successfully transformed the adjacent area with high quality office space,apartments and improvements to the public realm.

The proposed new office space at Temple Back will permit the growth of this area as a businesshub while the residential offer will provide much needed additional city centre housing. Theadditional staff and residents will help to support the local businesses and leisure offers furtherincreasing the vibrancy of the surrounding area.

The proposed landscaping and public realm works in and around Temple Back are also to bewelcomed - providing great new areas for visitors and those living and working in the city centre toenjoy.

The area around the Temple Back site has been significantly improved in recent years; thisdevelopment would futher enhance the immediate area and impact positively on the rest of Bristolcity centre.

I am very keen to support these plans for the redevelopment of the former Avon FireAnd Rescue Service site.

My current role is to work with businesses in the Redcliffe and Temple areas to introduce aBusiness Improvement District (BID) which businesses would fund jointly with the aim of improvingthe area in a co-ordinated way. Many of the businesses I have consulted with have expressed howimpressed they are with The Finzels Reach development, by this same developer, and welcomethe redevelopment of this adjacent derelict site.

This area has become an impressive new neighbourhood, with many residents now livingalongside modern sustainable offices with an increasing number of leisure facilities. Thisdevelopment would continue the transformation of the area with additional high quality officespace, apartments and improvements to the public realm - all of which are needed and all of whichwill help to increase the vibrancy of this part of the city centre.

SF-031

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 support the development of the old Temple Fire station I have significantconcerns with the plans submitted to support this planning application.The proposed building will block the sunlight and daylight for a significant number of thetemplebridge apartments. The sunlight and daylight assessment also fails to include the 2 topfloors of templebridge apartments and the impact on the sun terraces and indoors living spaces onthese 2 floors. Similarly to the findings for floors 1-5, the sun terraces and living spaces on floors 6and 7 will also have lighting levels below the BRE guidelines. The residents' privacy will also besignificantly compromised.Building a tall and vast structure on a narrow street, like Temple Back, it will introduce a windmicroclimate. Has this been assessed? The downdraught effect created by the tower block andthe 10 floor huge structure can introduce hazards for the pedestrians crossing Tempe Back.I hope that you will encourage the developers to revise their plans, reduced the height of theproposed buildings in keeping with the surrounding existing buildings and to engage with theresidents of both Templebridge apartments and Ferrymans Court apartments.

Sirs,Lyons Davidson Ltd occupies Bristol House with services and car parking access at the rear of thepremises via Temple Street.

Whilst we support mixed sustainable commercial and residential development in this area, wehave concerns about the impact of proposed highways changes, and in respect of low levels ofparking provision for occupiers and visitors.

The specific proposal to make both Temple Street and Temple Back one-way, is likely tonegatively impact on vehicle access to our service and car parking area as deliveries and cars willhave to travel further around a one-way system, and there is also likely to be increasedcongestion.

I object to this proposal on the grounds that it violates the following policy in the UrbanLiving SPD:

A tall building should not be located where:

- it has a significant negative impact on the amenity of nearby occupiers or on the public realm

I also object to the failures of the developers to properly consult with surrounding residents.

The most severe impacts will be on the residents of Temple Bridge Apartments, as several ofthem have explained in their objections. Densification can be conducted in a more sensitive waythan this. Through imaginative redesign, it will be possible to accommodate the same number ofunits on the site with less severe impacts on the surrounding housing. The Old Ambulance Stationwas a good example of how developers worked with surrounding residents to do that. Thesedevelopers have treated local residents with contempt.

Ferrymans Court, where I live, is located 120 metres as the crow flies from the proposed tower. A"back of the envelope" calculation suggests that the new tower will cast a shadow of roughly 200metres in our direction at mid-Winter, when sunlight is most needed. We were not included on thelist of neighbours notified, nor did we receive the leaflets, which the developers claimed to havesent out. I learned about this development in the press - after the application had been submitted -and then alerted my neighbours.

I support the principle of housing development on this site, which will inevitably be at relativelyhigh densities. I support the aim to minimise car parking, but I cannot support this design.

I would appeal to councillors to reject this application and advise the developers to engage withlocal residents and submit a revised design, which reduces the impact on surrounding homes.

Planning Application Reference 19/01255/FDemolition of existing buildings to facilitate mixed-use office (Use Class B1) and residential (318Units Use Class C3) redevelopment including amenity spaces and cycle and car provision withvehicular access, servicing arrangements, public realm works and landscaping (Major Application)

Dear Sir,I live in Templebridge Apartments, on Temple Back, and I am a director of the managementcompany for the buildingI want to register my observations and objections following the submission of the above planningapplication to Bristol City Council (BCC).

I fully support redevelopment of the old Temple fire station site, but not as set out at the publicconsultation event on Tuesday 11th December 2018, and as shown in the plans submitted tosupport the planning application.

The plans are, I believe, ignoring many of the points of guidance & good practice set out in theSupplementary Planning Documents (SPD)- Future of Redcliffe (no. 3)- Urban living - Making successful places at higher densities (November 2018)They seem to bear many similarities in respect of the tower block rejected for the site at 21 St

Thomas Street (application 18/04911/F), and the plans will severely affect me personally

I would urge that the plans are carefully evaluated for their alignment with guidance & goodpractice, and in addition for their deleterious effect on adjacent residential buildings and the area ingeneral

The proposals represent a massive over development of the site with respect to its area which willalso strain local community facilities such as retail, leisure, health care, child care and education.The plans do not appear to address any of these issues.It will have a massive impact on transport, and I believe will exacerbate an already very badsituation with presently over loaded roads.

When I purchased my flat August 2009, I did so knowing that the Finzels Reach development wasunder construction, and with the assurance that buildings fronting Counterslip would not exceedthat of the existing adjacent buildings, including Templebridge Apartments. The scale of the areahas been respected before when other redevelopment started back in the 1980's and since then.The latest building, the Aurora office building has also been respectful of the neighbourhood. Thatsense of scale and harmony with the surrounding remaining old buildings and the historic contextof the area will be destroyed by this overwhelmingly large and hyper-dense development

This is now the proposal:PDF image cannot be included - Please see 3 of the Rapley report Appendix 8 "DevelopmentAverage Daylight Factor Contour Drawings

A few years ago, we as residents of Templebridge Apartments were consulted on a previous pre-application enquiry for the redevelopment of the former Temple fire station site. The plans andinformation submitted in support of the pre-application enquiry indicated a development of aroundsix-storeys together with the re-establishment of the road through the site. This proposal wasconsistent with Supplementary Planning Document 3 on the future of Redcliffe.

That SPD includes Townscape policy guidance that expects:T2 Development should be fine grain with strong vertical rhythm to ensure human scale.T3 In instances of the redevelopment of existing large floor plate sites, fine grain developmentshould be wrapped around the ground floor to create active frontages.T4 Developments should respond to the historic context of the area.T5 Building heights should respond to the predominant existing context of 3-6 storeys, and shouldrelate to the site's context, surrounding development and urban design considerations. Redcliffe isnot generally considered an appropriate location for tall buildings.T7 Important views must be maintained.T8 Development near to landmarks and listed buildings should preserve and enhance their setting.All buildings in the vicinity of historic landmarks to be a height which allows the existing landmarkto be dominant, both from near and from more distant views.

I do not believe that the present proposal meets any of these points of guidance. It cannot be saidto:- Be on a human scale - this will dominate all the streets and create canyons for pedestrians- Have an active frontage.- Respond to the historic context- Respond to the predominant existing context- Maintain important views - views of Temple Church & the Generator Building will be severelyaffected- Enhance the setting of the Grade II* listed Generator building

There is guidance for the treatment of the Former Brewery Site (Section 6.10 page 58). Irecognise the proposal is not on the site, but it very close to it and only a few metres away. Closeenough to affect the landmark effect of the Generator Building.

The guidance sets out the aspirations for the area:2. Proposals should be conservation led and retain the listed Generator BuildingI acknowledge the Generator Building is not under physical threat, but it's pre-eminence in thearea will be destroyed, especially by the tower block part of the plans. The visual impact of theGenerator building when approaching from Passage Street and the Eastern harbour side pathfrom Castle Green will be severely reduced by the distraction of the towerSimilarly when approaching from the Victoria Street end of Counterslip, the attractive view acrossthe bridge of the old buildings on the far side, the trees surrounding the Pip & Jay church and OneCastlepark beyond will be obscured6. New build elements should be designed to respect the historic context of the site, especiallyalongside the Floating Harbour.The plans do not, I believe, respect that historic context.7. Create a permeable network of pedestrian friendly streets and spaces which respect the historicplot boundaries which are still very evident within the site.The layout of the development will reinforce the solid and exclusive nature of the present walledold fire station. One road is shown going into the development, but only to serve car parking.

