As direct neighbours of Bristol Zoo, we continue to object to the proposed developmentof the West car park site in its currently submitted form. We wish for our previous commentssubmitted on 2 June 2021, 16 August 2021 and 26 July 2022 to continue to be taken into accountand also add the following further observations in respect of this revised application:

Heritage harm - the Heritage Addendum note dated 17 September 2022 summarises the heritageeffects of the development on Hardelot (which encompasses the building at 50 College Road)simply as an enhancement to the building from improvement to the appearance, connectivity anduse of the site. This is rather short sighted as any reasonably informed third party would concludethat the construction of a five-storey block of flats no more than 10-12 metres away from ourproperty would cause a degree of harm in a heritage context, not least due to the overbearingnature of the structure being an invasion of our privacy but also as a result of the reduction indaylight / sunlight to all rooms in the property (with two rooms still being below recommendedlimits).

The latest token revisions made to the exterior of Block A are purely cosmetic and do not respondto the fundamental concerns of local residents that the sheer scale of Block A (in terms of bothsize and density) is totally out of keeping with the surrounding buildings (the Pavilion, the terracedproperties at 40-48 College Road and Hardelot and Roxborough villas) and would create anunattractive canyon effect at the north end of College Road.

Lack of parking provision - as previously trailed by many local residents in their objections, the lackof parking provision has still not been addressed which is disappointing. 45 parking spaces for 62residences plus the added impact of the c.200 properties to be constructed on the main Zoo

Gardens site will lead to a significant strain on local on-street parking. Even following the closureof the Zoo, we are often unable to park our cars outside or even in the vicinity of our property andthis will only get worse should the plans be approved.

Drainage - the drainage from our property is often sub-optimal, particularly during wet periods withwaste water slow to drain away to the main sewers and we have serious concerns that adding afurther 62 properties to the already creaking drains at this end of College Road will lead to greaterproblems going forward. This issue should be given further consideration.

Traffic concerns - during morning and evening school drop off / collection times there are longqueues of traffic at the junction of College Road and Clifton Down and The Avenue and CliftonDown which will only be exacerbated by the traffic from the proposed development. This will posea greater safety risk to both local residents and school children with increased volume of traffic inthe area from the development and should be given due consideration.

Lack of public amenities - the nearest local GP surgery on Pembroke Road and local schools arealready at capacity and struggling to cope with present demand. It often takes 10 days to get aphone call back from the GP and the situation will only deteriorate if this level of additional housinggets the green light. This impact should be given due consideration.

As stated previously, we are not adverse to development of the West car park site in principle,however, our view remains that in order to achieve a legacy that all parties can be satisfied with,Block A would need to be significantly reduced in height and broken up at street level to be morein keeping with the surrounding area as the scheme in its current form represents over-intensivedevelopment.

I strongly object to the planned development of the zoo car park; the propsed size,numer and architecture of the building is wholly out of character with the historic area.

The develpment will add to overcrowding and traffic congestion.

The revised plans are not materially different to the original plans submitted so all myprevious objections stand.

The changes in the planning application are minor, achieving nothing in terms ofexpectations in a conservation area so I stand by my previous objections.The city of Bristol lost numerous old buildings during WW2, many to be replaced, understandablyquickly and on a tight budget, with structures that did nothing to enhance the environment. Plansfor this development are in danger of doing likewise. This area of Bristol has some of its mostattractive and historically important buildings. Whilst I, and most other neighbours, have noobjection to dwellings being built on the site, I cannot accept the current amended plans asanything other than overdevelopment (with the apartments facing College Road far too high) withthe sole objective being to raise as much money as possible. This is not acceptable and iscertainly not a sound reason for granting planning permission.

The Conservation Advisory Panel object to the revised drawings.

The panel did not consider that the relatively minor changes to the design reduced the substantialharm that would be caused by the original proposal and repeated its previous objection:

This is the first phase of the redevelopment of the Zoo and its associated sites. It is noted thatthere is no overarching Masterplan that sets out and governs development. While the principle ofresidential development of this site is accepted, the Panel considers this application to be overintensive development.

Area 2 of the Conservation Area is defined in the Character Appraisal as being characterised by"Large Victorian villas of 3 storeys plus basement, up to 4 storeys, detached and semi-detached,two to three bays wide".

New development must respect and respond to this scale and form. The large monolithic block onCollege Road would be overbearing in nature, primarily due to its height and position close to thefront of the site, and is disappointing in design, particularly the inappropriate form of the mansard.Although the stairwell sections of the building are set back slightly from the facade, the buildingstill reads as a single block, and lacks the characteristic permeability of the historic development ofthe area.

There is insufficient parking provision on this site. The scheme removes 15 trees with very limitedtree replacement. This proposal does not respond to the character of the conservation area andconsequently does not enhance the character and appearance of this part of the conservation

area.

In summary it is considered that there are no positive elements of the scheme. Consequently, thePanel considers the proposal does not accord with relevant up to date Local Plan heritage policiesnor the requirements of the NPPF and provides insufficient public benefits to outweigh the harmcaused by the impact of such a poor scheme on relevant heritage assets

I can see the building footprint has been reduced & 3 flats less but the does not addressthe bulk of the objections I have.

Specifically I wish to object to this scheme for the following reasons:

GENERALThe proposals constitute over-intensive development.The buildings are too tall for the surrounding buildings.They are out of keeping with surrounding buildings.The poor design and over intensive development of the accommodation to square footage of landwill damage the settings of surrounding listed buildings and other unlisted buildings of meritaround this area.Parking there is so little parking its horrifying. It cannot be assumed people will not have carsunless there is a clear

PARKING:The proposed parking provision is totally inadequate. There should be a minimum of 1.5 parkingspaces per house / flat. Where is the visitors parking? Most households run 2 cars be it adult ornew driver. There is a massive strain in this area for street parking. It cannot be assumed peoplewill not have cars or all visitor walk or take public transport that is naive. This can only be assumedIF the leases to the flats have parking permit restrictions written in.No development should be build without adequate parking for the new residents. The councilcannot charge for residents parking when there is not enough street parking available already &then grant planning for such an intensive development.

AMENITIESAmenity space is severely lacking, Have we learnt nothing from Covid19. There should be moregreen space for all to enjoy so a sense of community can be created.

ENVIRONMENTAL15 mature trees will be lost in a conservation area.Complete double standards by the council rejects smaller planning applications all the time due totrees removal / potential damage.This development would fail to preserve or enhance the character of the Conservation Area.Where is the environmental design here: air source heat pumps, solar panels, electrical chargingpoints / Solar PV's, triple glazing / super Insulative housing.NO development should be allowed in Bristol without adequate parking space, electrical chargingpoints & environmental buildings.This could be a great opportunity to build an environmental development within Bristol.

SURROUNDING INFRASTRUCTUREThis development will put a huge strain on the existing infrastructure: schools / surgeries /hospitals / highwaysAn additional 167 new residents could live in this development (this being a realist number) - allrequiring health care provisions, educational provisions, parking provisions. These are all atbreaking point already in BristolThis development could mean accommodation for any where between 62 - 264 new resident.

SOCIAL HOUSINGThis development is not social housing or aimed at anyone other than medium - high incomepeople. The maintenance fees on a building with lifts are very high.

It would seem that the sole aim of this application is to render this site as profitable as possible.This is purely a development to make all concerned huge profits.

This planning proposal fails to have any regard whatsoever for local amenity, surroundingresidents, local architecture, the conservation area or the environment. If this application isgranted it would set a dangerous precedent for the redevelopment of the main zoo site and allplanning applications in the surrounding area.

I can see the building footprint has been reduced & 3 less flats but the does not addressthe bulk of the objections I have.

Specifically I wish to object to this scheme for the following reasons:

GENERALThe proposals constitute over-intensive development.The buildings are too tall for the surrounding buildings.They are out of keeping with surrounding buildings.The poor design and over intensive development of the accommodation to square footage of landwill damage the settings of surrounding listed buildings and other unlisted buildings of meritaround this area.Parking there is so little parking its horrifying. It cannot be assumed people will not have carsunless there is a clear

PARKING:The proposed parking provision is totally inadequate. There should be a minimum of 1.5 parkingspaces per house / flat. Where is the visitors parking? Most households run 2 cars be it adult ornew drivers. There is a massive strain in this area for street parking. It cannot be assumedresidents will not have cars or their visitors. This can only be assumed IF the leases to the flatshave parking permit restrictions written into them.

No development should be build without adequate parking for the new residents. The councilcannot charge for residents parking when there is not enough street parking available already &

then grant planning for such an intensive development.

AMENITIESAmenity space is severely lacking, Have we learnt nothing from Covid19. There should be moregreen space for all to enjoy so a sense of community can be created.

ENVIRONMENTAL15 mature trees will be lost in a conservation area.Complete double standards by the council rejects smaller planning applications all the time due totrees removal / potential damage to tree root systems.This development would fail to preserve or enhance the character of the Conservation Area.There is still a distinct lack on environmental design here: air source heat pumps, solar panels,multiple electrical charging points / Solar PV's, triple glazing / super Insulative housing.NO development should be allowed in Bristol without adequate parking space, electrical chargingpoints & environmental buildings.This could be a great opportunity to build an environmental development within Bristol.

SURROUNDING INFRASTRUCTUREThis development will put a huge strain on the existing infrastructure: schools / surgeries /hospitals / highwaysAn additional 167 new residents could live in this development (this being a realist number) - allrequiring health care provisions, educational provisions, parking provisions. These are all atbreaking point already in BristolThis development could mean accommodation for any where between 62 - 264 new resident.

SOCIAL HOUSINGThis development is not social housing or aimed at anyone other than medium - high incomepeople. The maintenance fees on a building with lifts are very high.

It would seem that the sole aim of this application is to render this site as profitable as possible.This is purely a development to make all concerned huge profits.

This planning proposal fails to have any regard whatsoever for local amenity, surroundingresidents, local architecture, the conservation area or the environment. If this application isgranted it would set a dangerous precedent for the redevelopment of the main zoo site and allplanning applications in the surrounding area.

I write to object to the revised proposal for the Zoo car park area.The slight modifications that have been made do not address the central issues.These are:- the high density of housing,- the institutional- looking design of the buildings- the lack of sympathetic understanding of the site's relationship to the neighbourhood.The claim that The Zoological Society must sell this site for the highest price has been shown tobe a fallacy: highest value should focus on the buildings contribution to the improvement of itsimmediate neighbourhood.

I do not believe that the relatively minor tweaks in the revised plans address the mass ofprevious objections - mine included.

These revised plans contain very few practical revisions, meaning that all the previousobjections to the plans remain. There is still no consideration given to enhancing the biodiversityand drainage of the site - a necessity given that the corner of Cecil and College Roads regularlyflood in heavy rain! There is no consideration given to the additional traffic and pollutionconsiderations caused by the creation of a new access road behind the existing villas on CollegeRoad and the noise and pollution that this will cause existing residents. The structure and designof the buildings in no way reflects or complements the existing design of the buildings.The design of this development in no way reflects the existing area and the site will causeconsiderable harm to the area and the existing residents. I hope that the many objections to thescheme will cause more significant changes to the design.

I wish to object again to the slightly revised plannig application.

In my view the development of this site is too dense.

Many of the properties have a single aspect, which gives rise to a poor quality of life inside

There is not enough green space or outdoor space for each dwelling.

The new road required to Cecil road will change the character of Cecil road significantly andincrease traffice.

The block of flats in College road is too high and the idea to makes the windows smaller at the topwill make the residents inside worse off, than in the previous application. A better solution wouldbe to provide fewer bigger dwellings with dual aspect.There is a loss of privacy for residents in Cecil road and Clifton Down.

We continue to have the following objections:

1. The number of dwellings proposed for this development is out of proportion to the number ofproposed parking spaces. This development and that of the main zoo site to follow will vastlyincrease the population density of this small area. The result will be a considerable increase instreet parking and a consequent large deficit of spaces and cars hunting for them.

2. The coming and going of residents' cars occupying the new development will coincide withchildren arriving and being picked up from the school. This is likely to increase the collision risk tochildren arriving and leaving both on foot and in cars. The significant increase in pollution (it will bemany years before the majority are not generating pollution) is known to be detrimental to theirhealth throughout their lives. This conflicts with the avowed policy of Bristol City Council to reducepollution and its adverse consequences.

3. It seems absurd that the plans for parking for this development are not to be considered inconjunction with the future plans for development of the main zoo site. This is a prescription forchaos.

4. The height of the proposed West Car Park development on College Road is still not inproportion to the existing neighbouring houses to the south west on College Road. Recentchanges incorporating recessed mansard windows do not improve this. The development needs tobe one storey lower and preferably incorporate at least one break in the long continuous frontageon College Road.

In my objection to the previous iteration of the proposed construction activity on theWest car Park site, I made a number of comments in respect of national policy, and in respect ofthe apparent failure of the applicant to demonstrate that their proposal complied even with thecompletely outdated BCS14 (which now lags some way behind what the National Planning Policyframework, and statements of policy in Government White Papers require).As well as placing the Council in an embarrassing position should it decide to recommend grantingof consent, the proposal - along with that for the main site - raises serious questions regarding theapplicant's commitment to conservation objectives. I set out why this is the case in an Appendix,taking the two applications - this one, and the proposal for the Main Site - into consideration.A key conclusion that I draw is that if all organisations were to act as the Zoo intends, regardingthe use of its assets and the associated increases in greenhouse gas emissions (and I have usedthe applicant's own figures in this respect), then the net effect of the planned construction wouldbe to shift the world from a path that is potentially consistent with limiting climate change to 1.5degrees, to a world in which a 2.2 degree temperature rise becomes distinctly possible. TheGlobal Biodiversity Outlook noted that global warming has to be kept well below 2 degrees Cabove pre-industrial levels, and preferably, close to 1.5 degrees C above pre-industrial levels, 'toprevent climate impacts from overwhelming all other actions in support of biodiversity.' This doesraise relevant questions regarding applicant's commitment to conservation, given the apparentabsence of meaningful integration of the matter of embodied carbon and energy into the design ofthe build.Embodied Carbon and EnergyRegarding the resubmitted application, nothing has been done to improve the embodiedgreenhouse gas emissions associated with the build. As I noted under my previous objection tothis proposal, then applying figures from the same applicant's assessment on the Main Car Park,

the embodied greenhouse gas emissions are many times the multiple of the emissions associatedwith the operational performance of the building. I wrote then:Based on a GIA of 6,514 m2, therefore, it can be estimated that the upfront embodied emissionsfrom construction at the West Car Park site to be of the order 5,048 tonnes CO2e. Embodiedemissions over the whole life-cycle will be of the order 7,165 tonnes CO2e.To place this into context, the regulated component of the operational emissions are claimed, bythe applicant, to be 92 tonnes CO2 per year, or 129 tonnes CO2 per year if you accept ourcomments regarding the apparent omission of emissions frome electricity needed to drive theASHP. The upfront emissions alone from the embodied carbon emitted in relation to the site arepotentially, therefore, between 39 and 55 times the annual emissions reported in the ESS.Planning decisions clearly cannot be made in line with the NPPF if embodied emissions areoverlooked. The Net Zero Strategy evidently 'banks' the outcomes expected as a result of planningauthorities making planning decisions consistent with the requirements of good design. TheNPPF's reference, through para 134, to the need to refuse developments that are not welldesigned, and the fact that the Model Design Code - to which the NPPF refers - indicates that inwell-designed developments, embodied energy should be minimised. The application makes noattempt to embed the need to minimise embodied energy in its design. Rather, it is considered anafterthought. It follows that the application should be refused.Noe that the applicant has considered application of BCS14 in the manner most favourable to it inrespect of the revised Part L Building Regulations, it claims emissions of 26 tonnes per annum.Given that assessment of embodied carbon emissions is not bound to consider any particularcarbon intensity figures, these would not be expected to have altered as a result of the proposals,save for:a) the embodied energy in the solar PV panels might need to be accounted for if they are notalready included in the figures reported by the Zoo's consultants at the Main Site; andb) the Design and Access Statement Addendum of Sept 2022 indicates a marginal change in GIAfrom 6,514 m2 to 6,485m2.Revising operational carbon emissions down to 26 tonnes per annum, therefore (and presumably,these might decline over time as electricity decarbonizes further), then the embodied emissionsnow look to be of the order 194 to 275 times the operational emissions. These figures, therefore,do nothing to diminish the case for addressing embodied carbon and energy: on the contrary, theyhighlight how foolish it is to ignore the issue - and that is why it is included as s requirement of'good design' in relevant government documents. And proposals that are not 'well designed'should be refused (as per NPPF para. 134).Evidence in Support of Climate Change PerformanceOn the Table 11 provided in the revised document from the applicant's consultants, Hydrock(Hydrock (2022) Bristol Zoo - West Car Park: Energy and Sustainability Statement, 27 September2022), there is no basis for understanding these figures. As with the previous iteration, there areno calculations, no modelling, no clear and transparent demonstration of how the claimedreductions in CO2 emissions are achieved, and at what step. Furthermore, the manner in whichthe Part L modelling has been conducted is quite unclear. The main change that the applicant hassought to apply is the revised Part L carbon factors (which it sets out in its Table 2). It is not at all

clear how the intends to treat the issue of compliance with BCS14 given the Part L changes: in theapplication on the Main Site, ironically, the same applicant (different consultants) has beenadvised that the old Part L factors should be applied.In any event, the figures in Table 11 still make no sense. Supposedly, once energy efficiencymeasures are applied at the Building, the energy demand falls by almost 38,000 kWh. Yet theCO2 emissions fall by only 1,035 kg. What's going on here? How is that possible? Where are thecalculations that demonstrate how these numbers are derived (they aren't in the document)?What's then included in the step 'after on-site renewables'? Where do the heat pumps 'come in'energy efficiency, or on site renewables? (They are not 'renewables', since the source of energythey use can be either renewable or non-renewable). So how can a council officer, let alone alowly resident objector, adjudicate on whether this proposal meets the requirements of BCS14?To re-state, therefore, part of my objection to the previous proposal (because it applies with nolesser force to this revised proposal):There is no transparency in the derivation of the figures which are presented in respect of theclimate change performance of the different measures being proposed, not to mention, thebaseline position. This is not consistent with the CCSPN which states, quite reasonably:'An effective energy strategy will combine a written explanation of the measures proposed, takingaccount of site constraints and opportunities, with detailed calculations showing the CO2 emissionsavings achieved. The proposed measures should be shown on the application drawings, in orderto provide certainty that they can be accommodated in the design, and to allow an assessment ofhow well they have been integrated into the proposed design.'Until the applicant clearly demonstrates the basis for its calculations - the validity of which wechallenge below - and until it is made clear how the development is consistent with therequirements of the NPPF, BCS14, BCS15 (and the procedural guidance elaborated in theCCSPN), then it is not possible to have confidence that it is well designed.Whilst the failure to meet requirements of good design as per the NPPF remains very obvious,officers may wish to go back to the applicant and request this information in a form in which thefigures can be meaningfully interrogated, which would include a transparent basis for thederivation of the figures. That would be a requirement to assess compliance against BCS14. Thatmight not be considered necessary given the more significant failings of the proposal asadjudicated against the requirements of national planning policy.Solar PVThe inclusion of solar PV in the amended proposal is baffling. We challenged the proposal's failureto include solar PV in 2021. Page 13 of the previous 'Energy and Sustainability Statement' ("ESS")- as written by Hydrock - stated, in relation to two renewables technologies - photovoltaic panelsand solar thermal - a conclusion on their viability as follows: "Potential - heritage setting wouldneed to be considered". In the explanation it states: "As the site is within the Clifton and HotwellsConservation Area, roof mounted PV panels may detract from the local character of the area andvisual impact would need to be considered". There are already solar panels on rooves in theConservation Area. It was certainly feasible to install them, and we argued at the time that it wasnot possible for the applicant to argue this was not-feasible, given that they were free - consistentwith principles of good design - to choose the design of / orientation of rooves.

The point was given further consideration at the Development Control Committee meeting atwhich it was recommended the 2021 proposal was granted consent. The officer's report to theCommittee stated:"The Applicants were invited to give further though[t] to the provision of Air Source Heat Pumps(ASHP) and PV panels. In response the Applicants commented:- Regarding the use of PVs, the following statement has been prepared by the application'ssustainability consultant: [...]- We believe that achieving this level of carbon reduction without the use of on-site generationdemonstrates greater sustainability objectives for the site, whilst reducing operational costs for theresidents through minimal heating energy requirements [this statement has certainly not stood thetest of time]. Solar PV panels were considered (within sustainability/energy statement), butdiscounted for a number of reasons, notable efficiency/orientation, aesthetics and impact onconservation area, and also provision of sedum roof and ecological enhancements."If efficiency / orientation was a reason to discount solar PV then, what has changed since then tomake them efficient now? There has been no discernible change in the efficiency of solar PV, andthe orientation of, for example, rooves is as it was back in 2021. We are entitled to ask what is itthat has suddenly made this viable? Why was something inefficient then, but efficient today? Whatelse, we can reasonably ask, might not have been proposed initially as a consequence of a failurein design that could be have been done. Obviously, there is the embodied carbon issue alreadymentioned, but there is more.It is a mockery for the client's consultants to state, as they do:The scheme has been designed to respond positively to all national, regional and localsustainability policy. The scheme will minimise any negative environmental impacts associatedwith energy, resource consumption, water, noise, air and light pollution.Sustainability has remained the golden thread tying together the design principles of the site tocreate an innovative, highly sustainable and energy efficient community.This report has demonstrated that the development can achieve 4% reduction in regulated carbonemissions (covered under Building Regulations Part L 2021) through the implementation ofpassive design measures. A further 51% reduction by including both low- carbon air source heatpumps, to provide heating and domestic hot water, and a PV array. Overall, the development willachieve a 53% total reduction against the Building Regulations Compliance carbon emissions,using SAP 10.2 carbon factors.Taking each paragraph in turn:- The scheme has not responded positively to all policy - it fails completely to grapple with theissue of embodied carbon generation, as it would have done had it sought to respect the designrequirements of the NPPF (through para 134). It has not minimised carbon emissions on theoperational side either.- Sustainability has obviously not been a golden thread in the design (if it had been, it would bewell-designed, as per the NPPF); and- The report has not 'demonstrated' anything: a series of numbers have been placed in a Tablewith no supporting calculations.The modifications proposed fail to do much to address the deficiencies in the scheme's design.

Indeed, the only positive change on the CO2 side - the solar PV - has probably been prompted bythe Part L revisions, but the inclusion of the solar PV seemingly contradicts the applicant'sconsultants' own earlier statements. Indeed, if the applicant is including solar PV on one part ofthe proposal, why is it not everywhere else?As I stated in my previous objection, the National Design Guide states:135. Well-designed places and buildings conserve natural resources including land, water, energyand materials. Their design responds to the impacts of climate change by being energy efficientand minimising carbon emissions to meet net zero by 2050. It identifies measures to achieve: mitigation, primarily by reducing greenhouse gas emissions and minimising embodied energy;andAnd:R1 Follow the energy hierarchy138 Well-designed places and buildings follow the energy hierarchy of: reducing the need for energy through passive measures including form, orientation and fabric; using energy efficient mechanical and electrical systems, including heat pumps, heat recoveryand LED lights; and maximising renewable energy especially through decentralised sources, including on-sitegeneration and community-led initiatives.139 They maximise the contributions of natural resources such as sun, ground, wind, andvegetation.140 They make use of potential for renewable energy infrastructures at neighbourhood andbuilding level. These include photovoltaic arrays, heat pumps and district heating systems, toreduce demand for non-sustainable energy sources. IT advances and app-based solutions allowusers to take ownership or to manage these systems so as to use them most efficiently.Also, the National Design Guide states:138 Well-designed places and buildings follow the energy hierarchy of: reducing the need for energy through passive measures including form, orientation and fabric; using energy efficient mechanical and electrical systems, including heat pumps, heat recoveryand LED lights; and maximising renewable energy especially through decentralised sources, including on-sitegeneration and community-led initiatives.139 They maximise the contributions of natural resources such as sun, ground, wind, andvegetation.140 They make use of potential for renewable energy infrastructures at neighbourhood andbuilding level. These include photovoltaic arrays, heat pumps and district heating systems, toreduce demand for non-sustainable energy sources. IT advances and app-based solutions allowusers to take ownership or to manage these systems so as to use them most efficiently.141 They follow the principles of whole life carbon assessment and the circular economy, reducingembodied carbon and waste and maximising reuse and recycling.142 Good developments minimise the cost of running buildings and are easy and affordable foroccupants to use and manage.The proposal fails in more or less every respect in this regard.

Para 134 states:Development that is not well designed should be refused, especially where it fails to reflect localdesign policies and government guidance on design52, taking into account any local designguidance and supplementary planning documents such as design guides and codes.Footnote 52 in the above extract explicitly references that the government guidance on design iscontained in the National Design Guide and National Model Design Code, from which aboveextracts have been taken.The direction from the NPPF is clear, therefore. The massive deficiencies in design demand thatthe application is refused.The letter from Harry Quartermain of Barton Wilmore (now Stantec) to Peter Westbury regardingthe minor amendments that have been made states:Although not required to ensure compliance with planning policy, the PV panels have been addedto further improve the building's carbon reduction performanceThe clause, 'Although not required', superfluous, in any case, to a factual description of themeasure, is wrong. As if to clarify the fact that these matters were never considered from theoutset (as they should have been), the amendments include documentation of how - in the contextof the design of the housing as it had been proposed, solar panels could be accommodated in amanner that would satisfy statutory consultees. Given that the above extract from the letter ofHarry Quartermain indicates that 'the PV panels ... improve the building's carbon reductionperformance', and given that these panels are only proposed on one block (nowhere else), it isquite clear that had the design been different, further reductions in greenhouse gas emissionswould have easily been possible.Sufficient as it (the only partial use of solar PV, and in circumstances where consultants hadpreviously deemed this not viable) to reject the application on grounds of design, it is in respect ofembodied carbon that the proposal is most deficient. That matter has not even been considered,other than ex post, essentially, as a procurement strategy rather than one that has informeddesign.TrafficTraffic in and around the proposed site has changed in recent weeks. There is much considerationof the impact of the site, as developed, relative to the situation where the site continues to be usedas a Car Park for visitors to the Zoo. Hence, the Transport Statement noted:It is proposed that the West Car Park would be closed to colleagues (staff, volunteers, andcommercial partners) and visitors in early 2022 with the BZG closing to visitors in late 2022.Notwithstanding the fact that the Society could close the West Car Park at any time in any event,the assessment also reviews the short term effect of the loss of West Car Park prior to BZGclosing to visitors.The Zoo has now closed. It is not, therefore, appropriate to consider traffic impacts relative to asituation which is no longer the relevant comparator. The application must be considered on itsown merits: the application to build houses on the site, therefore, will not lead to the changesanticipated in the Transport Statement.For example, at the end of Section 5 of the Transport Statement indicates:The traffic impact assessment of the development has identified that in the long term there would

be a net traffic benefit, with a decrease in traffic, compared to the current usage of the site as a carpark. However in the short term when BZG is still operational the traffic impact of the residentialdevelopment alone is not 'severe' and thus would not result in a road safety concern, in line withNPPF paragraph 109.Section 6 stated:Beyond the closure of BZG to visitors The Society would retain an operational presence on thesite until its final departure in late 2023. However during this period there would be no visitors andstaff numbers would be reduced. This time period is therefore not assessed.Yet this is the situation that prevails, and as such, ought to be the only one that now matters.Public BenefitsThe letter from Harry Quartermain of Barton Wilmore (now Stantec) to Peter Westbury seeks toset out an appraisal of public benefits associated with the scheme. The term 'benefits' is aninteresting one: in economics, the terms 'benefits transfer' is routinely used to inform the meansthrough which 'impacts' are assessed. Those impacts can be both 'positive' or 'negative'. It followsthat an assessment of 'public benefits' - not least, one which seeks to weight these up 'in thebalance' - should include both positive impacts of a scheme as well as its negative consequences.We find none of the latter in Harry Quartermain's subjective assessment of public benefits.In what follows, we comment first on the matters to which attention has been drawn by HarryQuartermain, before then providing not only some disbenefits of the scheme, but quantification ofthose (something not done by Harry Quartermain). The content of the original letter is italicised:Public Benefits SummaryWe have set out a summary of the public benefits and suggested a corresponding weight thatcould be attributed by the Council in its assessment. The list of public benefits is not considered tobe an exhaustive list and the Council may identify any additional number of public benefits.Furthermore, it is acknowledged that the Council may agree with the public benefits as set outbelow or take another view as part of the exercise which would need to be underpinned byrobustly justified reasoning.For the sake of clarity, we have used the following scale when weighing the benefits from lowest tohighest: moderate, significant, substantial.This is not an appropriate scale for assessment - the smallest public benefit is indicated as'moderate'. The term moderate means, broadly speaking, average. It is logically impossible for thelowest level of benefit to be 'moderate' unless all are 'moderate' (and in such a case also, we canbe sure the analysis has not been thought through). None of these benefits are quantified. Wehave quantified some of the public disbenefits below so that they might be properly considered inany balancing exercise.Bristol City Council is not able to demonstrate a five-year housing land supply. Irrespective of thetilted balance as set out in Paragraph 11 of the NPPF, the Council does not have a supply ofdeliverable housing land to meet its requirements for more than 3.7 years. Housing delivery overthe last 3 years has also remained below Housing Delivery Test measurement requirements. TheBristol City Council Corporate Strategy 2022-27 includes "accelerating home-building in the city toat least 2,000 homes each year, with at least 1,000 affordable, by 2024".The proposal provides for 62 new homes in a sustainable location for development, with good

access to shops, services and public access routes and represents an important and earlycontribution to the Council's 5-year housing land supply. In context of historic under-delivery inprevious years, an identified shortfall in future delivery and Council ambition for increased deliveryof homes to unprecedented levels within the last 10 years the provision of 62 new homes isassessed as a public benefit of substantial weight.The proposal includes 20% affordable housing provision and represents a 'threshold compliantscheme' in accordance with the Affordable Housing Practice Note (July 2022). Since adoption ofthe Council's affordable housing policies, monitoring of percentages of affordable housing hasshown that the Council's higher policy targets have not been met consistently. This led the Councilto adopt an Affordable Housing Practice Note in 2018 and update the practice note in July 2022.The Affordable Housing Practice Note is based on up-to-date evidence identifying that therecontinues to be a significant need for affordable homes across the city and sets out three routesavailable to applicants. The proposals are in accordance with 'Route 2: Threshold compliantscheme'. This consenting route requires commencement of development within 18 months of anypermission being granted. The early commencement and delivery of affordable homes to Bristol,within the suburb or Clifton, is assessed as a public benefit of substantial weight.Following discussions, it is considered that the Council is satisfied with the housing mix and thesecond revision of the scheme makes no changes to the housing mix also including accessibleand adaptable dwellings. This would be a benefit of moderate weight.As a fairly obvious point, this target for affordable housing will not be met unless, on average, theproportion of affordable housing is of the order 50%. A proposal which offers a 20% contribution isnot only non-compliant (reference my objection to the previous proposal) with the extant CoreStrategy policy (which, legally, according to the Council's own legal services, cannot be revisedthrough a Practice Note, which is what the applicant seems to believe is the basis for legitimatelyproposing the 20% figure), but also implies that 'above average' contributions will be required fromother schemes to meet any given target. Given that the residual land value is likely to besignificant (why else is the applicant doing this?), then rather than being a public benefit, we mightmore properly view the offer of 20% affordable housing as a means to maximise the private benefitaccruing to the Zoo (and the acquirer of the land) at the expense of additional public benefit thatwould otherwise be achieved. In the context, the 20% figure is an implicit subsidy to the applicant.Most of the site is unvegetated, and other areas have small quantities of common and widespreadspecies. Regular use of the site as a car park does not allow any significant value forinvertebrates. These areas are of minimal nature conservation value and there are no ecologicallysignificant trees or areas of scrub on the site, as set out in the submitted Ecological Report. Theproposals will create a net gain of tree planting on-site. The proposal has taken opportunities toincorporate measures which enhance the biodiversity of development as set out in national policyand local policy. This would be a benefit of moderate weight.This is a disingenuous assessment. Previous iterations of this scheme indicated a failure even tocomply with the Council's own policies. The public benefits derived from the proposed planting willlikely be extraordinarily limited (not least when compared with the value of emissions associatedwith the build - see below). Indeed, if, as the above states, the current state of the site is that itsconservation value is minimal, then it would ridiculous to assign this anything other than a

fractional benefit, if any, given the small level of improvement that is being claimed. The use of theterm 'moderate' is completely inappropriate - this is at best marginal, though occurs in the contextof a requirement to deliver on policies which were overlooked in the original proposals.The new population would generate additional income that would increase spending in the localeconomy to support local shops and services. The development would generate employmentduring the construction period. These are economic advantages of high to moderate weight.The site does not create 'new population'. The people who might, should the housing be built, beoccupying this sight are people who 'already exist' - they do not materialise as a result of the build.Their spending in local shops and services will not be 'additional'. Under any remotely sensibleconsideration of the matter, it is obvious that they would have spent that money elsewhere. Thespending is simply displaced from one place to another.The claim that the development would generate employment is also naïve. In the macroeconomiccontext, this is a trivial project. In order for it to be claimed that the scheme will 'generateemployment', it would have to be demonstrated that people who would not otherwise be employedare - additionally - employed by the scheme. In reality, the labour market in the UK is extremelytight at present, and the demand for construction workers is strong. In practice, this scheme willadd to the activity to be undertaken by the sector, but the likely outcome is not an increase inemployment, but additional activity to be undertaken, and that may mean that projects movearound in terms of their prioritisation. The generation of 'new jobs' can be expected to be, for allintents and purposes, zero. There may be displacement of employment associated with spendingand the associated multiplier effects, and whilst this might benefit a given area, it is likely simply todo so at the expense of other areas (see previous comment). The net impact of all this can beexpected to be roughly zero, unless there is something about the scheme itself that seems likely tolead to an increase in incomes / spending (which there isn't).It does seem relevant here, not least because the applicant is the operator of the recently closedZoo, to give proper consideration also to the far more significant displacement of activity fromClifton, in Bristol, to Wild Place Project in South Gloucestershire. This, of course, has adisplacement impact far greater than any being considered here.The traffic impact assessment of the development has identified that in the long term there wouldbe a net traffic benefit, with a decrease in traffic, compared to the current usage of the site as a carpark. The short term was considered to account for the time-period when BZG was still inoperation. In the weekday morning and evening road network peak hours the proposeddevelopment would have a net traffic decrease compared to the existing car park usage of thesite. When considering the daily traffic impact of the proposals there would also be a significantnet traffic decrease compared to days in which the car park is currently also used by visitors. Theresidential development traffic flows on weekends would be lower, giving an even greater nettraffic benefit than on weekdays.The Transport Assessment undertaken concludes that there would be a net traffic decrease at alllocal junctions in the road network peak hours compared to the existing situation with BZScolleagues travelling to/from BZG and parking in the West Car Park. The public benefit arisingfrom traffic benefits would be a benefit of significant weight.The above seems to have abstracted completely from the fact that BZG has effectively closed. It is

the impact of the site and its development that should be considered, not the impact of closing aneighbouring site, which has already occurred - that was a matter of choice for the applicant. Theappropriate measure of the impact of the proposal on traffic is the situation which now prevails, notthe circumstances which no longer exist. The suggestion above that significant weight should beattached to traffic reduction has been rendered absurd by the closure of BZG.Here is the extract from the Transport Statement to which this seems to have been referring:5.6.1 Based on the existing and proposed traffic generation of the site the following change intraffic movement to/from the site would occur:Site Traffic Generation - Two-wayScenario Existing BZG West Car Park Proposed Residential Net TrafficAM Peak Hour 45 14 -31PM Peak Hour 45 13 -32Weekday Daily 320 maximum 171 -149

5.6.2 In the weekday morning and evening road network peak hours the proposed developmentwould have a net traffic decrease compared to the existing car park usage of the site. Whenconsidering the daily traffic impact of the proposals there would also be a significant net trafficdecrease compared to days in which the car park is currently also used by visitors. However it isnoted that the daily usage of West Car Park varies depending on visitor usage.This assessment assumed a car park functioning as it was back in 2021. Much has changed, mostof it, owing to decisions the applicant has chosen to make. The Main Zoo site was open but it isnow closed). This is clearly a claim rendered meaningless by events which have occurred sincethe application was first submitted.The proposals will be required to contribute over £60,000 towards infrastructure improvements viathe Council's adopted Community Infrastructure Levy (CIL). The CIL financial contributions set outare considered to provide proportionate mitigation rather than benefits to be weighed in theheritage balance.This sum is trivial compared with the environmental costs of the development itself (see below),and the potential loss in asset values that may be incurred by existing residents.The Heritage Addendum Note (September 2022) provides further assessment of the proposals'effects on existing designated and non-designated heritage assets. The proposals are assessedby Cotswold Archaeology to result in specific heritage enhancements to the appearance,connectivity and use of the Site. These heritage enhancements are assessed to be of moderateweight. The package of public benefits overall can be afforded substantial weight.It would be very odd if, in considering the impact of the site on heritage assets, that amendmentsto a proposal would be considered as weighing in that balance. It is the proposal, in the round, thathas to be assessed, so to include changes, and not only that, but to then consider these as ofsubstantial weight is methodologically questionable, and surely, not credible.Public Benefits Not Considered AboveThere is no mention of the public impact of the build itself. I estimate that the build will generatearound 5,000 tonnes CO2 equivalent, or more than 7,000 tonnes over the life cycle.BEIS produces figures for the valuation of emissions for the purpose of policy and project

appraisal. Its most recent figures imply a lower, central and upper value of emissions in 2023 of£126, £252 and £378 in 2020 sterling terms (all figures are per tonne CO2 emitted), respectively,or (expressed in 2022 values) £127, £275 and £412 per tonne CO2. The central estimate of thedamages from emissions occurring in the construction phase only is £1.4 million, with this rising to£1.9 million if life cycle emissions are included (this is an underestimate since it assumes allemissions occur in 2023 - the BEIS values for CO2 emissions increase in real terms in the yearsto 2050). The CO2 emissions alone, therefore, generate environmental damages of the order £2million.Also associated with the use of the materials and energy will be the associated emissions of airpollutants, such as NOx, particulate matter and oxides of sulphur, which harm human health, aswell as emissions for which the valuations are deemed less certain in UK Government circles (butwhich, nonetheless, have a non-zero impact). Not all of these will occur in Bristol.My personal experience - having conducted HM Treasury Green Book compliant impactassessments and similar assessments on behalf of the European Commission (reviewed by theCommission's independent Regulatory Scrutiny Board) would suggest these might contributedamages of the same order of magnitude as the CO2 emissions. The Figure below, from a paperpublished in Nature Climate Change, shows the proportion of external costs of cement productioncoming from health damages, or emissions from energy use. This highlights that for a key material- cement - health damages do indeed often account for a high proportion of production-relatedexternalities, including in the UK.

