I am concerned for No 21 Bramble Drive regarding the issue of land.I am also concerned regarding the effects to neighbouring property.

The proposals are totally out of keeping with the Sneyd Park Conservation Area and theconcreting over of the site would result in the lack of soak away for rain, resulting in floodingfurther down the hill. This could ultimately affect the lake and Nature Reserve.

I object strongly to this application, and agree with other objectors in their submissions.

I write as Chair of the Sneyd Park Residents' Association (SPRA) and fully object to theapplication.SPRA fully understands residents may wish to alter properties, but this application goescompletely against the Sneyd Park Conservation Area.

Before I list SPRA's objections, I wish to remind Planning that in early March 2021 trees werefelled without planning permission (Section 211 notices) and Planning Enforcement (Nigel Butler)was notified by various residents.

SPRA's objections are shown below:-

1. Neighbours have not yet been formally notified by Planning; however assume this will behappening.2. No Arboricultural Survey and/or Environmental Impact Assessment has been supplied.3. The plans do not take into account neighbouring properties or show any form of impactassessment on neighbours.4. Plans show balconies with no regard to loss of privacy to neighbours.5. Plans show trees and shrubs but these appear to be in neighbours' gardens and not the gardenof the property.6. Whole site under the application is basically being built on, again against Sneyd ParkConservation Area key characteristics.7. No consideration has been given to neighbours' trees and hedges, which would inevitably beaffected by proposed works.

8. 21 Bramble Drive comment should be noted "My objection arises from what I say is inaccuracyin the location plan 21_00235_HLOCATION_PLAN-2859189.pdf and other documents that mightdepend on it, showing an area of land to which we have Title, this being at the SE end of ourproperty"9. No proposed landscaping scheme has been shown, which indicates using neighbours' borderhedges and trees as landscape.10. Proposed floor plans do not appear to be consistent for example showing of gym.11. No drainage details are shown, and this is of concern for water runoff into neighbours plus lackof consideration in recycling water into ground to preserve neighbours' trees.12. No ground works details are shown.13. No consideration to local wild life being taken into account. Example would be the deer, whichuse these gardens and SPRA can supply photographs to this fact.14. Proposed application fails to meet requirements of policy DM 26 and DM 27.

In conclusion, SPRA would urge the applicant to withdraw the application, as it is not in keepingwith the Sneyd Park Conservation Area and bring forward a fresh application in keeping with thecharacter of the Conservation Area and which properly respects the existing host property.However, if the applicant is not minded to withdraw his application, I would ask Planning to takeinto account all points raised and robustly refuse the application. I would also raise a concern atthe felling of trees without prior S211 notices, which needs to be considered.

Kind regards,Stephen SmallChair of SPRA

This Application is an example of how things can go very wrong with planningregulation.The Applicant stated on the Application Form that trees would be affected by this development,but the Applicant submitted no Arboricultural report or arboricultural impact statement, as required.Where is the Arboricultural report required to accompany the Application Form? It is a bit late nowbecause on 8th March 2021 a massive tree clearance of the site took place and was reported toPlanning Enforcement.A complaint to Planning Enforcement was made to the effect that trees to facilitate developmentwere being felled in advance of any planning consent and in the absence of an arboriculturalimpact statement. The reply from Planning Enforcement was "the tree removal will be properlyconsidered including testing against policy about replacement. It is of course regrettable that thelandowner has worked on trees ahead of permission being granted but other than to address thematter through the above planning application we propose no further action".Others who complained were told, on 9th March, that the case officer would undertake a site visitand robustly challenge the landowner about recent works to trees". I really hope that thishappened.The loss of trees to facilitate development requires mitigation under the Bristol Tree ReplacementStandard. I truly hope that there is with the Arboricultural Officers in the Planning Department ofBCC a record of the trees that WERE on the site. Images are available on Google Earth etc. Allthis tree loss is to the detriment of the Conservation Area's character and to the quality of theenvironment.It is not just about mitigation for tree loss either. Bristol has a planning policy - BCS9 - that statesthat green infrastructure will be retained wherever possible - and "planned around" if possible.