Almost identical guidance (page 46) relating to permeability is given for the nearby Temple areaabout pedestrian links and especially routes through the fire station site. The areas are completelyadjoined along Temple Street

The Planning obligations on page 67 reinforce the concept of routes through the site by theiremphasis on improvements to pedestrian and cycle movement. The obligations also emphasisethe Health facilities requirement that is not addressed by the present plans.

Urban living SPD - Making successful places at higher densities (November 2018)

Turning specifically to the tower block element of the plans located on the corner of Counterslipand Temple Back, I believe this is inconsistent with many of the questions and criteria that a well-designed tower should meet.

Visual qualityQ 3.1 & 3.2 - I do not feel that the tower is well located or that it makes a contribution to the long,mid-range, or immediate views.It is too close to the Grade II* listed Generator Building and the Grade II* listed façade of themunicipal generating station on Temple Back. Both will be dwarfed by the development and,especially the Generator Building by the tower. The landmark nature of both buildings will begrossly diminished.

The locational criteria state that a tall building should not be located where:- it hides or masks the topography of the city- it harms valued views from key vantage-points- it has a detrimental impact on the city's historic environment (see Appendix C)- it has a significant negative impact on the amenity of nearby occupiers or on the public realmThis development seems to fail to meet all of these criteria

Q3.3 - design excellence

This identifies that a "key failing of tall buildings is the way they meet the ground and thereforehow they are perceived/ experienced at the short distance. Ultimately the aim should be to createa public realm with a human scale. Human scale need not necessarily be prejudiced by highbuildings, provided that these are carefully located, and have regard to the effects on themicroclimate. This often involves the following:"- "stepping down a large mass to its neighbours; "- "ensuring that the ground level most relevant to the pedestrian experience is as active andinteresting as possible;"I believe the massive appearance at street level of this development fails to satisfy the aspirationsimplicit behind the failings above, and are similar to some of the reasons given for rejecting the 21St Thomas Street tower.- "mitigating against the adverse impacts a tall building can often make on the microclimate;"the plans seem to risk creating a wind funnelling through the canyon that will be formed by thedevelopment's bulk and the narrowing of Temple Back.

Functional qualityQ3.4 - I feel that the plan for a roof terrace with such a high density of residents in thedevelopment will pose a hazard to passers-by from material that could be dropped from the roof,and the balconies on Temple Back. For me the high density of occupation and likely congregationof people on the roof late into a summer evening both increase the possibility of accidental ormalicious dropping of items from height.

I believe that with the single entrance to the tower, and the one internal stair route, the fire safetyof so many occupants (~250 dwellings) is at severe risk.

Environmental qualityQ3.7 a pleasant, healthy environment for future occupants?The plans show residential spaces opening out on to an internal court on the development createdby its enclosing, excluding layout. The lower levels, especially on the Water Lane end of thedevelopment will get no natural light at all. This can cause mental health issues from living underartificial light.Similarly the development will remove virtually all of the natural light available to residents in myblock, Templebridge Apartments. This is acknowledged in the Daylight/Sunlight Analysisundertaken by Rapleys dated March 2019, which was done significantly after the publicconsultation event in December.

This fails to have adequately assessed the number of affected dwellings in TemplebridgeApartments through lack of available accurate information. Seemingly with little effort or interest inobtaining accurate information.The report concludes that the reduction in the existing level of natural light in TemplebridgeApartments is acceptable given that the development currently benefits from 'good or well overand above the average levels'!

This seems a perverse assessment by a professional person trying to justify drastically reducingthe existing level of natural light to a level below the minimum levels recommended by the BuildingResearch Establishment on the basis that the existing residential block benefits from 'good or wellover and above the average levels'

The impact on habitable rooms within Templebridge Apartments will be to the detriment of thephysical and mental health and well-being of existing and future occupiers.This reduction of light also seems to fail to comply with Q3.9 about the building being neighbourly.The report rather mendaciously states that Templebridge Apartments is 'likely' to be impacted onby the proposed development.

When planning permission was granted for Templebridge Apartments, during the constructionphase and for about 7 years after that, Temple fire station was operational. There was noindication that the fire station would become available for redevelopment, but the report makescontinued reference to the developer of Templebridge Apartments, together with the occupiers,designer and the local authority, that they "must have taken into account the likelihood of aneighbouring development". This seems to have great faith in accurately predicting the future.How could we know in 2009 and earlier when the neighbouring building was an operating firestation that in 2019 the site would be planned for redevelopment and on the presently plannedscale?

Q3.9 - will the scheme be neighbourly?As explained above, the apparent disregard of removing the majority of the natural light to ourhomes does not seem very neighbourly

I have other concerns about "neighbourliness" as the number of vehicle movements fromdeliveries, taxis and cars collecting & dropping off people, residents & visitors trawling for parking,removal lorries when flats are vacated and then occupied will I believe lead to vastly increasedtraffic at all hours of the day and night. This will be exacerbated by the location of the layby exactlyopposite Templebridge Apartments. Vehicles stopping & starting, and waiting with idling engineswill not be good for sleep during the summer months, and detrimental to air quality all year round.

The location of the single entry to the tower block again, exactly opposite TemplebridgeApartments gives me grave concern as it will be a meeting place for people, and stopping point(illegally) for vehicles. Given the ~250 dwellings, the arrival and departure of people is likely tostart very early in the day and go on late into the night.

I hope that my comments are relevant and give you more information on which to assess the plansfor their acceptability or not

Thank you for your attention

Dear Sirs,

As a resident of Templebridge Apartments and a Director of the Templebridge Apartments (Bristol)Management Company, I would take this opportunity to provide the following observations andobjections following the submission of the above planning application to Bristol City Council(BCC).

IntroductionMay I begin by stating that I fully support the principle of the redevelopment of the former Templefire station site, just not in the form displayed at the public consultation event, held on Tuesday11th December 2018, nor indeed as shown by the plans submitted in support of the planningapplication.

The proposals represent a massive over development of an unsuitable site in terms of its areawhich is also unsustainable in terms of local community facilities such as retail, leisure, healthcare, child care and education.

When I purchased my apartment in March 2009, I did so in the knowledge that the mixed-usedevelopment known as 'Finzels Reach' was under construction, and that the height of thebuildings fronting Counterslip would not exceed that of the existing adjacent buildings, includingTemplebridge Apartments.I proceeded with the purchase of my property in the knowledge that some natural light would be

lost upon the completion of the Premier Inn hotel and the Aurora office block.

ObjectionI formally object to the proposed development as a resident of Templebridge Apartments and onbehalf of all the existing owners and occupiers of Templebridge Apartments in my role as aDirector of the management company.

My main objection is to the height and density of the proposed development which will significantlyreduce the existing levels of natural light from which habitable rooms within TemplebridgeApartments currently benefit from. The justification that these rooms currently benefit from "toomuch natural light" is simply outrageous and laughable. A more detailed review of theDaylight/Sunlight Analysis submitted in support of the application is provided later in thedocument.

I also have grave concerns with regards to the proposed highway works and a more detailedreview of the Transport Statement submitted in support of the planning application is includedbelow.

During a recent meeting with a representative of Cubex, we suggested moving the 'tower' elementof the proposed development to the corner of Counterslip and Temple Street thereby relocatingthe proposed office use to the Temple Back frontage, a suggestion we repeated to arepresentative of the Bristol Civic Society and Councillor Smith and Councillor Dudd when we metthem on Saturday 6th April 2019. We currently await a response from the developer.

BackgroundMore recently the residents of Templebridge Apartments were consulted on a previous pre-application enquiry submitted to BCC for the redevelopment of the former Temple fire station site.The plans and information submitted in support of the pre-application enquiry indicated adevelopment of six-storeys together with the re-establishment of the road through the site, therebyincreasing its permeability. The current proposals do not include the re-establishment of the roadwhich I consider to be a missed opportunity.

The residents of Templebridge Apartments were recently invited to attend a public consultationevent at which the proposals for the redevelopment of the former Temple fire station site werepresented. We noted that the developer will be seeking planning permission for a mixed-usedevelopment delivering 150,000 square feet of office floorspace together with 310 dwelling units,in accordance with BCAP47 of the Bristol Central Area plan, which is reproduced below for theavoidance of doubt:

Policy BCAP47: The Approach to Redcliffe9.14.2 In north Redcliffe, outside of the Redcliffe Way area, the key to major change lies in theregeneration of a small number of major development sites that are presently underused, vacant

or derelict, including the former Courage Brewery, the Redcliffe Village site and the Temple Backfire station. The mixed-use redevelopment of these areas has the potential to significantlytransform the economy and appearance of the Redcliffe neighbourhood and deliver significantlyupon the vision, objectives and detailed proposals of SPD3 The Future of Redcliffe, which wasprepared in 2006 with the support of Redcliffe Futures.