Source: Sabbie Miller and Frances Moore (2020)/05/01Climate and health damages from globalconcrete production, Nature Climate Change, May 2020, 10.1038/s41558-020-0733-0A reasonably conservative estimate of the health damages, therefore, associated with constructionmight be of the order £1 million.The effect of construction noise on health and wellbeing will be felt by those living in proximity tothe site. These impacts are non-trivial in nature. Noise from construction is, according to aGovernment survey conducted in 2012, placed 4th in a list of 12 environmental problemspresented by the survey company (up from 9th in 2000). Although roughly the same proportion (ofthose surveyed) reported hearing noise from building, construction, demolition, renovation or roadworks in 2012 as in 2000, the proportion (of those surveyed) reporting 'being bothered, annoyed ordisturbed to some extent' by this form of noise increased from 15% to 29%, the largestproportionate increase in the time period for any of the 4 main sources of noise pollution (theothers being road traffic, neighbours, and aircraft - this development increases the number anddensity of neighbours, and will increase night-time and day-time road traffic relative to the currentsituation).Traffic at night will increase relative to the current situation. The impact in respect of traffic noiseshould be considered, both that which would take place during construction, and that which wouldfollow if the proposal is completed. The impact on noise, taken relative to current backgroundlevels, has the potential to be significant (see below). The Planning Noise Assessment noted:When windows are open to cool an overheating room, noise levels may be up to 6dB above therecommended criterion. This is slightly above the level considered to represent "reasonable"

conditions according to BS8233:2014 but it is not a significant exceedance and sleep is unlikely tobe significantly affected.We have indicated in previous objections to this proposal that the consultants' own appendicestend to contradict the view that a 6dB exceedance is 'not significant'.Relevant health endpoints for noise-related externalities are Ischaemic heart disease, stroke,diabetes and sleep disturbance. The methods for valuing these externalities are still beingdeveloped, as are those for valuing the benefits of quiet areas (see for example Defra (2014)Environmental Noise: Valuing impacts on sleep disturbance, annoyance, hypertension,productivity and quiet, November 2014; European Commission (2019) Handbook on the externalcosts of transport, January 2019). Defra estimates that the social costs of urban road noise wereon a par with the social costs of road accidents. There is some internalisation of costs of accidentsthrough insurance, but there is none in respect of road noise.A detailed assessment would allow for an estimation of the impact of the period of construction,and the period post construction. It is not zero. It is likely to be smaller than the estimates from airquality, climate change and property values (see below), but this might also reflect the evolvingstate of knowledge here.Property ValuesLocal residents' house values can be expected to be impacted, especially in the constructionperiod. The properties on College Road, Cecil Road and College Fields have an estimated valueof the order £2-4 million. The effect of construction at the site might be expected to affect, at least,those properties in closest proximity, of which there are 20 or so. Their combined value would beof the order £50-£60 million. There are surprisingly few studies of the effect on new constructionon house prices, especially ones which are a) conducted in the UK and b) adequately control forother variables.Nonetheless, even a study funded by Barratt and the NHBC Foundation indicates that short-termprices - during, or shortly after, construction - are likely to be affected by construction:Analysis of the price data suggests that there may be short-term disruption and downwardpressure on prices in the immediately surrounding area during or just after construction. This ismore likely to be the case with respect to sites which were seen to have high amenity value beforethe new development. Thereafter, the evidence indicates that in all types of areas the newdevelopment generally blends into the broader housing market quite quickly and prices moreclosely follow the patterns observed in the wider area. It also suggests that developments, of thesize and scale studied, even in areas where originally objections were significant, can lead torelatively rapid increases in prices in the neighbouring area.The study, however, did not look at any effect on prices during the planning application period,which might be expected to influence buyers' outlook during that period (which can be protracted),and which might have influenced the study's more general conclusions. It is difficult to lend anycredibility to these conclusions, which are drawn qualitatively, since by definition, they could onlybe drawn using quantitative analysis.We have analysed the data presented in the report and taking the data at face value, andcomparing the changes in price between the start of the period (2009) and end of the period(2014) studied, we considered the change in price of homes neighbouring the development as a

function of the value of the neighbouring properties (the study considered 8 differentdevelopments). There are good reasons to draw some caveats around this analysis, not least inrelation to the data quality. Nonetheless, there appears to be a functional link (see Figure below)between the drop in house prices over the five year period and their value: the higher the value,the larger is the fall in price, but the lower value properties might see their values enhanced. Thereare some intuitively reasonable explanations from this: for example, in areas where houses havelow value, their value is more likely to be lifted by new homes: the opposite might be true in areaswhere the existing homes are of higher value. Whatever, the nature of the functional link, a changeof the order 10% relative to 'control' properties (which is well below the highest price reductionsindicated by the study) would imply a significant loss in asset values on the part of the hostingcommunity, perhaps as much as £5-£6 million.Figure 1: Fall in Value of Properties Neighbouring New Housing Development, Relative to Changein Value at the Postcode Level (y-axis) v Property Value in 2009 (period from 2009 to 2014)

Source: own analysis, based on data in Christine Whitehead and Emma Sagor with Ann Edge andBruce Walker (2015) Understanding the Local Impact of New Residential Development: a PilotStudy, April 2015.

In summary, even on this brief assessment of benefits, we have identified quantifiable negativeexternalities of the order £8-£9 million. We have also highlighted why most of the alleged publicbenefits suggested by the applicant are either extremely slight, or non-existent.

2 NORTHCOTE ROAD, CLIFTON, BRISTOL BS8 3HB

Dear Sir or Madam

We have read the details of your revised proposals for the redevelopment of the West Car Parksite and make the following comments:-

We still believe that your proposed access from Cecil Road might cause congestion, safety issues,noise and pollution.

65 homes and parking on the site is very high density and likely to give rise, amongst other things,to considerable on-street parking.

We also remain concerned about the proposed storey height of Block A, despite the amendeddesign.

Clifton is a rare and beautiful village and we hope that the planning authority does nothing to spoilit.

Yours faithfully

Barry Ryder

Although, I understand it may legally be allowed and this may not be considered to be avalid objection, with two separate planning applications for both this site and the main zoo gardenswith a proposed injection into a small area of over 250 dwellings and over 500 residents, I find it itvery disappointing that the planning, design and potential combined impact of these twodevelopments is not being considered in a more integrated and holistic way.

Objection:The proposed development of the Zoo's former West Car Park site has not taken adequateaccount of Bristol City Council's published 'green' strategies notably:

Bristol Parks and Green Space Strategy,Bristol Allotments and Food Growing Strategy 2023-2038(which are linked to Bristol's Local Plan )

also Bristol's flagship initiative:One City Ecological Emergency Strategy

The Zoo site and Former west car park sites are prime 'showcase' sites for Bristol to demonstratecommitment to Bristol's One City Ecological Emergency Strategy, i.e. to invest in nature, for citizenhealth and well-being, (not just another housing development).

The proposed development (62 dwellings) is still much too dense.Any proposed development of the former Zoo Car Park needs to include green/outdoor space forevery dwelling, and should retain as much of the existing mature infrastructure (i.e. trees) aspossible.

Some extracts from BCC published reports / policies / strategiesa) One City Ecological Emergency Strategy (24/9/2020) - Marvyn Rees: 'We are proud Bristol wasthe first city in the UK to declare an Ecological Emergency, and this strategy is an important stepin taking concrete action to address nature's decline. Investing in nature is good for wildlife and

our health and well-being, 'b) Bristol Development Framework Core Strategy (adopted June 2011)section 4.9, Policy BCS9: Individual green assets should be retained wherever possible andintegrated into new development.

c) BCC Scrutiny Commission Report (dated 15/9/2022) highlighted the importance of local greenspaces for mental health,See section 1 'growing public awareness of the health and wellbeing benefits of food-growing andspending time outdoors'

d) BCC Communities Scrutiny Commission public report (dated 3/10/2022) highlighted how allproposed 'housing' or other developments need to incorporate local and accessible green spaces.See the BCC Officer's response, section 14 'recognition that green spaces are vital to the healthand wellbeing of its citizens.'

Objection:The proposed development of the Zoo's former West Car Park site has not taken adequateaccount of Bristol City Council's published 'green' strategies notably:

Bristol Parks and Green Space Strategy,Bristol Allotments and Food Growing Strategy 2023-2038(which are linked to Bristol's Local Plan )

also Bristol's flagship initiative:One City Ecological Emergency Strategy

The Zoo site and Former west car park sites are prime 'showcase' sites for Bristol to demonstratecommitment to Bristol's One City Ecological Emergency Strategy, i.e. to invest in nature, for citizenhealth and well-being, (not just another housing development).

The proposed development (62 dwellings) is still much too dense.Any proposed development of the former Zoo Car Park needs to include green/outdoor space forevery dwelling, and should retain as much of the existing mature infrastructure (i.e. trees) aspossible.

Some extracts from BCC published reports / policies / strategiesa) One City Ecological Emergency Strategy (24/9/2020) - Marvyn Rees: 'We are proud Bristol wasthe first city in the UK to declare an Ecological Emergency, and this strategy is an important stepin taking concrete action to address nature's decline. Investing in nature is good for wildlife and

our health and well-being, 'b) Bristol Development Framework Core Strategy (adopted June 2011)section 4.9, Policy BCS9: Individual green assets should be retained wherever possible andintegrated into new development.

c) BCC Scrutiny Commission Report (dated 15/9/2022) highlighted the importance of local greenspaces for mental health,See section 1 'growing public awareness of the health and wellbeing benefits of food-growing andspending time outdoors'

d) BCC Communities Scrutiny Commission public report (dated 3/10/2022) highlighted how allproposed 'housing' or other developments need to incorporate local and accessible green spaces.See the BCC Officer's response, section 14 'recognition that green spaces are vital to the healthand wellbeing of its citizens.'

The minor modifications to the design of building A do little to address the majorobjections to this plan.Building A is too massive for this site. The very long frontage onto College Road is not in keepingwith the surrounding buildings. The roof line is too high, even if the new parapet tries to give theillusion of being in scale with the surrounding buildings. The high ends of the building are too closeto the adjacent properties, adding to the feeling of density to the area, and particularly closing inthe aspect from the rear of Hardelot .The density of population which will be included in this developed space is out of proportion to theoriginal development of this area.Overall the objections are as those previously made .

Once again my husband and I write to object to this application for large solid blocks offlats facing the Zoo in the former West Car Park.I have seen it referred to as a brownfield site - its original purpose was, I understand, only forhorticultural use by the Zoo gardens. Part of the original site then metamorphosed into an overflowcar park. This is not a brownfield use, in our opinion.The proposed application for large blocks of flats; changing the entrance from College Road toCecil Road and generally spoiling the look of the conservation and history of this area is quiteunacceptable.As residents for many years we ask that this application [virtually the same as the last one] isrefused.

As residents of Cecil road we object to your amendments. Block A is towering above thecurrent dwellings on college road and Cecil road with no consideration to existing historicalarchitecture. Block B is also misaligned with the surrounding buildings and invading the privacy ofCecil road residents and Aubum house.

The site should be turned into a nature reserve to help with the climate crisis, not draining all ourresources further to create unsightly dwellings. This means, more exhaust fumes and traffic fromvehicles entering and exiting the site throughout the duration of the build / construction and oncecomplete.

We will also endure years of noise, drilling, site traffic, disturbance etc to enable the developersand zoo to profit from this project. We need more greenery in this world to help with the crisis.

I live directly opposite the proposed site and I am saddened that the new proposalshave not addressed the avalanche of objections originally raised. The development of the site isnot the issue, it's the nature of what is being proposed which is totally out of character with thesurrounding buildings. Surely buildings more in keeping with the area could be designed. Hasanyone explained why a new entrance onto Cecil Road has to be part of the proposal when therealready is a suitable entrance and exit onto College Road that have exited and functioned well fordecades. Insistence on maintaining the present access might help the rethinking of thedevelopment to rid it of such an ugly block of flats.

Could I ask that the planning committee reflect on the massive number of objections about thisproposal and try their best to ensure that the legacy of their decision is one they can be proud ofbecause it enhances the area rather than the opposite. I gather that at the original planningmeeting one of the officers publicly stated that he had never received so many objections and yetthe plans were passed and would have been carried out had there not been a judicial review.

My comments about the original development stand as I see no real difference between theoriginal proposal and the new proposal.

Dear Sirs,

The recent token modifications to the original plans for the Zoo's West Car Parkcontinue to be unacceptable. The housing estate envisaged is clearly not in keepingwith Historic Clifton's Conservation status, neither enhancing or improving the locality.The Planning officers will be failing in their duty to the owners of the neighbouring villasif consent is given.

Whilst it is acknowledged that Bristol needs to provide more housing there is aregrettable trend for the Planning committee to accept inappropriate designs, with adensity of buildings which allow for no private outdoor space, nor adequate localamenities. Bristol City has suffered from poor planning since the replacement of wardamaged and destroyed buildings, this is in contrast to many other cities where everyeffort has been made to provide desirable buildings, aesthetically pleasingcommensurate with the neighbourhood and complying with ever improved buildingregulations, where adequate parking facilities are provided and pedestrian zones arewell designed and maintained.

Clifton village has no municipal car park and as this one has already proved its worth itcould reduce the number of vehicles parked in the narrow Clifton roads providingparking facilities for a public garden to be developed on the old Zoo site rather thananother inappropriate ugly housing estate.

My comments made on the original proposal still stand. The revised proposal remainsunacceptable. Since the original proposal a planning application to develop the actual Zoo site hasbeen made. This proposal creates a new road access onto College Road, so I cannot understandwhy the Car Park proposal needs to create a new road access onto Cecil Road when it alreadyhas access onto College Road. I suspect the change is driven by greed to create an awful block offlats and pack as many units in as possible.

The Car Park proposal will be a blight on the architecture of the area and shows no respect for thesurrounding buildings or residents. At the original planning meeting it was apparent that some onthe committee believed it more important to support the Zoo (a failing business) rather thanconcentrate on the actual detail of the planning application. I trust this will be addressed at thenext planning meeting. Others on the committee, representing other parts of Bristol, showed noempathy for what local residents consider to be the destruction of the character of this part ofClifton. It seemed as though party politics was at play rather than an unbiased consideration of theplans proposed.

A child could produce a better proposal than the one at present. I call upon the committee to rejectthis proposal and insist on a development more in keeping with the immediate surroundings.

Having reviewed the proposal it has my full support.It looks much better than the car park.It provides much needed housing.The buildings have been designed by a first rate architect.The area has an abundance of green space at the Downs which are minutes away.The proposal is put forward by Bristol Zoo who are a not for profit charity.While not a neighbour I am a regular visitor to this area and work nearby.

The Clifton & Hotwells Improvement Society remains firmly opposed to this Application.The recent changes minimally address the harm that would be caused to the Conservation Area.CHIS, therefore, reiterates the objections already expressed.

1. The scheme constitutes over-intensive development.

2. A high proportion of the homes have only a single aspect. There is no daylight in somecorridors. Far too many have no access to private open space. There is nowhere for children toplay.

3. The buildings are too high, especially those on College Road. The poor design and over-massing would damage the setting of surrounding buildings.

4. A significant number of mature trees would be lost.

In sum, the proposals fail altogether to preserve or enhance the character of the ConservationArea.

Dear Sirss

Planning application case No. Zoo West Car Park.21/01999/F

I would like to register the foilowing objections to the proposed development

Lack of local amenities for social housing. Lack of school space, lack of NHS dentalfacilities, lack of low price shopping combined with high bus fares.

Over 400 objections to the scheme have been registered with only a few in favour andthe applicants have only made token changes to the development.

Although it was recorded that the Zoo's poor financial situation did not affect planningconsiderations this was not the case at the Council meeting in 2021 where the viewsand decisions of the Council and Counsellors were significantly nfluenced by finance.

Population too dense for the space available.

Insufficient parking space.

Poor quality of proposed building incompatible in form with adjacent buildings.singleaspect, little outside space, dark corridors, overlooking and affecting light in adjacentproperties. Entrances off pavement.

Long term maintenance cost of Green roofs which need regular attention to preventweed growth.

Reversal of previous planning policy for Auburn House where advice was that buildingsof greater height than single storey would affect conservation contours. and unlikely tobe granted, See previous correspondence.

A significant number of mature trees will be lost. The West Car Park was previouslygreenhouses and garden for plant propagation. Trees were subsequently planted aspart of the change of use permission at that time.

Yours faithfully

Block A continues to be completely out of proportion to all other residences in the areain both elevation andlength, despite minor changes. It would dominate the streetscape at the north end of CollegeRoad, so there would be a canyon effect between Block A and Clifton Pavilion, having a verynegative visual impact, completely out of scale with the rest of the road. It's taller than allsurrounding buildings whichmakes it inappropriate and out of keeping. Minor changes to the façade make minimal differenceto the overbearing nature of the blockBy adjoining our boundary wall at Garden Flat, 50 College Road, it would deprive our home of lightand privacy and have a serious effect on our quality of life. Some rooms in our home will receiveno natural light at all. This concern is borne out in the lighting reports and the reduction in height atthe north end makes no difference.There must be a significant reduction in height and length of Block A.There are still too many houses in one area with little space for landscaping.We recognise that it is a 'brown field' site but it is in a conservation area and there are many treeson the site at the moment. Not only do these old trees provide habitats but they are in keeping withthe entire conservation area. The proposed green areas in the new plans are totally inadequate.The two storey mews style houses seem appropriate for this development but the overallimpression is still of a housing estate that visually is totally out of keeping for a conservationarea. In particular block A is entirely unsuitable.

The minor revisions to this application fail to render it more acceptable.

It is still overmassed, too tall and incongruous in the setting of the listed and historic buildingssurrounding the site to which it will cause serious harm.The car parking provision is completely inadequate. The LPA must not continue to pretend thatresidents who use public transport, bicycles or walk, on an everyday basis, do not have cars whichthey use for shopping and pleasure trips.

This application needs to be considered together with that for the main Zoo Gardens. It might verywell be needed as a car park for that site.

I support this application as it provides much needed housing and makes good use of abrown field site. it also supports Bristol Zoo in their future plans

The Council letter dated 3 October 2022 gives no detail as to changes made since theoriginal application, so I am obliged to act as though my original concerns have not beenaddressed.I object to:Insufficient parking places within the development site. Consequently, pressure on surroundingstreets.

The revised plans do not appear to have addressed our previously stated concernsabout the inadequate amount of parking for the proposed number of dwellings. Our businesswould be negatively impacted by the increased demand for on street parking, and increasedtraffic.

I, Francis Greenacre, a resident of Cecil Road immediately opposite the proposeddevelopment, fully support the application.Following the revisions made to the previous applications, further detailed improvements havenow been made to Block A on College Road. These significantly improve its articulation andcharacter, make it more compatible with the adjacent Victorian terrace and modify its scale.Misconceptions concerning the dominance of Block A are likely to continue and deserve to berefuted. The height of the new cornice to Block A is lower than the roofline of all nearby buildings,including the Pavilion, Cecil Road semis and Auburn House etc, etc. The fifth storey of Block A(above the cornice) extends the height by under 2 1/2 m., that is to just over 1 m. higher than 3Cecil Road's roofline, under which I live. But this fifth storey is within a well-recessed mansardroof, which is barely visible from street level. On Clifton Down, bordering the site, Auburn andSutton House are the lowest of the sequence of grand semi-detached mansions, all of whichexceed the full height of Block A.The surrounding Conservation Area is impressively various in building type, style and scale andthis restrained development represents a positive improvement on the 'large brownfield car park' itsucceeds.There have been further improvements to the development's sustainability. There will be adecrease in traffic in comparison with times when the Zoo was open and there will be a slightincrease in the number of trees and of biodiversity.

Despite minor amendments I still strongly object to this planning application.

The mass of the proposed buildings is still far too great, too close to the road of of poor design.

Please do not allow the zoo to leave such a disappointing legacy.

I objected to the previous application and still do for much the same reasons. Theamended plans do not address the fundamental issue of the mass of building that is being createdthat will sit right next to the pavement of College Road. It is too high and should be set back fromthe road.

Despite minor amendments, the proposed buildings are monolithic and simply far toohigh.

I noticed that Historic England no longer objects. Please do not interpret this as anapproval from them - merely that that no longer object. In HE's own words the changes are '..minoramendments..' - that is not a ringing endorsement.

I had to flick backwards and forwards a few time between the old and new plans to spot thedifferences as they are so minor. This is an old negotiation game - you first ask for somethingunreasonable and then give a little and hope the counter party gets ground down and agrees.

It is not the council's job to help out the finances of the zoo, nor to maximise the profits ofdevelopers. I may be naïve but I thought the council would be looking after the interests of itscitizens - it is a mystery to me why that does not appear to be happening.

There are several local building that when you walk passed them you think 'what were theythinking when that was approved?'. Please do not add another to that list which will negativelyimpact our built environment for a generation.

These minor amendments do not alter the fact that the design of this application iswholly inappropriate.

Please reject.

We see that a tranche of new documents were published on the portal on 27 Septemberlast. These do not appear to include the documents that we have been calling for - in particular therequired Biodiversity Net Gain calculation. Is it intended that these will be provided?

We also note that the Energy and Sustainability document (21_01999_F-17556-HYD-XX-XX-RP-Y-5000_-_ENERGY_AND_SUSTAINABILITY_P05-3308780) states at 3.2 that 'An ecologicalreport has been produced for the site which includes a habitat survey.' Can you please send us acopy of these documents. Why have these not been published?

Is new arboricultural evidence required by the changes to the proposals? If so, when will this beprovided?

for Bristol Tree Forum

Dear Sirs.

We append our objections given in 2021.

We note that this important meeting is scheduled for the 24th of August at peak holidaytime.

Although the minutes of the meeting in 2021 stated that finance was not considered inthe recommendation presented, this was a major issue during the meeting.

The Conservational Advisory Panel have raised objections to the scheme which hasrepercussions for the main Zoo site.

The style of proposed architecture is incongruous. A good example of congruousarchitecture is the nursery/ primary department building of Clifton College and thebuildings replacing the old rifle range.

The reasons for the objections to these plans have been expressed in detail by manylocal people , and I continue to oppose this plan for the reasons so comprehensively stated inAdam Chivers letter.Historic England have repeated their comments, and yet Bristol City Council planners persist inresubmitting their unchanged plans.This shows a complete contempt for the opinions of Bristol citizens by their democratically electedcouncil, and a disregard of advice offered by statutory bodies advising on the environmentaleffects of this development.It is hoped that the planning group will meet to decide on this issue at a time when many localpeople can attend and observe the decision making process of our elected representatives.

I wish to register my continuing objection to the Zoo's plans for this site. Adam Chivers'letter summarises my position well.

Dear Sir/Madam, I refer to the above application and specifically the amendments made to the original submission. Having considered the revisions I believe my objections submitted on 28th June below are still relevant as the revisions do not meaningfully address the design and massing concerns that I expressed on 28th June. The site is in a Conservation Area and the scheme lacks sensitivity and is inappropriate for such a location. --------------------------------------------------------------------------------------------------------------------

Dear Sir/Madam, I write to object to the proposed development of the zoo car park in it's current form in terms of, inter alia: - the massing and scale of the proposed apartment buildings in a conservation area giving the appearance of a development from the post war Soviet Bloc era;- the overbearing design in a relatively narrow street scene;- the loss of 15 mature trees at a time when environmental issues are being highlighted daily;- the lack of amenity space for residents and- The lack of residents car parking, the cost of the units in this development will mean they will not sell to first time buyers but more likely to downsizers who will own at least one car (albeit electric in coming years and will also require an electric charging point)

I hope that the planning officer will be looking at this application with a critical eye and have cognisance of previous developments in Clifton in terms of design, scale and concept of future living. Your faithfully David Burston

I would like to confirm my objection on the basis of the harm this application would do tothe heritage assets and the local area.

It is not considered that a full and proper assessment of the impact on heritage assetsunder the parameters of paragraphs 195, 199-202 of the NPPF has been undertaken. If it had thiswould have concluded that the proposal has a significant impact on heritage assets.It provides insufficient substantial public benefits to outweigh the substantial harm caused by theimpact of such a poor scheme on the relevant heritage assets.It is not considered that this scale of development can be justified in a heritage context. Moreover,it does not accord with relevant Local Plan heritage policies nor the requirements of the NPPF. Itcannot be supported.

I object most strongly to this application.

1. Charitable status. Sadly, as has been the case throughout the planning process for this site, theZoo trustees have ignored the legitimate concerns of the objectors and, in their wish to maximisetheir commercial return to the exclusion of all other public benefit considerations, demonstrated asurprising ignorance of their duties as trustees. They assume they have a responsibility to achievemaximum price for the land. That is wholly wrong. Their responsibility is to achieve best value inaccordance with their charitable purposes which would include a proper responsibility forconservation, environmental and societal concerns. This has been pointed out to them onnumerous occasions.

2. Contempt for residents. Given(a) the fundamental nature of the heritage-related objections made by over 300 neighbours; and(b) the seriously defective manner in which those objections were addressed in the Officer's report

it is remarkable that the Zoo has decided not to revise its Application. Seeking consent for anunchanged Application demonstrates a degree of contempt both for local residents and theheritage objections that were common to all the objections previously raised.

3. Irrelevant financial considerations. Shortly before the planning application was originally granted(and then quashed) I participated in a Zoom call which various residents had with the PlanningOfficer. During the conversation, the Planning Officer admitted that he was under severe pressurefrom the Zoo. He appeared to believe that this was a relevant consideration. It is not. The processis quasi-judicial in nature and both the Planning Officer and the relevant councillors should confine

themselves to planning considerations. Anything else will inevitably lead to another judicial reviewapplication and a further waste of Council money.

4. Conservation. The scheme for which the Zoo seeks approval is wholly inconsistent with thebasic principles of conservation. As Historic England has noted in its submissions, the NationalPlanning Policy framework defines 'conservation' as 'the process of maintaining and managingchange to a heritage asset in a way that sustains and, where appropriate, enhances itssignificance.' The scheme comes nowhere near satisfying that basic principle. Well over 300people object to the scheme - some 95% or so of those who have made submissions. Theproportion would be greater if the Zoo had not inflated the numbers in favour by ensuring thatcertain of its directors made submissions in support (without indicating either their status or thatthey had an obvious interest in the success of the application).

In essence, the objectors make the same or similar points in complaining about the scheme. It canbe no coincidence that so many people have reached the same conclusions nor that, crucially,their objections are reinforced in the submissions of Historic England. Helpfully, Historic Englandhas drawn attention to the 'combination of formal Gothic architecture and mature planting [that] arean essential focus of this part of the conservation area [and the] liberal use of rubble limestoneand Bathstone dressings on both building and walls [that] also predominates and [so] creates aconsistency between buildings and their settings.' The proposals make no concessionswhatsoever to this highly relevant context in which the development is proposed - a uniqueConservation Area of national significance.

The common features of the huge number of objections are these:

A. The proposals constitute over intensive development. In the words of Historic England, 'theproposed layout, massing and design fails to respond to the character and appearance of theConservation Area'.

B. The buildings are too tall, especially those proposed on College Road and are out of keepingwith surrounding buildings. As Historic England puts it, '[the] robust rhythm of weighty Victorianvillas, constructed predominantly from dressed rubble and Bath stone detailing, is certainly theoverriding built form and the concept of a terraced approach of this scale alongside the existingshort terrace is of considerable concern.'

C. The poor design and over-massing would damage the settings of surrounding buildings.

D. The parking provision is hopelessly inadequate.

E. Amenity space is inadequate.

F. A significant number of trees would be lost.

G. There is no conservation merit in creating a vehicular entrance to the site from Cecil Roadwhen there already exists a perfectly satisfactory entrance from College Road.

H. The proposals fail altogether to preserve or enhance the character of the Conservation Area. Infact, they would do the opposite: significant damage.

I agree with all these objections. The applicants have made no attempt to ensure that the schemeis appropriate for the Conservation Area.

As Historic England has explained, 'While the existing car park does not contribute positively tothe Conservation Area, its open aspect and enclosure behind the high stone wall of College Roadis indicative of the juxtaposition of rows of substantial villas against substantial, open spaces'.

The proposals should at the very least have taken notice of the positive contribution to theConservation Area of this wall and the need to comply with the Conservation Area Appraisal, bothof which Historic England has emphasised. As it has explained: 'If development were to be furtherset back into the site, the impact of the development could be reduced and the boundary wallcould be retained in a more meaningful and contextual way.'

5. Environmental considerations. Although the Zoo has claimed that 'our plans demonstrate highenvironmental and sustainable standards' this is patently untrue. The proposals for energyperformance meeting go nowhere near even the requirements of the Council's Policy BCS 14.

The Zoo's reason for discounting solar PV panels on grounds of orientation is self-serving andmanifestly disingenuous: it was up to the Zoo to determine the orientation of the roofs. And in anyevent the Zoo has included solar PV panels in its proposals for the main site. Its consultants needto explain why what was not feasible on one site is deemed eminently feasible on the other.

6. Embodied carbon. The housing is of such construction that the embodied energy andgreenhouse gas emissions (i.e. the energy generated, and greenhouse gas emitted, associatedwith the materials and construction process) will be way above far that recommended by RIBA andthe UK Green Building Council. These embodied emissions dominate the greenhouse gasemissions associated with energy use in the operational phase. Giving consent to housing of thisnature is wholly inconsistent with the Council's declaration of a climate emergency.

7. Affordable homes. The site offers 20% affordable homes. This accords with the AffordableHomes Practice Note. In the Council's response to the pre-action protocol letter from Leigh Day(regarding the granting of the now quashed Application) the Council's legal opinion was clear: thata Practice Note cannot change or establish policy. It is clear that this Application has clearly beendealt with in ways which would not be considered appropriate under the existing Policies in theCore Strategy. In effect, the Application assumes the very change of policy, via the Practice Note,

that the Council's own legal opinion considers inappropriate. It therefore fails to comply with theCouncil's own policies on affordable homes.

I object most strongly to this application.