"Individual green assets should be retained wherever possible and integrated into newdevelopment." With tree clearance prior to planning consent there has been no opportunity toconsider this.One might weep at the answers to the two "tree" questions on the Application Form"Are there trees or hedges on the proposed development site? Yes No""and/or: Are there trees or hedges on land adjacent to the proposed development site that couldinfluence the development or might be important as part of the local landscape character? YesNo"These two answers should now be phrased in the past tense. Even the two remaining Silver Birchtrees are apparently doomed. The importance of the local landscape character has been ignored.Planning Consent procedures with reference to existing trees have been ignored.If consent is granted, please ensure mitigation for the tree loss at the very least. Please could thismitigation not be two tiny shrubs squeezed on to the last remaining square cm. of garden? Ifpossible, please ensure retention of the two remaining trees. Maybe even some kind ofenforcement procedure could be considered please?

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In addition to the points above, the owners of number 36 have also noticed an error with the location

plan. The location plan appears to include additional land, not within the applicants ownership. I

enclose an extract from Land Registry for Number 21 Bramble Drive, which sits to the rear of the

application boundary. This shows (in blue) the land in question which sits within the application

boundary. Whilst the applicant is well within their rights to do this, the correct certificate within the

application form has not been completed and therefore no formal notice has been given to the

additional landowner. It is therefore important that either the redline boundary is corrected or the

application form corrected and formal notice served.

In the absence of such information, it is extremely difficult if not impossible to determine the full

extent of the impact of the proposal or the extent of the rear extensions. It would be somewhat

pointless seeking this information at this juncture, given the unacceptability of the proposal.

However, if the Local Planning Authority were minded to grant planning consent, such permission

would be extremely vulnerable to judicial review given the absence of the above information.

Given the large rear extension proposed, it is vital that the planning Officer, Conservation Officer

and Tree Officer all make a site visit. If this is not possible, it is crucial that a full photographic audit

is requested, as there are little if no images showing the existing rear garden.

Heritage Assessment and Impact

The submitted information does not provide a robust justification as to how the proposal responds to

context nor the heritage asset which is a significant material consideration of relevance to the

determination of this application.

Instead, there are numerous statements explaining why the building has been designed in the way it

has, but without any justification as to how the policy standards have been addressed.

There is no dispute as to the desire to see the delivery of a high quality, well-designed building in this

location, however, it must be demonstrated that it is appropriate taking into consideration adopted

policies and most importantly in this instance, the site’s location within the Sneyd Park Conservation

Area.

The Conservation Area Enhancement Statement identifies that:

From its origins to today, landscape has been an important element in the character of the area,

which together with rubble walls defines and encloses streets and provides the setting for

housing; creating a very mature arcadian suburb.

One enhancement objective states that:

The layout, form, design, landscaping and means of enclosure in new residential developments

in the Conservation Area needs to respect the traditional forms characteristic of the area.

Whilst the contemporary redesign of the existing house does appear sympathetic, the significant

redevelopment to the rear of the existing house, which removes all natural landscaping and proposes a

near doubling of the footprint is not in keeping with the character of the Conservation Area, where

houses are located in large plots with significant landscaped gardens.

It is a well-established principle of development management procedure that the onus is upon the

applicant to demonstrate that a proposal is compliant with relevant policies, or is supported by material

considerations so as to outweigh any perceived conflict with the Development Plan. In this case, the

application is not supported by sufficient information to evidence that the design approach sought is

appropriate so as to preserve or enhance the character of the Conservation Area, especially bearing in

mind the significant rear extension.

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The character of the local area is representative of the Conservation Area generally. In particular the

northern side of Church Road comprises large detached houses, following a straight line, set back slightly

from the road, with large rear verdant gardens behind. This existing pattern is shown on the below

extract:

As can be seen from the above images all existing properties sit between the two yellow lines except

for number 34a. However number 34a does still retain an area of natural verdant landscape, whereas

the proposed application would extend significantly into the landscape as shown in the submitted aerial

comparison view drawing ref: D710.