9.14.3 In south and west Redcliffe, development opportunities are generally smaller and scarcer,with the exception of the former Bristol General Hospital site. Much of the area is an establishedresidential community supported by a range of local services including convenience shopping. Theapproach to south and west Redcliffe therefore focuses on protecting local services and improvingpedestrian routes across the area rather than delivering major change.

The planning applicant which has been submitted to BCC differs slightly in that is seekspermission for 15,472 square feet of office use together with 318 residential units. During thepublic consultation event, I was told that one of the aims was to expand the 'Finzels Reach''community', however, I note that the application does not include any community facilities.

It was during the public consultation event that we first learned of the ambition of the developer toconstruct a sixteen-storey building directly opposite our homes.

The above policy does not encourage the redevelopment of the former Temple fire station site toinclude a 'high rise' building and I can find no other BCC policy which has been formally adoptedby the elected local Members which encourages 'high rise' development in central Bristol. I wastold at the public consultation event that the height of the proposed building is being driven by oneof BCC's planning officers, a claim that was repeated when we met a representative ofConversation PR and Cubex on the evening on Monday 25th March 2019. Surely the height of aproposed development cannot be determined by a single city council officer? Surely no individualcity council officer has sufficient delegated powers to encourage a 'high rise' development in suchan unsuitable, unsustainable location?

When planning permission was granted for Templebridge Apartments, it is clear that the developerwas told that the height of the development should not exceed that of the existing adjacentbuildings, including the Grade II* Listed 'Generator Building'. I would like to know when BCC'splanning policy for this area of Temple changed to encourage 'high rise' developments and beprovided a link to the associated policy which has been adopted by the local elected Members.

I would also be keen to view a copy of the adopted BCC criteria that a site needs to meet to bedeemed suitable for a 'high rise' development.

Observations Made at Public Consultation EventThere are several observations which I made at the public consultation event, which I considerneed to be formally raised and recorded.

The 'Emerging Context' exhibition board confirmed that BCC has granted planning permission forseveral 'high rise' development near the former Temple fire station site:- Former Central Ambulance Station (17/04267/FUL) - height ranging between 4 and 24-storeys;- The Assembly (16/06195/FUL) - height ranging between 5 and 12-storeys; and- Redcliff Quarter (16/02349/FUL) - height ranging between 8 and 22-storeys.

I note that none of the sites 'allocated' for 'high rise' development overlooks existing residentialdwellings. During the public consultation event, I enquired as the results of the light and shadowsurvey and was told that one had not been undertaken, a response which I found to be incredible.How can you possibly consult existing local residents without being fully aware of the effect thatthe construction of a sixteen-storey building will have on the levels of natural light from which theycurrently benefit?

When the light and shadow survey is undertaken, it will clearly demonstrate that most of thenatural light currently being enjoyed by the residents of Templebridge Apartments will be lost, tothe detriment of their physical and mental health and well-being. Should the proposals be takenforward to a full planning application, this will surely prompt BCC officers to recommend refusal ofthe proposed development.

The proposed development will also have a negative effect on the value of our properties asnobody will be interested in purchasing an apartment which is continually in shade.The proposed sixteen-storey will also overshadow the 'Generator Building', a Grade II* listedstructure, which first opened in 1899 and remains one of Bristol's iconic buildings which will bedominated by the proposed works.

During the public consultation event, I was told that the proposed development is essentially acontinuation of 'Finzels Reach' to create a community, however, the developer is not proposing toprovide any community facilities which is surely an oversight on their part?

The representative of Cubex also stated that the main entrance to the residential units was chosenas being on the corner of Counterslip and Temple Back as this is 'thought' to be the point at whichoccupiers would arrive. However, the developer is proposing to provide only 15 off-street carparking spaces, meaning that the majority of future occupiers will be expected to arrive by publictransport and walk to the development from either Bristol Temple Meads railway station or Bristolbus station, suggesting that the main entrance is not ideally located to receive them.

Assuming that the main entrance provides access to all the proposed 310 residential dwellings, itis fair to assume that around 620 future occupiers will use the main entrance which will causenoise and disruption to existing residents where currently none exists.

I appreciate that BCC's adopted car parking standards are a maximum, however, the provision of

15 off-street car parking spaces is most definitely an insufficient number, as it represents a singlespace per 20 flats. The proposed development will generate a significant number of vehicular tripswhich will lead to drivers circulating the area in search of an on-street car parking space, to thedetriment of local air quality.

I also note that the developer proposes to remove several existing well used on-street car parkingspaces which will be to the detriment of local business.

I assume that, as with Templebridge Apartments, future occupiers of the proposed residential unitsand the office space will not be eligible to apply to BCC for parking permits, which will lead to anincrease in illegal waiting activities.

Bristol City Council - Urban Living SPD Making Successful Places at Higher DensityPart 3 of this document provides 'Guidance for Tall Buildings' and the introduction highlights that:

- A poorly located, poorly designed tall building can have a detrimental impact on the historictownscape of a city like Bristol; and- Tall buildings can put a strain on local transport and social infrastructure.

I completely agree that the proposed development will have a detrimental impact on the historiclandscape of the local area as well as putting a strain on local transport and social infrastructure.

The document continues to state that: "Tall buildings can be poor neighbours, overshadowingsurrounding development and open spaces and putting a strain on local transport and socialinfrastructure" - something I also complete agree with as it is particularly relevant to habitablerooms within Templebridge Apartments as well as the local transport and social infrastructure.

Question 3.1 - 'Is the tall building well located?' recommends:

- C. The impact of tall buildings proposed in sensitive locations should be given particularconsideration. Such areas might include conservation areas, listed buildings and their settings,scheduled monuments and registered historic parks and gardens;- E. Generally speaking, larger sites (2ha and over) offer the greater potential for taller buildings,as these sites are more able to set their own context than smaller sites. Larger sites provide theopportunity to site tall buildings away from existing buildings, and thus protect them from over-shadowing and adverse wind effects;- G. Tall buildings will generally be discouraged on physically constrained sites within existing builtup areas, where a tall building is likely to have a negative impact on the daylight and sunlightpenetration into the habitable rooms of existing buildings, or onto well used parts of the publicrealm; and- H. Stand-alone tall buildings (i.e. buildings that do not form part of a block and street structure)will also be discouraged.

Whilst all of the above points are relevant to the proposed development, points G and H areespecially salient and I would draw your attention to these.

Question 3.2 - 'Does the scheme make a positive contribution to the long range, mid-range andimmediate views to it?' recommends:

- When siting a tall building, it will be important early on to test out a range of long-range, mediumrange and local viewpoints to understand the suitability of a site to accommodate a tall building.This should be undertaken in line with guidance from both Historic England and the LandscapeInstitute.

There is no evidence that the developer has undertaken the tests recommended by the SPD.

Figure 12 - Locational Criteria states that "a tall building should not be located where":

- It hides or masks the topography of the city;- It harms valued views from key vantage-points;- It has a detrimental impact on the city's historic environment;- It has a significant negative impact on the amenity of nearby occupiers or on the public realm;- It has a negative impact on existing nearby renewable energy systems; and- There is insufficient transport, utilities or community infrastructure to support a more intensiveform of development.

Again, whilst all of the above are relevant to the proposed development, I would particularly drawyour attention to bullet points 4 and 6 which are especially salient.

Question 3.4 - 'Does the scheme ensure the safety of occupants and passers-by?' includes anumber of recommendations, the most salient of which are included below:

- B. Careful consideration of public realm and landscape design around the base of tall buildings toensure access by emergency vehicles and easy evacuation and muster points; and- C. The preparation of a Fire Statements/strategy produced by a third-party independent suitablyqualified competent professional for consideration by Building Control or should therecommendations of the Hackitt Review be adopted, by the Joint Combined Authority (JCA).

There is no evidence that the developer has complied with these salient recommendations.

I would respectfully request that the developer has to comply with all of the recommendationscontained within this BCC documents, especially those which are particularly salient to the effecton Templebridge Apartments and the local transport and social infrastructure.

Future of Redcliffe - Supplementary Planning DocumentThis document has been guided by a ground-breaking initiative between BCC and the localcommunity of Redcliffe working together on how the area should be developed. Redcliffe Futuresbrings together local residents, businesses, developers and other agencies in a partnership whereeveryone can have a say about the changes happening in the area.

'Townscape Policy Guidance' T5 is specific in that: "Building heights should respond to thepredominant existing context of 3-6 storeys and should relate to the site's context, surroundingdevelopment and urban design considerations. Redcliffe is not generally considered anappropriate location for tall buildings." The proposed development is contrary to one of the statedobjectives of the Supplementary Planning Document (SPD).