1. Charitable status. Sadly, as has been the case throughout the planning process for this site, theZoo trustees have ignored the legitimate concerns of the objectors and, in their wish to maximisetheir commercial return to the exclusion of all other public benefit considerations, demonstrated asurprising ignorance of their duties as trustees. They assume they have a responsibility to achievemaximum price for the land. That is wholly wrong. Their responsibility is to achieve best value inaccordance with their charitable purposes which would include a proper responsibility forconservation, environmental and societal concerns. This has been pointed out to them onnumerous occasions.

2. Contempt for residents. Given(a) the fundamental nature of the heritage-related objections made by over 300 neighbours; and(b) the seriously defective manner in which those objections were addressed in the Officer's report

it is remarkable that the Zoo has decided not to revise its Application. Seeking consent for anunchanged Application demonstrates a degree of contempt both for local residents and theheritage objections that were common to all the objections previously raised.

3. Irrelevant financial considerations. Shortly before the planning application was originally granted(and then quashed) I participated in a Zoom call which various residents had with the PlanningOfficer. During the conversation, the Planning Officer admitted that he was under severe pressurefrom the Zoo. He appeared to believe that this was a relevant consideration. It is not. The processis quasi-judicial in nature and both the Planning Officer and the relevant councillors should confine

themselves to planning considerations. Anything else will inevitably lead to another judicial reviewapplication and a further waste of Council money.

4. Conservation. The scheme for which the Zoo seeks approval is wholly inconsistent with thebasic principles of conservation. As Historic England has noted in its submissions, the NationalPlanning Policy framework defines 'conservation' as 'the process of maintaining and managingchange to a heritage asset in a way that sustains and, where appropriate, enhances itssignificance.' The scheme comes nowhere near satisfying that basic principle. Well over 300people object to the scheme - some 95% or so of those who have made submissions. Theproportion would be greater if the Zoo had not inflated the numbers in favour by ensuring thatcertain of its directors made submissions in support (without indicating either their status or thatthey had an obvious interest in the success of the application).

In essence, the objectors make the same or similar points in complaining about the scheme. It canbe no coincidence that so many people have reached the same conclusions nor that, crucially,their objections are reinforced in the submissions of Historic England. Helpfully, Historic Englandhas drawn attention to the 'combination of formal Gothic architecture and mature planting [that] arean essential focus of this part of the conservation area [and the] liberal use of rubble limestoneand Bathstone dressings on both building and walls [that] also predominates and [so] creates aconsistency between buildings and their settings.' The proposals make no concessionswhatsoever to this highly relevant context in which the development is proposed - a uniqueConservation Area of national significance.

The common features of the huge number of objections are these:

A. The proposals constitute over intensive development. In the words of Historic England, 'theproposed layout, massing and design fails to respond to the character and appearance of theConservation Area'.

B. The buildings are too tall, especially those proposed on College Road and are out of keepingwith surrounding buildings. As Historic England puts it, '[the] robust rhythm of weighty Victorianvillas, constructed predominantly from dressed rubble and Bath stone detailing, is certainly theoverriding built form and the concept of a terraced approach of this scale alongside the existingshort terrace is of considerable concern.'

C. The poor design and over-massing would damage the settings of surrounding buildings.

D. The parking provision is hopelessly inadequate.

E. Amenity space is inadequate.

F. A significant number of trees would be lost.

G. There is no conservation merit in creating a vehicular entrance to the site from Cecil Roadwhen there already exists a perfectly satisfactory entrance from College Road.

H. The proposals fail altogether to preserve or enhance the character of the Conservation Area. Infact, they would do the opposite: significant damage.

I agree with all these objections. The applicants have made no attempt to ensure that the schemeis appropriate for the Conservation Area.

As Historic England has explained, 'While the existing car park does not contribute positively tothe Conservation Area, its open aspect and enclosure behind the high stone wall of College Roadis indicative of the juxtaposition of rows of substantial villas against substantial, open spaces'.

The proposals should at the very least have taken notice of the positive contribution to theConservation Area of this wall and the need to comply with the Conservation Area Appraisal, bothof which Historic England has emphasised. As it has explained: 'If development were to be furtherset back into the site, the impact of the development could be reduced and the boundary wallcould be retained in a more meaningful and contextual way.'

5. Environmental considerations. Although the Zoo has claimed that 'our plans demonstrate highenvironmental and sustainable standards' this is patently untrue. The proposals for energyperformance meeting go nowhere near even the requirements of the Council's Policy BCS 14.

The Zoo's reason for discounting solar PV panels on grounds of orientation is self-serving andmanifestly disingenuous: it was up to the Zoo to determine the orientation of the roofs. And in anyevent the Zoo has included solar PV panels in its proposals for the main site. Its consultants needto explain why what was not feasible on one site is deemed eminently feasible on the other.

6. Embodied carbon. The housing is of such construction that the embodied energy andgreenhouse gas emissions (i.e. the energy generated, and greenhouse gas emitted, associatedwith the materials and construction process) will be way above far that recommended by RIBA andthe UK Green Building Council. These embodied emissions dominate the greenhouse gasemissions associated with energy use in the operational phase. Giving consent to housing of thisnature is wholly inconsistent with the Council's declaration of a climate emergency.

7. Affordable homes. The site offers 20% affordable homes. This accords with the AffordableHomes Practice Note. In the Council's response to the pre-action protocol letter from Leigh Day(regarding the granting of the now quashed Application) the Council's legal opinion was clear: thata Practice Note cannot change or establish policy. It is clear that this Application has clearly beendealt with in ways which would not be considered appropriate under the existing Policies in theCore Strategy. In effect, the Application assumes the very change of policy, via the Practice Note,

that the Council's own legal opinion considers inappropriate. It therefore fails to comply with theCouncil's own policies on affordable homes.

I object most strongly to this application.

1. Charitable status. Sadly, as has been the case throughout the planning process for this site, theZoo trustees have ignored the legitimate concerns of the objectors and, in their wish to maximisetheir commercial return to the exclusion of all other public benefit considerations, demonstrated asurprising ignorance of their duties as trustees. They assume they have a responsibility to achievemaximum price for the land. That is wholly wrong. Their responsibility is to achieve best value inaccordance with their charitable purposes which would include a proper responsibility forconservation, environmental and societal concerns. This has been pointed out to them onnumerous occasions.

2. Contempt for residents. Given(a) the fundamental nature of the heritage-related objections made by over 300 neighbours; and(b) the seriously defective manner in which those objections were addressed in the Officer's report

it is remarkable that the Zoo has decided not to revise its Application. Seeking consent for anunchanged Application demonstrates a degree of contempt both for local residents and theheritage objections that were common to all the objections previously raised.

3. Irrelevant financial considerations. Shortly before the planning application was originally granted(and then quashed) I participated in a Zoom call which various residents had with the PlanningOfficer. During the conversation, the Planning Officer admitted that he was under severe pressurefrom the Zoo. He appeared to believe that this was a relevant consideration. It is not. The processis quasi-judicial in nature and both the Planning Officer and the relevant councillors should confine

themselves to planning considerations. Anything else will inevitably lead to another judicial reviewapplication and a further waste of Council money.

4. Conservation. The scheme for which the Zoo seeks approval is wholly inconsistent with thebasic principles of conservation. As Historic England has noted in its submissions, the NationalPlanning Policy framework defines 'conservation' as 'the process of maintaining and managingchange to a heritage asset in a way that sustains and, where appropriate, enhances itssignificance.' The scheme comes nowhere near satisfying that basic principle. Well over 300people object to the scheme - some 95% or so of those who have made submissions. Theproportion would be greater if the Zoo had not inflated the numbers in favour by ensuring thatcertain of its directors made submissions in support (without indicating either their status or thatthey had an obvious interest in the success of the application).

In essence, the objectors make the same or similar points in complaining about the scheme. It canbe no coincidence that so many people have reached the same conclusions nor that, crucially,their objections are reinforced in the submissions of Historic England. Helpfully, Historic Englandhas drawn attention to the 'combination of formal Gothic architecture and mature planting [that] arean essential focus of this part of the conservation area [and the] liberal use of rubble limestoneand Bathstone dressings on both building and walls [that] also predominates and [so] creates aconsistency between buildings and their settings.' The proposals make no concessionswhatsoever to this highly relevant context in which the development is proposed - a uniqueConservation Area of national significance.

The common features of the huge number of objections are these:

A. The proposals constitute over intensive development. In the words of Historic England, 'theproposed layout, massing and design fails to respond to the character and appearance of theConservation Area'.

B. The buildings are too tall, especially those proposed on College Road and are out of keepingwith surrounding buildings. As Historic England puts it, '[the] robust rhythm of weighty Victorianvillas, constructed predominantly from dressed rubble and Bath stone detailing, is certainly theoverriding built form and the concept of a terraced approach of this scale alongside the existingshort terrace is of considerable concern.'

C. The poor design and over-massing would damage the settings of surrounding buildings.

D. The parking provision is hopelessly inadequate.

E. Amenity space is inadequate.

F. A significant number of trees would be lost.

G. There is no conservation merit in creating a vehicular entrance to the site from Cecil Roadwhen there already exists a perfectly satisfactory entrance from College Road.

H. The proposals fail altogether to preserve or enhance the character of the Conservation Area. Infact, they would do the opposite: significant damage.

I agree with all these objections. The applicants have made no attempt to ensure that the schemeis appropriate for the Conservation Area.

As Historic England has explained, 'While the existing car park does not contribute positively tothe Conservation Area, its open aspect and enclosure behind the high stone wall of College Roadis indicative of the juxtaposition of rows of substantial villas against substantial, open spaces'.

The proposals should at the very least have taken notice of the positive contribution to theConservation Area of this wall and the need to comply with the Conservation Area Appraisal, bothof which Historic England has emphasised. As it has explained: 'If development were to be furtherset back into the site, the impact of the development could be reduced and the boundary wallcould be retained in a more meaningful and contextual way.'

5. Environmental considerations. Although the Zoo has claimed that 'our plans demonstrate highenvironmental and sustainable standards' this is patently untrue. The proposals for energyperformance meeting go nowhere near even the requirements of the Council's Policy BCS 14.

The Zoo's reason for discounting solar PV panels on grounds of orientation is self-serving andmanifestly disingenuous: it was up to the Zoo to determine the orientation of the roofs. And in anyevent the Zoo has included solar PV panels in its proposals for the main site. Its consultants needto explain why what was not feasible on one site is deemed eminently feasible on the other.

6. Embodied carbon. The housing is of such construction that the embodied energy andgreenhouse gas emissions (i.e. the energy generated, and greenhouse gas emitted, associatedwith the materials and construction process) will be way above far that recommended by RIBA andthe UK Green Building Council. These embodied emissions dominate the greenhouse gasemissions associated with energy use in the operational phase. Giving consent to housing of thisnature is wholly inconsistent with the Council's declaration of a climate emergency.

7. Affordable homes. The site offers 20% affordable homes. This accords with the AffordableHomes Practice Note. In the Council's response to the pre-action protocol letter from Leigh Day(regarding the granting of the now quashed Application) the Council's legal opinion was clear: thata Practice Note cannot change or establish policy. It is clear that this Application has clearly beendealt with in ways which would not be considered appropriate under the existing Policies in theCore Strategy. In effect, the Application assumes the very change of policy, via the Practice Note,

that the Council's own legal opinion considers inappropriate. It therefore fails to comply with theCouncil's own policies on affordable homes.

I object most strongly to this application.

1. Charitable status. Sadly, as has been the case throughout the planning process for this site, theZoo trustees have ignored the legitimate concerns of the objectors and, in their wish to maximisetheir commercial return to the exclusion of all other public benefit considerations, demonstrated asurprising ignorance of their duties as trustees. They assume they have a responsibility to achievemaximum price for the land. That is wholly wrong. Their responsibility is to achieve best value inaccordance with their charitable purposes which would include a proper responsibility forconservation, environmental and societal concerns. This has been pointed out to them onnumerous occasions.

2. Contempt for residents. Given(a) the fundamental nature of the heritage-related objections made by over 300 neighbours; and(b) the seriously defective manner in which those objections were addressed in the Officer's report

it is remarkable that the Zoo has decided not to revise its Application. Seeking consent for anunchanged Application demonstrates a degree of contempt both for local residents and theheritage objections that were common to all the objections previously raised.

3. Irrelevant financial considerations. Shortly before the planning application was originally granted(and then quashed) I participated in a Zoom call which various residents had with the PlanningOfficer. During the conversation, the Planning Officer admitted that he was under severe pressurefrom the Zoo. He appeared to believe that this was a relevant consideration. It is not. The processis quasi-judicial in nature and both the Planning Officer and the relevant councillors should confine

themselves to planning considerations. Anything else will inevitably lead to another judicial reviewapplication and a further waste of Council money.

4. Conservation. The scheme for which the Zoo seeks approval is wholly inconsistent with thebasic principles of conservation. As Historic England has noted in its submissions, the NationalPlanning Policy framework defines 'conservation' as 'the process of maintaining and managingchange to a heritage asset in a way that sustains and, where appropriate, enhances itssignificance.' The scheme comes nowhere near satisfying that basic principle. Well over 300people object to the scheme - some 95% or so of those who have made submissions. Theproportion would be greater if the Zoo had not inflated the numbers in favour by ensuring thatcertain of its directors made submissions in support (without indicating either their status or thatthey had an obvious interest in the success of the application).

In essence, the objectors make the same or similar points in complaining about the scheme. It canbe no coincidence that so many people have reached the same conclusions nor that, crucially,their objections are reinforced in the submissions of Historic England. Helpfully, Historic Englandhas drawn attention to the 'combination of formal Gothic architecture and mature planting [that] arean essential focus of this part of the conservation area [and the] liberal use of rubble limestoneand Bathstone dressings on both building and walls [that] also predominates and [so] creates aconsistency between buildings and their settings.' The proposals make no concessionswhatsoever to this highly relevant context in which the development is proposed - a uniqueConservation Area of national significance.

The common features of the huge number of objections are these:

A. The proposals constitute over intensive development. In the words of Historic England, 'theproposed layout, massing and design fails to respond to the character and appearance of theConservation Area'.

B. The buildings are too tall, especially those proposed on College Road and are out of keepingwith surrounding buildings. As Historic England puts it, '[the] robust rhythm of weighty Victorianvillas, constructed predominantly from dressed rubble and Bath stone detailing, is certainly theoverriding built form and the concept of a terraced approach of this scale alongside the existingshort terrace is of considerable concern.'

C. The poor design and over-massing would damage the settings of surrounding buildings.

D. The parking provision is hopelessly inadequate.

E. Amenity space is inadequate.

F. A significant number of trees would be lost.

G. There is no conservation merit in creating a vehicular entrance to the site from Cecil Roadwhen there already exists a perfectly satisfactory entrance from College Road.

H. The proposals fail altogether to preserve or enhance the character of the Conservation Area. Infact, they would do the opposite: significant damage.

I agree with all these objections. The applicants have made no attempt to ensure that the schemeis appropriate for the Conservation Area.

As Historic England has explained, 'While the existing car park does not contribute positively tothe Conservation Area, its open aspect and enclosure behind the high stone wall of College Roadis indicative of the juxtaposition of rows of substantial villas against substantial, open spaces'.

The proposals should at the very least have taken notice of the positive contribution to theConservation Area of this wall and the need to comply with the Conservation Area Appraisal, bothof which Historic England has emphasised. As it has explained: 'If development were to be furtherset back into the site, the impact of the development could be reduced and the boundary wallcould be retained in a more meaningful and contextual way.'

5. Environmental considerations. Although the Zoo has claimed that 'our plans demonstrate highenvironmental and sustainable standards' this is patently untrue. The proposals for energyperformance meeting go nowhere near even the requirements of the Council's Policy BCS 14.

The Zoo's reason for discounting solar PV panels on grounds of orientation is self-serving andmanifestly disingenuous: it was up to the Zoo to determine the orientation of the roofs. And in anyevent the Zoo has included solar PV panels in its proposals for the main site. Its consultants needto explain why what was not feasible on one site is deemed eminently feasible on the other.

6. Embodied carbon. The housing is of such construction that the embodied energy andgreenhouse gas emissions (i.e. the energy generated, and greenhouse gas emitted, associatedwith the materials and construction process) will be way above far that recommended by RIBA andthe UK Green Building Council. These embodied emissions dominate the greenhouse gasemissions associated with energy use in the operational phase. Giving consent to housing of thisnature is wholly inconsistent with the Council's declaration of a climate emergency.

7. Affordable homes. The site offers 20% affordable homes. This accords with the AffordableHomes Practice Note. In the Council's response to the pre-action protocol letter from Leigh Day(regarding the granting of the now quashed Application) the Council's legal opinion was clear: thata Practice Note cannot change or establish policy. It is clear that this Application has clearly beendealt with in ways which would not be considered appropriate under the existing Policies in theCore Strategy. In effect, the Application assumes the very change of policy, via the Practice Note,

that the Council's own legal opinion considers inappropriate. It therefore fails to comply with theCouncil's own policies on affordable homes.

I continue to object to this planning application for the reasons set out in my previoussubmission in June 2021.

Since then the decision to grant planning permission was declared unlawful by the Court and theapplication has reverted to being 'undetermined'. I am very disappointed and amazed that the Zoohas not revised its original planning application given the volume and significance of the objectionsraised. In determining the application the Council should ignore the financial implications of theirdecision on the Zoo and concentrate solely on the lawful grounds for determination.

My objection is a simple one: it appears the submission of the identical planningapplication that was quashed before is not attempting to take into account any of the concernspreviously identified and expressed by the previous objections from the local residents, especiallyregarding the scale of the development and its impact in a conservation area.

Also, shouldn't this application now be considered in light of the application for the main zoo site inits combined impacts?

Unfortunately, this apparent complete disregard for the Zoo planning team following localconsultations comes across as somewhat contemptuous and arrogant and is in contrast to theimage it seeks.

I hope the Council will refuse this application and get the Zoo planning team to properly engagewith the residents of this conservation area for both planning projects. It is not that the residentsare saying that these projects shouldn't necessarily happen but they should be done with respectand a view of preserving and enhancing this unique and historic conservation area.

In the Officer's report to the Development Control Committee on 22 September 2021 it was stated at para 1.5 that the key areas in the determination of the application are:1) Is this an acceptable location for housing in principle?2) Is the design of the proposal appropriate in this location in the Clifton and Hotwells Conservation Area?3) Would the proposal give rise to an unacceptable loss of trees?4) Would the proposal give rise to unacceptable congestion and parking issues in the area?In my view:1) It is an acceptable location for housing in principle.2) The sheer ugliness of the buildings, the massing, the proposed building materials, the enormous block on College Road, the sheer size of the proposed development, the lack of sufficient car parking, the lack of outside space, the proposed new entrance on Cecil Road, the lack of solar panels, the huge number of heat pumps, the lack of play space for children, make this a totally inappropriate design for the Clifton and Hotwells Conservation Area. The views of Historic England and the vast number of local residents should not and cannot be ignored. A fundamental rethink of the design is required not simply tinkering around the edges. It is just not good enough and represents greed over taste and good design.3) At least 15 mature trees would be lost. Many of these trees are over 100 years old. Replacement trees will not be looked after and many will die quite quickly as we see on a number of new estates around the country. For a Zoo which prides itself on Conservation this is an atrocious proposal and is totally unacceptable.4) There exist two entrances to the site on College Road, one to enter, one to leave. This is an eminently sensible feature together with a pedestrian crossing. It is one which the local neighbourhood is used to and compliant with. Its existence and maintenance

would enable the proposed massive terrace to be broken -up and be less enormous and ugly. Moreover it would mean that a new entrance on Cecil Road would be unnecessary. Cecil Road can already be a traffic nightmare during the morning and evening rush hour. Traffic seeks to avoid the junction at the top of Bridge Valley Road by sprinting from The Promenade, past the Mansion House, along Cecil Road and then either left to the Downs or right to the various means of access to Pembroke Road. There is no doubt at all that the proposed entrance to the site, if it were to go ahead, will mean enormous congestion in the area, made worse by the paucity of car parking spaces for the residents of and visitors to the 62 residences on the site. It is make believe to think that the present proposals will not lead to massive congestion, parking issues and danger in the area. The assessment of the issue was carried out during the pandemic when there was little or no traffic on the roads. Wake up Transport Development Management you need to object to the lack of car parking on site, the inevitable overspill on to surrounding roads and to the proposed Cecil Road entrance before the inevitable serious accidents occur due to the Council's negligence.

In the Officer's report to the Development Control Committee on 22 September 2021 it was stated at para 1.5 that the key areas in the determination of the application are:1) Is this an acceptable location for housing in principle?2) Is the design of the proposal appropriate in this location in the Clifton and Hotwells Conservation Area?3) Would the proposal give rise to an unacceptable loss of trees?4) Would the proposal give rise to unacceptable congestion and parking issues in the area?In my view:1) It is an acceptable location for housing in principle.2) The sheer ugliness of the buildings, the massing, the proposed building materials, the enormous block on College Road, the sheer size of the proposed development, the lack of sufficient car parking, the lack of outside space, the proposed new entrance on Cecil Road, the lack of solar panels, the huge number of heat pumps, the lack of play space for children, make this a totally inappropriate design for the Clifton and Hotwells Conservation Area. The views of Historic England and the vast number of local residents should not and cannot be ignored. A fundamental rethink of the design is required not simply tinkering around the edges. It is just not good enough and represents greed over taste and good design.3) At least 15 mature trees would be lost. This is totally unacceptable.4) There exist two entrances to the site on College Road, one to enter, one to leave. This is an eminently sensible feature and one which the local neighbourhood is used to and compliant with. Its existence and maintenance would enable the proposed massive terrace to be broken -up and be less enormous and ugly. Moreover it would mean that a new entrance on Cecil Road would be unnecessary. Cecil Road can already be a traffic nightmare during the morning and evening rush hour. Traffic seeks to avoid the junction

at the top of Bridge Valley Road by sprinting from The Promenade, past the Mansion House, along Cecil Road and then either left to the Downs or right to the various means of access to Pembroke Road. There is no doubt at all that the proposed entrance to the site, if it goes ahead, will mean enormous congestion in the area, made worse by the paucity of car parking spaces for the residents of and visitors to the 62 residences on the site. It is make believe to think that the present proposals will not lead to massive congestion, parking issues and danger in the area. The assessment of the issue was carried out during the pandemic when there was no traffic on the roads. Wake up Transport Development Management you need to object to the lack of car parking on site, the inevitable overspill on to surrounding roads and to the proposed Cecil Road entrance before you get egg over your face!

As the owner of Flat 9 in 40 College Road I am writing to object again to the above application for the development of the site behind my property of which I have a star view. My tenant has also written to you.

I am, firstly, amazed that the application has not been revised. The residents were the ones who initiated the Judicial Review and your unchanged position implies that there is no consideration for local residents and the Heritage arguments they made so strongly, although the Zoo says it takes the residents' views on board! How is this so?

Secondly the financial situation of the Zoo should in no way affect a planning decision and are not lawful grounds for its determination.

In addition to these very strong points I would also like to make further comment on the fact that the whole proposal with its poor design, high density, loss of mature trees, lack of open space, completely inadequate provision for cars, and complete lack of sensitivity to the splendid Victorian villas that make up the beautiful streets around the development and lastly but certainly by no means least the access proposed in Cecil Road would completely destroy the harmonious character of that street when there is already a perfectly adequate entrance off College Road.

I hope my objections will be given some consideration.

I own Flat 3 in 40 College Road and I would like to say that I think the above Application, despite being quashed by the Judicial Review, has been submitted again without change and I think this reflects a total lack of consideration for those objections which have already been submitted to you.

I am astonished that this Application has not been revised in any way.

Any pressure from the Zoo reflecting its financial situation is of no revlevance to this planning application.

What is relevant is the views of the residents both around the proposed site for development and the rest of the citizens of Bristol not to mention the citizens of the world who come to view our great and beautiful historic city.

It is also extraordinary that there has not been any consideration given to the the accepted opinions of such bodies as Historic England and our own CHIS, indeed they seem to have been completely ignored, which in a City of this importance is nothing less than a scandal.

Once again I would like to point out that my objections are as follows:

This site with 62 houses is crammed to bursting.

The planning for the accommodation of the cars that will be generated from these households is hopelessly inadequate.

The planned entrance in Cecil Road will destroy the character of Cecil Road and there is already a good entrance off College Road.

The beautiful character, peace and tranquillity of this gracious historic area will suffer greatly from loss of trees and open space and the noise generated from so many households living in such cramped conditions will impinge greatly on those already living close by.

The design needs to be completely rethought without priority being given to the Zoo's own financial problems. The work of the Zoo in the conservation field has been impressive and there are other sources they can draw on to accommodate their own plans for the future. They do not have to leave their close by supporters and residents smarting from this total lack of consideration for the future of the area they have used so well in the past and now leave behind without a care. It feels like a slap in the face - and to the very people who would be likely to be future supporters and donors to their new project.

Please give my objections consideration.

Timothy Cook

The need for housing cannot be denied. However, it is of great importance that thehouses built provide attractive decent housing and that developments do not harm the areas thatthey are built in.

The proposed development falls short on all these measures.

It is of particular concern that the views of an expert body, Historic England, do not appear to havebeen taken into account. They specifically mention that the 'layout, massing and design fails torespond to the character and appearance of the Conservation Area'.

In addition, the Zoo has consistently said that it wants to take the views of local residents onboard. However, there is little evidence that this is the case. If they truly meant this they surelywould have submitted a revised application which addressed the many concerns that have beenexpressed by residents?

It has also been pointed out that environmental and sustainable standards outlined fall short of therequirements of the Council's Policy BCS 14. Given the importance placed on sustainability surelythe development should aim to set a high bar?

Please do not grant planning permission for the scheme in its current form.

As a benchmark, the site that Bristol Zoo is relinquishing, on both sides of CollegeRoad, has for well over 150 years been a place that people from Clifton, Bristol, and the SouthWest visit for pleasure and interest.

Given the fine location I believe that it would be in the interest of Bristol as a whole to seek areplacement brown sign attraction.

As it stands I see the losses and benefits of the current application as:

Benefit 1 Provides new housing at a time of shortage.Benefit 2 Makes money for Bristol Zoo, although I'd discount "ends justify the means" appeals (egBristol Zoo's intended animal conservation work justifies monetizing the site via intensive housingdevelopment).

Loss 1 Squanders the opportunity offered by the location to produce a potentially award winningaddition.I find it telling that, in an age when virtual reality walk throughs are common in developmentproposals, this application has no link to an animation to show off the design of exteriors andinteriors. From the graphics in the application my impression of the main blocks is of uninteresting,ponderous, even forbidding, exteriors, covering far, far too many flats cramped into the space. Theambition seems merely to provide "places to live" meeting minimum regulatory thresholds, or,perhaps more accurately, "as many places as possible to sell". The proposals in the main swerveaway from extras that future generations might appreciate, such as generous interior layouts,advanced energy performance, low building maintenance, private outside spaces like gardens,

yards or loggia balconies, or even sufficient provision for residents' and visitors' transport. Theproposed units nowhere excel, and mainly trade on their location. With too much take, and toolittle give, they are a sad example of build back worse.Loss 2 Prevents consideration of the future the whole of Bristol Zoo's Clifton site by breaking it intotwo.Loss 3 Numerous grown trees.Loss 4 The open aspect of the existing low/no rise compound.

I urge the Development Control Committee to reject this application sufficiently decisively to makeit clear to the applicant that only an extensively rethought application, and not a series of tweaks tothe current application, has any chance of being approved.

Dear Sirs

I wish to object to the plans for developing the above site.

Firstly I do not believe that the council determining the application while not altering theirplans will satisfy the views of Historic England with regards to this site. Historic Englandstated " the proposed layout , massing and design fails to respond to the character andappearance of the Conservation Area." The Council reconsidering the same plans doesnot satisfy this concern. Seeking consent for an unchanged Application demonstrates adegree of contempt for both Historic England's arguments and also for local residentswho raised the same concerns .

The financial needs of the zoo appear to be the only concern of the Council andCouncillors. The financial needs of any institution are never a relevant issue indetermining a planning application. Why then did a planning officer make it clear toresidents that he was under severe pressure from the zoo. This planning officer shouldbe considered unfit to consider any applications as financial considerations are notlawful in terms of determining an Application?

I also do not believe environmental considerations have been accurately reported by thezoo. Far from the homes being sustainable, the planned housing fails to even meet theCouncil's own BCS14 policy. Furthermore the houses are of a construction that doesnot meet the required standard to satisfy RIBA and uk Green Building council .

I ask that the above points are all taken into consideration. The Conservation of Cliftonis important. We do not want a site that people look back at in 10 years time and say "how on earth was that allowed to be built ".

I am writing to object to Bristol Zoo's planning application noted above.

1. Disregard of existing objections.The Zoo has resubmitted the same application that was quashed; they have totally ignored the objections that were raised at that time. Since it has already been refused, resubmitting without alteration rides roughshod over the previous refusal. Without substantiation this can surely only result in another refusal.

2. Financial mattersThe Planning Officer confirmed to various residents that he was under a great deal of pressure from the Zoo. I understand the Zoo needs to get as much money as it possibly can for the site, but it is not acceptable to do this by any means possible, and certainly not put pressure on council employees.

3. Environmental issuesIt appears that the energy performance of the proposed dwellings does not meet the requirements of the Council's Policy BCS 14. This document itself may well be out of date.

4. Solar PVThe application states that Solar PV panels were discounted for a number of reasons. We all know the cost of energy has sky rocketed (and continues to do so). There are already Solar PV panels on listed buildings in Clifton, so why not on this scheme? Given that the proposals for the main Zoo site include Solar PV panels why does the reasoning not apply to the car park proposal?

5. Carbon produced during manufacture of materials and during constructionThe nature of construction indicates that carbon emissions will be far in excess of the Council's stated requirements. We have a climate crisis and this application ignores this fact.

6. Affordable HomesIt appears to me that the 20% planned affordable homes do not comply with the Council's policy given that a Practice Note cannot change or even establish policy.

In addition to the above observations, the following points also apply:-

1. The development is over intensive2. The buildings are too high, far higher than those on College Road3. The masonry detailing departs from the existing dressed rubble and Bath stone4. Over massing will damage the settings of the surrounding buildings.5. Parking and amenity space is inadequate6. The proposed vehicular access from Cecil Road is unnecessary; an entrance already exists from College Road.

7. The fact that the site is in a conservation area appears to have been disregarded.Lastly, I have already lodged my objection to this proposal and trust that these will remain before you.

Yours faithfully,

Michael McLennan

As the owner of a flat in College Road, Clifton, I write to express my concerns relating to the above planning application. I made comment on the original submission of the planning application and those comments, which you should have on file, still stand. In addition I would make the following points:

1. I am surprised that Bristol Zoo has resubmitted its application without making any alterations or amendments.

2. It would appear that the Council and Councillors appear to be mindful of the fact that the Zoo is seeking to capitalise on the value of the site. This seems grossly unfair as local residents stand to have the quality of their life ruined by the greed shown by the Zoo owners.

3. Despite claims that the plans are environmentally "friendly", this does not appear to be the case as far from being sustainable housing the energy performance of the planned housing fails to meet the basic requirements of the Council's Policy BCS 14.

4. At this time of rising fuel costs and global warming it seems unbelievable that renewable energy technologies such as solar panels and living green roofs have been discounted. There are already PV panels installed on listed buildings in Clifton and so a precedent has been set.

5. The Council has already declared that there is a climate emergency, and yet the construction of the housing in this application will lead to embodied energy and greenhouse gas emissions far in excess of recommendations by such bodies as

the RIBA and UK Green Building Council.

6. It would appear that the 20 percent affordable housing suggested fails to comply with the Council's policy on affordable homes.

Sandra McLennan

SUBMISSION REGARDING RECONSIDERED APPLICATION, WEST CAR PARKI am writing to (re-)confirm my objection to the revised proposal, as set out in the documentsinitially published on Bristol City Council's website on 22nd July 2021.I make reference to the following documents:City Council DocumentsBristol City Council (2011) Bristol Development Framework: Core Strategy, Adopted June 2011.I refer to this as The Core StrategyBristol City Council (2018) Affordable Housing: Practice Note, April 2018I refer to this as Affordable Housing Practice Note, or AHPN.Bristol City Council (2020) Climate Change and Sustainability: How to design low carbon andresilient developments: Practice Note, July 2020I refer to this as the Climate Change and Sustainability Practice Note or CCSPNDocuments Submitted by the ApplicantBarton Willmore (2021) Planning Statement: West Car Park of Bristol Zoo Gardens, College Road,Clifton, Report on behalf of Bristol, Clifton & West of England Zoological Society, March 2021.I refer to this as 'the Planning Statement'.Hydrock (2021) Bristol Zoo - West Car Park: Energy and Sustainability Statement for Bristol Zoo,18 March 2021I refer to this as the Energy and Sustainability AssessmentCentral Government DocumentsMinistry of Housing, Communities and Local Government (2021) National Planning PolicyFramework, July 2021,https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf

I refer to this as the NPPF

National Policy and LawThe National Planning Policy Framework has an environmental objective:8...c) an environmental objective - to protect and enhance our natural, built and historicenvironment; including making effective use of land, improving biodiversity, using naturalresources prudently, minimising waste and pollution, and mitigating and adapting to climatechange, including moving to a low carbon economy.Paragraph 16 states that:16. Plans should:a) be prepared with the objective of contributing to the achievement of sustainable development;b) be prepared positively, in a way that is aspirational but deliverable;Para 134 states:Development that is not well designed should be refused, especially where it fails to reflect localdesign policies and government guidance on design52, taking into account any local designguidance and supplementary planning documents such as design guides and codes.The footnote 52 in the above extract indicates that the government guidance on design iscontained in the National Design Guide and National Model Design Code, which we refer to below.