The proposals make no attempt in terms of design to integrate aesthetically into the townscape and

landscape of the area. The proposed scheme also makes no reference to the historical value of the site

or the Conservation Area. In the absence of such information, it is currently considered that the

application is an incongruous addition to the Conservation Area, and thus fails to preserve or enhance

the character and appearance of the Conservation Area, contrary to S72 of the Planning (Listed Buildings

and Conservation Areas) Act 1990.

The application does not propose to offset this harm by any public benefit and indeed, the only benefit

that would accrue if the proposals were accepted would be private. Accordingly, the Local Planning

Authority have a statutory duty to refuse this application in accordance with Section 72 and ensure that

unnecessary harm is not caused to the designated heritage asset, namely the Sneyd Park Conservation

Area in addition to local policy DM 31.

Design

The proposed application description states:

Side annexe to be demolished. Double storey side extension. Double storey rear extension with

balcony. New Pool area to be built to replace existing one. 2 X Silver Birch to be felled.

This description implies that there will be several extensions to the existing dwelling house, however

the reality is that the entire plot is subject to comprehensive redevelopment. It is accepted that the

Area of

proposed

new building

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front elevation to Church Road will largely remain as it currently is, subject to new materials. However

the rear in particular proposes a significant extension in the form of a new enclosed pool house,

basement gym, large terrace as well as reconfigured garden space and new sports court. These

extensions are certainly not considered subservient, nor in keeping with the character of the surrounding

houses.

The applicants website includes the below image, which has not been formally submitted along with the

other visualisation images:

Image taken from applicants website

This images shows the sheer scale of the proposal and how extensive development within the plot truly

will be. There is little if no natural landscaping proposed. The proposed extensions more than double

the footprint of the existing house, which itself is a large dwelling measuring 4,326 sqft.

The characterisation of the Sneyd Park Conservation Area is of large 19th and 20th Century detached

houses within their own grounds. Whilst there may be examples of more modern houses, It is not

characterised by contemporary, highly glazed, angular buildings with flat roofs. This form of design is

alien to this area and flies in the face of the surrounding current built form, particularly in relation to

the rear development.

It is noted within the Design and Access Statement on the last page, there is a selection of images

entitled ‘street views of neighbouring properties’ . This is inaccurate and misleading and gives the

impression that both are directly adjacent neighbours. This is incorrect. It conveniently excludes number

36, which sits directly adjacent and is of a more traditional Arts and Craft design. Images are enclosed

below for reference.

Front, rear and garden Images of number 36 Church Road

The Statement also highlights the ‘green’ roof of number 34a, although this is a simple flat roof garage

with an AstroTurf style material on top.

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Based on the above, it is clear that the proposal is a significant over development of the plot and

certainly not subservient to the host building. Its proposes developing the entire rear garden with hard

surfacing.

The significant quantity of hard surfacing proposed also raises concerns regarding surface water run off

into adjacent properties, particularly as no drainage information has been provided or details on levels

in relation to the adjacent properties.

Whilst the design of the main house may be considered acceptable, the rear additions are not considered

to be sensitive to the character of the Conservation Area, where all gardens are naturally landscaped

and verdant in nature. The application would therefore be contrary to policy DM26 and DM27 as well

as DM30.

Privacy and overlooking

Whilst the proposed design to the main house is generally accepted, the proposal is for additional

windows on the eastern elevation, in addition to the significantly glazed pool and raised sitting terrace.

All of these additions would lead to overlooking and impact on privacy between the adjacent properties.

Number 36 has a double height bay window looking west, directly towards the eastern elevation of the

proposal at a distance of approximately 12 metres. Within the bay window at ground floor is the main

living room, above which is the main principal bedroom. There is also a second floor bedroom windows

above the bay. See below image of the western elevation of number 36.

View of western elevation to number 36

The proposal includes additional windows from a bedroom and bathroom, as well as new access doors

at ground floor level to the garage and a separate self-contained guest room, which would increase

activity along this boundary. It is accepted that currently there is a hedge forming this boundary,

although this is well maintained by the owners of number 36 and as can be seen from the below images,

views are easily possible.