'Movement Policy Guidance' M1 states: "All significant proposals ("major" planning applicationsmust include a Transport Assessment to establish impacts of proposals and identify appropriatemitigation measures." The planning application being considered by BCC is supported by aTransport Statement and not a Transport Assessment as required and is therefore contrary to oneof the stated objectives of the SPD.

'Parking' M17 confirms: "No further residents' parking permits will be issued within the ControlledParking Zone, that are directly linked to new developments, albeit dispensation should be madefor spaces to accommodate disabled individuals, car club initiatives or equivalent."

Paragraph 5.31 of the 'Social Profile and Community' confirms that: "There are presently nodoctor's surgeries in Redcliffe and the two closest surgeries are full. The South West Primary CareTrust believe there is a demand for surgery for two doctors to serve the growing population." Thishighlights that there are insufficient existing health care facilities to accommodate future occupiersof the proposed residential units.

The proposed development fails to address points 3 and 7 of the aspirations for theredevelopment of the Temple area:

- 3. Create a new pedestrian link from Victoria Street past the Cornubia Pub, across TempleStreet, through the Fire station site and on to reconnect into a new section of the riverside walk.This will better reconnect the pub into the urban fabric, as this is currently a hidden and poorlyconnected building. The permeability of the area will also be improved; and- 7. Develop the Fire Station site with a perimeter building. Establish pedestrian ways through thissite to allow ease of permeability as well as vehicle access ways to service the site.

The proposed development fails to consider point 5 of the 'Former Brewery Site', which states: "5.New buildings should respond to the scale of the Generator Building which must be maintained asthe dominant landmark building within the site." The SPD also identifies the view of the 'GeneratorBuilding' as being one which needs to be preserved. The proposed development will dwarf this

Grade II* Listed building such that it will no longer be the dominant landmark building.

Paragraph 7.12 of the 'Planning Applications' section requires major planning applications toinclude a 'Design Statement' which demonstrates how proposals respond to the overall vision forRedcliffe. The integration of townscape, movement, social and economic benefits must be clearlyset out and how the integration of these factors has been addressed. I am not convinced that theapplicant has provided such a document.

Paragraph 7.13. Major applications should provide context drawings and images illustrating theproposed development within the existing surrounding environment, demonstrating how adevelopment has responded to the issues and recommendations contained within this SPD.Again, I am not convinced that the applicant has provided suitable drawings and images.

Paragraph 7.14 requires major planning applications (i.e. large buildings in excess of 1,000 squaremetres, and developments of 10 houses or more) submitted for development within Redcliffe areexpected to include the following information:- Planning Statement (including proposal package of SPD4 obligations);- Sustainable Development Profile;- Transport Assessment;- Travel Plan;- Urban Design Statement;- Landscape Strategy;- Conservation Plan if proposals include an historic building within the Conservation Area and/or alisted building;- Public Art Plan;- Assessment of the impact of the proposals in the light of the findings of a desk-basedarchaeological assessment and evaluation;- Ground Investigation Report; and- A Statement of Community Involvement, including details of involvement events, the issuesraised by the community and how those issues have been addressed within the developmentproposals.

The planning application is not supported by all of the documents requested above and istherefore contrary to the to one of the stated objectives of the SPD.

I would be grateful if the applicant can confirm that they have formally consulted with 'RedcliffeFutures' as their response is not currently available on BCC's Planning Portal.

Consistent Bristol City Council Officer AdviceDuring January 2018, a planning application was made to BCC relating to number 21 St ThomasStreet, Redcliffe, reference 18/04911/F. Under a previous planning application, permission wasgranted for the erection of a nine-storey block of 387 student bed spaces and 270 square metres

of commercial space.Planning application reference 18/04911/F sought to increase the height of the previous approvedbuilding from nine-storeys to a maximum of fourteen-storeys providing over 400 student flats.

BCC officers recommended that the application be refused for five reasons, with the officer'sreport highlighting that by extending the building by five additional storeys it would create adevelopment which is "out of step with the surrounding area and creating harm to the RedcliffeConservation Area."

The report continued: "It is further considered by extending the building by five storeys, a greaterdegree of less than substantial harm would be attributed to the setting of the surrounding heritageassets, including a number of Grade II* and Grade II Listed Building."

As the former Temple fire station site is also located within the Redcliffe Conservation Area, wewould expect officers to provide members of the planning committee with consistent advice withregards to the harm the proposed development will create to the Redcliffe Conservation Area.

We would also expect officers to make members of the planning committee aware of the harm thatthe proposed development will have on the existing Grade II* Listed 'Former Tramway GeneratingStation' on Counterslip together with the 'Central Electric Lighting Station' on Temple Back.

It is also noted that the proposed development of the 13-storey building would also badly affect theview from Temple Church.It is imperative that BCC officers provide members of the planning committee with consistentadvice with regards to two planning application sites, both of which are located within the RedcliffeConservation Area.

The following sections provide observations on the various documents submitted in support of theplanning application.

General ObservationsThe elevation section indicates that the 'tower' element of the proposed development will bebenefit from balconies fronting onto Temple Back, use of which have the real potential to causenoise and disruption directly opposite existing habitable rooms and bedrooms within TemplebridgeApartments.

Material planning considerationsMaterial planning considerations can include, but are not limited to, the following:- Overlooking/loss of privacy- Loss of daylight/sunlight or overshadowing- Scale and dominance- Layout and density of buildings

- Appearance and design of development and materials proposed- Disabled persons' access- Highway safety- Traffic and parking issues- Drainage and flood risk- Noise, dust, fumes etc- Impact on character or appearance of area- Effect on listed buildings and conservation areas- Effect on trees and wildlife/nature conservation- Impact on the community and other services- Economic impact and sustainability- Government policy- Proposals in the Local Development Plan- Previous planning decisions (including appeal decisions)

Whilst all of the above are relevant to the planning application currently being considered by BCC,I consider that points 1, 2, 3, 4 7, 8, 10, 11 , 12 and 14 are especially salient.

Daylight/Sunlight AnalysisThe following section summarises observations made having reviewed the Daylight/SunlightAnalysis undertaken by Rapleys dated March 2019, which is significantly AFTER the publicconsultation event, referencing their paragraph numbers:- Paragraph 1.6 - the author focuses on 'around' five living rooms, failing to identify that five loungewindows also exists on the western elevation of Templebridge Apartments all of which will beimpacted by the development. I fail to see how the author can focus on 'around' five living rooms -surely there are either 5 living rooms, or there are not;- Paragraph 1.6 - appears to conclude that the reduction in the existing level of natural lightTemplebridge Apartments currently benefits from is acceptable given that the developmentcurrently benefits from 'good or well over and above the average levels' which is simplyoutrageous. How can a professional person possibly justify reducing the existing level of naturallight from which Templebridge Apartments benefits from to a level below the minimum levelsrecommended by BRE on the basis that the existing residential block benefits from 'good or wellover and above the average levels'? This statement simply leaves me lost for words given that theimpact on habitable rooms within Templebridge Apartments will be to the detriment of the physicaland mental health and well-being of existing and future occupiers;- Paragraph 1.6 - confirms that Templebridge Apartments is 'likely' to be impacted on by theproposed development.

Surely the results of the of the analysis will indicate whether Templebridge Apartments will or willnot be impacted. Why has the author concluded that Templebridge Apartments is 'likely' to beimpacted - either it will be, or it will not be;- Paragraph 1.6 - when planning permission was granted to the erection of Templebridge

Apartments, during the construction phase and post-construction, Temple fire station wasoperational, comprising a combination of fire appliances and administration staff. There was noindication that the fire station would become available for redevelopment, therefore how can theauthor possibly make continued reference to the developer of Templebridge Apartments, togetherwith the occupiers, designer and the local authority "must have taken into account the likelihood ofa neighbouring development" when the neighbouring building was an operation fire station?- Paragraph 1.6 - as referred to earlier in this document, the residents of Templebridge Apartmentswere consulted on a previous pre-application enquiry relating to the proposed redevelopment ofthe former Temple fire station site. The submitted plans indicated the height of the proposedbuildings being a maximum of six-storeys which is in keeping with the existing structures. Howcould any of the occupiers possibly anticipate a neighbouring development of sixteen-storeyscoming forward?- Paragraph 1.9 - please can the author provide a clear and concise justification for arriving at theconclusion that: "We therefore recommend that the impact 'likely' to be experienced withTemplebridge Apartments should be deemed acceptable 'in this instance' and the proposeddevelopment itself will benefit from acceptable levels of Daylight and Sunlight, given the context ofits location";- Paragraph 1.9 - could the author please expand on why the impact 'likely' to be experienced withTemplebridge apartments should be deemed acceptable 'in this instance';- Paragraph 1.9 - could the author please provide a clear and concise justification for plunging fiveexisting, habitable rooms within Templebridge Apartments, which have been occupied for tenyears, into permanent shadow? Occupiers will become reliant on artificial light to the to thedetriment of their physical and mental health and well-being; and- Paragraph 1.9 - I believe that the author has failed to identify a further five habitable rooms onthe western elevation of Templebridge Apartments which will be impacted by the proposeddevelopment.