Para 152 of the NPPF notes:152. The planning system should support the transition to a low carbon future in a changingclimate.... It should help to: shape places in ways that contribute to radical reductions ingreenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse ofexisting resources, including the conversion of existing buildings; and support renewable and lowcarbon energy and associated infrastructure.153. Plans should take a proactive approach to mitigating and adapting to climate change.....[footnote 53] In line with the objectives and provisions of the Climate Change Act 2008. ie in linewith the 80% cut by 2035 and net zero by 2050.As well as:154. New development should be planned for in ways that:......b) can help to reduce greenhouse gas emissions, such as through its location, orientation anddesign.In its response to the Housing, Communities and Local Government Select Committee report thatwas published on 29 October 2021 following the Select Committee's inquiry into LocalGovernment and the Path to Net Zero, a Government (DLUHC) policy paper included thefollowing:On powers, local authorities already have a combination of powers across housing, planning andtransport which gives them significant autonomy to take action on net zero. We will havediscussions on any additional powers local authorities think they may need to play their part inmeeting national net zero targets, and the evidence for this, as part of the Local Net Zero Forum.It highlighted the respective roles of BEIS and DLUHC:As outlined in the Net Zero Strategy, BEIS has overall responsibility for achieving net zero and for

coordinating with local authorities and other local actors on designing effective policies, includingthe local delivery of net zero. The Department for Levelling Up, Housing and Communities(DLUHC) acts as a steward for the local government finance system and has overall responsibilityfor the planning system.(We reference the Net Zero Strategy below.) The same policy document referenced the uplift fornew homes in terms of carbon performance which we have discussed above:On 15 December, we implemented an uplift for new homes. This is a key stepping-stone that willenable us to successfully implement the Future Homes Standard. Once the uplift comes into force,new homes will be expected to produce around 30% fewer CO2 emissions compared to currentstandards. This will deliver high-quality homes that are in line with our broader housingcommitments and encourage homes that are future proofed for the longer term.The policy report references embodied carbon in buildings:The government's Net Zero Strategy also sets out our ambitions to help the construction sectorimprove its reporting on embodied carbon in buildings. We are exploring the potential of amaximum embodied carbon level for new buildings in the future while encouraging the sector toreuse materials and make full use of existing buildings. In championing low-carbon materials,increased energy efficiency and enhanced product design, we are supporting the sector to deliverthe cleaner, greener buildings of tomorrow.In referencing embodied energy, it makes specific reference to the National Model Design Code:The National Planning Policy Framework (NPPF) is clear that the planning system should supportthe transition to a low-carbon future in a changing climate, taking full account of flood risk andcoastal change. It should help to shape places in ways that contribute to radical reductions ingreenhouse gas emissions [...] The NPPF expects Local Plans to take account of climate changeover the longer term; local authorities should adopt proactive strategies to reduce carbonemissions and recognise the objectives and provisions of the Climate Change Act 2008.In July 2021 we updated the NPPF, placing a stronger emphasis on delivering sustainabledevelopment and a proactive approach to mitigating and adapting to climate change.Simultaneously, we also published the National Model Design Code which guides local authoritieson measures they can include within their own design codes to create environmentally responsiveand sustainable places. The National Model Design Code encourages the implementation ofsustainable construction that focuses on reducing embodied energy, designing for disassemblyand exploring the remodel and reuse of buildings where possible rather than rebuilding. TheNational Model Design Code also provides tools and guidance for local planning authorities to helpensure developments respond to the impacts of climate change, are energy efficient, embedcircular economy principles and reduce carbon emissions.Local authorities have the power to set local energy efficiency standards that go beyond theminimum standards set through the Building Regulations, through the Planning and Energy Act2008. In January 2021, we clarified in the Future Homes Standard consultation response that inthe immediate term we will not amend the Planning and Energy Act 2008, which means that localauthorities still retain powers to set local energy efficiency standards that go beyond the minimumstandards set through the Building Regulations. In addition, there are clear policies in the NPPF onclimate change as set out above. The Framework does not set out an exhaustive list of the steps

local authorities might take to meet the challenge of climate change and they can go beyond this.The Government's Net Zero Strategy, a policy paper setting out policies and proposals fordecarbonising all sectors of the UK economy to meet the 2050 net zero target, stated:48. ...The National Model Design Code, published in July this year, guides local planningauthorities on measures they can include within their own design codes to create environmentallyresponsive and sustainable places. The National Model Design Code provides tools and guidancefor local planning authorities to help ensure developments respond to the impacts of climatechange, are energy efficient, embed circular economy principles and reduce carbon emissionsThe recent House of Commons Environmental Audit Committee Report on Net Zero constructionstated:73. Local authorities are mandating WLC [whole life carbon] assessments of their own accord.Evidence so far shows that the policy is achievable and is working, with few barriers to itsintroduction. Introducing mandatory WLC assessments for buildings could be an easy way for theGovernment to dramatically reduce carbon in construction.It is clear, therefore, that local authorities are acting on embodied carbon, not least given theorientation provided by para 134 of the NPPF, and the associated government guidance in theNational Design Guide and National Model Design Code (see next Section).National Guidance on DesignIt will be recalled that para 134 of the NPPF indicates that:'Development that is not well designed should be refused, especially where it fails to reflect localdesign policies and government guidance on design'.The National Design Guide states:135. Well-designed places and buildings conserve natural resources including land, water, energyand materials. Their design responds to the impacts of climate change by being energy efficientand minimising carbon emissions to meet net zero by 2050. It identifies measures to achieve: mitigation, primarily by reducing greenhouse gas emissions and minimising embodied energy;and adaptation to anticipated events, such as rising temperatures and the increasing risk of flooding.[...]137 Well-designed places: have a layout, form and mix of uses that reduces their resource requirement, including for land,energy and water; are fit for purpose and adaptable over time, reducing the need for redevelopment andunnecessary waste; use materials and adopt technologies to minimise their environmental impact.It includes two key themes to be considered in well-designed proposals:R1 Follow the energy hierarchy138 Well-designed places and buildings follow the energy hierarchy of: reducing the need for energy through passive measures including form, orientation and fabric; using energy efficient mechanical and electrical systems, including heat pumps, heat recoveryand LED lights; and maximising renewable energy especially through decentralised sources, including on-site

generation and community-led initiatives.139 They maximise the contributions of natural resources such as sun, ground, wind, andvegetation.140 They make use of potential for renewable energy infrastructures at neighbourhood andbuilding level. These include photovoltaic arrays, heat pumps and district heating systems, toreduce demand for non-sustainable energy sources. IT advances and app-based solutions allowusers to take ownership or to manage these systems so as to use them most efficiently.141 They follow the principles of whole life carbon assessment and the circular economy, reducingembodied carbon and waste and maximising reuse and recycling.142 Good developments minimise the cost of running buildings and are easy and affordable foroccupants to use and manage.As will become clear from the discussion of the application below, the design fails to meet theseobjectives. In doing so, it fails to meet the requirements of the NPPF. It also fails to align - asGovernment (and the NPPF, through its references to the Climate Change Act) says it should -with the Net Zero Strategy.The second theme relates to 'Careful selection of materials and construction techniques':143 The selection of materials and the type of construction influence how energy efficient abuilding or place can be and how much embodied carbon it contains.144 Well-designed proposals for new development use materials carefully to reduce theirenvironmental impact.The Guidance Notes on the National Model Design Codes state:197. Well-designed places and buildings conserve natural resources including buildings, land,water, energy and materials. Their design responds to the impacts of climate change by beingenergy efficient and minimising carbon emissions to meet net zero targets by 2050. It identifiesmeasures to achieve: mitigation, primarily by reducing greenhouse gas emissions and minimisingembodied energy; and adaptation to anticipated events, such as rising temperatures and theincreasing risk of flooding.It is clear that good design, therefore, also includes consideration of the embodied carbon andenergy in materials. We highlight below that there has been no 'Careful selection of materials andconstruction techniques' in the proposal, that materials have not been considered in terms of howtheir selection might minimize embodied carbon, and that as a result, the application fails to alignwith the Government's Net Zero Strategy, and the requirements for good design in the NPPF. Itshould, therefore, be rejected.The NPPF's clear direction - that unless buildings are well-designed, the applications should berejected - when taken alongside the clear guidance that good design would seek to minimiseoperational carbon emissions, and minimise embodied energy, consistent with the net zero goal,suggests that it would be unwise to fail to do either, let alone both. That, however, is exactly whatthis application does.Bristol City Council PoliciesIn Bristol's own Core Strategy, , the Core Strategy includes the following policy:Policy BCS13Development should contribute to both mitigating and adapting to climate change, and to meeting

targets to reduce carbon dioxide emissions.Development should mitigate climate change through measures including:- High standards of energy efficiency including optimal levels of thermal insulation, passiveventilation and cooling, passive solar design, and the efficient use of natural resources in newbuildings.- The use of decentralised, renewable and low-carbon energy supply systems.- Patterns of development which encourage walking, cycling and the use of public transportinstead of journeys by private car.Development should adapt to climate change through measures including:- Site layouts and approaches to design and construction which provide resilience to climatechange.- Measures to conserve water supplies and minimise the risk and impact of flooding.- The use of green infrastructure to minimise and mitigate the heating of the urban environment.- Avoiding responses to climate impacts which lead to increases in energy use and carbon dioxideemissions.These measures should be integrated into the design of new development.New development should demonstrate through Sustainability Statements how it would contributeto mitigating and adapting to climate change and to meeting targets to reduce carbon dioxideemissions by means of the above measures.Note that the policy BCS13 is not prescriptive, but neither is it restrictive, as regards whatdevelopment should consider. It highlights matters that should be included as regards mitigation,but the overarching principle is that:Development should contribute to both mitigating and adapting to climate change, and to meetingtargets to reduce carbon dioxide emissions.The 'targets' referenced in the above seem to be (in the Core Strategy) the targets in the nowabolished Local Area Agreements. It might be considered that the NPPF's reference to theClimate Change Act would indicate that the targets therein should guide the application of BCS13.Nonetheless, the Core Strategy notes that, regarding Policy BCS13:This policy will be delivered through the development management process, by means of therequirement for Sustainability Statements and the implementation of Policy BCS14, Policy BCS15and Policy BCS16.The mitigation aspect is given further substance through BCS14:Policy BCS14Proposals for the utilisation, distribution and development of renewable and low carbon sources ofenergy, including large-scale freestanding installations, will be encouraged. In assessing suchproposals the environmental and economic benefits of the proposed development will be affordedsignificant weight, alongside considerations of public health and safety and impacts onbiodiversity, landscape character, the historic environment and the residential amenity of thesurrounding area.Development in Bristol should include measures to reduce carbon dioxide emissions from energyuse in accordance with the following energy hierarchy:1. Minimising energy requirements;

2. Incorporating renewable energy sources;3. Incorporating low-carbon energy sources.Consistent with stage two of the above energy hierarchy, development will be expected to providesufficient renewable energy generation to reduce carbon dioxide emissions from residual energyuse in the buildings by at least 20%. An exception will only be made in the case where adevelopment is appropriate and necessary but where it is demonstrated that meeting the requiredstandard would not be feasible or viable.The use of combined heat and power (CHP), combined cooling, heat and power (CCHP) anddistrict heating will be encouraged. Within Heat Priority Areas, major development will be expectedto incorporate, where feasible, infrastructure for district heating, and will be expected to connect toexisting systems where available.New development will be expected to demonstrate that the heating and cooling systems havebeen selected according to the following heat hierarchy:1. Connection to existing CHP/CCHP distribution networks2. Site-wide renewable CHP/CCHP3. Site-wide gas-fired CHP/CCHP4. Site-wide renewable community heating/cooling5. Site-wide gas-fired community heating/cooling6. Individual building renewable heatingThe underlined paragraph provides the only quantifiable requirement in respect of the climatechange performance of buildings. The Core Strategy adds further explanation of this:4.14.6 Proposals for development should be accompanied by an energy strategy as part of theSustainability Statement submitted with the planning application, which should set out measures toreduce CO2 emissions from energy use in accordance with the energy hierarchy. The energystrategy should:- Set out the projected annual energy demands for heat and power from the proposeddevelopment against the appropriate baseline (2006 Building Regulations Part L standards), alongwith the associated CO2 emissions.- Show how these demands have been reduced via energy efficiency and low carbon energysources such as CHP and district heating, and set out the CO2 emissions associated with theresidual energy demand.- Demonstrate how the incorporation of renewable energy sources will offset the CO2 emissionsarising from the residual energy demand.4.14.7 The energy strategy should integrate sustainable approaches to design and constructionsuch as optimising solar gain and natural light and ventilation to maximise the energy efficiency ofthe development and minimise its overall energy demand.The policy itself, however, demands 'at least' 20% reduction in residual CO2 emissions.Perhaps recognising the chasm emerging between the Council's declaration of a 'ClimateEmergency', and its existing Core Strategy, the Council developed a Climate Change andSustainability Practice Note, published in July 2020. The Climate Change and SustainabilityPractice Note (CCSPN) indicates that:The following key principles apply to all Sustainability Statements:

1. Sustainability Statements should address both mitigation and adaptation as set out under policyBCS13.2. Sustainability Statements should engage with and address the energy requirements of policyBCS14, the water management requirements of policy BCS16 and each of the key issues listed inpolicy BCS15.3. In respect of each of these issues, Sustainability Statements should set out what possiblemeasures have been explored, which measures have been adopted and integrated into the designand, where relevant, why it was not feasible to incorporate certain measures into the proposeddevelopment.4. A failure to convincingly address each of these issues will result in a refusal of planningpermission.5. If it is argued that including sufficient measures to meet the energy requirements of policyBCS14 would render the development unviable, then the applicant will be required to submit a fullviability assessment.Again, it has to be noted that BCS14 indicates that use of renewables should, "reduce carbondioxide emissions from residual energy use in the buildings by at least 20%." Neither BCS13 norBCS14 are restrictive in what they say should be done, rather, they indicate what process theapplicant should demonstrate that they have followed in order to have their consent granted. Thatan application achieves a 20% reduction in residual CO2 would not, therefore, in and of itself,indicate compliance. It is the procedural logic of the policy that is set out. The CCSPN then placesflesh on the bones in terms of this process, as well as making it clear that where applicants fail todo what the CCSPN sets out, the result will be refusal of the application.This would be completely consistent with the view in the NPPF regarding good design: indeed,even if BCS14 were absent, para 134 clearly states that where the design fails against criteria thatare quite clear in what they require, consistent with national policy (see above), it should berejected.There is also sufficient already in the Core Strategy to support the view that those making planningapplications should ensure that embodied emissions and energy are considerations that shouldinfluence the design of housing for which planning consent is being sought. Notwithstanding theabsence (as yet) of specific policies or targets on embodied energy or embodied carbon, PolicyBCS15 allows for this, in stating:Sustainable design and construction will be integral to new development in Bristol. In deliveringsustainable design and construction, development should address the following key issues:- Maximising energy efficiency and integrating the use of renewable and low carbon energy;- Waste and recycling during construction and in operation;- Conserving water resources and minimising vulnerability to flooding;- The type, life cycle and source of materials to be used;- Flexibility and adaptability, allowing future modification of use or layout, facilitating futurerefurbishment and retrofitting;- Opportunities to incorporate measures which enhance the biodiversity value of development,such as green roofs.New development will be required to demonstrate as part of the Sustainability Statement

submitted with the planning application how the above issues have been addressed.It would be consistent with the NPPF, as revised, for the Sustainability Statement to show howenergy efficiency had been maximized (not simply marginally exceeding what would be achievedby Part L Building Regulations compliant proposals), and how the choice of materials had beenmade such as to minimize embodied carbon emissions.Operational Emissions from the ProposalParas 138-142 of the National Design Guide (see above) are relevant here. BCS14 also sets outrequirements for 'at least' 20% reduction in residual CO2 emissions, whilst BCS 15 sets out designrequirements, and the CCSPN sets out the procedural logic which applicants should follow if theyare to avoid refusal. This echoes para 134 of the NPPF which also indicates that 'developmentthat is not well designed should be refused'.In support of its application on the West Car Park, The Energy and Sustainability Assessment(ESA) prepared for ZooSoc claims that:All guidelines [in the aforementioned Practice Note] throughout this document have been adheredto in the production of this energy and sustainability strategy.Whilst the Energy and Sustainability Assessment does indeed cover some of these matters, itdoes so in a perfunctory manner. This is not consistent with the test of good design as per theNPPF. Nor is it consistent with the procedure outlines in BCS4, and elaborated further in theCCSPN.In terms of 'minimising energy', the ESA plans indicates it will make use of materials for thebuilding fabric that have low U-values. Some of these are now - following the change to Part L ofthe Building Regulations that was announced in December 2021 - the Regulated minimum. Theuse of heat pumps might be considered welcome, but again, this is not about to deliver a zerocarbon home in the short-term, not least because of the increase in demand for energy.There is no detail provided for how the demand for heat will be matched by the supply from the sixheat pumps illustrated in the Plan in Block B of the development. There is no transparency in thederivation of the figures which are presented in respect of the climate change performance of thedifferent measures being proposed, not to mention, the baseline position. This is not consistentwith the CCSPN which states, quite reasonably:'An effective energy strategy will combine a written explanation of the measures proposed, takingaccount of site constraints and opportunities, with detailed calculations showing the CO2 emissionsavings achieved. The proposed measures should be shown on the application drawings, in orderto provide certainty that they can be accommodated in the design, and to allow an assessment ofhow well they have been integrated into the proposed design.'Until the applicant clearly demonstrates the basis for its calculations - the validity of which wechallenge below - and until it is made clear how the development is consistent with therequirements of the NPPF, BCS14, BCS15 (and the procedural guidance elaborated in theCCSPN), then it is not possible to have confidence that it is well designed.There is no provision planned for any on-site generation of renewable electricity. This is becausepoint 3 in the above extract from the CCSPN was not adhered to. There was no reasonableexploration of measures which could be adopted, let alone any rational argument as to why, forexample, it would have been unreasonable for rooftop PV to be in place in the development. Both

solar thermal and solar PV move from 'having potential', as per p.13 of the Energy andSustainability Statement, to being dismissed in the final proposals. Table 7 in the Energy andSustainability Assessment - the header for which states that it has been taken from the CCSPN -as well as the supporting text, speak only in general terms about how 'consideration ofconservation would need to be taken into account', and 'the benefit of solar thermal panels wouldneed to be considered against impact to the local Conservation Area and sedum roofs'.These are not justifications (certainly, not adequate ones) for overlooking the potential of solar PV.There are solar PV panels already on properties in Clifton in Conservation Areas, several of themin close proximity to the site. Also, there is some evidence to suggest, in respect of green rooves,that these can help improve output from solar PV because of their cooling effect: furthermore,shaded areas might actually enhance the diversity of microclimates for wildlife. The points madedo not demonstrate why these are not viable options for inclusion in this proposed development,which is what the CCSPN not only requires, but which, if absent, ought to have led to theapplication being refused. Had this matter been properly considered, the development itself mightlook rather different, for example, in respect of orientation of the rooves. There is no reason whythe provision of on-site renewable electricity is not viable, and no reasonable one was given.In an amendment sheet presented to the Development Control Meeting where this application waspreviously considered in 2021, and initially approved, the applicant's sustainability consultantsstated:Solar PV panels were considered (within sustainability/energy statement), but discounted for anumber of reasons, notable efficiency/orientation, aesthetics and impact on conservation area,and also provision of sedum roof and ecological enhancements.Yet the CCSPN states:Policy BCS13 requires that measures to mitigate and adapt to climate change are integral to thedesign of new development. This reflects the fact that certain sustainability measures cannot beretrofitted and, to be effective, measures to mitigate and adapt to climate change such as site-widerenewable energy measures have to be planned into development from the earliest stage as theydirectly affect the layout and design of development. For example, to make the best use of solarfor the generation of heat or power, a development will require south-facing roof slopes.Elsewhere, it notes: 'When designing a building, applicants are encouraged to consider whetheropportunities for PV can be maximised through the layout and orientation of buildings.' The pointsare obvious ones: the applicant has choice over matters of orientation of the rooves at newhousing proposals.And it is not only the Council's own policy that requires this. The National Design Guide states:135. Well-designed places and buildings conserve natural resources including land, water, energyand materials. Their design responds to the impacts of climate change by being energy efficientand minimising carbon emissions to meet net zero by 2050. It identifies measures to achieve: mitigation, primarily by reducing greenhouse gas emissions and minimising embodied energy;andAnd:R1 Follow the energy hierarchy138 Well-designed places and buildings follow the energy hierarchy of:

reducing the need for energy through passive measures including form, orientation and fabric; using energy efficient mechanical and electrical systems, including heat pumps, heat recoveryand LED lights; and maximising renewable energy especially through decentralised sources, including on-sitegeneration and community-led initiatives.139 They maximise the contributions of natural resources such as sun, ground, wind, andvegetation.140 They make use of potential for renewable energy infrastructures at neighbourhood andbuilding level. These include photovoltaic arrays, heat pumps and district heating systems, toreduce demand for non-sustainable energy sources. IT advances and app-based solutions allowusers to take ownership or to manage these systems so as to use them most efficiently.Invoking 'efficiency / orientation' as an explanation as to why solar PV could not be fitted is akin tothe applicant denying that it had any choice in the matter of the orientation of the rooves. Not onlywas the applicant free to determine orientation, but it was required through national policy to'maximise the contributions of natural resources such as sun, ground, wind and vegetation', notdeliberately choose an orientation which it is claimed reduces their useful contribution to zero. Towilfully choose an orientation that would make such integration impossible (if indeed one acceptsthat is the case) is as close to a definition of poor design as one could imagine.The grounds in relation to aesthetics effectively presume the outcome of the application, and makelight of the fact that there are already PV panels installed at listed buildings in Clifton (as well asothers in the conservation zone), whilst the supposed preference for sedum roof vis a vis PV a)suggests a conflict which does not exist - indeed, the CCSPN itself states: 'Combininggreen/brown roofs with solar photovoltaic (PV) panels can enhance the power production of thePV units.' - but also b) suggests a preference ordering (green rooves over solar PV) which ifanything, runs counter to the requirements of policy and the CCSPN.The only reason solar PV would have been non-feasible at the site was if the sun did not shine atthat location. The failure to integrate PV is clearly a failure of design. In line with para 134 ofrevised NPPF, it should be refused. Para 134 indicates that buildings that are not well-designedshould have their applications refused, and the Guidance Notes on the National model DesignCode are abundantly clear that well-designed buildings respond 'to the impact of climate changeby being energy efficient and minimising carbon emissions'.To reiterate the National Design Guide:138 Well-designed places and buildings follow the energy hierarchy of: reducing the need for energy through passive measures including form, orientation and fabric; using energy efficient mechanical and electrical systems, including heat pumps, heat recoveryand LED lights; and maximising renewable energy especially through decentralised sources, including on-sitegeneration and community-led initiatives.139 They maximise the contributions of natural resources such as sun, ground, wind, andvegetation.140 They make use of potential for renewable energy infrastructures at neighbourhood andbuilding level. These include photovoltaic arrays, heat pumps and district heating systems, to

reduce demand for non-sustainable energy sources. IT advances and app-based solutions allowusers to take ownership or to manage these systems so as to use them most efficiently.141 They follow the principles of whole life carbon assessment and the circular economy, reducingembodied carbon and waste and maximising reuse and recycling.142 Good developments minimise the cost of running buildings and are easy and affordable foroccupants to use and manage.The proposal fails in more or less every respect in this regard. The application should be refused.Performance Against BCS14 - Residual CO2Lest it be considered that the application actually delivers performance that is remotely impressive,we now discuss the actual performance of the proposed build.If one reviews the figures in the Energy and Sustainability Assessment, using some basic algebra,we can drill into the detail of the heat and electricity demand in the baseline, and with themeasures proposed by the applicant to be in place. This is necessary because, contrary to whatthe CCSPN requires of the applicant, the applicant provides virtually no information that wouldenable one to readily understand whether what is being proposed would actually deliver theclaimed outcomes.Using the SAP 2012 figures (see Table 1 in the Energy and Sustainability Assessment), theproposed measures associated with the proposal claim to deliver a 33% reduction relative toresidual emissions. Note that these residual emissions are relatively high because the energyefficiency measures are somewhat limited: notwithstanding the intent to use materials with a lowerU-value than under Part L of the Building Regulations, the measures achieve a small - 5% -improvement relative to what is required to comply with Building Regulations. The Energy andSustainability Assessment does not actually report how this Figure has been calculated other thanthrough referencing U-values. No materials are actually mentioned, the U-values are simplystated, with no reference to what it is that delivers those lower U-values, and hence, what fabric isto be used. This is despite the fact that the CCSPN is very clear, as per Table 1 in the CCSPN,that:The summary table should be supported by a written explanation of the measures proposed and afull set of calculations as set out under "Detailed Measures" below. Where relevant, the proposedmeasures should also be shown on the application drawings.These calculations are not presented. Without seeing these, it might reasonably be asked whetherthe energy hierarchy has been adequately respected.Notwithstanding the lack of transparency in the presentation of calculations, one can deriveinteresting further insights into the performance of the proposed development. The emissonsperformance of the proposed development are shown in Table 6, which is reproduced (with someadditional labelling) from the Energy and Sustainability Statement.Table 6: Energy strategy summary as required by BCS14Energy Demand (kWh/year) Energy Saving Achieved (%) Regulated CO2 Emissions(kgCO2/year) Savings Achieved on Residual (%)A. Building Regulations Compliance 421,200 146,300B. Proposed after energy efficiency 395,300 6% 138,400C. Proposed after on-site renewables 395,300 6% 92,100 33%

D. Proposed scheme offset for financial contribution or allowable solutions N/A N/AE. Total saving on residual emissions 37%Source: Hydrock (2021) Bristol Zoo - West Car Park: Energy and Sustainability Statement forBristol Zoo, 18 March 2021Of particular interest is the change in emissions between Rows B and C. Given that the sum ofelectricity and heat demand is 395,300 kWh (row B), and given also that the product of theelectricity and heat demand, and the respective unit CO2 emission figures (also presented in theEnergy and Sustainability Statement) is equal to 138,400 (from Row B), it is possible to calculatethe respective demand for electricity and heat:- 174,968 kWh electricity, and- 220,332 kWh heat.Row C incorporates the effect on emissions of using air source heat pumps to deliver heat. Theemissions fall by 46,300 tonnes CO2. This is equivalent to virtually all the heat demand being metby a heat source with zero carbon emissions: the emissions that would be associated with thegrid-based electricity necessary to drive the ASHPs do not seem to have been accounted for. Theoverall energy demand is kept the same in Row C as in Row B. It is effectively being assumed, incalculating the savings in residual emissions, that the electricity used to drive the ASHPs has azero carbon intensity. There is, though, no provision for this (see above).In the proposed scheme, the demand for heat is met (the assumption is that it is more or less metin its entirety) through the use of ASHPs, and these would increase the demand for electricity,which is the driver of the heat output from the ASHPs. Using an assumption of 3:1 for the seasonalcoefficient of performance (SCoP) factor of the ASHPs (higher than the 2.5 quoted by Hydrock inthe Energy and Sustainability Statement), the electricity demand needed to deliver the heat wouldbe of the order 73,444 kWh, and the associated emissions would be more than 38,000 tonnesCO2. If this figure is added back to the analysis in Table 6, the emissions in row C should bereported as 128,926 tonnes. The saving in residual emissions would be 7%, less than half whatBCS14 suggests as a minimum, and much lower than claimed by the aplicant.An alternative way of looking at this is that in order for Hydrock's figures to be correct, the ASHPswould have needed to be capable of delivering heat with a Seasonal Coefficient of Performance ofthe order 6:1. Hydrock's own Energy and Sustainability Statement states:Heat pumps operate with a typical Seasonal Coefficient of Performance (SCoP) of 2.5:1 to 5:1(depending on heat source/sink); meaning that for every 1kW of electric in, 2.5kW of heat isgenerated (for ASHP) and up to 5kW (for some ground or water source heat pumps).A ratio of 6:1 is not yet within reach for air source heat pumps in the UK.In summary, the reduction in residual CO2 emissions - which is given as a policy compliant 33% -should have been reported as around 7%. The development fails even to satisfy the minimumtarget set out in BCS14.Revised Part L Building RegulationsIt may also be noted that months after the Council's decision to grant the application, which hasnow been quashed, the Government issued amendments to the Building Regulations which weredesigned to improve the performance of buildings by reducing CO2 emissions as per Part L of theBuilding Regulations. The Amendment Regulations and accompanying Approved Documents L:

Volumes 1 and 2 were published on 15 December 2021 and came into force on 15 June 2022.Transitional arrangements were put in place as follows:the changes will not apply in relation to building work where a building notice or an initial noticehas been given to, or full plans deposited with, a local authority before 15 June 2022 provided thatthe building work is started before 15 June 2023.Please note that "building notice", "initial notice" and "full plans" have the meanings given inRegulation 2 of the Building Regulations 2010.In respect of the second paragraph, the relevant point would be when the local authority hadreceived a building notice in accordance with Regulation 13 of the Building Regulations or wherefull plans had been deposited with the local authority in accordance with Regulation 14 of theBuilding Regulations 2010. It seems unlikely that either has happened.In practice, what this means is that the claimed energy efficiency improvements made in the ESSwill be lower than had been claimed by the applicant: some of the U-values presented asimprovements in the ESS are no longer improvements but are required under the amendedRegulations. The improvement claimed for the proposal was already marginal: it is now evensmaller.Addressing Non-compliance with BCS14Joanne Mansfield, from Bristol City Council's legal services, in the Council's response to a pre-action protocol letter indicating the intent of CHIS to commence proceedings to quash the initialapplication, stated:The Report clearly had the E&S Statement in mind because it discussed use of ASHPs and the37% total emissions reduction, which were specifically set out in the E&S Statement. Condition 8of the permission also referred to the E&S Statement.Condition 8 of the now quashed permission - referenced by Joanne Mansfield - was renderedcompletely ambiguous as a result of the fact that the Table in the ESS - to which the Conditionreferred - was inconsistent with the actions that would lead to the claimed outcome - how wouldthe Council ensure that the Condition had been discharged? Of the two options - ensuring that therelevant installations had been installed, or measuring the regulated carbon emissions associatedwith the completed buildings on an ongoing basis (and requiring the applicant to makeimprovements where the target CO2 emissions reduction was not achieved), the former is the farmore likely approach. The fact that the Table and the proposed measures are inconsistent is not,therefore, a trivial matter, and it is not something that Condition 8 of the now quashed applicationwould have resolved.It is worth reiterating - again - that all these matters should be dealt with at the design stage, notafter the fact after a decision has been made by the Development Control Committee. The NPPFclearly makes the decision contingent on the design. Logically, any such matters of design need tobe resolved prior to a decision being reached. I am asking only that the decision is made in alawful manner. The point made below regarding the location of the ASHPs in the proposal is alsoof relevance here. Given that the proposed plan has the ASHPs adjacent to bedrooms, and giventhat that would not be allowed under the revised Regulations, then the design fails again, even tocomply with the Building Regulations, which are simply reflecting common sense in this regard.Embodied Carbon Emissions from the Proposal

All infrastructure projects involve the use of materials, and the processes of extraction of rawmaterials and the production of the materials themselves have, associated with them, emissions ofgreenhouse gases. These emissions are what are referred to as the 'embodied' emissions inmaterials. Embodied, or embedded, greenhouse gas emissions are those 'embodied' in thematerials used in building dwellings (i.e. those expended in their manufacture), and in theprocesses used to construct the buildings.it has become increasingly obvious that the issue of embodied materials in construction projectscannot be ignored, and for obvious reasons: in line with the carbon budgeting concept providedabove, if building houses (or other infrastructure) draws down heavily on remaining carbonbudgets, then whatever the emissions associated with the house once occupied, these upfrontemissions during the build phase are potentially very problematic: they happen 'early' (i.e. beforethe house has been completed), and they cannot easily be 'clawed back' post construction unless,for example, over time, the non-fossil energy delivered back to the grid exceeded consumption,and then, only where accounting approaches allowed for any reductions associated with suchgeneration to be accounted for within the relevant framework. Recent studies indicate that theshare of embodied emissions in total life cycle emissions is likely to have been around 25% in thepast, rising to around 42% in modern buildings with improved operational performance (see Figure4). In our own view, these figures are likely to understate the contribution, especially if one takesaccount of a progressively decarbonising energy system, and the fact that genuinely low-carbonsources of key construction materials such as steel and concrete are far from the norm at present.Appreciation of this fact is nothing new. In 2013, HM Treasury reviewed the carbon impacts ofinfrastructure. It used the term 'capital carbon' rather than the term 'embodied emissions', andregarding capital carbon, it noted:The relative significance of capital carbon will increase as the grid is decarbonised and operationalemissions reduce. At the same time, the substantial planned increase in infrastructure investmentwill tend to increase capital carbon emissions in spite of future construction efficiencies, thereforeeven greater action is required by the sector to drive down capital carbon.