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View from principal bedroom View from second storey additional bedroom

In addition to the overlooking and privacy concerns between the two existing properties, there are also

serious concerns of overlooking and impacts from the new glazed pool building and siting terrace. The

plans do not show any form of screening to the eastern boundary and therefore it is highly likely that

overlooking and disturbance will impact on number 36, particularly in winter when the existing boundary

planting will be significantly thinner.

Without detailed cross sections/level details it is not clear if this will also appear overbearing, although

the large terrace feature beyond the pool house does appear to sit at a high level and jut out over the

general ground level, which drops away.

In summary and based on the above, the proposed development, specifically the new openings within

the eastern elevation together with the new rear balconies, new glazed pool building and associated

seating terrace would all have a negative impact on the residential amenity of the occupier of number

36, contrary to policy’s DM26, DM27 and DM30.

Trees and landscaping

The existing layout plan identifies two trees proposed to be felled to facilitate the development. However

no aboricultural survey or impact assessment has been included with the application. Whilst this should

have been a registration requirement, no decision can be made without fully understanding the current

heath and quality of the trees. The local authority should therefore request a full survey.

Given the location within a Conservation Area, tree felling is unlawful without first gaining consent from

the City Council, given that trees offer particular importance within Conservation Areas. The application

drawings and description implies only two trees are to be removed, however aerial imagery suggest

that there will be significant vegetation loss.

Information on existing and proposed landscaping as part of this development is not provided, however

the owners of number 36 have noticed that significant site clearance has already begun with large

amount of vegetation and trees already removed. Some of the remains are visible from the garden of

number 36.

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Images from inside number 36 of trees already felled in anticipation of the planning application

The owners have already made contact with Nigel Butler (Planning Enforcement Manager) to make him

aware that there appears to have already been tree felling without consent.

If following investigations it is found that trees have been felled, the tree replacement calculation should

also include the trees already felled, in addition to the two identified. This should be separate to any

legal action the City Council may wish to take against unlawful tree felling.

Summary

It is clear that the current application is missing numerous important documents and therefore

clarification is sought on these, prior to any determination.

In summary, the proposal is considered to constitute an overdevelopment of the site, with a negative

impact on the privacy and residential amenity of the neighbours at 36 Church Road. The most significant

factor is the harm to a designated heritage asset, a matter which must be afforded considerable

importance and weight. Outright refusal is justified on this matter alone.

Furthermore, the residential amenity would be compromised for neighbouring properties in terms of

overlooking, overshadowing and visual dominance. The proposal therefore fails to meet the

requirements of policy DM 26 and DM 27.

As a consequence of the excessive scale and overbearing nature of the development, the proposal will

cause harm to the designated Sneyd Park Conservation Area and is thus contrary to Policy DM31 from

the Local Plan 2014, which states that development will be expected to:

“Development within or which would affect the setting of a conservation area will be expected

to preserve or, where appropriate, enhance those elements which contribute to their special

character or appearance”

Furthermore, in the absence of any supporting Heritage Assessment, the applicant has failed to

demonstrate that the proposals respond to the significance prevailing and character of the Conservation

Area. The primacy to be afforded to the protection of heritage assets is fully established within case law

and in the absence of such as assessment, the application is incomplete. It is considered that the

application should not have been validated and registered given the importance of this key matter.

Lastly the application has failed to fully investigate the existing landscaping in the form of a

aboricultural survey, which would be required to ensure suitable tree loss is compensated for.

Given all of the above comments, it is respectfully requested that the planning application is refused, as

that there are clear policy contraventions. It is noted that these concerns have been endorsed by the

other residents in the area, demonstrating the negative reception the proposal has received. In short,

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there is a fundamental presumption under S38(6) Planning and Compulsory Purchase Act, 2004, against

the grant of planning permission and we would therefore respectfully ask that this application is refused.

Yours sincerely,

David Hagan MTCP (Hons), MRPTI

Principal Planner

dh@csj-planning.co.uk

Enc. Land Registry Extract for 21 Bramble Drive

Cc. Owners of 36 Church Road

My objection arises from what I say is inaccuracy in the location plan 21_00235_H-LOCATION_PLAN-2859189.pdf and other documents that might depend on it, showing an area ofland to which we have Title, this being at the SE end of our property