The catastrophic extent to which the existing level of natural light currently being experienced byhabitable rooms within Templebridge Apartments is clearly demonstrated by the extract below,which has been reproduced from a document that is publicly available on BCC's Planning Portal:

The observations summarised above are made with regards to the effect of the proposeddevelopment on the Daylight and Sunlight on Templebridge Apartments included within the'Executive Summary' of the Rapleys report. I would very much hope that the summary would ringalarm bells with both BCC officers and elected Members to the extent that the proposeddevelopment should be recommended for refusal given its forecast detrimental effect on aminimum number of five habitable rooms within Templebridge Apartments in so far as it reducesthe existing level of natural light below the minimum recommended by BRE

The following observation are made having reviewed the main body of the Rapleys report:- Paragraph 3.14 - the first floor and sixth floor plans of Templebridge Apartments (undated) onwhich the analysis is based were found via on-line research. What level of confidence does the

author have that these plans are an accurate representation of Templebridge Apartments 'as-built'? Why have plans for the second to fifth floors inclusive not been included in the analysis?- Paragraph 4.4 - Policy DM27 of The Site Allocations and Development Management PoliciesLocal Plan states: "Sunlight and daylight studies may be required for schemes where there isdoubt over the acceptability of their impact on the amenity of existing development." The analysisleaves us in no doubt that the proposed development will have an unacceptable impact on thelevel of natural light from which a number of habitable rooms within Templebridge Apartmentscurrently benefit;- Paragraph 4.4 - the proposed development appears to be contrary to Policy DM27 of The SiteAllocations and Development Management Policies Local Plan, which states: "Proposals for newbuildings will be expected to ensure that existing and proposed development achieve appropriatelevels of privacy, outlook and daylight." The analysis clearly concludes that the proposeddevelopment will reduce the level of natural light from which Templebridge Apartments currentlybenefits to a level below the minimum recommended by BRE - this is simply unacceptable;- Paragraph 4.5 - it appears as if the proposed development is contrary to the 'Tall Buildings inBristol City Centre' policy, which states: "Tall buildings are those that are significantly taller thantheir neighbours and/or significantly change the skyline. Within the city centre, backgroundbuildings tend to be 4-6 storeys high and a tall building would therefore be in the region of 9 ormore storeys. Due to their impact over a wide area, proposals for tall buildings require carefulassessment against Policy BCS21 of the Core Strategy and Policies DM26, DM27, DM29 andDM30 of The Site Allocations and Development Management Polices." I can find no evidence thatthe proposed development conforms with the policies summarised above;- Paragraph 4.6 - agree that the former Temple fire station site is included in the in the BristolCentral Area Plan (2015);- Paragraph 4.7 - SPD3 outlines the 'Vision for Redcliffe': "A sustainable neighbourhood ofcompact, mixed-use development that is human-scale, accessibility to all and respectful of thearea's history and character." There is simply no way that the developer has demonstrate that theproposed development is in any way respectful of the area's history and character;- Paragraph 8.3 - why did the author not take the opportunity of determining the use of rooms onthe sixth and seventh floors of Templebridge Apartments which are referenced in the report as'unknown'. There are habitable rooms at least on the sixth floor which will be impacted by theproposed development and not including these in the analysis makes me question if the report isfit for purpose given that it does not demonstrate the effect that the proposed development willhave on Templebridge Apartments as a whole;- Paragraph 10.14 - perhaps the author would be kind enough to outline the circumstances underwhich the BRE guidelines would not be strictly applied?- Paragraph 12.1 (7) - the majority of affected rooms within Templebridge Apartments arebedrooms with the BRE Report states are 'less important' than other habitable rooms - I reiteratemy earlier point that I believe the author has failed to identify habitable lounge room windows onthe western elevation of Templebridge Apartments which will be impacted by the proposeddevelopment; and- Paragraph 12.1 (7) - A number of existing occupiers of Templebridge Apartments use the 'spare'

bedroom as a study, a point that the analysis fails to identify. I also consider that the constructionof the proposed 'tower' will impact upon the levels of natural from which habitable lounge roomsfronting the north elevation of the building will benefit from, something that has not been identifiedby the analysis.

I am somewhat at a loss to understand why the author makes repeated reference to thehypothetical scenario of Templebridge Apartments being constructed post the redevelopment ofthe former Temple fire station site, as this is not a material concern. Templebridge Apartmentshave been occupied since March 2009 and the analysis really does need to focus on thesignificant impact the proposed development will have on the level of natural light habitable roomswithin Templebridge Apartments benefit from, to the detriment of the physical and mental healthand well-being of existing and future occupiers.

Continued reference to whether Templebridge Apartments would have been designed differently ifthe block had been constructed post-redevelopment of the former Temple fire station site appearsto have no relevance to the planning application currently being determined by BCC.

In summary, the Daylight and Sunlight Analysis concludes that a number of habitable rooms withinTemplebridge Apartments will be impacted by the proposed development, reducing natural lightinglevels below the minimum recommended by BRE. The justification for this is that the existingresidential block currently benefits from 'good or well over and above the average levels' which issimply outrageous.

The reduction in the level of natural light to habitable rooms within Templebridge Apartments willbe to the detrimental physical and mental health and well-being of existing and future occupiers.

I consider that the Daylight and Sunlight Analysis fails to identify existing lounge windows on thewestern elevation of Templebridge Apartments and does not consider the effect on these rooms ofthe forecast reduction in the level of natural light. I also consider that the report fails to identify theeffect the reduction in natural lighting levels will have on habitable rooms which front the northernelevation of Templebridge Apartments.

I would respectively suggest that the justification of the forecast impact on the natural lightinglevels from which habitable rooms within Templebridge Apartments currently benefit, together withthe numerous omissions from the report, are suitable grounds on which the application beingdetermined by BCC should be recommended for refusal.

Transport StatementThe following observations are made having reviewed the Transport Statement (TS) prepared byKey Transport Consultants referencing their paragraph numbers:- Paragraph 1.1 - given the scale of the proposed redevelopment, I am somewhat surprised thatBCC highway officers consider it appropriate that the application is supported by a Transport

Statement (TS) rather than a full Transport Assessment (TA). I would have thought that therequirement for a full TA which considers the effect of additional vehicular trips generated by theproposed development would have on an already saturated local highway network would havewould have been communicated to the applicant during the pre-application enquiry stage;- Paragraph 1.2 - indicates that the proposed office use will be split over eight floors, however, itfails to identify the number of floors over which the proposed residential use will be split;- Paragraph 1.2 - it is noted that 43 off-street car parking spaces will be provided for the proposedoffice use, at a ratio of one space per 33m2, and that 15 off-street car parking spaces will beprovided for the proposed residential use, which includes the provision of six spaces for thededicated use of blue badge holders. It is noted from paragraphs 8.4 and 8.6 that the proposednumber of off-street car parking spaces for both the office and residential uses are below themaximum standard required by BCC's adopted parking standards, however, the reason why thedeveloper considers the proposed number off-street to be satisfactory is unclear;- Paragraph 1.2 - the TS provides no information on whether the proposed off-street car parkingspaces for both the office and residential will be available on a first-come-first-served basis, orwhether they will be allocated, which is a really important point. If they are available on a first-come-first served basis, drivers who arrive at the proposed development site after the car park isfull will trawl the local area in search of a vacant on-street car parking space to the detriment of airquality. This conflicts with the stated aims of BCC to improve air quality in central Bristol, to theextent that the authority is in the early stages of designing and implementing a Clean Air Zone(CAZ) whereby polluting vehicles will be charged to enter the CAZ zone;- Paragraph 1.2 - allocating the proposed off-street spaces for both the office and residential useswill not prevent more vehicles arriving at the proposed application site than can be accommodatedwithin the car park, again to the detriment of local air quality;- Paragraph 1.2 - assuming that the proposed off-street car parking provided for the residential useis allocated, the TS provides no indication as to where parking activities associated with theremaining 303 residential units will be accommodated. There is limited on-street car parkingcapacity in the vicinity of the application site and I note that the applicant actually proposes toreduce the existing number of on-street car parking provision in order to provide a three-metrewide segregated cycleway along the north side of Counterslip, between its junctions with TempleStreet and Temple Back;- Paragraph 1.2 - the TS makes no reference to the fact that future occupiers will not be eligible toapply to BCC for on-street parking permits and there is very limited publicly available off-street carparking available within a comfortable walking distance of the application site;- Paragraph 2.1 - identifies that the area is predominately occupied by commercial offices, butbuildings have a number of other ground floor uses. The TS fails tom identify that there are anumber of residential buildings in the area, including Templebridge Apartments;- Paragraph 2.2 - it is unclear why the applicant proposes to reduce the existing 70 basement carparking spaces to a total of 58;- Paragraph 2.26 - are any highway improvements proposed at the Water Lane / Temple Backjunction where a cluster of collisions involving cyclists has been identified?- Paragraph 2.29 - are any highway improvements proposed at the St Thomas Lane East / Victoria