Figure 4: Trends in Embodied and Operational Emissions, and Share of Embodied Emissions inTotal (right-and axis)

Source: Röck, M., Saade, M. R. M., Balouktsi, M., Rasmussen, F. N., Birgisdottir, H.,Frischknecht, R., et al. (2020). Embodied GHG Emissions of Buildings - the Hidden challenge forEffective Climate Change Mitigation. Appl. Energ. 258, 114107.doi:10.1016/j.apenergy.2019.114107Various other reports have noted the importance of embodied greenhouse gas emissions in theconstruction sector. An interesting representation of the opportunity for abatement is shown inFigure 1. This highlights the fact that these opportunities are likely to be greatest in the planningand design stages, with the opportunities to make savings in the actual construction phase beingmuch less than in those planning and design stages. Of course, this is a simplified representation,but the conceptual basis for this is widely supported.Figure 5: Opportunities to reduce embodied carbon from stage of design process

Source: HM Treasury (2013) Infrastructure Carbon Review, 2013.Note that the 'build clever' aspect is key in ensuring significant carbon reduction is made, and thatcentral to this is to 'design in the use of low carbon materials; streamline delivery processes;minimise resource consumption'. Post design, the opportunity is lost.As regards what is proposed at the West Car Park site, there is no evidence of any focus onembodied energy in the design of the proposal. The Energy and Sustainability Statementaccompanying the planning application mentions "embodied energy" only once. This is within asection entitled 'Material Selection':The BRE 'Green Guide to Specification' is proposed to be used when selecting the constructionmaterials, to encourage the use of materials which have been produced with minimal impact to theenvironment in line with good-practice methodology. The Guide promotes the use of sustainablematerials with low embodied energy, ecotoxicity and long-life span.Additionally, the materials selected will be responsibly sourced and where practicable meet thefollowing guidelines:- ISO14001;- BES6001;- PEFC / FSC;- Chain of Custody.Materials have been chosen in keeping with the local vernacular of the area, and wherepracticable will be sourced locally.This completely misses the point: embodied energy and emissions have to be considered at thedesign stage so that the choice of materials can be made consistent with the objective of, otherthings being equal, minimising embodied energy (and carbon emissions) consistent with para 134of the NPPF and the National Design Code. The above extract overlooks the fact that the choiceof materials has already been made by architects, and that considerations of the potentialembodied energy of the build have had no impact on that choice (there is no evidence of, forexample, an attempt to estimate this for the build, or indeed, alternative choices of design andmaterial choice). The ESS is merely describing how materials - the choice of which has alreadybeen determined - will be procured. The Green Guide is 'proposed to be used' - i.e. it is proposedto do this in the future. Embodied energy has not been considered in the design.We have attempted to make a basic estimate of the embodied GHG emissions from the West CarPark drawing on recent literature. Regarding the dwellings planned for the West Car Park, theSchedule of Accommodation (SoA) quotes a figure for the Gross Internal Area (GIA) of 6,514 m2.The applicants submission in relation to the Main Site includes, in the Planning SustainabilityStatement, Appendices seeking to establish target figures for the embodied emissions per unit ofGross Internal Area. The main body of the report states, however:The actual construction specification and building methods are to be established at the detaileddesign stages post-planning. Based on the energy modelling and architectural design assumptionsit is anticipated that the upfront embodied carbon of the development will around 675-875kgCO2e/m2 and whole lifecycle carbon performance of 1000-1200 kgCO2e/m2.These values can be compared with figures - see Table 9 - being proposed by LETI and RIBA for

upfront embodied carbon, and for whole lifecycle performance (the figures reflect different scopesof analysis). The lower end of the range for the upfront embodied carbon - 675 kgCO2e/m2 - isabove (i.e., worse than) the LETI target value for residential construction in 2020 (and in the caseof LETI targets, the year refers to the year of design, not the build), although the residential figuresin the Table are based on data 'for multi-residential of 6 storeys and above'. At the upper end, itfalls into the 'next to worst' band. In terms of banding, performance is marginally better against theRIBA whole life-cycle target for 2030.Table 9: Banding Proposed for Embodied Carbon by LETI and RIBA (different scopes)

Source: LETI, with RIBA, GLA, IStructE and UKGBC (2021) Embodied Carbon Target AlignmentWe have chosen to base our estimate of upfront embodied carbon for the West Car Park site on afigure in the middle of the range quoted in the report for the Main Car Park of 0.775 kg CO2e/m2,(excluding sequestration) which seems a reasonable figure given the nature of the constructionbeing proposed. The mid-range figure for whole life cycle emissions is 1,100 kg CO2e/m2. Thismay be optimistic - we noted above that there appears to have been little clear consideration ofmatters of embodied carbon in the design for which the application has been made.Based on a GIA of 6,514 m2, therefore, it can be estimated that the upfront embodied emissionsfrom construction at the West Car Park site to be of the order 5,048 tonnes CO2e. Embodiedemissions over the whole life-cycle will be of the order 7,165 tonnes CO2e.To place this into context, the regulated component of the operational emissions are claimed, bythe applicant, to be 92 tonnes CO2 per year, or 129 tonnes CO2 per year if you accept ourcomments regarding the apparent omission of emissions frome electricity needed to drive theASHP. The upfront emissions alone from the embodied carbon emitted in relation to the site arepotentially, therefore, between 39 and 55 times the annual emissions reported in the ESS.Planning decisions clearly cannot be made in line with the NPPF if embodied emissions areoverlooked. The Net Zero Strategy evidently 'banks' the outcomes expected as a result of planningauthorities making planning decisions consistent with the requirements of good design. TheNPPF's reference, through para 134, to the need to refuse developments that are not welldesigned, and the fact that the Model Design Code - to which the NPPF refers - indicates that inwell-designed developments, embodied energy should be minimised. The application makes noattempt to embed the need to minimise embodied energy in its design. Rather, it is considered anafterthought. It follows that the application should be refused.Other Aspects of DesignWhilst I have highlighted above the failings in the proposal's design from the perspective of whatthe Model Design Code terms 'Resources' - specifically, in respect of its impact on climate change- it would be similarly straightforward to highlight other failings in the design that are relevant toplanning policy.The National Design Guide indicates that, regarding Identity:53 Well-designed new development is influenced by: an appreciation and understanding of vernacular, local or regional character, including existingbuilt form, landscape and local architectural precedents; the characteristics of the existing built form - see Built form ;

the elements of a place or local places that make it distinctive; and other features of the context that are particular to the area - see Context .This includes considering: the composition of street scenes, individual buildings and their elements; the height, scale, massing and relationships between buildings; views, vistas and landmarks; legibility - how easy it is for people to find their way around; roofscapes; the scale and proportions of buildings; façade design, such as the degree of symmetry, variety, the pattern and proportions of windowsand doors, and their details; the scale and proportions of streets and spaces; hard landscape and street furniture; soft landscape, landscape setting and backdrop; nature and wildlife, including water; light, shade, sunshine and shadows; and colours, textures, shapes and patternsIt would be difficult to conclude that the application could be considered 'well designed' whenadjudicated against these criteria. The application is effectively a challenge to the local area,rather than a proposal that demonstrates an appreciation of the local character.Questions asked in relation to Identity (in the Guidance) are:Have you considered: How the identity suits the proposed approach to development such as construction technologies,diversity of procurement or ownership models? How the proposed character responds to climate change? How natural features such as tree planting, wetlands or other sustainable drainage systems cancontribute to a positive character and perform a multifunctional role?It would be difficult for the proposal to place a tick in any of these boxes.I also reiterate points made in my previous submission, but would suggest these (and no doubtother matters) be considered alongside the National Design Guide, and with para 134 of the NPPFin mind:1. The Planning Statement selectively cites Policy UL2 in the Draft Policies Document in seekingto support a densification of development. A full reading of the same UL2 suggests that in areaswhere the character of the locality demands it, reduced densities are "essential";2. The proposal makes any attempt to comply with the requirements of DM16, and it makes noreference at all to DM 14, which relates to the Health Impacts of Development. In particular, thefollowing features give rise to concerns regarding the health of would-be occupiers:a. The absence of space for children to play even though it is not difficult to imagine thedevelopment, as it is proposed, to house more than 50, and potentially, 60 children;b. The fact that dwellings will be unable to ensure that noise levels are below those recommendedby the WHO at night because of a combination of the prevailing noise levels (even before oneconsiders those generated at the site itself) and the thermal properties of the dwellings. In

addition, a number of bedrooms appear to be adjacent to 6 air-source heat pumps (ASHPs),exposing them (notwithstanding the improvements in noise characteristics of ASHPs) to night-timenoise;3. As well as the effects on the health of would-be occupiers, the application fails to consider theeffect of noise emanating from the development itself, whether from the occupants' vehicles, ortheir use of the balconies, or any other source. Only the ASHPs have been considered as potentialsources of noise which could affect existing residents. It is obvious that the development will be asource of noise, and that the change in night-time noise (and traffic) in particular (the car park isnot generally occupied at night) has the potential to affect existing residents.In my previous submission, I wrote the following:"The plan for renewable energy generation [...] is centred on the deployment of air-source heatpumps (ASHPs). The Energy and Sustainability Assessment indicates that these will be housed asfollows:ASHP units would need to sit in either an acoustically treated external plant enclosure or within awell-ventilated internal plantroom. The current architectural design allows for an internal groundfloor plant room in Block B with louvred wall to allow for suitable airflow.A review of the floorplan for Block B indicates a plan for 6 Mitsubishi CAHV units (it is notcompletely clear whether the room will enable their proper functioning - some of the dimensionslook suspect given the face to face / side by side nature of the layout). It is a peculiar designchoice that these will sit directly under the bedrooms of Flat 53 and Flat 58, and beside thebedroom in Flat 48. Perhaps other considerations have trumped the issue of exposure of residentsin the development to the ASHPs: the Planning Noise Assessment considers the noise fromASHPs largely in respect of their impact on nearby existing residential properties. Laudable as thisis as a principle, it overlooks the need to ensure that the development is also tolerable to thosewho will be living there in future. It is difficult to imagine circumstances where the bedroomwindows of the Flats mentioned would be exposed to noise levels below those that BritishStandards and the WHO consider likely to be injurious to sleep, and thence, to the health ofresidents."Since I made that submission, in December of 2021, Part L Building Regulations were amended.Regarding Heat Pump Systems, the Building Regulations note:6.42 Heat pumps should not be sited adjacent to sleeping areas, nor should they be located onmaterials that can readily transmit vibrations. Additionally, the location of external fans and heatpump compressors should be appropriately selected to minimise disturbance to neighbours, whileremaining in compliance with planning requirements.This is surely just common sense, but the failure of the applicant to have consider this issue inrelation to noise reflects the poor quality of the design. We have a design in front of us that doesnot comply with Building Regulations.4. Last, but by no means least, and consistent with the absence of space for play, and the failureof design to integrate environmental features, the loss of sixteen trees from the site, some of whichare at the perimeter of the site and could have been accommodated in an alternative, moresympathetic design, is disappointing given the stated objectives of the applicant. There is norationale given for the proposals to fell the trees (other than that this is what would need to be

done if the development is as proposed). The logic is that the proposal necessitates the felling,rather than the proposal itself being influenced by the presence of the existing trees. The revisedapplication increases the number of replacements proposed on site from 10 to 17. On the onehand, this confirms the nature of the previous objection: with minimal change in design, sevenadditional trees magically appear in the site plan. Nonetheless, no effort has been made to avoidfelling and no effort has been made to increase the number of trees planted on site to the levelthat Tree Replacement Policy suggests should be provided on site where possible. The revisiondoes nothing to silence the questions regarding why it would have been impossible to design thedevelopment so that the necessary number of replacements were integrated into the development(this would have provided an incentive to cut down far only what was absolutely necessary). Thequestion of where any replacements will go remains.None of these matters would be ones that necessitated comment had the proposal been well-designed.Affordable HomesIn my original objection, I questioned the rationale for the way 'fast-track' proposals would betreated under the Affordable Housing Practice Note (AHPN). In particular, I made the point that theCouncil was likely to exceed targets it had previously set for building new homes, but failed tomeet its target for affordable homes. The approach in the AHPN seemed inconsistent with asincere attempt to deliver the required number of affordable homes.At the time, I had considered that Practice Notes could constitute policy. Whether and to whatextent Practice Notes are deemed to have changed planning policy is likely a matter for the courtsto decide. The view of Joanne Mansfield, from Bristol City Council's legal services, as expressedin the Council's response to a pre-action protocol letter indicating the intent of CHIS to commenceproceedings to quash the initial application, was as follows:'There can be no obligation for a development to comply with advice in a non-statutory documentthat cannot set out any policies.'It would follow from this that no new policies can be set out in the Affordable Homes Practice Note,and that the Core Strategy policies would remain the locally relevant ones. We note, however, thatthe Council appears to have accepted (and apparently, adjudicated upon) applications as thoughthe Affordable Homes Practice Note constituted policy. The question has to be raised as towhether - if the view of the Council's own legal services is correct - the Council is acting lawfully inadjudicating on applications in such a manner.BCS17 in the Core Strategy states:Affordable housing will be required in residential developments of 15 dwellings or more. Thefollowing percentage targets will be sought through negotiation:- 40% in North West, Inner West and Inner East Bristol;- 30% in all other locationsIt would be extremely difficult, in the circumstances, to argue that 20% affordable homes is theoutcome that would have resulted under the extant policy BCS17. If that is not the case, then itwould be reasonable to argue that the AHPN had materially influenced the policy in exactly themanner that the Council's own legal services claims it cannot do.There is a general understanding (it is a matter of public record) that the applicant seeks to sell the

land to generate revenue in support of its objectives. It is not the role of the Council's planningfunction, or the development control committee, to facilitate the achievement of a higher value forland than might otherwise be the case. In the context, therefore, and recognizing that there is likelyto be sufficient residual value in the land value to justify a higher proportion of affordable homes,then if consent were given to the proposal, it would be difficult to argue that the AHPN had notgiven rise to a material change in the application of the extant policy on affordable homes, BCS17.The 20% affordable homes offered by the applicant a) is inadequate, and b) has been arrived at ina manner that is inconsistent with the application of BCS17. To the extent that the AHPN haseffectively set a threshold that is not consistent with the proper application of BCS17, then I wouldsuggest that effect has been given to the AHPN which is not lawful. Effectively, the AHPN hasdone what the Council's legal services says it cannot do.Concluding RemarksIt would be tempting to believe that with a decision having been made previously in favour of theapplicant, and with the decision being quashed as a result of what the Council clearly views as aprocedural matter, that remaking the same decision on the basis of an amended officer reportwould address the shortcomings of the previous decision. For the reasons set out above, I believethis would be a mistake. We have had time to consider the ramifications of a revised NPPF (therevision was published after I had drafted my previous submission, and I cited the 2019 version),we have also seen the Government's Net Zero Strategy, and Government has issued a policydocument responding to the Select Committee Inquiry into Local government and the path to netzero.

The revised National Planning Policy Framework published in 2021 contains, through its referenceto the National Design Guide and National Model Design Code, important new provisions aroundthe design of development. Para 134 is clear:Development that is not well designed should be refused, especially where it fails to reflect localdesign policies and government guidance on design52, taking into account any local designguidance and supplementary planning documents such as design guides and codes.The footnote 52 cited in the above extract indicates that government guidance on design iscontained in the National Design Guide and National Model Design Code.A recent study commissioned by the Place Alliance has highlighted the myths that have prevailedamong Council officers and decision makers:For decades local planning authorities up and down the country have been reluctant to refusepoorly designed residential and other developments on design grounds. Six perceptions haveunderpinned this reluctance:1. Design is too subjective - design has been seen by many as too subjective, potentially openingup planning judgements to challenge.2. Quantity not quality is prioritised - in the past government guidance has prioritised other factorsover design quality, most notably housing supply.3. Housebuilders are too formidable - pragmatically some authorities have taken the approach thatit is better to negotiate and accept what you can get, rather than refuse schemes, given thathousebuilders will eventually wear them down and get their own way.4. Good design takes too long - some believe that negotiation on design takes too much time, time

which already stretched planning officers don't have.5. Design is an afterthought - practices of determining the principle of development (in an outlineapplication) prior to determining how schemes will be delivered in design terms (in reservedmatters) undermine design-based arguments from the start.6. Costs will be awarded - for all the reasons above, cash strapped local planning authorities worrythat refusing on design will open them up to costs being awarded against them at appeal.It indicates how misplaced these myths now are, if indeed they ever held any weight. Itencourages decision makers to stand up against poor-quality residential design:Drawing on recent planning appeals data, this report reveals that none of these perceptions areany longer true (some never were).The National Planning Policy Framework (NPPF) was revised on July 20th 2021, and since thenhas unequivocally stated: "Development that is not well designed should be refused" (para. 134).The message to all local planning authorities is therefore that they should have the courage oftheir convictions and stand up against poor quality residential design wherever it is found.Examining a representative sample of thirty-two design related 'major' planning appeals from2021, it is apparent that a marked shift in the likelihood of local authorities successfully defendingdesign-based appeals has occurred.This shift is clearly apparent in the arguments used by Inspectors who, on the face of it, seem tohave been liberated to consider design on equal terms with other factors. In doing so theyregularly reference the changed policy position in the NPPF, as well as guidance in both theNational Design Guide and National Model Design Code.Comparing the decisions after July 20th 2021 to those before, the odds in favour of local planningauthorities winning cases on design grounds have shifted from just 5:7 (against) to 13:7 (infavour). In other words, previously there were more losses than wins (for local authorities), andnow there are close to two times more wins than losses.Where applications are characterized by poor design, and where they fail to reflect the guidance inboth the National Design Guide and National Model Design Code, then Councillors should makelawful decisions and reject such applications.In the case of the specific application, I have drawn specific attention to the climate changeperformance of the proposed development. I have referred to both the operational carbonemissions from the proposal, which are also the subject of the Council's own policy, BCS14, andthe embodied carbon associated with the proposal. Both are included as aspects of well-designeddevelopment in the National Design Guide and the Guidance accompanying the National ModelDesign Code, and the current proposal fails to address them.The proposal fails even to meet the far from challenging residual carbon dioxide emissions targetwithin BCS 14, confirming just how poor this application is, and how distant it is from the aspirationof the NPPF to ensure that plans and planning decisions are consistent with the Climate ChangeAct, as well as the Net Zero Strategy, published since the application was previously considered,which effectively 'banks' the expected effect of decisions taken by planning authorities to ensurethat development is well designed.I also consider the affordable homes issue to have been dealt with in a manner inconsistent withBCS17, and in a manner that suggests that the Affordable Housing Practice Note has acquired a

status of establishing a new policy, something which is not consistent with the view of theCouncil's own legal services.Finally, other matters - some linked to matters raised in my previous objection - should beconsidered in respect of the quality of the design of this proposal. I believe that the proposal failson multiple fronts in this regard, and should therefore be rejected.

As direct neighbours of Bristol Zoo, we continue to object to the proposed developmentof the West car park site in its currently submitted form. We wish for our previous commentssubmitted on 2 June 2021 and 16 August 2021 to continue to be taken into account and also addthe following further comments in respect of this application:

The Judicial Review found that the plans for the West car park site failed to properly consider thelevel of heritage harm and failed to accurately take into account the advice provided by HistoricEngland who stated that 'the proposed layout, massing and design fails to respond to thecharacter and appearance of the Conservation Area'. Bristol Zoo have taken no action to addressthese concerns prior to reconsideration of the application by the Council which just goes to showthe level of contempt shown to both neighbours, Historic England and the overall planningprocess. As mentioned previously, the design and sheer scale of Block A (in terms of both sizeand density) remain a significant concern for us as residents of 50 College Road as the buildingwould be so out of keeping with neighbouring buildings and would dwarf all existing buildings atthe north end of College Road.

I was present at the Development Control Committee meeting last September and by the PlanningOfficer's own admission, there was an unprecedented level of objections to this scheme beyondanything he had seen before. When reconsidering the status of this planning application, thestrength of feeling among the local community should be fully taken into account, backed up bycomments from entities such as Historic England and the Clifton and Hotwells ImprovementSociety. The precarious financial position of Bristol Zoo has been mentioned in the past as areason for supporting this planning application however this should not be taken into account as avalid reason for determining a planning application.

I would urge you on this occasion to fully take on board the comments made by Historic Englandthereby rejecting this planning application for the West car park site and sending a strongmessage back to Bristol Zoo that their plans for the site (and in particular Block A) need to bedramatically reconsidered.

National Policy and Law

The National Planning Policy Framework has an environmental objective:1

8…c) an environmental objective – to protect and enhance our natural, built and historic

environment; including making effective use of land, improving biodiversity, using natural

resources prudently, minimising waste and pollution, and mitigating and adapting to climate

change, including moving to a low carbon economy.

Paragraph 16 states that:2

16. Plans should:

a) be prepared with the objective of contributing to the achievement of sustainable

development;

b) be prepared positively, in a way that is aspirational but deliverable;

Para 134 states:3

Development that is not well designed should be refused, especially where it fails to reflect

local design policies and government guidance on design52, taking into account any local

design guidance and supplementary planning documents such as design guides and codes.

The footnote 52 in the above extract indicates that the government guidance on design is contained

in the National Design Guide and National Model Design Code, which we refer to below.

Para 152 of the NPPF notes:4

152. The planning system should support the transition to a low carbon future in a changing

climate…. It should help to: shape places in ways that contribute to radical reductions in

greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the

reuse of existing resources, including the conversion of existing buildings; and support

renewable and low carbon energy and associated infrastructure.

153. Plans should take a proactive approach to mitigating and adapting to climate change…..

[footnote 53] In line with the objectives and provisions of the Climate Change Act 2008. ie in

line with the 80% cut by 2035 and net zero by 2050.

As well as:5

154. New development should be planned for in ways that:……

b) can help to reduce greenhouse gas emissions, such as through its location, orientation and

design.

1 Ministry of Housing, Communities and Local Government (2021) National Planning Policy Framework, July 2021, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf 2 Ibid. 3 Ibid. 4 Ibid. 5 Ibid.

In its response to the Housing, Communities and Local Government Select Committee report that

was published on 29 October 2021 following the Select Committee’s inquiry into Local Government

and the Path to Net Zero, a Government (DLUHC) policy paper included the following:6

On powers, local authorities already have a combination of powers across housing, planning

and transport which gives them significant autonomy to take action on net zero. We will

have discussions on any additional powers local authorities think they may need to play their

part in meeting national net zero targets, and the evidence for this, as part of the Local Net

Zero Forum.

It highlighted the respective roles of BEIS and DLUHC:7

As outlined in the Net Zero Strategy, BEIS has overall responsibility for achieving net zero and

for coordinating with local authorities and other local actors on designing effective policies,

including the local delivery of net zero. The Department for Levelling Up, Housing and

Communities (DLUHC) acts as a steward for the local government finance system and has

overall responsibility for the planning system.

(We reference the Net Zero Strategy below.) The same policy document referenced the uplift for

new homes in terms of carbon performance which we have discussed above:8

On 15 December, we implemented an uplift for new homes. This is a key stepping-stone that

will enable us to successfully implement the Future Homes Standard. Once the uplift comes

into force, new homes will be expected to produce around 30% fewer CO2 emissions

compared to current standards. This will deliver high-quality homes that are in line with our

broader housing commitments and encourage homes that are future proofed for the longer

term.

The policy report references embodied carbon in buildings:9

The government’s Net Zero Strategy also sets out our ambitions to help the construction

sector improve its reporting on embodied carbon in buildings. We are exploring the potential

of a maximum embodied carbon level for new buildings in the future while encouraging the

sector to reuse materials and make full use of existing buildings. In championing low-carbon

materials, increased energy efficiency and enhanced product design, we are supporting the

sector to deliver the cleaner, greener buildings of tomorrow.

In referencing embodied energy, it makes specific reference to the National Model Design Code:10

The National Planning Policy Framework (NPPF) is clear that the planning system should

support the transition to a low-carbon future in a changing climate, taking full account of

flood risk and coastal change. It should help to shape places in ways that contribute to

radical reductions in greenhouse gas emissions […] The NPPF expects Local Plans to take

account of climate change over the longer term; local authorities should adopt proactive

6 Department for Levelling-up Housing and Communities (2022) Policy paper: Local government and the path to net zero: government response to the Select Committee report, 13th January 2022. 7 Ibid. 8 Ibid. 9 Ibid. 10 Ibid.

strategies to reduce carbon emissions and recognise the objectives and provisions of the

Climate Change Act 2008.

In July 2021 we updated the NPPF, placing a stronger emphasis on delivering sustainable

development and a proactive approach to mitigating and adapting to climate change.

Simultaneously, we also published the National Model Design Code which guides local

authorities on measures they can include within their own design codes to create

environmentally responsive and sustainable places. The National Model Design Code

encourages the implementation of sustainable construction that focuses on reducing

embodied energy, designing for disassembly and exploring the remodel and reuse of

buildings where possible rather than rebuilding. The National Model Design Code also

provides tools and guidance for local planning authorities to help ensure developments

respond to the impacts of climate change, are energy efficient, embed circular economy

principles and reduce carbon emissions.

Local authorities have the power to set local energy efficiency standards that go beyond the

minimum standards set through the Building Regulations, through the Planning and Energy

Act 2008. In January 2021, we clarified in the Future Homes Standard consultation response

that in the immediate term we will not amend the Planning and Energy Act 2008, which

means that local authorities still retain powers to set local energy efficiency standards that

go beyond the minimum standards set through the Building Regulations. In addition, there

are clear policies in the NPPF on climate change as set out above. The Framework does not

set out an exhaustive list of the steps local authorities might take to meet the challenge of

climate change and they can go beyond this.

The Government’s Net Zero Strategy, a policy paper setting out policies and proposals for

decarbonising all sectors of the UK economy to meet the 2050 net zero target, stated:11

48. ...The National Model Design Code, published in July this year, guides local planning

authorities on measures they can include within their own design codes to create

environmentally responsive and sustainable places. The National Model Design Code

provides tools and guidance for local planning authorities to help ensure developments

respond to the impacts of climate change, are energy efficient, embed circular economy

principles and reduce carbon emissions

The recent House of Commons Environmental Audit Committee Report on Net Zero construction

stated:12

73. Local authorities are mandating WLC [whole life carbon] assessments of their own

accord. Evidence so far shows that the policy is achievable and is working, with few barriers

to its introduction. Introducing mandatory WLC assessments for buildings could be an easy

way for the Government to dramatically reduce carbon in construction.

It is clear, therefore, that local authorities are acting on embodied carbon, not least given the

orientation provided by para 134 of the NPPF, and the associated government guidance in the

National Design Guide and National Model Design Code (see next Section).

11 HM Government (2021) Net Zero Strategy: Build Back Greener, October 2021. 12 Environmental Audit Committee (2022) Building to net zero: costing carbon in construction, First Report of Session 2022–23, https://committees.parliament.uk/publications/22427/documents/165446/default/

National Guidance on Design

It will be recalled that para 134 of the NPPF indicates that:13

‘Development that is not well designed should be refused, especially where it fails to reflect

local design policies and government guidance on design’.

The National Design Guide states:14

135. Well-designed places and buildings conserve natural resources including land, water,

energy and materials. Their design responds to the impacts of climate change by being

energy efficient and minimising carbon emissions to meet net zero by 2050. It identifies

measures to achieve:

■ mitigation, primarily by reducing greenhouse gas emissions and minimising embodied

energy; and

■ adaptation to anticipated events, such as rising temperatures and the increasing risk of

flooding.

[…]

137 Well-designed places:

■ have a layout, form and mix of uses that reduces their resource requirement, including for

land, energy and water;

■ are fit for purpose and adaptable over time, reducing the need for redevelopment and

unnecessary waste;

■ use materials and adopt technologies to minimise their environmental impact.

It includes two key themes to be considered in well-designed proposals:15

R1 Follow the energy hierarchy

138 Well-designed places and buildings follow the energy hierarchy of:

■ reducing the need for energy through passive measures including form, orientation and

fabric;

■ using energy efficient mechanical and electrical systems, including heat pumps, heat

recovery and LED lights; and

■ maximising renewable energy especially through decentralised sources, including on-site

generation and community-led initiatives.

13 Ministry of Housing, Communities and Local Government (2021) National Planning Policy Framework, July 2021, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf 14 Ministry of Housing, Communities and Local Government (2021) National Design Guide: Planning practice guidance for beautiful, enduring and successful places, 2021. 15 Ibid.

139 They maximise the contributions of natural resources such as sun, ground, wind, and

vegetation.

140 They make use of potential for renewable energy infrastructures at neighbourhood and

building level. These include photovoltaic arrays, heat pumps and district heating systems, to

reduce demand for non-sustainable energy sources. IT advances and app-based solutions

allow users to take ownership or to manage these systems so as to use them most efficiently.

141 They follow the principles of whole life carbon assessment and the circular economy,

reducing embodied carbon and waste and maximising reuse and recycling.

142 Good developments minimise the cost of running buildings and are easy and affordable

for occupants to use and manage.

As will become clear from the discussion of the application below, the design fails to meet these

objectives. In doing so, it fails to meet the requirements of the NPPF. It also fails to align – as

Government (and the NPPF, through its references to the Climate Change Act) says it should – with

the Net Zero Strategy.

The second theme relates to ‘Careful selection of materials and construction techniques’:16

143 The selection of materials and the type of construction influence how energy efficient a

building or place can be and how much embodied carbon it contains.

144 Well-designed proposals for new development use materials carefully to reduce their

environmental impact.

The Guidance Notes on the National Model Design Codes state:17

197. Well-designed places and buildings conserve natural resources including buildings, land,

water, energy and materials. Their design responds to the impacts of climate change by

being energy efficient and minimising carbon emissions to meet net zero targets by 2050. It

identifies measures to achieve: mitigation, primarily by reducing greenhouse gas emissions

and minimising embodied energy; and adaptation to anticipated events, such as rising

temperatures and the increasing risk of flooding.

It is clear that good design, therefore, also includes consideration of the embodied carbon and

energy in materials. We highlight below that there has been no ‘Careful selection of materials and

construction techniques’ in the proposal, that materials have not been considered in terms of how

their selection might minimize embodied carbon, and that as a result, the application fails to align

with the Government’s Net Zero Strategy, and the requirements for good design in the NPPF. It

should, therefore, be rejected.

The NPPF’s clear direction - that unless buildings are well-designed, the applications should be

rejected - when taken alongside the clear guidance that good design would seek to minimise

operational carbon emissions, and minimise embodied energy, consistent with the net zero goal,

suggests that it would be unwise to fail to do either, let alone both. That, however, is exactly what

this application does.

16 Ibid. 17 Ministry of Housing, Communities and Local Government (2021) National Model Design Code: Part 2 – Guidance Notes.

Bristol City Council Policies

In Bristol’s own Core Strategy, , the Core Strategy includes the following policy:18

Policy BCS13

Development should contribute to both mitigating and adapting to climate change, and to

meeting targets to reduce carbon dioxide emissions.

Development should mitigate climate change through measures including:

• High standards of energy efficiency including optimal levels of thermal insulation, passive ventilation and cooling, passive solar design, and the efficient use of natural resources in new buildings.

• The use of decentralised, renewable and low-carbon energy supply systems.

• Patterns of development which encourage walking, cycling and the use of public transport instead of journeys by private car.

Development should adapt to climate change through measures including:

• Site layouts and approaches to design and construction which provide resilience to climate change.

• Measures to conserve water supplies and minimise the risk and impact of flooding.

• The use of green infrastructure to minimise and mitigate the heating of the urban environment.

• Avoiding responses to climate impacts which lead to increases in energy use and carbon dioxide emissions.

These measures should be integrated into the design of new development.

New development should demonstrate through Sustainability Statements how it would

contribute to mitigating and adapting to climate change and to meeting targets to reduce

carbon dioxide emissions by means of the above measures.

Note that the policy BCS13 is not prescriptive, but neither is it restrictive, as regards what

development should consider. It highlights matters that should be included as regards mitigation,

but the overarching principle is that:19

Development should contribute to both mitigating and adapting to climate change, and to

meeting targets to reduce carbon dioxide emissions.

The ‘targets’ referenced in the above seem to be (in the Core Strategy) the targets in the now

abolished Local Area Agreements. It might be considered that the NPPF’s reference to the Climate

Change Act would indicate that the targets therein should guide the application of BCS13.

Nonetheless, the Core Strategy notes that, regarding Policy BCS13:20

This policy will be delivered through the development management process, by means of the

requirement for Sustainability Statements and the implementation of Policy BCS14, Policy BCS15

and Policy BCS16.

18 Bristol City Council (2011) Bristol Development Framework: Core Strategy, Adopted June 2011. 19 Ibid. 20 Ibid.

The mitigation aspect is given further substance through BCS14:21

Policy BCS14

Proposals for the utilisation, distribution and development of renewable and low carbon sources

of energy, including large-scale freestanding installations, will be encouraged. In assessing such

proposals the environmental and economic benefits of the proposed development will be

afforded significant weight, alongside considerations of public health and safety and impacts on

biodiversity, landscape character, the historic environment and the residential amenity of the

surrounding area.

Development in Bristol should include measures to reduce carbon dioxide emissions from energy

use in accordance with the following energy hierarchy:

1. Minimising energy requirements;

2. Incorporating renewable energy sources;

3. Incorporating low-carbon energy sources.

Consistent with stage two of the above energy hierarchy, development will be expected to

provide sufficient renewable energy generation to reduce carbon dioxide emissions from

residual energy use in the buildings by at least 20%. An exception will only be made in the case

where a development is appropriate and necessary but where it is demonstrated that meeting

the required standard would not be feasible or viable.

The use of combined heat and power (CHP), combined cooling, heat and power (CCHP) and

district heating will be encouraged. Within Heat Priority Areas, major development will be

expected to incorporate, where feasible, infrastructure for district heating, and will be expected

to connect to existing systems where available.

New development will be expected to demonstrate that the heating and cooling systems have

been selected according to the following heat hierarchy:

1. Connection to existing CHP/CCHP distribution networks

2. Site-wide renewable CHP/CCHP

3. Site-wide gas-fired CHP/CCHP

4. Site-wide renewable community heating/cooling

5. Site-wide gas-fired community heating/cooling

6. Individual building renewable heating

The underlined paragraph provides the only quantifiable requirement in respect of the climate

change performance of buildings. The Core Strategy adds further explanation of this:

4.14.6 Proposals for development should be accompanied by an energy strategy as part of the

Sustainability Statement submitted with the planning application, which should set out measures

to reduce CO2 emissions from energy use in accordance with the energy hierarchy. The energy

strategy should:

21 Ibid.

• Set out the projected annual energy demands for heat and power from the proposed development against the appropriate baseline (2006 Building Regulations Part L standards), along with the associated CO2 emissions.

• Show how these demands have been reduced via energy efficiency and low carbon energy sources such as CHP and district heating, and set out the CO2 emissions associated with the residual energy demand.

• Demonstrate how the incorporation of renewable energy sources will offset the CO2 emissions arising from the residual energy demand.

4.14.7 The energy strategy should integrate sustainable approaches to design and construction

such as optimising solar gain and natural light and ventilation to maximise the energy efficiency

of the development and minimise its overall energy demand.

The policy itself, however, demands ‘at least’ 20% reduction in residual CO2 emissions.

Perhaps recognising the chasm emerging between the Council’s declaration of a ‘Climate

Emergency’, and its existing Core Strategy,22 the Council developed a Climate Change and

Sustainability Practice Note, published in July 2020. The Climate Change and Sustainability Practice

Note (CCSPN) indicates that: 23

The following key principles apply to all Sustainability Statements:

1. Sustainability Statements should address both mitigation and adaptation as set out under

policy BCS13.

2. Sustainability Statements should engage with and address the energy requirements of

policy BCS14, the water management requirements of policy BCS16 and each of the key

issues listed in policy BCS15.

3. In respect of each of these issues, Sustainability Statements should set out what possible

measures have been explored, which measures have been adopted and integrated into the

design and, where relevant, why it was not feasible to incorporate certain measures into the

proposed development.

4. A failure to convincingly address each of these issues will result in a refusal of planning

permission.

5. If it is argued that including sufficient measures to meet the energy requirements of policy

BCS14 would render the development unviable, then the applicant will be required to submit

a full viability assessment.

Again, it has to be noted that BCS14 indicates that use of renewables should, “reduce carbon dioxide

emissions from residual energy use in the buildings by at least 20%.” Neither BCS13 nor BCS14 are

restrictive in what they say should be done, rather, they indicate what process the applicant should

demonstrate that they have followed in order to have their consent granted. That an application

achieves a 20% reduction in residual CO2 would not, therefore, in and of itself, indicate compliance.

It is the procedural logic of the policy that is set out. The CCSPN then places flesh on the bones in

22 Since the Core Strategy was adopted, the UK has signed up to the Paris Agreement, a legally binding international treaty on climate change, and the Council itself has declared climate and ecological emergencies, and has committed, in the One City Plan, to becoming carbon neutral and climate resilient by 2030. 23 Bristol City Council (2020) Climate Change and Sustainability: How to design low carbon and resilient developments: Practice Note, July 2020.

terms of this process, as well as making it clear that where applicants fail to do what the CCSPN sets

out, the result will be refusal of the application.

This would be completely consistent with the view in the NPPF regarding good design: indeed, even

if BCS14 were absent, para 134 clearly states that where the design fails against criteria that are

quite clear in what they require, consistent with national policy (see above), it should be rejected.

There is also sufficient already in the Core Strategy to support the view that those making planning

applications should ensure that embodied emissions and energy are considerations that should

influence the design of housing for which planning consent is being sought. Notwithstanding the

absence (as yet) of specific policies or targets on embodied energy or embodied carbon, Policy

BCS15 allows for this, in stating:24

Sustainable design and construction will be integral to new development in Bristol. In delivering

sustainable design and construction, development should address the following key issues:

• Maximising energy efficiency and integrating the use of renewable and low carbon energy;

• Waste and recycling during construction and in operation;

• Conserving water resources and minimising vulnerability to flooding;

• The type, life cycle and source of materials to be used;

• Flexibility and adaptability, allowing future modification of use or layout, facilitating future refurbishment and retrofitting;

• Opportunities to incorporate measures which enhance the biodiversity value of development, such as green roofs.

New development will be required to demonstrate as part of the Sustainability Statement

submitted with the planning application how the above issues have been addressed.

It would be consistent with the NPPF, as revised, for the Sustainability Statement to show how

energy efficiency had been maximized (not simply marginally exceeding what would be achieved by

Part L Building Regulations compliant proposals), and how the choice of materials had been made

such as to minimize embodied carbon emissions.

Operational Emissions from the Proposal

Paras 138-142 of the National Design Guide (see above) are relevant here. BCS14 also sets out

requirements for ‘at least’ 20% reduction in residual CO2 emissions, whilst BCS 15 sets out design

requirements, and the CCSPN sets out the procedural logic which applicants should follow if they are

to avoid refusal. This echoes para 134 of the NPPF which also indicates that ‘development that is not

well designed should be refused’.

In support of its application on the West Car Park, The Energy and Sustainability Assessment (ESA)

prepared for ZooSoc claims that:25

All guidelines [in the aforementioned Practice Note] throughout this document have been

adhered to in the production of this energy and sustainability strategy.

24 Bristol City Council (2011) Bristol Development Framework: Core Strategy, Adopted June 2011. 25 Hydrock (2021) Bristol Zoo - West Car Park: Energy and Sustainability Statement for Bristol Zoo, 18 March 2021.

Whilst the Energy and Sustainability Assessment does indeed cover some of these matters, it does

so in a perfunctory manner. This is not consistent with the test of good design as per the NPPF. Nor

is it consistent with the procedure outlines in BCS4, and elaborated further in the CCSPN.

In terms of ‘minimising energy’, the ESA plans indicates it will make use of materials for the building

fabric that have low U-values. Some of these are now – following the change to Part L of the Building

Regulations that was announced in December 2021 – the Regulated minimum. The use of heat

pumps might be considered welcome, but again, this is not about to deliver a zero carbon home in

the short-term, not least because of the increase in demand for energy.

There is no detail provided for how the demand for heat will be matched by the supply from the six

heat pumps illustrated in the Plan in Block B of the development. There is no transparency in the

derivation of the figures which are presented in respect of the climate change performance of the

different measures being proposed, not to mention, the baseline position. This is not consistent with

the CCSPN which states, quite reasonably:26

‘An effective energy strategy will combine a written explanation of the measures proposed,

taking account of site constraints and opportunities, with detailed calculations showing the

CO2 emission savings achieved. The proposed measures should be shown on the application

drawings, in order to provide certainty that they can be accommodated in the design, and to

allow an assessment of how well they have been integrated into the proposed design.’

Until the applicant clearly demonstrates the basis for its calculations – the validity of which we

challenge below – and until it is made clear how the development is consistent with the

requirements of the NPPF, BCS14, BCS15 (and the procedural guidance elaborated in the CCSPN),

then it is not possible to have confidence that it is well designed.

There is no provision planned for any on-site generation of renewable electricity. This is because

point 3 in the above extract from the CCSPN was not adhered to. There was no reasonable

exploration of measures which could be adopted, let alone any rational argument as to why, for

example, it would have been unreasonable for rooftop PV to be in place in the development. Both

solar thermal and solar PV move from ‘having potential’, as per p.13 of the Energy and Sustainability

Statement, to being dismissed in the final proposals. Table 7 in the Energy and Sustainability

Assessment – the header for which states that it has been taken from the CCSPN – as well as the

supporting text, speak only in general terms about how ‘consideration of conservation would need to

be taken into account’, and ‘the benefit of solar thermal panels would need to be considered against

impact to the local Conservation Area and sedum roofs’.27

These are not justifications (certainly, not adequate ones) for overlooking the potential of solar PV.

There are solar PV panels already on properties in Clifton in Conservation Areas, several of them in

close proximity to the site. Also, there is some evidence to suggest, in respect of green rooves, that

these can help improve output from solar PV because of their cooling effect: furthermore, shaded

areas might actually enhance the diversity of microclimates for wildlife. The points made do not

demonstrate why these are not viable options for inclusion in this proposed development, which is

26 Bristol City Council (2020) Climate Change and Sustainability: How to design low carbon and resilient developments: Practice Note, July 2020. 27 As a separate point, in terms of the design of the proposed buildings, one might reasonably expect, when new developments are proposed, that whether in a conservation area or any other location, the design of the buildings might actually consider how beneficial attributes, such a rooftop PV, can be integrated so that they are acceptable. Instead, the possibility was described, and then rejected out of hand.

what the CCSPN not only requires, but which, if absent, ought to have led to the application being

refused. Had this matter been properly considered, the development itself might look rather

different, for example, in respect of orientation of the rooves. There is no reason why the provision

of on-site renewable electricity is not viable, and no reasonable one was given.

In an amendment sheet presented to the Development Control Meeting where this application was

previously considered in 2021, and initially approved, the applicant’s sustainability consultants

stated:

Solar PV panels were considered (within sustainability/energy statement), but discounted for

a number of reasons, notable efficiency/orientation, aesthetics and impact on conservation

area, and also provision of sedum roof and ecological enhancements.

Yet the CCSPN states:

Policy BCS13 requires that measures to mitigate and adapt to climate change are integral to

the design of new development. This reflects the fact that certain sustainability measures

cannot be retrofitted and, to be effective, measures to mitigate and adapt to climate change

such as site-wide renewable energy measures have to be planned into development from the

earliest stage as they directly affect the layout and design of development. For example, to

make the best use of solar for the generation of heat or power, a development will require

south-facing roof slopes.

Elsewhere, it notes: ‘When designing a building, applicants are encouraged to consider whether

opportunities for PV can be maximised through the layout and orientation of buildings.’ The points

are obvious ones: the applicant has choice over matters of orientation of the rooves at new housing

proposals.

And it is not only the Council’s own policy that requires this. The National Design Guide states:28

135. Well-designed places and buildings conserve natural resources including land, water,

energy and materials. Their design responds to the impacts of climate change by being

energy efficient and minimising carbon emissions to meet net zero by 2050. It identifies

measures to achieve:

■ mitigation, primarily by reducing greenhouse gas emissions and minimising embodied

energy; and

And:29

R1 Follow the energy hierarchy

138 Well-designed places and buildings follow the energy hierarchy of:

■ reducing the need for energy through passive measures including form, orientation and

fabric;

■ using energy efficient mechanical and electrical systems, including heat pumps, heat

recovery and LED lights; and

28 Ministry of Housing, Communities and Local Government (2021) National Design Guide: Planning practice guidance for beautiful, enduring and successful places, 2021. 29 Ibid.

■ maximising renewable energy especially through decentralised sources, including on-site

generation and community-led initiatives.

139 They maximise the contributions of natural resources such as sun, ground, wind, and

vegetation.

140 They make use of potential for renewable energy infrastructures at neighbourhood and

building level. These include photovoltaic arrays, heat pumps and district heating systems,

to reduce demand for non-sustainable energy sources. IT advances and app-based solutions

allow users to take ownership or to manage these systems so as to use them most efficiently.

Invoking ‘efficiency / orientation’ as an explanation as to why solar PV could not be fitted is akin to

the applicant denying that it had any choice in the matter of the orientation of the rooves. Not only

was the applicant free to determine orientation, but it was required through national policy to

‘maximise the contributions of natural resources such as sun, ground, wind and vegetation’, not

deliberately choose an orientation which it is claimed reduces their useful contribution to zero. To

wilfully choose an orientation that would make such integration impossible (if indeed one accepts

that is the case) is as close to a definition of poor design as one could imagine.

The grounds in relation to aesthetics effectively presume the outcome of the application, and make

light of the fact that there are already PV panels installed at listed buildings in Clifton (as well as

others in the conservation zone), whilst the supposed preference for sedum roof vis a vis PV a)

suggests a conflict which does not exist - indeed, the CCSPN itself states: ‘Combining green/brown

roofs with solar photovoltaic (PV) panels can enhance the power production of the PV units.’ - but

also b) suggests a preference ordering (green rooves over solar PV) which if anything, runs counter

to the requirements of policy and the CCSPN.

The only reason solar PV would have been non-feasible at the site was if the sun did not shine at that

location. The failure to integrate PV is clearly a failure of design. In line with para 134 of revised

NPPF, it should be refused. Para 134 indicates that buildings that are not well-designed should have

their applications refused, and the Guidance Notes on the National model Design Code are

abundantly clear that well-designed buildings respond ‘to the impact of climate change by being

energy efficient and minimising carbon emissions’.

To reiterate the National Design Guide:

138 Well-designed places and buildings follow the energy hierarchy of:

■ reducing the need for energy through passive measures including form, orientation and

fabric;

■ using energy efficient mechanical and electrical systems, including heat pumps, heat

recovery and LED lights; and

■ maximising renewable energy especially through decentralised sources, including on-site

generation and community-led initiatives.

139 They maximise the contributions of natural resources such as sun, ground, wind, and

vegetation.

140 They make use of potential for renewable energy infrastructures at neighbourhood and

building level. These include photovoltaic arrays, heat pumps and district heating systems, to

reduce demand for non-sustainable energy sources. IT advances and app-based solutions

allow users to take ownership or to manage these systems so as to use them most efficiently.

141 They follow the principles of whole life carbon assessment and the circular economy,

reducing embodied carbon and waste and maximising reuse and recycling.

142 Good developments minimise the cost of running buildings and are easy and affordable

for occupants to use and manage.

The proposal fails in more or less every respect in this regard. The application should be refused.

Performance Against BCS14 – Residual CO2

Lest it be considered that the application actually delivers performance that is remotely impressive,

we now discuss the actual performance of the proposed build.

If one reviews the figures in the Energy and Sustainability Assessment, using some basic algebra, we

can drill into the detail of the heat and electricity demand in the baseline, and with the measures

proposed by the applicant to be in place. This is necessary because, contrary to what the CCSPN

requires of the applicant, the applicant provides virtually no information that would enable one to

readily understand whether what is being proposed would actually deliver the claimed outcomes.

Using the SAP 2012 figures (see Table 1 in the Energy and Sustainability Assessment), the proposed

measures associated with the proposal claim to deliver a 33% reduction relative to residual

emissions. Note that these residual emissions are relatively high because the energy efficiency

measures are somewhat limited: notwithstanding the intent to use materials with a lower U-value

than under Part L of the Building Regulations, the measures achieve a small - 5% - improvement

relative to what is required to comply with Building Regulations.30 The Energy and Sustainability

Assessment does not actually report how this Figure has been calculated other than through

referencing U-values. No materials are actually mentioned, the U-values are simply stated, with no

reference to what it is that delivers those lower U-values, and hence, what fabric is to be used. This

is despite the fact that the CCSPN is very clear, as per Table 1 in the CCSPN, that:31

The summary table should be supported by a written explanation of the measures proposed

and a full set of calculations as set out under “Detailed Measures” below. Where relevant,

the proposed measures should also be shown on the application drawings.

These calculations are not presented. Without seeing these, it might reasonably be asked whether

the energy hierarchy has been adequately respected.

Notwithstanding the lack of transparency in the presentation of calculations, one can derive

interesting further insights into the performance of the proposed development. The emissons

performance of the proposed development are shown in Table 1, which is reproduced (with some

additional labelling) from the Energy and Sustainability Statement.32

30 The changes to Part L announced in December 2021, and that took effect in June 2022, would reduce this figure (the baseline for the assessment would be a lower carbon building). This is another failure of design in that the Energy Hierarchy referenced in the National Design Guide (and articulated in BCS14) has not been strictly followed. 31 Bristol City Council (2020) Climate Change and Sustainability: How to design low carbon and resilient developments: Practice Note, July 2020. 32 Hydrock (2021) Bristol Zoo - West Car Park: Energy and Sustainability Statement for Bristol Zoo, 18 March 2021.

Table 1: Energy strategy summary as required by BCS14

Energy

Demand (kWh/year)

Energy Saving

Achieved (%)

Regulated CO2

Emissions (kgCO2/year)

Savings Achieved

on Residual

(%)

A. Building Regulations Compliance

421,200 146,300

B. Proposed after energy efficiency

395,300 6% 138,400

C. Proposed after on-site renewables

395,300 6% 92,100 33%

D. Proposed scheme offset for financial contribution or allowable solutions

N/A N/A

E. Total saving on residual emissions

37%

Source: Hydrock (2021) Bristol Zoo - West Car Park: Energy and Sustainability Statement for Bristol Zoo, 18 March 2021

Of particular interest is the change in emissions between Rows B and C. Given that the sum of

electricity and heat demand is 395,300 kWh (row B), and given also that the product of the

electricity and heat demand, and the respective unit CO2 emission figures (also presented in the

Energy and Sustainability Statement) is equal to 138,400 (from Row B), it is possible to calculate the

respective demand for electricity and heat:33

• 174,968 kWh electricity, and

• 220,332 kWh heat.

Row C incorporates the effect on emissions of using air source heat pumps to deliver heat. The

emissions fall by 46,300 tonnes CO2. This is equivalent to virtually all the heat demand being met by

a heat source with zero carbon emissions: the emissions that would be associated with the grid-

based electricity necessary to drive the ASHPs do not seem to have been accounted for. The overall

energy demand is kept the same in Row C as in Row B. It is effectively being assumed, in calculating

the savings in residual emissions, that the electricity used to drive the ASHPs has a zero carbon

intensity. There is, though, no provision for this (see above).

In the proposed scheme, the demand for heat is met (the assumption is that it is more or less met in

its entirety) through the use of ASHPs, and these would increase the demand for electricity, which is

the driver of the heat output from the ASHPs. Using an assumption of 3:1 for the seasonal coefficient

of performance (SCoP) factor of the ASHPs (higher than the 2.5 quoted by Hydrock in the Energy and

33 Essentially, this is through solving simultaneous equations for heat and electricity use, given the carbon intensity figures for electricity and heat upon which the calculations are based.

Sustainability Statement),34 the electricity demand needed to deliver the heat would be of the order

73,444 kWh, and the associated emissions would be more than 38,000 tonnes CO2. If this figure is

added back to the analysis in Table 1, the emissions in row C should be reported as 128,926 tonnes.

The saving in residual emissions would be 7%, less than half what BCS14 suggests as a minimum, and

much lower than claimed by the aplicant.

An alternative way of looking at this is that in order for Hydrock’s figures to be correct, the ASHPs

would have needed to be capable of delivering heat with a Seasonal Coefficient of Performance of

the order 6:1. Hydrock’s own Energy and Sustainability Statement states:

Heat pumps operate with a typical Seasonal Coefficient of Performance (SCoP) of 2.5:1 to 5:1

(depending on heat source/sink); meaning that for every 1kW of electric in, 2.5kW of heat is

generated (for ASHP) and up to 5kW (for some ground or water source heat pumps).

A ratio of 6:1 is not yet within reach for air source heat pumps in the UK.35

In summary, the reduction in residual CO2 emissions – which is given as a policy compliant 33% -

should have been reported as around 7%. The development fails even to satisfy the minimum target

set out in BCS14.

Revised Part L Building Regulations

It may also be noted that months after the Council’s decision to grant the application, which has now

been quashed, the Government issued amendments to the Building Regulations which were

designed to improve the performance of buildings by reducing CO2 emissions as per Part L of the

Building Regulations. The Amendment Regulations and accompanying Approved Documents L:

Volumes 1 and 2 were published on 15 December 2021 and came into force on 15 June 2022.

Transitional arrangements were put in place as follows:

the changes will not apply in relation to building work where a building notice or an initial

notice has been given to, or full plans deposited with, a local authority before 15 June 2022

provided that the building work is started before 15 June 2023.

34 The figure of 3.0 seems reasonable given figures reported in work by Colin Meek (Colin Meek (2021) Heat pumps and UK’s decarbonisation: lessons from an Ofgem dataset of more than 2,000 domestic installations, Spring 2021, https://www.recc.org.uk/pdf/performance-data-research-focused.pdf): ‘Although there are important limitations, the overall results are sobering. More than one quarter of the main sample and 28% of ASHPs [air source heat pumps] were found to have an SPF [seasonal performance factor] below 2.5. The average SPF was found to be 2.76 for all installations analysed (2.71 for ASHPs and 3.07 for GSHPs [ground source heat pumps]). The analysis found no discernible improvement in performance after the UK standard for heat pump installation was changed in 2017. The analysis of installations since that date found the average ASHP SPF to be 2.69 and the average GSHP SPF to be 2.98.’ The Seasonal Performance Factor (SPF) is defined as the measured annual efficiency of a heat pump in a specific location. The figure is also reasonably aligned with the analysis for CCC in Element Energy and UCL (2019) Analysis on abating direct emissions from ‘hard-to-decarbonise’ homes, with a view to informing the UK’s long-term targets, study for the Committee on Climate Change, July 2019. 35 Note that a recent performance review concluded that: ‘Of additional concern is that the problems related to the performance gap are compounded by current methods used to forecast design performance. As explored in 1.2c, it is known the SCOP metric is a measure of product efficiency. When used as a tool to predict the efficiency of the heating system the SCOP metric will most likely exaggerate performance.’ For that reason, we base analysis on measured performance, as assessed through the Seasonal Performance Factor (see main text and next footnote). See Colin Meek (2021) Heat pumps and UK’s decarbonisation: lessons from an Ofgem dataset of more than 2,000 domestic installations, Spring 2021, https://www.recc.org.uk/pdf/performance-data-research-focused.pdf .

Please note that “building notice”, “initial notice” and “full plans” have the meanings given in

Regulation 2 of the Building Regulations 2010.

In respect of the second paragraph, the relevant point would be when the local authority had

received a building notice in accordance with Regulation 13 of the Building Regulations or where full

plans had been deposited with the local authority in accordance with Regulation 14 of the Building

Regulations 2010. It seems unlikely that either has happened.

In practice, what this means is that the claimed energy efficiency improvements made in the ESS will

be lower than had been claimed by the applicant: some of the U-values presented as improvements

in the ESS are no longer improvements but are required under the amended Regulations. The

improvement claimed for the proposal was already marginal: it is now even smaller.

Addressing Non-compliance with BCS14

Joanne Mansfield, from Bristol City Council’s legal services, in the Council’s response to a pre-action

protocol letter indicating the intent of CHIS to commence proceedings to quash the initial

application, stated:

The Report clearly had the E&S Statement in mind because it discussed use of ASHPs and the

37% total emissions reduction, which were specifically set out in the E&S Statement.

Condition 8 of the permission also referred to the E&S Statement.

Condition 8 of the now quashed permission - referenced by Joanne Mansfield - was rendered

completely ambiguous as a result of the fact that the Table in the ESS – to which the Condition

referred - was inconsistent with the actions that would lead to the claimed outcome – how would

the Council ensure that the Condition had been discharged? Of the two options - ensuring that the

relevant installations had been installed, or measuring the regulated carbon emissions associated

with the completed buildings on an ongoing basis (and requiring the applicant to make

improvements where the target CO2 emissions reduction was not achieved), the former is the far

more likely approach. The fact that the Table and the proposed measures are inconsistent is not,

therefore, a trivial matter, and it is not something that Condition 8 of the now quashed application

would have resolved.

It is worth reiterating – again - that all these matters should be dealt with at the design stage, not

after the fact after a decision has been made by the Development Control Committee. The NPPF

clearly makes the decision contingent on the design. Logically, any such matters of design need to be

resolved prior to a decision being reached. I am asking only that the decision is made in a lawful

manner. The point made below regarding the location of the ASHPs in the proposal is also of

relevance here. Given that the proposed plan has the ASHPs adjacent to bedrooms, and given that

that would not be allowed under the revised Regulations, then the design fails again, even to comply

with the Building Regulations, which are simply reflecting common sense in this regard.

Embodied Carbon Emissions from the Proposal

All infrastructure projects involve the use of materials, and the processes of extraction of raw

materials and the production of the materials themselves have, associated with them, emissions of

greenhouse gases. These emissions are what are referred to as the ‘embodied’ emissions in

materials. Embodied, or embedded, greenhouse gas emissions are those ‘embodied’ in the materials

used in building dwellings (i.e. those expended in their manufacture), and in the processes used to

construct the buildings.36

it has become increasingly obvious that the issue of embodied materials in construction projects

cannot be ignored, and for obvious reasons: in line with the carbon budgeting concept provided

above, if building houses (or other infrastructure) draws down heavily on remaining carbon budgets,

then whatever the emissions associated with the house once occupied, these upfront emissions

during the build phase are potentially very problematic: they happen ‘early’ (i.e. before the house

has been completed), and they cannot easily be ‘clawed back’ post construction unless, for example,

over time, the non-fossil energy delivered back to the grid exceeded consumption, and then, only

where accounting approaches allowed for any reductions associated with such generation to be

accounted for within the relevant framework. Recent studies indicate that the share of embodied

emissions in total life cycle emissions is likely to have been around 25% in the past, rising to around

42% in modern buildings with improved operational performance (see Figure 1).37 In our own view,

these figures are likely to understate the contribution, especially if one takes account of a

progressively decarbonising energy system, and the fact that genuinely low-carbon sources of key

construction materials such as steel and concrete are far from the norm at present.

Appreciation of this fact is nothing new. In 2013, HM Treasury reviewed the carbon impacts of

infrastructure. It used the term ‘capital carbon’ rather than the term ‘embodied emissions’, and

regarding capital carbon, it noted:38

The relative significance of capital carbon will increase as the grid is decarbonised and

operational emissions reduce. At the same time, the substantial planned increase in

infrastructure investment will tend to increase capital carbon emissions in spite of future

construction efficiencies, therefore even greater action is required by the sector to drive

down capital carbon.

36 For example, the embodied emissions of a metal would include the emissions released during the extraction of ores, the transportation and processing of those ores, and the manufacture of the metal in the form it exists at the point where it is purchased (for example, as a metal sheet). Steel and concrete have been major components of materials used in construction. The pace at which the production of these materials has decarbonized has been far slower than the pace at which, for example, electricity has decarbonized. The implications are that until industry decarbonizes significantly, the embodied emissions become (as we will show later) the major contributor to the greenhouse gas emissions associated with new buildings. Until now, much of the focus has been on operational emissions, and whilst this makes sense for those dwellings already in existence, the focus is misplaced where one is considering new build housing and non-housing construction projects. 37 Röck, M., Saade, M. R. M., Balouktsi, M., Rasmussen, F. N., Birgisdottir, H., Frischknecht, R., et al. (2020). Embodied GHG Emissions of Buildings – the Hidden challenge for Effective Climate Change Mitigation. Appl. Energ. 258, 114107. doi:10.1016/j.apenergy.2019.114107 38 HM Treasury (2013) Infrastructure Carbon Review, 2013.

Figure 1: Trends in Embodied and Operational Emissions, and Share of Embodied Emissions in Total (right-and axis)

Source: Röck, M., Saade, M. R. M., Balouktsi, M., Rasmussen, F. N., Birgisdottir, H., Frischknecht, R., et al. (2020). Embodied

GHG Emissions of Buildings – the Hidden challenge for Effective Climate Change Mitigation. Appl. Energ. 258, 114107.

doi:10.1016/j.apenergy.2019.114107

Various other reports have noted the importance of embodied greenhouse gas emissions in the

construction sector.39 An interesting representation of the opportunity for abatement is shown in

Figure 2. This highlights the fact that these opportunities are likely to be greatest in the planning and

design stages, with the opportunities to make savings in the actual construction phase being much

less than in those planning and design stages. Of course, this is a simplified representation, but the

conceptual basis for this is widely supported.40

39 World Green Building Council, with support from C40 Cities and Ramboll (2019) Bringing embodied carbon upfront: Coordinated action for the building and construction sector to tackle embodied carbon, September 2019, https://www.worldgbc.org/sites/default/files/WorldGBC_Bringing_Embodied_Carbon_Upfront.pdf ; Committee on Climate Change (2019) UK housing: Fit for the future? February 2019; BioComposites Centre et al (2019) Wood in Construction in the UK: An Analysis of Carbon Abatement Potential, February 2019, report for the Committee on Climate Change; Carbon Neutral Cities Alliance & Bionova Ltd (2020) “City Policy Framework for Dramatically Reducing Embodied Carbon”, accessed 10 Nov 20, https://www.embodiedcarbonpolicies.com/; Aecom, for the Committee on Climate Change, (2019) “Options for incorporating embodied and sequestered carbon into the building standards framework” Link 40 The figure was reproduced in World Green Building Council, with support from C40 Cities and Ramboll (2019) Bringing embodied carbon upfront: Coordinated action for the building and construction sector to tackle embodied carbon, September 2019, https://www.worldgbc.org/sites/default/files/WorldGBC_Bringing_Embodied_Carbon_Upfront.pdf

Figure 2: Opportunities to reduce embodied carbon from stage of design process

Source: HM Treasury (2013) Infrastructure Carbon Review, 2013.

Note that the ‘build clever’ aspect is key in ensuring significant carbon reduction is made, and that

central to this is to ‘design in the use of low carbon materials; streamline delivery processes;

minimise resource consumption’. Post design, the opportunity is lost.

As regards what is proposed at the West Car Park site, there is no evidence of any focus on

embodied energy in the design of the proposal. The Energy and Sustainability Statement

accompanying the planning application mentions “embodied energy” only once. This is within a

section entitled ‘Material Selection’:41

The BRE ‘Green Guide to Specification’ is proposed to be used when selecting the construction

materials, to encourage the use of materials which have been produced with minimal impact to

the environment in line with good-practice methodology. The Guide promotes the use of

sustainable materials with low embodied energy, ecotoxicity and long-life span.

Additionally, the materials selected will be responsibly sourced and where practicable meet the

following guidelines:

• ISO14001;

• BES6001;

• PEFC / FSC;

• Chain of Custody.

Materials have been chosen in keeping with the local vernacular of the area, and where

practicable will be sourced locally.

41 Hydrock (2021) Bristol Zoo - West Car Park: Energy and Sustainability Statement for Bristol Zoo, 18 March 2021.

This completely misses the point: embodied energy and emissions have to be considered at the

design stage so that the choice of materials can be made consistent with the objective of, other

things being equal, minimising embodied energy (and carbon emissions) consistent with para 134 of

the NPPF and the National Design Code. The above extract overlooks the fact that the choice of

materials has already been made by architects, and that considerations of the potential embodied

energy of the build have had no impact on that choice (there is no evidence of, for example, an

attempt to estimate this for the build, or indeed, alternative choices of design and material choice).

The ESS is merely describing how materials – the choice of which has already been determined – will

be procured. The Green Guide is ‘proposed to be used’ – i.e. it is proposed to do this in the future.

Embodied energy has not been considered in the design.

We have attempted to make a basic estimate of the embodied GHG emissions from the West Car

Park drawing on recent literature. Regarding the dwellings planned for the West Car Park, the

Schedule of Accommodation (SoA) quotes a figure for the Gross Internal Area (GIA) of 6,514 m2.

The applicants submission in relation to the Main Site includes, in the Planning Sustainability

Statement, Appendices seeking to establish target figures for the embodied emissions per unit of

Gross Internal Area. The main body of the report states, however:

The actual construction specification and building methods are to be established at the

detailed design stages post-planning. Based on the energy modelling and architectural

design assumptions it is anticipated that the upfront embodied carbon of the development

will around 675-875 kgCO2e/m2 and whole lifecycle carbon performance of 1000-1200

kgCO2e/m2.

These values can be compared with figures – see Table 2 - being proposed by LETI and RIBA for

upfront embodied carbon, and for whole lifecycle performance (the figures reflect different scopes

of analysis). The lower end of the range for the upfront embodied carbon – 675 kgCO2e/m2 - is above

(i.e., worse than) the LETI target value for residential construction in 2020 (and in the case of LETI

targets, the year refers to the year of design, not the build), although the residential figures in the

Table are based on data ‘for multi-residential of 6 storeys and above’.42 At the upper end, it falls into

the ‘next to worst’ band. In terms of banding, performance is marginally better against the RIBA

whole life-cycle target for 2030.

42 LETI, with RIBA, GLA, IStructE and UKGBC (2021) Embodied Carbon Target Alignment

Table 2: Banding Proposed for Embodied Carbon by LETI and RIBA (different scopes)

Source: LETI, with RIBA, GLA, IStructE and UKGBC (2021) Embodied Carbon Target Alignment

We have chosen to base our estimate of upfront embodied carbon for the West Car Park site on a

figure in the middle of the range quoted in the report for the Main Car Park of 0.775 kg CO2e/m2,

(excluding sequestration) which seems a reasonable figure given the nature of the construction

being proposed. The mid-range figure for whole life cycle emissions is 1,100 kg CO2e/m2. This may be

optimistic – we noted above that there appears to have been little clear consideration of matters of

embodied carbon in the design for which the application has been made.

Based on a GIA of 6,514 m2, therefore, it can be estimated that the upfront embodied emissions

from construction at the West Car Park site to be of the order 5,048 tonnes CO2e. Embodied

emissions over the whole life-cycle will be of the order 7,165 tonnes CO2e.

To place this into context, the regulated component of the operational emissions are claimed, by the

applicant, to be 92 tonnes CO2 per year, or 129 tonnes CO2 per year if you accept our comments

regarding the apparent omission of emissions frome electricity needed to drive the ASHP. The

upfront emissions alone from the embodied carbon emitted in relation to the site are potentially,

therefore, between 39 and 55 times the annual emissions reported in the ESS. Planning decisions

clearly cannot be made in line with the NPPF if embodied emissions are overlooked. The Net Zero

Strategy evidently ‘banks’ the outcomes expected as a result of planning authorities making planning

decisions consistent with the requirements of good design. The NPPF’s reference, through para 134,

to the need to refuse developments that are not well designed, and the fact that the Model Design

Code – to which the NPPF refers – indicates that in well-designed developments, embodied energy

should be minimised. The application makes no attempt to embed the need to minimise embodied

energy in its design. Rather, it is considered an afterthought. It follows that the application should be

refused.

Other Aspects of Design

Whilst I have highlighted above the failings in the proposal’s design from the perspective of what the

Model Design Code terms ‘Resources’ – specifically, in respect of its impact on climate change - it

would be similarly straightforward to highlight other failings in the design that are relevant to

planning policy.

The National Design Guide indicates that, regarding Identity:

53 Well-designed new development is influenced by:

■ an appreciation and understanding of vernacular, local or regional character, including

existing built form, landscape and local architectural precedents;

■ the characteristics of the existing built form – see Built form ;

■ the elements of a place or local places that make it distinctive; and

■ other features of the context that are particular to the area – see Context .

This includes considering:

■ the composition of street scenes, individual buildings and their elements;

■ the height, scale, massing and relationships between buildings;

■ views, vistas and landmarks;

■ legibility - how easy it is for people to find their way around;

■ roofscapes;

■ the scale and proportions of buildings;

■ façade design, such as the degree of symmetry, variety, the pattern and proportions of

windows and doors, and their details;

■ the scale and proportions of streets and spaces;

■ hard landscape and street furniture;

■ soft landscape, landscape setting and backdrop;

■ nature and wildlife, including water;

■ light, shade, sunshine and shadows; and

■ colours, textures, shapes and patterns

It would be difficult to conclude that the application could be considered ‘well designed’ when

adjudicated against these criteria. The application is effectively a challenge to the local area, rather

than a proposal that demonstrates an appreciation of the local character.

Questions asked in relation to Identity (in the Guidance) are:

Have you considered:

■ How the identity suits the proposed approach to development such as construction

technologies, diversity of procurement or ownership models?

■ How the proposed character responds to climate change?

■ How natural features such as tree planting, wetlands or other sustainable drainage

systems can contribute to a positive character and perform a multifunctional role?

It would be difficult for the proposal to place a tick in any of these boxes.

I also reiterate points made in my previous submission, but would suggest these (and no doubt other

matters) be considered alongside the National Design Guide, and with para 134 of the NPPF in mind:

1. The Planning Statement selectively cites Policy UL2 in the Draft Policies Document in seeking

to support a densification of development. A full reading of the same UL2 suggests that in

areas where the character of the locality demands it, reduced densities are “essential”;

2. The proposal makes any attempt to comply with the requirements of DM16, and it makes no

reference at all to DM 14, which relates to the Health Impacts of Development. In particular,

the following features give rise to concerns regarding the health of would-be occupiers:

a. The absence of space for children to play even though it is not difficult to imagine

the development, as it is proposed, to house more than 50, and potentially, 60

children;

b. The fact that dwellings will be unable to ensure that noise levels are below those

recommended by the WHO at night because of a combination of the prevailing noise

levels (even before one considers those generated at the site itself) and the thermal

properties of the dwellings. In addition, a number of bedrooms appear to be

adjacent to 6 air-source heat pumps (ASHPs), exposing them (notwithstanding the

improvements in noise characteristics of ASHPs) to night-time noise;

3. As well as the effects on the health of would-be occupiers, the application fails to consider

the effect of noise emanating from the development itself, whether from the occupants’

vehicles, or their use of the balconies, or any other source. Only the ASHPs have been

considered as potential sources of noise which could affect existing residents. It is obvious

that the development will be a source of noise, and that the change in night-time noise (and

traffic) in particular (the car park is not generally occupied at night) has the potential to

affect existing residents.

In my previous submission, I wrote the following:

“The plan for renewable energy generation […] is centred on the deployment of air-

source heat pumps (ASHPs). The Energy and Sustainability Assessment indicates that

these will be housed as follows:

ASHP units would need to sit in either an acoustically treated external plant

enclosure or within a well-ventilated internal plantroom. The current architectural

design allows for an internal ground floor plant room in Block B with louvred wall to

allow for suitable airflow.