Street junction where a cluster of six collisions in 36-months has been identified?- Paragraph 3.17 - the existing traffic signal-controlled crossing across Counterslip is a Toucancrossing not a Puffin;- Paragraph 3.17 - states that the existing signal-controlled crossing will be relocated onto a speedtable proposed to be constructed for the whole of the Counterslip / Temple Street junction. Thereason for the proposed raised speed table has not been stated and suggests that there is anexisting problem with the speed of vehicles using Counterslip, however, the recorded 85thpercentile speed is not included within the TS. I am interested in the design of the proposed raisedspeed table as constructing it to the top of the existing full-height kerbline will place vulnerableroad users in direct conflict with motor vehicles;- Paragraph 3.17 - I would also be interested to understand if BCC officers support theconstruction of the proposed raised speed table, including assuming responsibility for its futuremaintenance;- Paragraph 3.17 - Counterslip is a strategic route for the emergency services and vertical trafficmeasures have the potential to exacerbate injuries to patients being transported to hospital byambulance, especially those with spinal injuries and have the potential to have a detrimentalimpact on the response times of the emergency services. When local service bus routes are eitherblocked or closed, Counterslip provides a temporary public transport route and there is evidencethat vertical traffic calming measures cause injury to bus drivers and passengers, especially thoseon the top deck of a double-decker vehicle;- Paragraph 3.5 - should be expanded to confirm if the off-street car parking spaces associatedwith the proposed office use will be available on a first-come-first-served basis or if they will beallocated;- Paragraph 3.7 - as with paragraph 1.2, this paragraph fails to identify the number of floors overwhich the residential units will be split;- Paragraph 3.8 - confirms that the 'Build to Rent' residential units will be served by a singlepedestrian access from Counterslip which has the real potential to cause noise and disruption toexisting residents at all times of the day and night where none currently exists. I would beinterested to see the observation of Avon and Somerset fire brigade with regards to a single pointof access serving 252 residential units;- Paragraph 3.8 - I would also be interested to understand any concerns raised by Avon andSomerset fire brigade with regards to a single point of pedestrian access serving the proposed 66affordable residential units;- Paragraph 3.10 - should be expanded to confirm if the off-street car parking spaces associatedwith the proposed residential use will be available on a first-come-first-served basis or if they willbe allocated;- Paragraphs 3.12 to 3.24 inclusive provide a summary of proposed highway works; however, theplanning application is not supported by a Stage 1 Road Safety Audit in accordance with GG119or a 'Response Report' produced by designer. How can a combination of BCC elected Membersand officers provide comment on the suitability of the proposed highway works withoutunderstanding their potential impact on highway safety?- Paragraphs 3.12 to 3.24 inclusive - should BCC elected Members be minded to grant planning

permission subject to the construction of the proposed highway works being a Condition attachedto the planning permission, there is a real possibility that the checking of the detailed designpackage will identify problems with the proposed highway works which mean that the applicanthas secured planning permission that they are unable to implement;- Paragraphs 3.12 to 3.24 inclusive - has any micro-simulation modelling been undertaken whichdemonstrates the effect of the proposed highway works on the operation of the local highwaynetwork. Is it not unusual to see traffic using Counterslip and Passage Street stationary in bothdirections for the full length of both roads, especially during the pm peak period when VictoriaStreet and Temple Way are heavily congested. This also occurs when the M32 motorway is eithervery busy or closed;- Paragraphs 3.12 to 3.24 inclusive - reducing the width of Temple Back and making it one-waynorthbound removes the ability for a fire engine responding to an emergency call to pass anobstruction in the carriageway, be it a parked vehicle or a vehicle which has broken down, whichhas the potential to have a detrimental effect on response times, endangering lives and property- Paragraph 3.13 - the proposed segregated cycleway along the north side of Counterslip,between its junctions with Temple Street and Temple Back, is located to the rear of three maturetrees and across the existing vehicular access to 'Finzels Reach' underground car park. The 'treepits' are constructed from loose material which increases the risk of cyclists becoming unseatedresulting in injury and the presence of the existing vehicular access places vulnerable road users(pedestrians and cyclists) in direct conflict with motor vehicles;- Paragraph 3.14 - is the proposed retained carriageway width of six-metres sufficient to safelyaccommodate opposing vehicles given that Counterslip is a popular route for heavy goodsvehicles, coaches accessing the various hotels in the area and buses when their scheduled routeis closed?- Paragraph 3.17 - the location of the existing Toucan crossing on Counterslip, east of its junctionwith Temple Street, is contrary to national advice and the proposal to make Temple Street one-way southbound rather conveniently addresses this point;- Paragraph 3.19 - I assume that the proposed Zebra crossing will replace the existing centralpedestrian refuse island which has been the cause of a number of collisions. Can the applicantdemonstrate that they are able to achieve the required Stopping Site Distance to the proposedZebra crossing in both directions given the vertical alignment of the carriageway?- Paragraph 3.19 - The TS does not include proposed measures to prevent light spillage from theflashing Belisha Beacons which will be required at the proposed Zebra from causing a nuisance tohabitable rooms on the northern elevation of Templebridge Apartments;- Construction Phasing - it is imperative, should BCC elected Members be minded to grantplanning permission, that all construction activities be accommodated with boundary of the site.During the construction of the Premier Inn hotel and the Aurora office building, heavy goodsvehicles used the east side of Temple Back as a marshalling yard. Templebridge Apartmentsresidents regularly woke to fine several heavy goods vehicles waiting on the east side of TempleBack with their diesel engines running which prevented us from opening our windows, which wasespecially inconvenient during the summer months.The residents of Templebridge Apartments reported this to BCC planning enforcement on several

occasions only to be told that there was nothing they could do, which was simply unacceptable;- Construction Phasing - should BCC elected Members be minded to grant planning permission, Iwould expect one of the Conditions to request a detailed Construction Management Plan (CMP)which must take account of the application site being in close proximity to a number of residentialunits and insist that the applicant abide by the CMP;- Paragraph 4.10 - agree that paragraph 109 of the National Planning Policy Framework February2019 states that "Development should only be prevented or refused on highway grounds if therewould be an unacceptable impact on highway safety, or the residual cumulative impacts on theroad network would be severe." Vehicles trawling the area in search of on-street car park as aresult of the lack of proposed off-street car parking, no Road Safety Audit and no modelling of theeffect of the proposed highway improvements mean that, as things stand, the applicant is unableto demonstrate the effect that the proposed works will have on the local highway network and Iconsider that there are material grounds for officers to refuse the application on highway safetygrounds;- 5. Accessibility to Homes, Shops and Services - this section of the TS fails to identifyaccessibility to local health care, child care or education facilities or that the applicant has been intouch with local providers to determine that they have sufficient spare capacity to accommodatefuture occupiers of the proposed residential units;- Paragraph 6.3 - as predicted when I met Councillor Smith and Councillor Dudd, the applicant hasused TRICS to precure trips rates based upon the number of car parking spaces rather than thearea of the proposed office use and the number of residential units. I have undertaken my ownTRICS assessment on the basis of the area of the proposed office use and the number ofresidential units which is reproduced below:- The TRICS summary above demonstrates that the number of arrivals and departures forecastare significantly more than those forecast by the TS and I therefore question if trip rates based onthe proposed number of off-street spaces is appropriate;- Templebridge Apartments is a prime example where the 22 apartments generate significantlymore vehicular trips during the am peak period, pm peak period and on a daily basis than the 12off-street car parking spaces provided. This is due to the occupiers of the one-bed apartmentsowning at least one car, despite not being allocated an off-street car parking space, together withoccupiers of a number of the two-bedroomed apartments owning more than one car;- This observation applies to a number of existing office and residential uses in the vicinity of theapplication site;- Paragraph 7.4 - a loading bay is proposed to be constructed on the west side of Temple Back toaccommodate 'day-to-day deliveries', however, the proposed location is directly opposite theexisting pedestrian access to Templebridge Apartments and has the potential to cause nuisanceto existing residents. Given the existing loading only bays to be retained on Counterslip, is theproposed loading bay on Temple Back actually necessary? If it is, could the proposed location bereconsidered?- 8. Parking - I have set out my observations with regards to the proposed off-street car parkingprovision earlier in this section;

In conclusion, I consider that there are a number of points which the TS does not adequatelyaddress, which I why I raise an objection to the proposed development on highway safetygrounds. A copy of this letter of objection will be copied to the applicant, the elected Members whorepresent the Temple ward and the local Member of Parliament.