A review of the floorplan for Block B indicates a plan for 6 Mitsubishi CAHV units (it

is not completely clear whether the room will enable their proper functioning –

some of the dimensions look suspect given the face to face / side by side nature of

the layout). It is a peculiar design choice that these will sit directly under the

bedrooms of Flat 53 and Flat 58, and beside the bedroom in Flat 48. Perhaps other

considerations have trumped the issue of exposure of residents in the development

to the ASHPs: the Planning Noise Assessment considers the noise from ASHPs largely

in respect of their impact on nearby existing residential properties. Laudable as this

is as a principle, it overlooks the need to ensure that the development is also

tolerable to those who will be living there in future. It is difficult to imagine

circumstances where the bedroom windows of the Flats mentioned would be

exposed to noise levels below those that British Standards and the WHO consider

likely to be injurious to sleep, and thence, to the health of residents.”

Since I made that submission, in December of 2021, Part L Building Regulations were

amended. Regarding Heat Pump Systems, the Building Regulations note:

6.42 Heat pumps should not be sited adjacent to sleeping areas, nor should they be

located on materials that can readily transmit vibrations. Additionally, the location of

external fans and heat pump compressors should be appropriately selected to

minimise disturbance to neighbours, while remaining in compliance with planning

requirements.

This is surely just common sense, but the failure of the applicant to have consider this issue

in relation to noise reflects the poor quality of the design. We have a design in front of us

that does not comply with Building Regulations.

4. Last, but by no means least, and consistent with the absence of space for play, and the

failure of design to integrate environmental features, the loss of sixteen trees from the site,

some of which are at the perimeter of the site and could have been accommodated in an

alternative, more sympathetic design, is disappointing given the stated objectives of the

applicant. There is no rationale given for the proposals to fell the trees (other than that this

is what would need to be done if the development is as proposed). The logic is that the

proposal necessitates the felling, rather than the proposal itself being influenced by the

presence of the existing trees. The revised application increases the number of replacements

proposed on site from 10 to 17. On the one hand, this confirms the nature of the previous

objection: with minimal change in design, seven additional trees magically appear in the site

plan. Nonetheless, no effort has been made to avoid felling and no effort has been made to

increase the number of trees planted on site to the level that Tree Replacement Policy

suggests should be provided on site where possible. The revision does nothing to silence the

questions regarding why it would have been impossible to design the development so that

the necessary number of replacements were integrated into the development (this would

have provided an incentive to cut down far only what was absolutely necessary). The

question of where any replacements will go remains.

None of these matters would be ones that necessitated comment had the proposal been well-

designed.

Affordable Homes

In my original objection, I questioned the rationale for the way ‘fast-track’ proposals would be

treated under the Affordable Housing Practice Note (AHPN). In particular, I made the point that the

Council was likely to exceed targets it had previously set for building new homes, but failed to meet

its target for affordable homes. The approach in the AHPN seemed inconsistent with a sincere

attempt to deliver the required number of affordable homes.

At the time, I had considered that Practice Notes could constitute policy. Whether and to what

extent Practice Notes are deemed to have changed planning policy is likely a matter for the courts to

decide. The view of Joanne Mansfield, from Bristol City Council’s legal services, as expressed in the

Council’s response to a pre-action protocol letter indicating the intent of CHIS to commence

proceedings to quash the initial application, was as follows:

‘There can be no obligation for a development to comply with advice in a non-statutory

document that cannot set out any policies.’

It would follow from this that no new policies can be set out in the Affordable Homes Practice Note,

and that the Core Strategy policies would remain the locally relevant ones. We note, however, that

the Council appears to have accepted (and apparently, adjudicated upon) applications as though the

Affordable Homes Practice Note constituted policy. The question has to be raised as to whether – if

the view of the Council’s own legal services is correct - the Council is acting lawfully in adjudicating

on applications in such a manner.

BCS17 in the Core Strategy states:

Affordable housing will be required in residential developments of 15 dwellings or more. The

following percentage targets will be sought through negotiation:

• 40% in North West, Inner West and Inner East Bristol;

• 30% in all other locations

It would be extremely difficult, in the circumstances, to argue that 20% affordable homes is the

outcome that would have resulted under the extant policy BCS17. If that is not the case, then it

would be reasonable to argue that the AHPN had materially influenced the policy in exactly the

manner that the Council’s own legal services claims it cannot do.

There is a general understanding (it is a matter of public record) that the applicant seeks to sell the

land to generate revenue in support of its objectives. It is not the role of the Council’s planning

function, or the development control committee, to facilitate the achievement of a higher value for

land than might otherwise be the case. In the context, therefore, and recognizing that there is likely

to be sufficient residual value in the land value to justify a higher proportion of affordable homes,

then if consent were given to the proposal, it would be difficult to argue that the AHPN had not

given rise to a material change in the application of the extant policy on affordable homes, BCS17.

The 20% affordable homes offered by the applicant a) is inadequate, and b) has been arrived at in a

manner that is inconsistent with the application of BCS17. To the extent that the AHPN has

effectively set a threshold that is not consistent with the proper application of BCS17, then I would

suggest that effect has been given to the AHPN which is not lawful. Effectively, the AHPN has done

what the Council’s legal services says it cannot do.

Concluding Remarks

It would be tempting to believe that with a decision having been made previously in favour of the

applicant, and with the decision being quashed as a result of what the Council clearly views as a

procedural matter, that remaking the same decision on the basis of an amended officer report

would address the shortcomings of the previous decision. For the reasons set out above, I believe

this would be a mistake. We have had time to consider the ramifications of a revised NPPF (the

revision was published after I had drafted my previous submission, and I cited the 2019 version), we

have also seen the Government’s Net Zero Strategy, and Government has issued a policy document

responding to the Select Committee Inquiry into Local government and the path to net zero.43

The revised National Planning Policy Framework published in 2021 contains, through its reference to

the National Design Guide and National Model Design Code, important new provisions around the

design of development. Para 134 is clear:

Development that is not well designed should be refused, especially where it fails to reflect

local design policies and government guidance on design52, taking into account any local

design guidance and supplementary planning documents such as design guides and codes.

The footnote 52 cited in the above extract indicates that government guidance on design is

contained in the National Design Guide and National Model Design Code.

A recent study commissioned by the Place Alliance has highlighted the myths that have prevailed

among Council officers and decision makers:44

For decades local planning authorities up and down the country have been reluctant to

refuse poorly designed residential and other developments on design grounds. Six

perceptions have underpinned this reluctance:

1. Design is too subjective – design has been seen by many as too subjective, potentially

opening up planning judgements to challenge.

2. Quantity not quality is prioritised – in the past government guidance has prioritised other

factors over design quality, most notably housing supply.

3. Housebuilders are too formidable – pragmatically some authorities have taken the

approach that it is better to negotiate and accept what you can get, rather than refuse

schemes, given that housebuilders will eventually wear them down and get their own way.

4. Good design takes too long – some believe that negotiation on design takes too much

time, time which already stretched planning officers don’t have.

5. Design is an afterthought – practices of determining the principle of development (in an

outline application) prior to determining how schemes will be delivered in design terms (in

reserved matters) undermine design-based arguments from the start.

6. Costs will be awarded – for all the reasons above, cash strapped local planning authorities

worry that refusing on design will open them up to costs being awarded against them at

appeal.

It indicates how misplaced these myths now are, if indeed they ever held any weight. It encourages

decision makers to stand up against poor-quality residential design:

Drawing on recent planning appeals data, this report reveals that none of these perceptions

are any longer true (some never were).

43 Department for Levelling-up Housing and Communities (2022) Policy paper: Local government and the path to net zero: government response to the Select Committee report, 13th January 2022. 44 Matthew Carmona and Valentina Giordano (2022) Appealing Design: The evidence of planning appeals and the need to reject poor and mediocre housing design, Report for the Place Alliance, April 2022.

The National Planning Policy Framework (NPPF) was revised on July 20th 2021, and since

then has unequivocally stated: “Development that is not well designed should be refused”

(para. 134). The message to all local planning authorities is therefore that they should have

the courage of their convictions and stand up against poor quality residential design

wherever it is found.

Examining a representative sample of thirty-two design related ‘major’ planning appeals

from 2021, it is apparent that a marked shift in the likelihood of local authorities successfully

defending design-based appeals has occurred.

This shift is clearly apparent in the arguments used by Inspectors who, on the face of it, seem

to have been liberated to consider design on equal terms with other factors. In doing so they

regularly reference the changed policy position in the NPPF, as well as guidance in both the

National Design Guide and National Model Design Code.

Comparing the decisions after July 20th 2021 to those before, the odds in favour of local

planning authorities winning cases on design grounds have shifted from just 5:7 (against) to

13:7 (in favour). In other words, previously there were more losses than wins (for local

authorities), and now there are close to two times more wins than losses.

Where applications are characterized by poor design, and where they fail to reflect the guidance in

both the National Design Guide and National Model Design Code, then Councillors should make

lawful decisions and reject such applications.

In the case of the specific application, I have drawn specific attention to the climate change

performance of the proposed development. I have referred to both the operational carbon

emissions from the proposal, which are also the subject of the Council’s own policy, BCS14, and the

embodied carbon associated with the proposal. Both are included as aspects of well-designed

development in the National Design Guide and the Guidance accompanying the National Model

Design Code, and the current proposal fails to address them.

The proposal fails even to meet the far from challenging residual carbon dioxide emissions target

within BCS 14, confirming just how poor this application is, and how distant it is from the aspiration

of the NPPF to ensure that plans and planning decisions are consistent with the Climate Change Act,

as well as the Net Zero Strategy, published since the application was previously considered, which

effectively ‘banks’ the expected effect of decisions taken by planning authorities to ensure that

development is well designed.

I also consider the affordable homes issue to have been dealt with in a manner inconsistent with

BCS17, and in a manner that suggests that the Affordable Housing Practice Note has acquired a

status of establishing a new policy, something which is not consistent with the view of the Council’s

own legal services.

Finally, other matters – some linked to matters raised in my previous objection - should be

considered in respect of the quality of the design of this proposal. I believe that the proposal fails on

multiple fronts in this regard, and should therefore be rejected.

Dear sirs

I object to the plans for developing the above site. I do not believe that the council determining the application while not altering their plans will satisfy the views of Historic England with regards to this site.

Historic England stated " the proposed layout , massing and design fails to respond to the character and appearance of the Conservation Area." The council reconsidering the same plans does not satisfy this concern. Seeking consent for an unchanged Application demonstrates a degree of contempt for both Historic Englands arguments and also local residents who raised the same concerns .

The financial needs of the zoo appear to be the only concern of the Council and Councillors. The financial needs of any institution are never a relevant issue in determining a planning application. Why then did a planning officer make it clear to residents that he was under severe pressure from the zoo. Should this planning officer be considered unfit to determine as Financial considerations are not lawful in terms of determining an Application?

I do not believe environmental considerations have been accurately reported by the zoo. Far from the homes being sustainable , the planned housing fails to even meet the councils BCS14 policy. Furthermore the houses are of a construction that does not meet the required standard to satisfy RIBA and uk Green Building council .

I ask that the above points are all taken into consideration. The Conservation of Clifton is important. We do not want a site that people look back at in 10 years time and say "

how on earth was that allowed to be built ".

Yours sincerely

Sarah kenny

Dear SirsApplication no 21/01999/F Bristol Zoo West Car ParkI am writing to support the planning application in respect of the development proposed for theWest Car Park at Bristol Zoo. I am a trustee of the Zoological Society but am also a long-timeresident of Bristol, having lived here since 1975. I know the area around Bristol Zoo Gardens welland my comments in support of the application reflect my familiarity with the site and the areasurrounding it.I believe the following factors are supportive of the planning application:- The proposed development on a site, which will no longer be needed for parking once the Zoomoves represents an optimum use of a brownfield site, which are rarely available in Clifton.- Considerable effort has been made to design much needed fresh and energy efficient housing ina popular area of the city. In particular, care has been taken to ensure that the height of thedevelopment is not excessive and blends in with its surroundings.- The development will be a valuable contribution to the city's social housing and will help meet thehigh demand for housing in the area.- The density of the development is well within planning requirements and a reduction in densitywould represent an inefficient use of the site and a waste of a prime location.- There is a balanced provision of parking and bicycle storage in the development.- The closure of the zoo will mean that traffic movements around the area will be considerablyreduced even after the development has been completed.- The surrounding area has a large number of Victorian and late Georgian buildings, with manymature trees. However, this development is not removing any of these features from the area, noolder buildings are being demolished and thus in my view, there will be little adverse impact on thecharacter of the area.

Yours faithfully

Andrew Martyn-Johns

I have already supported the original application but wanted to reiterate my support nowit has been resubmitted. I am a Trustee of Bristol Zoological Society but also a near neighbour.The proposed scheme provides much needed housing in Clifton, and is a responsible andappropriate use of the existing brownfield site. Smaller sized units will be particularly welcome asaccommodation of that size is in very short supply in the area and the lack of it is inhibitingdownsizing. The proceeds of sale of the site will be utilised in pursuing the Society's charitableobjectives. I believe that the proposed scheme achieves a balance between maximising theproceeds and providing a scheme which is sympathetic to its setting.

The Clifton and Hotwells Improvement Society reiterates in the strongest possible terms its opposition to this inappropriate and damaging set of proposals. CHIS is also more than surprised that, in the light of the views of English Heritage and CAP, the Application has not been amended before being re-submitted.

The following points are of particular importance in assessing the proposals :

1. The scheme constitutes over-intensive development. In the words of Historic England, 'the proposed layout, massing and design fails to respond to the character and appearance of the Conservation Area'.

2. A high proportion of the homes have only a single aspect. There is no daylight in some corridors. Far too many have no access to private open space. There is nowhere for children to play.

3. The buildings are too high, especially those proposed on College Road, and are out of keeping with surrounding buildings. As Historic England puts it, '(the) robust rhythm of weighty Victorian villas, constructed predominantly from dressed rubble and Bath stone detailing, is certainly the overriding built form and the concept of a terraced approach of this scale alongside the existing short terrace is of considerable concern'.The poor design and over-massing would damage the setting of surrounding buildings.

4. A significant number of mature trees would be lost.

In sum, the proposals fail altogether to preserve or enhance the character of the

Conservation Area. In fact, they would do the opposite and cause significant harm.

It is also relevant to point out that the housing is of such construction that the embodied energy and greenhouse gas emissions will be far in excess of what is targeted by bodies such as the RIBA and the UK Green Building Council. Giving consent to housing of this nature is not consistent with the Council's own declaration of a climate emergency.

Chris Jefferies, on behalf of the Clifton and Hotwells Improvement Society.

I have previously objected to this application and my objection stands for thisreapplication:I reinforce my previous objections to a development that is too dense, too tall and out of keeping inan area of such historic importance, with scant regard for safeguarding the ecology of the area.The lack of foresight in the plans for the car parking for this development and the impact this willhave on the surrounding residential roads which are already congested with parking. Also the exitsfrom the Development onto the surrounding roads which constitute a real hazard for the pupils andteachers of the neighbouring primary and senior school who cross the roads at all times of the dayand the increased likelihood of potential accidents.

Greed, arrogance and showing contempt for their neighbours is the only way todescribe Bristol Zoo's decision to resubmit, unchanged, their previous application despitehundreds of objections and the Judicial Review process. I am aghast that no attempt has beenmade to address the issues of adherence to good Conservation Area and environmental practiceraised by the letter from Leigh Day as part of the Review.I reinforce my previous objections to a development that is too dense, too tall and out of keeping inan area of such historic importance, with scant regard for safeguarding the ecology of the area.

The zoo has made it abundantly clear to the Council that they are desperate for money. This is noreason to grant planning permission, indeed, it would be illegal. I sincerely hope that the Counciland all Councillors reflect on their duty to all of us and this very special, irreplaceable environmentwhen considering this application and are not pursuaded by the Zoo's economic woes.

I believe this application has been resubmitted without amendment by the Zoo andtherefore my previous comments still stand. I now provide further comment.The Zoo states that it fully consulted with and took into consideration the views of local residents inits application yet it is the residents that initiated the Judicial Review.

I also find it astonishing that the Zoo's finances appear to have some sway with the Council andCouncillors. This should never be relevant to determining any Planning Application. Further theZoo mistakenly states that as a charity it is required to obtain the highest possible price for thisredevelopment. As a Trustee on a grant making CIO, I know this not to be the case and perhapsthe Zoo should refer itself to the Charity Commission for clarification.

On the subject of Affordable Housing one can assume that no Affordable Housing Survey wasundertaken as this would have shown that one bedroom flats are not in great demand in Cliftonbut there is a greater need for family houses.

I believe the planning committee should reject this application and ask the Zoo to rethink its plansand put forward a new plan taking into account Clifton's heritage and the views of its residents.

I note the the above application is being reconsidered by the council. My original objections stand and I have the following additional comments:

1. The fact that the Zoo has not reassessed the application but is plowing on regardless I find extraordinary. This suggests a degree of arrogance on the Zoo's behalf that the views of residents and neighbours are irrelevant to them.

2. The Zoo has claimed that the application demonstrates "high environmental and sustainable standards". This is simply untrue as others have pointed out, and as evidenced by the applicant's astonishing rejection of the need for solar PV.

Kind RegardsChris

This is a copy of the email sent Development Management on 5 July 2022. We have yetto have a response though we are pleased to see that the earlier comments have now beenreactivated.

"Dear Development Management,

Given that this application will now be reconsidered afresh, please advise if the applicant nowintends now to submit the biodiversity survey and report (together with a Biodiversity Metric 3.1Calculation) that is required in order to comply with part three of the under Planning ApplicationRequirements Local List May 2022 (given that it failed to do in its original application) whichrequires this evidence to be adduced for all developments in or adjacent to:A Special Area of Conservation - The Avon Gorge and Leigh WoodsA Site of Special Scientific Interest (SSSI) - The Avon Gorge and Leigh WoodsSite of Nature Conservation Interest (SNCI) - Clifton and Durdham DownsA Wildlife CorridorA Regionally Important Geological Sites (RIGS) - the Avon Gorge

Can you please also ensure that all the 474 public comments previously published on the planningportal are made publicly available again."

The Bristol Tree Forum14 July 2022.

I believe that the plans for this development have been resubmitted following a judicialreview. My comments for the initial application still stand as I can see no real attempt to addressconcerns.

I attended the meeting at which the original application was voted on. It was the first time I hadever done so and I was surprised that partisan politics for some seemed to override the actualplans being submitted. I was equally surprised that comments were made encouraging the panelto support the application as a thank you to the zoo rather than considering the actual buildingsbeing proposed. I hope that this time the actual merits of the application and its impact on the localcommunity will be considered.

In addition to my comments of the first application I want to add further concerns: the applicationfails to meet environmental considerations with regard to solar energy, fails to provide space forchildren to play, fails to conform to the aesthetic of the surrounding homes in this conservationarea and allows greed to win over common sense. The zoo has plans to create a new entrance onto College Road so why can't the car park entrance and exit be kept where they are at present.The proposal to create a new entrance/exit onto Cecil Road will cause unnecessary trafficproblems and risk. This road is often used by parents from the local school to drop off and pick uptheir children.

I remain bewildered that the buildings proposed have been designed in a manner that is so out ofkeeping with others in this conservation area.

I strongly object to the latest proposal to develop the land referred to as the former carpark.

I would refer you to the objection I previously submitted to the proposal, a proposal that was laterquashed by the High Court. I would like all my previous comments to be fully and properly lookedat, especially given that objections were not correctly considered on the previous occasion, hencethe decision being quashed.

I am deeply disappointed that given the decision by the High Court the Zoo has expressedcomplete contempt for local residents and is not even revising the application. Although the Zooclaims it consulted with residents, the judicial review was initiated as matters had not been dealtwith properly in granting the application. Seeking to continue with an unchanged application showscontempt for local people and the solid research, time and effort put into compiling a detailedheritage statement.

I am also concerned that the Zoo's finances have been mis-managed to the point that they aredesperate to get a planning application through, to the detriment of the local area and heritageassets. These are not relevant issues in determining a Planning Application, yet it was made clearby the Planning Officer to certain residents that he was under severe pressure from the Zoo. Muchof the original support for the Application was based on matters which are not ones which wouldbe lawful grounds for determination. It would appear that the financial needs of the Zoo seem to becolouring the views of the Council and Councillors.

Although the CEO of the Zoological Society has claimed that 'our plans demonstrate high

environmental and sustainable standards' this is simply untrue. Far from the homes beingsustainable, the energy performance of the planned housing fails to meet even the requirementsof the Council's Policy BCS 14 (we will be providing documentary evidence) which is in any eventoutdated.

The initial consideration of renewable energy technologies, such as solar PV, is not acceptablegiven not only the relevance of climate change but, just as important, and clearer now than ever,the affordability of energy. In an amendment sheet presented to the Development ControlCommittee the Applicant's sustainability consultants stated:

'Solar PV panels were considered (within sustainability/energy statement) but discounted for anumber of reasons notably efficiency/orientation, aesthetics and impact on Conservation Area.And also provision of sedum roof and ecological enhancements.'

The notion that efficiency/orientation would render the PV non-feasible is quite simply ridiculous inthe context we are discussing - the Applicant was free to determine the orientation of the roofs.

There are already PV panels installed on listed buildings in Clifton, whilst the supposed preferencefor sedum roof vis-à-vis PV not only suggests a conflict which does not exist but also runs counterto the existing policies of the Council. The statement is made all the more farcical given that theproposals for the main Zoo site now include solar PV panels. The consultants need to explain whywhat was not feasible for one site is deemed eminently feasible on the other.

Following on from the above, the housing is also of such construction that the embodied energyand greenhouse gas emissions (i.e. the energy generated, and greenhouse gas emitted,associated with the materials and construction process) will be far in excess of what is targeted bybodies such as the RIBA and the UK Green Building Council. These embodied emissionsdominate the greenhouse gas emissions associated with energy use in the operational phase.Giving consent to housing of this nature is not consistent with the Council's own declaration of aclimate emergency.

The site offers 20% affordable homes. This appears to reflect the approach set out in theAffordable Homes Practice Note. In the Council's response to the pre-action protocol letter fromLeigh Day regarding the granting of the now quashed Application the Council's legal option wasclear: that a Practice Note cannot change or establish policy. It is our view that this Application hasclearly been dealt with in ways which would not be considered appropriate under the existingPolicies in the Core Strategy. In effect, the Application assumes the very change of policy, via thePractice Note, that the Council's own legal opinion indicated cannot be achieved through thecontent of a Practice Note. It therefore fails to comply with the Council's own policies on affordablehomes.

This application has been re-opened because of the dogged efforts of a few people whorisked their own money challenging the council. The council is supposed to be representing theneeds of its citizens - but it seems more keen to align itself with the needs of developers. With thisapplication the zoo is seeking to maximise the value of its land sale and the builders are seekingto maximise their profit from the ensuing project. People like the area around the zoo because it isbeautiful - the council should be protecting and enhancing that beauty not undermining it byworking against its own citizens' interests.

It looks like the council wants to view the legal loss as a failure of process rather than a failure ofthe underlying plans. Again - what is the motivation for that? What has been proposed from thebeginning, even with a few minor tweaks, is a boring pastiche of high density. If it is granted theproject will no doubt then be developed to be minimally compliant with the UK's building standardsin order to maximise profit. If we must have something built (whether we do or not is a separatequestion) then let's have something that genuinely has design flair and build quality.

Finally, to wrap this whole project up as 'eco' or 'sustainable' is just cynical greenwashing.

I strongly object to this development as I consider it has been badly planned and it willsignificantly and negatively affect the existing community. While additional houses are needed inBristol, this development is poorly planned and will just create additional pressures negativelyaffect the quality of life of existing residents. As planned, the development includes a block of flatswhich will be at least two storeys higher than all of the other buildings on the same section of road,thus overshadowing all these buildings. At the same time, this area has a very specific character(with red/ brown bricks, cream stone, steeply pitched roofs and bay windows and the newdevelopment makes no attempt to complement the existing architectural character.

The new development proposes to include 62 dwellings but the site includes provision for roughlyhalf that number of cars. While it is possible that some householders do not own cars, it is alsopossible that some households own multiple cars. There is currently significant pressure on on-street car parking and this development will exacerbate rather than reduce that pressure.

The area at the corner of College Road and Cecil Road currently experiences significant flooding/extremely large puddles when it rains and I am concerned that the development of this site willadd to the existing floodwater/ sewage pressure.

The current access to the car park is via College Road, the proposed development will removethat existing access route and re-site it around the corner in Cecil Road. Cecil Road isconsiderably narrower than College Road and has a considerable amount of on-street parking andmoving the access route to the site onto Cecil Road will massively increase traffic pressure on thisquite, narrow road. I am also concerned as to how large lorries/ vans (for example delivery vans,bin lorries etc) will negotiate the tight turning - which is set one house back from the junction with

College Road, potentially causing backing up of traffic down College Road - of considerableconcern given the location near the site of a school where children and young people are regularlycrossing the road. Given the difficulty I witnessed the gardeners at the Zoo have in driving a largeride-on mower out of the access gate on Cecil Road, I cannot imagine drivers of cars or evenlarger vehicles will have any less difficulty in making that same turning.

The existing dwellings on the block of College Road where the development will be sited havevery narrow back gardens and the siting of the new access road means that the road will passwithin meters of these houses, which are all multiple occupation houses - meaning that this roadwill introduce noise and pollution right into the living or bedrooms of at least 12 householderswhereas the existing layout of the houses means that traffic disruption is currently either confinedto a side of the house with no windows or a side of the house which has considerably greaterdistance between the traffic and the house. In addition, the scale of the new development willmake the disruption caused by traffic much greater than it is currently. In addition to this, thelocation of a row of three storey mews houses on the site of what is a currently a one-two storeybuilding will significantly impact the light and views as well as significantly reducing my privacybecause these new houses will have a direct view into my bedroom.

I consider this new development to be poorly planned and intended to cram too many dwellingsinto too small a site with no appreciation for how the added traffic or the changed access route willnegatively affect the existing residents, not only in terms of amenity but also in terms of safety (bychanging the location of the access road to a tight, narrow turn too close to the junction withCollege Road) and health (by putting in the new access road right beside/ underneath people'sliving and sleeping spaces).

The objections and comments that I have made before on 21st July 2021 and 7thAugust 2021 still stand.According to the National Planning Policy Framework the West Car Park and the Zoo should beconsidered together as a 'Park'.NOTE: that the North Car Park is part of the Downs and thus protected from development.This site is in a conservation area with many listed heritage Georgian and Victorian buildings. Thecurrent poor design is totally out of keeping with the surrounding buildings.In particular block A is too high, long and massive. It looks like a military barracks. 62 dwellings istoo many and dense for the size of the area. There is insufficient parking planned, which will causehuge problems in view of the planned over 200 dwellings on the main Zoo site, where there isagain insufficient parking planned..Developments like this should not be just about maximizing profit.

Objection to the Zoo West Car Park development plans for the following reasons:- it's over intensive- it's out of keeping with the conservation area and existing historic buildings- the buildings are too tall- insufficient individual garden areas and/or a community 'town garden'- destruction of existing mature trees.

Any proposed development of the Zoo's West car park area needs to reflect the historic legacy ofthe Zoo Gardens, with a high proportion of green space, gardens and trees.

The revised development plan fails to preserve the character of Clifton's leafy green ambiance,historic buildings and Clifton's Conservation Area.

Dear Sir or Madam

I have read the details of your proposals for the redevelopment of the West Car Park site andmake the following comments:-

I believe that your proposed access from Cecil Road might cause congestion, safety issues, noiseand pollution.

65 homes and parking on the site is very high density and likely to give rise, amongst other things,to considerable on- street parking.

I am also concerned about the proposed 4.5 story height of Block A. If this is agreed by theplanners and continued for the further development, we in Northcote Road could find ourselveswith more noise and less privacy, light and sun if houses were to be built up to the boundary wall.

Clifton is a rare and beautiful village and we hope that the planning authority does nothing to spoilit.

Yours faithfully

Barry Ryder

We object for the following reasons1. Block A is too massive in height and length and the design is not sympathetic to the surroundingarchitecture. It will cause irreparable heritage harm2. Specifically, the height of Block A will block much light to the window of our first floor room atHardelot which faces the Block. The reduction in height by one level makes little difference. Theend of the block should be further reduced in height.3. The car parking provision is completely inadequate. Residents of the development will be forcedto park on the streets and with the building of 200 new residences on the main zoo site, theparking problem will be exacerbated.4. Given the the planning process for the car park and the main zoo site are now on more or lessthe same timeframe, it surely makes sense to consider the design and amenities such as parkingfor both proposals together.Tony and Jenny Dugdale

(1) If the Application were to be granted in its present form, there would be problems onaccount of insuffiicient provision for parking on site for the new residents. That would add topressure on theadjacent neighbourhood.(2) There would be additional pressure from tail backs on the A4176 down to The Portway.

I must reiterate my concerns and objection to this overblown scheme in the heart of aconservation area. I feel that the scale of this massive development overbears neighbouringheritage buildings. The large dwellings proposed but no relationship to neighbouring houses. Thisarea is more important than merely providing maximum commercial benefit to the developers. Iappreciate that this site will be developed with more dwellings, but please must be in keeping withthe scale and style of the neighbourhood. I feel the development as it stands will harm the areas oflocal heritage. It is both massive in style and densely populated. I hope this scheme isreconsidered on a more reasonable and appropriate scale. Developments like this should not bejust about maximising profit.

Our objections to the development are listed below

o The development is incongruous with a heritage site and too dense.o The land was originally covenanted for a garden area.o The style of architecture is completely inappropriate.o The privacy of neighbouring villas will be invaded and views obstructed.o Historic boundary walls will be demolished or damaged.o The density will impede traffic and increase congestion. o A large majority public opinion against the project in the previous application.o Lack of infrastructure in Clifton for increased population particularly for social housing residents.

In view of the judicial review against the previous procedures we would request that more consideration is given to residents objections. We look forward to your reply.

David and Ruth Slinn

As I have said before, 62 homes and only 40-odd parking spaces in Clifton is just notdoable. Every resident will have guests and even if they do not have a vehicle their guests might.There should be at least one parking space (off road) per residence.

The buildings on the plans I have seen open onto the pavement unlike the other homes in thestreet making the plans look out of character and somewhat brutal. The architectural style of theproposed buildings bear no resemblance to the Clifton architecture which is pleasing to the eyeand of a certain type. These planned buildings will stand out like a sore thumb and will not blend inwith their surroundings.

This project seems to me to be trying to cram far too many homes into a space that would bebetter suited to a smaller number with parking for all.

I trust the Planning Department can avoid accepting this application unless it is modified so that itblends in with Clifton's elegant style and accepts the need for off-street parking for all.

Thank you for your consideration.Geraldine Davies

As a neighbouring property within the area we are concerned that this developmentwould have a negative impact on our business due to increased demand for parking spaces. Theproposal does not include sufficient parking provision and therefore residents of the new dwellingswould likely park on the roads in the surrounding area. This would mean that our staff andstudents would likely not be able to find parking spaces while attending college.

I oppose the erection of 62 dwellings on the site of the car park as being too much infillfor the space, of no public benefit and would cause harm to the unique heritage of the area.Clifton is considered one of the finest suburbs in the UK and attracts tourism, this developmentwould run counter to these attributes and cause local traffic congestion.

This planning application is the same as that which was submitted in 2021. At that timethere were many predominantly opposing public comments which have been removed from thisreapplication.The proposed development of the West Car Park, College Road, raises the following points ofobjection:1. The erection of 62 dwellings on this site is too dense ( especially as it is now proposed to erect201 dwellings on the zoo site). Whilst it is necessary to increase much needed housing in Bristol,the density of population proposed for this site is out of keeping with this conservation area, andwill substantially damage its character.2. The access via Cecil Rd will result in congestion and pollution in Cecil Rd and College Fields.Inadequate on-site parking will result in congestion of surrounding roads.3. Block A is too big. Its height will dwarf adjacent properties, and reduce light, especially at 50College Road/Hardelot House, where the new block extends right up to the boundary wall.The massive design of this building is incompatible with the surrounding historic environment , andcombined with the proposed buildings on the College Rd side of the zoo site, will produce a'concrete canyon' effect in this attractive residential road, which might be more suited to a citycentre commercial development. The elevation is neither of a sensitive light modern design orfacsimile of other local styles.The preservation of this sensitive environment in a renowned attractive area of Bristol is ofparamount importance to residents and visitors to our City. The present proposals do not fulfillthese requirements.

I continue to support this well thought out application. I hope this important project canbe reconsidered for approval at the earliest opportunity.

Dear Sir,

I would like to object fully to this proposal on the following ground:

1) The density of this development is extraordinary and certainly not in keeping with the rest of thesurrounding dwellings.

2) The College road site in particular is overdeveloped. It seems the view has been to put as manydwellings as possible on the site with no regard to whether this is adequate or not for thesurrounding area. The design of this block is oppressive, sitting almost right on the street insteadof being set back.It looks like an ugly bunker which dwarves the neighbouring properties, being higher than they are.

3) The proposed design for the mews houses is even more atrocious than the block looking onCollege road. It is lazy and unimaginative, a generic set of cubes, using generic and inappropriatematerial which would be an eyesore for this conservation area.

4) The loss of a very significant number of mature trees is unacceptable and cannot be mitigatedby planting others.

5) Paragraph 197 Section 16 of the National Policy Framework states that plans should enhancethe significance of heritage assets. This proposal as it stands is completely inadequate from thatperspective and would be detrimental to this beautiful conservation area and to the neighbouringlisted buildings.

Dear Sirs,

We wish to bring to your attention the poor advice from the Bristol Planning Department for Councillors to accept their current recommendation to accept the proposed plans to develop the west car park No. 21/011999/F

The report summary and recommendations are out of proportion to that of local opposition to the scheme. Part of at least one listed property will inevitably be damaged should the scheme been accepted. The Planning Department have been informed and chosen to ignore this.

The Planning Department have also ignored the overall impact on the Conservation Area Item 1 9.14

Item 1 7.4 APPLICANTS response to comments from neighbours with adjoining properties was inadequate.

Item 1 7.4 Consultation was inadequate with no reported indication of the proportion of local descent and opposition.

Item 1 3.4 and 6.1The land of present car park was covenanted to the Zoo by owners of the villas in Clifton Down for the use of the Zoo solely for horticulture purposes. It has never been used for housing, industry or commerce. Its use as a car park was tolerated by planning only on condition of extra landscaping with trees, which are now to be felled.