SummaryIn summary, I formally object to the proposed development as a resident of TemplebridgeApartments and on behalf of all the existing owners and occupiers of Templebridge Apartments inmy role as a Director of the management company.

My main objection is to the height and density of the proposed development which will significantlyreduce the existing levels of natural light from which habitable rooms within TemplebridgeApartments currently benefit from. The justification that these rooms currently benefit from "toomuch natural light" is simply outrageous and laughable.

I would respectfully request that the developer has to comply with all of the recommendationscontained within the 'Bristol City Council Urban Living SPD Making Successful Places at HigherDensity' document, especially those which are particularly salient to the effect on TemplebridgeApartments and the local transport and social infrastructure

The planning application is contrary to a number of stated aims and objectives of the 'Future ofRedcliffe - Supplementary Planning Document'.

BCC officer advice in respect of planning application reference 18/04911/F relating to number 21St Thomas Street, Redcliffe was that the proposed increase in the height of the building which hadplanning permission would create a development which is "out of step with the surrounding areaand creating harm to the Redcliffe Conservation Area."

The report continued: "It is further considered by extending the building by five storeys, a greaterdegree of less than substantial harm would be attributed to the setting of the surrounding heritageassets, including a number of Grade II* and Grade II Listed Building."

As the former Temple fire station site is also located within the Redcliffe Conservation Area, wewould expect officers to provide members of the planning committee with consistent advice withregards to the harm the proposed development will create to the Redcliffe Conservation Area.

We would also expect officers to make members of the planning committee aware of the harm thatthe proposed development will have on the existing Grade II* Listed 'Former Tramway GeneratingStation' on Counterslip together with the 'Central Electric Lighting Station' on Temple Back.

It is imperative that BCC officers provide members of the planning committee with consistentadvice with regards to two planning application sites, both of which are located within the Redcliffe

Conservation Area.

The Daylight/Sunlight Analysis concludes that the construction of the proposed development willreduce the level of natural light from which the five identified habitable rooms within TemplebridgeApartments will benefit from will be below the minimum levels recommended by BRE. This willresult in existing and future occupiers relying on artificial light all day every day to the detriment oftheir physical and mental health and well-being. This is simply unacceptable.

The Daylight/Sunlight Analysis fails to identify existing lounge windows on the western elevation ofTemplebridge Apartments and therefore does not consider the effect that the reduced level ofnatural light will have on these habitable rooms.The Daylight/Sunlight Analysis does not identify the use of rooms on either the sixth or seventhfloor of Templebridge Apartments therefore it does not consider the effect on the reduced level ofnatural light will have on these habitable rooms.In short, the Daylight/Sunlight Analysis is essentially incomplete and does not demonstrate howTemplebridge Apartments as a whole will be impacted by the significantly reduced levels of naturallight. I would respectfully suggest that theDaylight/Sunlight Analysis provides insufficient information to allow BCC elected Members andofficers to make an informed decision and that the application should be refused as it will have aseverely detrimental effect on existing residents.

The level of proposed off-street car parking spaces for both the office and residential use is simplyinsufficient and the TS acknowledges that the proposed provision for both uses is below standard.This, coupled with the proposed reduction in the existing number of on-street car parking spacesin the vicinity of the application site, will result in cars trawling the local area to the detriment oflocal air quality. This appears to conflict with the stated aims of BCC to improve air quality incentral Bristol, to the extent that the authority is in the early stages of designing and implementinga Clean Air Zone (CAZ) whereby polluting vehicles will be charged to enter the CAZ zone;

The planning application is not supported by a Stage 1 Road Safety Audit, in accordance withGG119, which demonstrates that the proposed highway works are safe. A 'Response Report'prepared by the designer has not been provided.

No micro-simulation modelling has been undertaken to identify what effect the proposed highway'improvements' will have on the safe operation of the adopted public highway.

Forecast traffic generation is based on trip rates derived from the proposed number of off-streetcar parking spaces and not from a combination of the area of the proposed office use and thenumber of proposed residential units. The forecast traffic generation is low when compared to myown assessment and there is no evidence that the existing congested local highway network hassufficient spare capacity to safely accommodate the predicted number of additional vehicle trips.

In short, I consider that the TS submitted in support of the planning application does not providesufficient information to allow BCC elected Members and officers to make an informed decisionand that the application should be refused as it has not been demonstrated that the proposeddevelopment will not result in an unacceptable impact on highway safety, or that the residualcumulative impacts on the road network will not be severe.

Dear Sirs,

Since uploading my initial letter of objection to the Bristol City Council (BCC) planning portal, myattention has been drawn to previous planning application reference 18/01890/F, which relates to'The Bell' Public House, 7 Prewett Street Bristol BS1 6PB.

The application sought permission for the demolition of existing buildings to provide residentialdwellings (Use class C3), commercial retail space (Use Class A1) and community facilities (UseClasses D1/D2) with associated landscaping and works.

The planning case officer recommended that the application was recommended for refusal, asfollows:

REASONS FOR REFUSAL:

1. Urban DesignThe proposed development, by reason of its siting, scale, massing, urban form and architecturaldetailing fails to contribute positively to the urban character and identity of the area and as suchfails to create or reinforce local distinctiveness. The proposed development is therefore contrary topolicies BCS2, BCS20 and BCS21 of the Core Strategy (2011); policies DM26, DM27 and DM29of the Site Allocations and Development Management Policies (2014); policy BCAP47 of theBristol Central Area Plan (2015) and the provisions of the National Planning Policy Framework.

2. Heritage AssetsThe proposed development, by reason of its siting, scale, massing, urban-form, detailed designand architectural detailing represents harm to both designated and non-designated heritageassets. This includes the Grade I listed St Mary Redcliffe Church, Grade II listed assetssurrounding St Mary Redcliffe, including those on Colston Parade and Redcliffe Parade, and thecharacter and appearance of the City Docks Conservation Area. The non-designated assetsharmed by this development include the Redcliffe Estate and the complete loss of the Bell publichouse. There is a lack of robust justification for the proposed works, or evidence suggesting thatwider public benefits will be secured such that would outweigh the identified harm to the heritageassets identified above. The application is subsequently contrary to guidance contained withinSections 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990; Section16 of the National Planning Policy Framework (2018); policy BCS2, BCS22 of the Core Strategy(2011); and policy DM31 of the Site Allocations and Development Management Policies (2014).

3. Landscaping and loss of treesThe proposed development includes the provision of a substandard landscaping scheme whichwould result in a public realm of reduced quality. The development also includes the loss ofmature trees that currently make a significant contribution to the character and appearance of thearea. As such the proposals are contrary to policies BCS9 and BCS21 of the Core Strategy(2011); and policies DM15, DM17 and DM28 of the Site Allocations and DevelopmentManagement Policies (2014).

4. Residential AmenityThe proposed development, by reason of its siting, scale, massing and urban form would prejudicethe levels of daylight currently experienced by the existing residents of both Corinthian Court andMagdalena Court. In addition, the proposed development would appear as an overbearing,oppressive structure for these residents. As such the proposals would materially harm theamenities of existing residents contrary to policy BCS21 of the Core Strategy (2011); policiesDM27 and DM29 and the provisions of the National Planning Policy Framework5. Living ConditionsThe proposed development, by reason of its design to incorporate large numbers of single aspectdwellings, in addition to creating a number of dwellings that fail to meet BRE daylight standards,has failed to provide adequate living conditions for future residents. As such the proposals arecontrary to policy BCS21 of the Core Strategy (2011); policies DM29 of the Site Allocations andDevelopment Management Policies (2014) and the provisions of the National Planning PolicyFramework.

6. Dwelling MixThe proposed development consists entirely of one and two bedroom flats and in so doing fails toprovide any family sized homes. As such the proposals are contrary to policy BCS18 of the CoreStrategy (2011); and policy BCAP3 of the Bristol Central Area Plan (2015).

7. Transport and MovementThe proposed development is unacceptable for the following reasons:

The proposal does not include improved facilities for the bus stop on Somerset Street and itconflicts with the proposed loading bay;- No effective waste collection facilities are provided;- The cycle parking proposals are inadequate;- The loading and servicing facilities are inadequate;- The facilities provided for pedestrians and cyclists are inadequate and would not create anacceptable public realm- The travel plan has not been approved; and- There is no disabled parking on site. 6 disabled bays are required.

For these reasons the proposals are contrary to policies BCS10 and BCS13 of the Core Strategy(2011); and policies DM23 of the Site Allocations and Development Management Policies (2014).

8. Nature ConservationIn the absence of an up-to-date bat survey, the proposed development fails to comply with policyDM19 of the Site Allocations and Development Management Policies (2014) which requires thatdevelopment likely to have any impact upon habitat, species or features which contribute to natureconservation is expected to be informed by an appropriate survey and assessment of impacts

The planning application was refused permission.Whilst not all of the reasons for refusal are applicable to the planning application currently beingconsidered by BCC officers, officers recognised that the "The proposed development, by reason ofits siting, scale, massing and urban form would prejudice the levels of daylight currentlyexperienced by the existing residents of both Corinthian Court and Magdalena Court. In additionthe proposed development would appear as an overbearing, oppressive structure for theseresidents. As such the proposals would materially harm the amenities of existing residentscontrary to policy BCS21 of the Core Strategy (2011); policies DM27 and DM29 and the provisionsof the National Planning Policy Framework."

As per my initial letter of objection, I would ask that BCC officers provide consistent advice whendetermining the planning application for the redevelopment of the former Temple fire station.

As Director of Friska which has several stores and our HQ in close proximity to theproposed redevelopment of the fire station I thoroughly support this project. We have built ourbusiness from our first store on Victoria St, BS1 6BY and a large part of our success and thesuccess of our business has been the continued development of the city centre, attracting high-quality office occupiers, resident and amenities. We believe this area is really in need ofredevelopment which would further help with the economic renewal that this part of the city hasseen over the past 10 years.

Ed Brown, Co-Founder, Friska Ltd

Site suitable for redevelopment but present proposal is out of character and far too high- a substantially lower proposal could be welcome.

The proposed building seems too high as it will affect the light and views of surroundingapartments.

As Manager of The Galleries Shopping Centre I am fully supportive of this application.We have watched with interest the surrounding area being developed over the past few years andthis further plan can only enhance the overall city centre as a whole. To bring employment andalso residents living just over the river will help to keep the main shopping area vibrant and this isimportant for the city. In addition the public realm works planned will help reinvigorate thisparticular area. Therefore I support this wholeheartedly.

I am writing to object to this proposal as an owner of a property within the TempleBridge Apartments. My primary objection to this proposal is the loss of light that will result andconsequent degradation in the quality of life of those living within the apartments.

I have studied the application in detail and in particular the daylight and sunlight analysis report asprepared by Rapleys LLP. I note that, if the development were permitted, parts of my apartmentwould then have lighting levels below the BRE guidelines where currently they exceed therequirements. Indeed the report indicates that 77% of the rooms facing the development will havelighting levels that no longer meet the BRE guidelines. These guidelines were introduced for areason and should not be summarily dismissed by the developer. The proposed development, ifapproved, would represent an unwanted loss of amenity to myself and similarly affected owners.

It should be noted that the report fails to take into account the impact upon the sun terraces thatare present on the affected elevation. These currently offer access to the early evening sunlight forthose returning from work. This amenity will be completely lost for if the proposal is approved.

As noted within the report, Bristol's Quality of Urban Design Policy BCS21 makes the followingstatement:4.21.13 A high quality built environment should consider the amenity of both existing and futuredevelopment. Consideration should be given to matters of privacy, outlook, natural lighting,ventilation, and indoor and outdoor space.

It is difficult to see how depriving the owners of natural light complies with this requirement.

In mitigation the report suggests that as some of these rooms are bedrooms they are lessimportant. However on each floor at least one of these rooms is a living room so some ownersface the possibility of a reduction in light throughout their apartments. Furthermore in these days ofhome working many people use bedrooms as both living and sleeping space.

The report also suggests that in mitigation I should have foreseen this possibility at the time ofpurchase, however I fail to see how that is possible given that I bought my apartment severalyears before the planning application was submitted to rebuild the fire station, the local authorityplan for the area makes no suggestion that any buildings in the vicinity would be of such a scaleand all of the surrounding Finzels Reach development is of a comparable height and scale toTemple Bridge Apartments.

The cut back analysis within the report makes it clear that the cause of the problem is that thebuilding is greater than 6 floors i.e. if the scale of the development were restricted to that of thesurrounding properties there would be no impact. It is therefore clear that the unreasonable scaleof the proposal is the cause of the problem.

It should also be noted that the impact of the proposal on Temple Bridge Apartments has beenexacerbated by reducing the distance between it and the old fire station. The developerssubmitted plans show the distance between the existing property and the apartments to be17.75m whilst the separation of the proposed building is only 15m. This is a reduction of 15%which is significant in the context of the resulting loss of light. I note that Radleys' study does notconsider the aspect of restricting the building line within its cut back analysis. In addition to theloss of light there is also the aspect that reducing the distance makes the proposed buildingappear to loom over the apartments as is clear in the shadow analysis. The psychological aspectof living under the shadow of this building should not be dismissed.

In conclusion the development represents a very substantial increase in the housing densitycompared to the surrounding properties and if approved would signal a race to the bottom in thisregard. The report also rather disingenuously suggests that if the proposed building had been builtbefore Temple Bridge Apartments this would not have affected the development of theapartments. I suggest that had this been the case the proposed apartment block would be of asimilar height and scale as that being proposed for the fire station as, if you were to approve, thiswould be giving a green light to tower blocks within this area therefore encouraging developers toover exploit the opportunity as is the case here.

I ask that the currently submitted application be refused and the developer advised to resubmitwith the building separation restored and of a height commensurate with the other buildings in thearea.

The building is going to block out the sun to my flat which I only bought 6 months ago.One of the main reasons for buying this flat was the sun shining onto my balcony. How can thispossibly be allowed to go ahead?

I'm truly outraged.

As a resident in the building adjacent to this proposal I wish to lodge an objectionagainst the proposed plans. Little communication has been made and little effort taken to ascertainthe effects on residents of the Templeback community. This is despite the extremely significantimpact the proposals will make upon light quality, accessibility and the potential impact upon thevalue of properties in the vicinity.

This is a busy part of the city centre with limited parking given council changes made inSeptember 2018. The proposals to change road layouts and sizes, plus the additional loss of onstreet parking will cause severe disruption to residents and will likely impact surrounding trafficflow and commercial businesses in the area. The impact of deliveries to residents at the newbuilding alone will block up the proposed 1 way system with regularity. Given the building workthat regularly takes places and results in vans being parked in the area, the problem will be furtherexacerbated.

The light impact will severely effect the quality of life for residents of Templebridge, Ferryman'scourt and Finzel's reach. That such a proposal can be entertained is a descredit to what claims tobe a forward thinking council such as Bristol with a green agenda looking to develop Bristol as acultural city.

proportions of the surrounding streetscene and to the detriment of the visual amenities of the area - it should be in keeping with other recent developments as it is very near the waterside amenity that is part of Bristol's tourist attraction - this type of development will adversely affect the character of the area to the detriment of lifestyle, external amenity and tourist income for local businesses. We also object to the extremely low level of car parking allowed for in the development - this will lead to serious congestion in terms of on street parking and traffic driving round looking for places to park, impacting on air quality and safety.We also believe that this scale of residential accommodation in this area is simply not supported by the infrastructure - e.g. schools, doctors, dental surgeries, child care, etc. We would ask that planning permission for this development (as it stands) be denied for the above reasons.

Dear Bristol Council,

I am writing to express my concerns at the nature of the proposed development 19/01255/F. WhileI do not object to the height of the proposal or to basic plan of building more offices andapartments in this part of Bristol, I must object to the design and lost opportunity the buildingrepresents. The visualisations imply a building that is uninspiring and devoid of visual orarchitectural merit. Individually such considerations may seem indulgent but taken together theyare crucial to the fabric of the city, and the kind of place it will become to live and work. We mustnot be afraid to demand better from developers.

I have further concerns regarding the lost opportunity to showcase development truly fit for the21st century. Despite the intention that the development will be BREAM rated 'excellent' and willcontain solar panels and be connected to the district heating system, this is a building that willexist long into a future which will need to be zero carbon, and should be built to proper zerocarbon standards.

Similarly we are in the midst if an ecological crisis. Bird, insect, and mammal populations are allcollapsing. Hedehogs may be functionally extinct in the south west. Swifts, starlings, sparrows andsongbirds are all in steep decline. All new developments must be required to do what they can toaddress this - for example through the use of greenwalls, interconnected gardens and biophilicdesign to provide spaces for wildlife to live amidst the steel and glass. The current plans merelystate that the 'masterplan conforms with the ecological strategy' and that mitigation measures will

be taken. There is no indication of what these will entail. Again, we must not be afraid to demandbetter, and demand that all new developments make it possible for life to exist alongside them inour cities. What really is the alternative? We cannot continue as we are.

Sincerely,

Alasdair Cameron