The comments form HISTORIC ENGLAND Item 1 7.6 7.7 and 7.8 all of which have a negative impact on the proposal and do not advise support for the proposed scheme.

The comments from the CONSERVATION ADVISORY PANEL Item 1 7.8 concludes that the proposed scheme does not accord with NPPF and there are insufficient public benefits for the plans to be accepted.

Bristol waste are yet to receive adequate details but happy for further consultation.

Transport and Parking are further potential problems.

Item 7.12 The revised plan to set back buildings 1m in College Road considered to be inadequate June 24th 2021. But as yet not revised or changed.

We consider that even the revised proposals are unacceptable in every way. Hoping that integrity will outweigh political expediency, especially in the light of dubious assumptions made about drainage, heating, and ge convenience of the site in relation to transport in general, during construction and subsequently. We trust that all councillors will read the report in detail and refuse to accept the Planning Department's recommendation to give permission for such an unsuitable housing estate in Clifton.

In addition the local facilities are inadequate for social housing clients. ie Only one overcrowded primary school, no NHS dentist, already busy GP practice, no cut price super market in Clifton nearest Crow Lane!!!!!!

Thank you for your attention Ruth Slinn.

I would like to object in the strongest possible terms to this application to build acrowded housing complex on a unique and special site. Please, please use this opportunity tobuild something quite different considering the environment that we are all trying to improve andthe immediate environment that this appalling mass of housing will ruin. Can we have someimagination and real care shown to present and future residents.

Sir/madamI most definitely object to the proposed development plan of this site. Reasons are;Destruction of the old walls surrounding the site.No recycling of old materials.Lack of variety of use.(everything now turned to housing no matter what it was before hand ) Increasing traffic volume in a highly built up area. Increase of building in a sensitive area(the downs ) Over use of a site , too many dwellings . Lack of imagination in a unique "one off" opportunity to create something really innovative. Please refuse permission to anything that does not take any of the above into consideration. Susie k lincoln Clifton resident and Bristolian .

This won't be in keeping with any of the surrounding area, and is not sustainableenough. It's 2021 a lot more effort should be put into sustainability, this is purely being built forprofit above people and the planet.

Since our initial lodged objection, some very minor changes have been subjected by thedevelopers. In no way do they address our original objections concerning the monolithic frontageof the proposed flats facing College Road, their height, and the lack of any attempt to tie in orcompliment the surrounding architecture. The long frontage is unbroken unlike the currententrances to this area from College Road.No attempt is made to solve the inevitable lack of parking space or excessive density of theproposed dwellings.Like the nearby WHSmith development, it looks as though the development tactic is to makeminimal changes so that resistance by concerned parties is eventually worn down and a long termdevelopment, undesirable for Clifton and the city of Bristol, goes through.

As the Zoo's latest planning application is virtually the same as the original, with onlyminor changes, my original objection still stands.

Seriously this is just property developers looking to make as much money as possible by stickingup as many properties as possible in the centre of our city. This is so far from what the people ofBristol want or need!

21/01999/F: Former Car Park College Road Clifton Bristol BS8 3HXAmended Plans - Heritage Assessment

Further to our representations submitted yesterday, my wife and I have sought the advice ofGregory Beale of Planning Heritage who has provided the following critique of the proposedadjustments to the submitted application and I particular the Heritage Assessment Addendum.

'Reducing the roofline of one building, hipping a roof and retaining a boundary wall to the height ofc1m (it is currently approx. 2-2.5m high) does not constitute considered revisions to a scheme thatis blatantly seeking to maximise value rather than create sympathetic development which blendsand compliments the aesthetics of the locality.

In terms of the assessment of what constitutes harm, it is flawed: The scheme does not amount toimprovements to the current aesthetic of the Site, and its better integration into the local historicenvironment 'experience' .

The revisions to the design are minimal and focussed entirely upon the frontage to College Roadand avoids any modification or reduction in the density, scale or massing of development withinthe site. The 'adjustments' fail to take on board the fundamental concerns that the scheme raiseswith regard to the density, impact upon the setting of the Listed Buildings and the detriment to thecharacter and appearance of the Conservation Area.

The design of the College Road element is described as having been strongly influenced by theadjacent Victorian 40-48 College Road, whilst clearly identifiable as current, and not comprising

pastiche. This is a bold statement when the design bears no relationship to the existing terrace.The concern is that it

- Does not respect the mass or scale of the terrace;- Introduces elements such as full height windows, sedum roofs, cladding, balconies/verandasetc., none of which are seen on the terrace;- Is utilitarian and reflective of a standardised approach to apartment block development;- Fundamentally fails to respond to the context of the location.

The claim that the historic wall is being retained is derisory. The existing wall, which forms animportant visually strong feature on College Road, is to be reduced to a low plinth.

The Council recognise the importance and contribution of boundary walls to the character andappearance of boundary wall especially front walls within Conservation Areas and state in theirConservation Area Character Assessment that the demolition of traditional boundary walls andmeans of enclosure will be resisted: The proposed alterations to the wall will be detrimental to thecharacter of the Conservation Area and result in substantial harm to what is a non-designatedheritage asset.

On the matter of non-designated heritage assets, the addendum claims that the demolition of theformer coach house will result in enhancement of the site, failing to assess the importance of thisbuilding or indeed to the adjacent walls, and therefore does not state what level harm this may be.

The coach house is a building of significance revealing the historic association between the siteand the listed buildings on Clifton Down. It is a historic link to when the gardens of those propertiesextended across the site. The level of harm is substantial harm (NPPF 207).

In assessing the impact of the development upon views, the argument that the development willcause less than substantial harm is equally false. The proposed development will not 'channel'views but will in fact remove views in all directions;

- From Clifton Down towards the south and the villas on Cecil Road;- Across the site from College Fields and Cecil Road to the zoo and the pavilion.

These views, which allow for an understanding the open and verdant character of the conservationarea, will be lost.

In terms of the impact upon the setting of the listed buildings, the development will causesubstantial loss/harm. Setting is defined as the surrounding in which a heritage asset isexperienced. The setting may, as stated in the NPPF;

'make a positive or negative contribution to the significance of an asset, may affect the ability to

appreciate that significance or may be neutral. The significance is the value of a heritage asset tothis and future generations because of its heritage interest. That interest may be archaeological,architectural, artistic or historic. Significance derives not only from a heritage asset's physicalpresence, but also from its setting...'

The assessment carried out by the applicants heritage consultants;

- Fails to assess the impact of the change;- Focuses appears simply on a visual connection and an assessment of the proposal's impactupon it;- Set to one side the historic, social and economic connections between the site and the adjacenthomes and other properties;- Does not consider the historical factors which can be enough on their own to bring a site withinthe setting of a listed building, as is the case with the villas of Clifton Down: A visual connection isnot necessary in every case, although in this case there is a strong visual connection.

Although setting of a listed building is a concept recognised by statute, it is not statutorily defined,nor does it lend itself to precise definition (see R. (on the application of Williams) v Powys CountyCouncil [2017] EWCA Civ 427, at paragraphs 53 to 58).

However, implicit in section 66 of the Listed Buildings Act is that the setting of a listed building iscapable of being affected in some discernible way by development, whether within the setting oroutside it.

Identifying the extent of the setting for the purposes of a planning decision is a matter of fact andplanning judgment for the decision-maker. In this case, the application is clearly within the settingof the listed building, and it proposes the land that has a well-documented historic connection to allthe properties on Clifton Down.

In assessing the development an assessment must include other factors beyond the visual andphysical, including but not limited to, economic, social and historical. These other considerationsmay include for example, the historic relationship between places.

In this regard, the setting which the listed buildings on Clifton Down are experienced includes theapplication site with which there is a strong historical relationship. Equally, the site contributes tothe character and appearance of the conservation area and forms one part of the manyestablished open 'blocks' within the Character Area, all of which contribute to the special interestof the conservation area.

The impact upon the setting of the listed buildings it is not just the direct impact the developmentwill have upon views across the site, it is the impact upon the visual relationship between theapplication site and those heritage assets. It is accepted the setting of those listed buildings has

changed over time, albeit quite modestly, however the historical relationship has continued as aresult of the site remaining open and has not been intruded upon by inappropriate developmentwhich rises above the boundary walls that screen the car park and the former grounds of the listedbuildings.

In assessing the setting of the listed buildings, the area of former gardens contribute to thehistorical, cultural and visual understanding of that setting and establish the extent of theimmediate setting of the properties. In this regard, there would be substantial harm to the setting ofthe villas on Clifton Down from development within it.

The heritage statement fails to consider these issues and advocates the development will enhancethe appearance of the site. This is not the case. The proposed development will impinge upon anderode the setting of the listed buildings and comprise the character and appearance of theconservation area In this regard the level of harm must be viewed as substantial.

I conclude that the development will cause substantial harm to heritage assets, including bycausing harm the setting of the listed buildings, harm to the character of the Clifton ConservationArea and harm to the non listed heritage assets of the former rear garden wall of the listed Villasfronting College Road and the only remaining former coach house of the listed Villas.'

We had hoped that, following the submission of our previous representations the applicants wouldhave given full consideration to the impact of the proposed development upon the heritage assets.Unfortunately, this is not the case.

It is clear from the above that the applicants have not correctly assessed the impact of thedevelopment upon the heritage assets, wrongly concluding that the impact of development whichwould dominate the setting of listed buildings, block important views across the conservation area,fundamentally alter the character of the conservation area and result in the demolition of importantnon listed heritage assets, would either be of low significance, no significance at all or animprovement.

Gregory Beales critique of the submitted and amended Heritage Assessment, and his own view asa Heritage professional of considerable experience, is that the development will cause significantharm.

This leads to the conclusion that the application for planning permission should be refused due tothe significant harm development would cause to heritage assets.

Thank you for taking into account these further comments.

Kind regards,

Mr & Mrs Shalash

I have already made my objections to the previous planning proposal and your new one is not very different.

All my original reasons for objecting still stand and I am objecting once again.

Your plans are inappropriate to such a special area of Bristol. The site will be congested, there are still too many houses even though the number is slightly reduced, parking provision has not been thought about, mature trees will be a huge amenity loss as trees are so much a part of this beautiful area and the entrance next to our property which is on the corner of College and Cecil roads will be too close causing pollution of both air and sound. The entrance needs to be moved to give more space for turning and to avoid congestion dangerous to pedestrians as well as other road users.

This proposal needs a major re-think as it will severely damage the health both mental and physical of the present residents of this area and be an irreversible deterioration to the amenities of Bristol.

We had bought the garden flat in our building with a view to retiring there in due course. You are causing us to revise our plans which have been twenty years in the making. The effect on many peoples' lives will be devastating.

Patricia Cook

Please note my previous objections to the proposed housing development sill stand.

Maxine Leung

The alteration to reduce the proposed apartment block by one storey mitigates slightlythe overdevelopment of this site but does nothing to mitigate the other flaws of the development.There is no proposed alteration to the number of car parking spaces, still leaving the proposeddevelopment with an additionally huge number of cars in the area, adding to traffic and pollutionconcerns. Nor do the alterations change the proposed access road which will cause additional andsignificant pollution and noise directly underneath or beside the living quarters of most of thearea's existing residents - and this means the pollution from those fifty cars flowing into ourbedrooms and living rooms. Nor does it change the danger of the location of this proposed accessroute - there is insufficient clearance on Cecil Street and insufficient distance from the intersectionwith College Road, particularly in bad weather, to safely allow heavy traffic to turn into and out ofthis new access road safely and there is no concern over heavy traffic, rubbish collection ordelivery vans which will be significantly larger than normal domestic vehicles and which will still beusing this access route and its accompanying tight turn into the new site.Nor has there been any attempt to remedy the inequity in amenities (privacy, access to openspace etc) between both existing and new residents and between new residents. The zoo, as amajor conservation institution should be promoting a design that encourages ecological andconservation values. At the same time, the past year has shown us the importance of communityand access to open space and this development, as currently planned, shows that access to openspace is apparently a right based on income - only those who can afford a ground floor flat or oneof the houses on the site have the right to open space. By thinking differently, it could be possibleto change the layout of the site to include a communal garden, allowing both for ecologicalplanting, encouragement of small amphibians, reptiles and mammals that cannot beaccommodated in household gardens, but also providing much needing communal space thatcould encourage a sense of community between not only the new residents of the area but also

between new and existing residents, rather than enmity caused by the inequality promoted bythese designs and the sense of loss to existing residents of privacy, quiet and community to bereplaced by traffic and pollution and a poorly planned, insensitively designed residentialdevelopment.

This application is a very slight variation on the previous one and it remains completelyat odds with the local environment.It is high density housing out of sync with the local style and fails to preserve the character of theconservation area as required by Planning Policy and by Planning Law.The development facing onto College Road is higher than the existing properties and the groundfloor flats all face directly onto the road and the building is not set back from the road in keeping.There is inadequate parking associated with the development and will adversely impact thesurrounding area.I believe the development is totally unsuitable and will have a detrimental impact to theConservation Area.

Objections to the proposed scheme:The adjustments to the original scheme are insignificant.The proposal fails to preserve the character of the Conservation Area required by planning law.The buildings are too tall and are out of keeping with the surrounding buildings.Precious trees would be lost.Parking is inadequate.The scheme lacks the imagination needed for such an historic area of Bristol

Bristol Zoo's planned development of the West Car Park is detrimental to theConservation Area: it is over-intensive in breadth as well as in height, inappropriate in design andundermines the special quality of the surrounding architecture. Please reject this application.

I made a detailed objection when the first application was made and so I will not repeatit all here. The changes made are really very minor and do not address the key issues.

In particular I remain concerned about the high density of housing. I now have information kindlyprovided by CHIS which shows clearly that the density is way higher than most other areas inBristol let alone Clifton conservation area. The number of flats that would reflect current densitywould be about 28 so considerably less than half that suggested.

The area is said to be previously developed, this has only been latterly with a car park - nobuildings and the adjacent walls were untouched. Prior to that it was green houses and used forhorticulture. It is a not at all clear that it can be considered a brown field site in which case theargument for any sort of development starts from a very different place. Could the council pleasedemonstrate clearly how they have considered and resolved this issue.

Unfortunately the latest application still very much fails to protect the character of the conservationarea in layout , design and density of dwellings. It is my understanding that this is required by law.

There are successful examples in Clifton e.g. 46 and 48 Canygne Road which are of a scale andstyle that suits the area. This sort of approach would be much better and would seem to requirethe zoo and it's architects to go straight back to the drawing board and start again.

Unfortunately this development seems to be about squeezing the maximum number of smalldwellings into the area as possible with little regard for the future or existing residents of the area.

I am a supporter of the wider goals of the zoo , but unfortunately feel that the desire to raise fundshas blinded the trustees to the environmental damage they are attempting to create on their owndoorstep.

The applicant's recently submitted minor amendments make no real difference to thedesign or scale of this application. I continue to object most strongly to the application for the samereasons as previously:

1. Our property backs directly onto the development site and if the development was built, ourquality of life would be adversely affected. Our courtyard garden currently is very quiet, is notoverlooked and has clean air. The proposed new access road would run along the rear boundry ofour small garden, a few feet from where we sit in summer. Our outdoor space would be badlypolluted by the sound and exhaust fumes from the vehicles accessing and making deliveries to theproposed 65 dwellings. Furthermore, our privacy would be taken away as our garden and kitchenwould be overlooked from the upper units in Block B.

2. Considering the scheme as a whole, I consider that it constitutes over intensive development, isof very poor design and is not appropriate for such a special, sensitive and historic location.

3. The number of new dwellings proposed is excessive. 62 is too many for the site and thatnumber would generate traffic and parking issues for the neighbourhood. The parking provision onsite is wholly inadequate.

4. The proposed new access from Cecil Road is ill conceived. The existing access from CollegeRoad should be used to service the development as it is existing and has a good safety record.

5. All the buildings are too tall and Block A is an ugly block of flats without any architectural merit.It is completely incongruous to its surroundings.

6. The development would fail to preserve or enhance the character of the Conservation Area.

7. The proposed loss of 15 mature trees is unacceptable.

The applicant's recently submitted minor amendments make no real difference to thedesign or scale of this application. I continue to object most strongly to the application for the samereasons as previously:

1. Our property backs directly onto the development site and if the development was built, ourquality of life would be adversely affected. Our courtyard garden currently is very quiet, is notoverlooked and has clean air. The proposed new access road would run along the rear boundry ofour small garden, a few feet from where we sit in summer. Our outdoor space would be badlypolluted by the sound and exhaust fumes from the vehicles accessing and making deliveries to theproposed 65 dwellings. Furthermore, our privacy would be taken away as our garden and kitchenwould be overlooked from the upper units in Block B.

2. Considering the scheme as a whole, I consider that it constitutes over intensive development, isof very poor design and is not appropriate for such a special, sensitive and historic location.

3. The number of new dwellings proposed is excessive. 62 is too many for the site and thatnumber would generate traffic and parking issues for the neighbourhood. The parking provision onsite is wholly inadequate.

4. The proposed new access from Cecil Road is ill conceived. The existing access from CollegeRoad should be used to service the development as it is existing and has a good safety record.

5. All the buildings are too tall and Block A is an ugly block of flats without any architectural merit.It is completely incongruous to its surroundings.

6. The development would fail to preserve or enhance the character of the Conservation Area.

7. The proposed loss of 15 mature trees is unacceptable.

The applicant's recently submitted minor amendments make no real difference to thedesign or scale of this application. I continue to object most strongly to the application for the samereasons as previously:

1. Our property backs directly onto the development site and if the development was built, ourquality of life would be adversely affected. Our courtyard garden currently is very quiet, is notoverlooked and has clean air. The proposed new access road would run along the rear boundry ofour small garden, a few feet from where we sit in summer. Our outdoor space would be badlypolluted by the sound and exhaust fumes from the vehicles accessing and making deliveries to theproposed 65 dwellings. Furthermore, our privacy would be taken away as our garden and kitchenwould be overlooked from the upper units in Block B.

2. Considering the scheme as a whole, I consider that it constitutes over intensive development, isof very poor design and is not appropriate for such a special, sensitive and historic location.

3. The number of new dwellings proposed is excessive. 62 is too many for the site and thatnumber would generate traffic and parking issues for the neighbourhood. The parking provision onsite is wholly inadequate.

4. The proposed new access from Cecil Road is ill conceived. The existing access from CollegeRoad should be used to service the development as it is existing and has a good safety record.

5. All the buildings are too tall and Block A is an ugly block of flats without any architectural merit.It is completely incongruous to its surroundings.

6. The development would fail to preserve or enhance the character of the Conservation Area.

7. The proposed loss of 15 mature trees is unacceptable.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

The minor amendments the Zoo have made to their planning application areinsignificant and I continue to object to this planning application because:

1. Our currently peaceful small garden would be polluted by the noise and fumes from carspassing a few feet away from where we sit.

2. Our garden and rear living area would be overlooked by the occupiers of the upper floors inBlock B and our privacy lost.

3. The conservation area would not be preserved or enhanced by the over intensive developmentthat is proposed.

4. There are too many dwellings proposed for the site and the buildings are too tall.

5. There are not enough parking spaces within the scheme which will cause parking issues on theadjacent streets.

6. The overall design is poor and not appropriate for the area.

7. The access should be from College Road and not Cecil Road.

8. Block A on College Road is ugly, oversized and looks like a city centre block of flats.

9. 15 lovely trees would be lost

The minor amendments the Zoo have made to their planning application areinsignificant and I continue to object to this planning application because:

1. Our currently peaceful small garden would be polluted by the noise and fumes from carspassing a few feet away from where we sit.

2. Our garden and rear living area would be overlooked by the occupiers of the upper floors inBlock B and our privacy lost.

3. The conservation area would not be preserved or enhanced by the over intensive developmentthat is proposed.

4. There are too many dwellings proposed for the site and the buildings are too tall.

5. There are not enough parking spaces within the scheme which will cause parking issues on theadjacent streets.

6. The overall design is poor and not appropriate for the area.

7. The access should be from College Road and not Cecil Road.

8. Block A on College Road is ugly, oversized and looks like a city centre block of flats.

9. 15 lovely trees would be lost

The applicants have made a small concession in the amended application, generally inthe right direction. They probably cynically always intended to do this - since the originalapplication was ridiculously out of line with Clifton architecture and housing density.I object to the amended proposal since it is still incompatible with the architecture of thesurrounding conservation area, and far too densely housed to incorporate sympathetically. Thereare good examples of new residential buildings in the immediate area (e.g. 46/48 Canynge Road)which fit in without discord. I trust also that this application will not be looked upon favourablysimply because it is being made on behalf of the zoo.

I strongly object to this revised planning application, for much the same reasons as Iobjected to the original application. It seems to me an overdevelopment in a sensitive location, andin its scale and in its details completely out of character with the Clifton Conservation Area.

21/01999/F: Former Car Park College Road Clifton Bristol BS8 3HXAmended Plans

My wife and I have studied the amended plans submitted to the Council and wish to maintain ourobjection to the proposed development for the reasons set out in our previous submission dated2nd June 2021.

The amended plans seem to illustrate a very slight amendment to Block A, reducing a smallsection of the northern elevation fronting College Road to four rather than five storey height, andproposes the retention of stone piers forming a very small part of the historic rear garden wall ofthe listed Villas that still fronts onto College Road.

It is very disappointing to us and our neighbours that the tiny amendments proposed do notaddress our detailed representations one iota.

The Zoo seems to have again totally disregarded views from residents and have disregarded ormisrepresented the impact of the proposed development upon the heritage assets that are soimportant to the character of the conservation area, the setting of the listed buildings and thecharacter of this part of Clifton as a whole.

Beautiful Development instead of Carbuncles

The revised National Planning Policy Framework introduces the term 'beautiful', advising thatensuring beautiful well designed places is a social objective of sustainability. Paragraph 126

further advises that;

'126. The creation of high quality, beautiful and sustainable buildings and places is fundamental towhat the planning and development process should achieve. Good design is a key aspect ofsustainable development, creates better places in which to live and work and helps makedevelopment acceptable to communities.'

The development proposed is directly contrary to the above because it removes two beautiful andimportant heritage assets, being the historic wall fronting College Road and the former coachhouse within the site, and proposes to replace them with 3, 4 and 5 storey carbuncles: NPPF wasamended precisely to give Councils the power to stop such ugly and inappropriate development.

Heritage Addendum

We are concerned that the Heritage Statement has not been amended to take into account therepresentations we have made in relation to the importance of the heritage assets, the need toretain the former garden wall, the need to retain the former coach house and the need to respectthe setting of the listed buildings in design, scale and proximity of development.

We refer particularly to the revised assessment of affects; which presents a wholly inappropriateview of the impact upon the heritage assets. We are very concerned that;

1. The harm to the conservation area is assessed as being on the lower end of less thansubstantial: The fact that an area that has remained essentially open since first developed, usedeither as garden or car park throughout its history and offers important views of heritage assetsacross the conservation area is totally ignored. Blocking these views entirely by erecting amassive block that will be the tallest building in the area will have a significant impact;

2. The harm to the setting of the listed buildings is also assessed as being at the lower end of lessthan substantial harm. This is again not credible: The listed buildings are currently the largestbuildings in the vicinity that are identified as being important assets in the Conservation Areacharacter assessment but will in future be dominated by a massive block of flats and 3 storey townhouses in very close proximity to them. The City Council has previously concluded that a twostorey home far further from the heritage assets would cause substantial harm and can onlyconclude that the proposed development will cause even greater harm;

3. The harm to the non-heritage assets is also considered to be low or an enhancement: Themajority of the former rear garden wall fronting onto College Road is to be demolished as is theformer coach house. How can the impact of demolishing important heritage assets be describedas being a low impact or even enhancing the area? The impact will again be significant;

4. The assessment also concludes that erecting rather ugly and massive modern buildings that

show no respect to the character of the area or setting of the listed buildings in an improvement.The site cannot be seen from the surrounding area due to the beautiful high stone walls, with onlythe trees being visible, giving the public impression of an open setting garden as it has alwaysbeen. To describe the impact of replacing an open area with 5 storeys of development as being animprovement lacks credibility and illustrates that the Heritage Addendum should be disregarded inits entirety.

Harm Caused by the Development

We remain of the view that the proposed development will cause substantial harm and requestthat the Council refuses the above application for the following reasons;

1. Impact on Residential Amenity - Significant loss of privacy;2. Impact on Residential Amenity - Overbearing development;3. Impact on Residential Amenity - Harm to outlook;4. Scale of Development - Over intensive development;5. Proximity to Listed Buildings - Harm to setting of listed buildings;6. Highway Layout - Inappropriate form of development no respecting character of the area;7. Conservation Area - Significant harm to the character of the Clifton Conservation Area;8. Loss of Heritage Assets - Including former coach house and a massive section of wall that hasexisted since the area was first developed;9. Loss of Open Space - The loss of the open space across the site that contributes significantlytowards the character of the area;10. Quality of Design - The proposed buildings are far from being beautiful;11. Conflict with policies of the development plan and the Framework.

Conclusion

We again request the Authority refuses the application for planning permission for all of thereasons given above.

We also again confirm that we would not oppose an appropriate form and scale of developmentthat retains and protects heritage assets, protects views across, into and out of the site to thebenefit of the conservation area and does not harm the setting of the listed buildings, the characterof the conservation area or residential amenity.

We thank you for taking these views into account.

Kind Regards

I still object to this proposal, the revision does very little to address the totallyinappropriate nature of the development. The developers should be going back to the start todesign something that is suited to the area and the site.

The revised plans only pay lip service to the objections previously raised. Thedevelopment remains over intensive and totally out of character with the neighbourhood and theConservation Area principles. I do support the Zoo's conservation activities but expect them tosupport local conservation too !! I am sure here is a much more acceptable solution providing thedevelopment reduces it's intensity and takes note of the many objections from neighbours. It is nocoincidence that the vast majority of the supporters do not live in Clifton.

I repeat the same objections I made previously as follows:

Comment:I wish to strenuously object to this proposed development on the following grounds:

1. Not in keeping with the character of the surrounding buildings nor with the whole conservationarea.

2. The buildings are too tall.3. The development is significantly over-intensive4. There is inadequate amenity space5. Unnecessary loss of mature and attractive trees.6. Inadequate parking facilities

My Consulting rooms are in Clifton. I am frequently in the area of the planneddevelopment. Te new proposal makes no difference to my opinion.I object to the application proceeding for the following reasons.1. The area should be considered a park and not be used for development.. It is not developedland and is home to several mature trees that are irreplacable. In this era of Climate change, theCouncil should be making every endeavour to maintain all treesAND NOT BE PARTY TOFELLING TREES.2 The architecture of the proposed building is totally out of keeping with the area and will be astark contrast when anyone drives past. It will draw detrimental comment from any passerby.Tourists to Bristol will regard this as planning in poor taste. A modern building sticking out on thepavement will be such a hideous sight for the next century, if it lasts that long. The elegantarchitecture of the whole area will be dominated by this modern "clever" building.3. If the Council approve, they will leave behind an ugly legacy which history will severely criticise.

As very little appears to have changed in the revised plans, my original objection stands- as follows:

- The proposed buildings along College Road are too tall and the design is out of keeping withsurrounding buildings.- The inappropriate design and overbearing size would damage the settings of surrounding listedbuildings and other unlisted buildings of merit.- The proposed parking provision is inadequate. Most households will have 1-2 cars to park even ifthey walk, cycle or take public transport to work. The need for visitor parking and the pressure thatthis will put on the surrounding on street parking also needs to be acknowledged and addressed.The surrounding on street parking is at capacity at certain times of the day as it is, and with thefuture development of the main zoo site (and any possible parking pressures resulting from this)still to be decided, these proposals should not put any additional pressure on the local on streetparking.- The proposed vehicular access provided is totally inadequate. Having just a single entrance andexit would cause congestion at peak times of the day and cause issues for existing local residentstrying to use their driveways. Changes to the design of the proposed buildings along CollegeRoad, for example to keep the existing vehicular access there, could assist with this.- Amenity space and children's play space is lacking in the design.- It appears that 15 mature trees will be lost the proposals do not address the need to compensatefor this.- The proposals constitute over-intensive development in what is a Conservation Area and fail topreserve or enhance the character of the Conservation Area. It would seem that the sole aim ofthis application is to render this site as profitable as possible. It fails to have any regard

whatsoever for local amenity, surrounding residents, local architecture, the conservation area orthe environment generally. If this application is granted it would set a dangerous precedent for theredevelopment of the main zoo site.

As the revised plans seem to be very similar to the original, my original objection stands- as follows:

Comment:I object to the proposals on the basis that:- The buildings are incongruous with the adjacent listed buildings and the rest of the area, being aConservation Area.- The proposed flats along College Road are too tall and the design does not compliment thesurrounding buildings. The density of development is too great in comparison with the rest of thelocal area.- The proposed parking and vehicular access provisions are inadequate.- The mature trees need to be protected (I understand that when planning permission for the sitepreviously changed from garden to carpark, landscaping and tree planting were importantconditions).

Dear Mr Westbury

Please see my first objection to this Planning Application. My objections remain notwithstandingthe Zoo's very minor amendments to this wholly inappropriate scheme. It is quite clear that theZoo is not listening to the neighbourhood and is certainly not making any meaningful attempt tochange the proposed development into something appropriate for an important ConservationArea. These pathetic amendments only really illustrate how determined the Zoo is to foist an uglyoverdevelopment onto its neighbours.

The scheme represents over development, is poor quality in design and materials and whollyinappropriate for its location. I therefore rely on my previous objections since this amendment failsto address any of my concerns.

Caroline Stent

Please add my name and address to my submitted objection

Caroline StentWestfield House1 Cecil RoadCliftonBristol. Bs8 3hr

Objection regarding application no 21/01/1999/fZoo Former Car Park College Road Clifton Bristol

Regarding application number 21 01/1999/FZoo Former Car Park College Rd Clifton Bristol

Dear Mr Westbury

Regarding the Zoo's amended planning application for the car park site, I still object to theapplication. It is an insult to the local community in that the changes are so minor as to be of noconsequence. There has been no genuine attempt to improve the defective aspects ( of whichthere are many) and as a result there are no meaningful changes proposed. Therefore all mypreviously stated objections stand.

Despite the Zoo's claims to listen and engage with the neighbourhood, this grudging, minimalamendment simply serves to underline the contempt which the Zoo clearly feels for the area fromwhich it has profited over the years. The application is nothing more than a cynical exploitation of avaluable asset that belongs to the City and the people of Bristol - namely the Conservation Area.All the public relations guff in the world can't turn a substandard overdevelopment into somethingacceptable. The Zoo should be ashamed.

Please reject this scheme.

Stuart LawsonWestfield House1 Cecil RoadClifton BS8 3HR

As direct neighbours of Bristol Zoo, we continue to object to the proposed developmentof the West car park site in its revised form for the following main reasons:

Size and scale of Block A

Despite the small 'token' revisions to the plans submitted on 22 July 2021, the sheer scale of BlockA (in terms of both size and density) remains a significant concern for us as residents of 50College Road with the block to be constructed no more than 10-12 metres away from our property.Block A, even in its revised form, would still significantly dwarf all existing buildings at the northend of College Road and would set a worrying precedent for the development of the main zoo site.

The building design as currently proposed represents over-intensive development and would lookcompletely out of place in this leafy garden city area of Bristol, causing irreparable damage to thewider Clifton and Hotwells Conservation Area by leaving behind a legacy which local residents willhave to endure for many years to come. The Heritage Addendum prepared by CotswoldArchaeology notes that the development would represent an enhancement to the ConservationArea as it "includes improvements to the current aesthetic of the Site, and its better integration intothe local historic environment 'experience'." In reality, this statement couldn't be further from thetruth for those of us directly overlooking the West car park site as the construction of a poorlydesigned five storey apartment block metres from our property would quite simply have theopposite effect!

Furthermore, the updated Daylight and Sunlight Assessment undertaken by Hydrock continues toshow the detrimental impact that a building the size of Block A would have on the quality of life

and privacy of those residing at 50 College Road with all rooms showing a reduction in daylight /sunlight and two rooms continuing to be below recommended limits, even with the minoramendments to Block A which frankly are so minimal in the grand scheme of the overalldevelopment that they would almost be considered derisory.

Lack of parking provision

The revised plans also do not address any of the concerns raised by local residents in relation tothe lack of parking which is disappointing as the provision of 45 parking spaces for 62 residencesis insufficient and will put undue strain on the availability of parking in the vicinity of the site.

For the reasons stated above we therefore continue to strongly oppose the development of theWest car park site in its current form and urge you to reject the application on these grounds. Asstated in our previous objection, we are not adverse to tasteful development of the site howeverour view is that to achieve this, Block A would need to be significantly reduced in height andbroken up at street level to be more in keeping with the surrounding area.

The proposed buildings would not benefit the existing residents. There are too manyunits for such a small area. The parking isn't practical. The outside space proposed is far too smallfor the well being of the residents. It's not eco friendly and there's little if nothing to indicate anyfuture plans for the area for electric cars or solar energy. Basically this application is about profitand has no interest for the existing residents or future of Clifton Village. The only individuals tobenefit from this proposal are the developers and zoo shareholders. This proposal is about moneyonly and there's no consideration for residents present or future. It's very disappointing this caneven be proposed let alone built.

Commenter Type: Area resident

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Commenter Type: Area resident

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Commenter Type: Area resident

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Commenter Type: Area resident

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Commenter Type: Area resident

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

amenity, or the environment generally. It appears to be designed purely to reap the most profit from the piece of land.

j. Because this application may set a precedent for the development of the site of the main zoo, it is particularly important that this application is scrutinised carefully and the views of the public, especially local residents, are taken into account. The minor changes made in this revised application are an insult to the many local people who have objected and this application should be refused.

Dear Sir or Madam,I trust you will not mind this unconventional way of contacting you but I am currently on holiday.

I am concerned about the proposals to develop the West Zoo Car Park in Clifton. My main concern is the overintensive development, leading to increased traffic in College Road, Guthrie Road and the near surrounding streets where there are two schools. The traffic is already heavy, especially early mornings and late attentions. Parking provision would appear to be inadequate with frustrated residents attempting to park in adjoining streets, already full.

The character of the proposed structure would be too tall and out of keeping with the surrounding buildings.

The amenity spaces for the new residents would appear to be completely lacking. Perhaps more attention could be given to the provision of more green space including trees, shrubs and lawns.

I am mindful that Clfton is a unique suburb in the UK and indeed as some say the world. Our descendants would never forgive us if were to blight this precious corner.

Thank you for your valuable time and hope you will reject the proposal as it stands.

Yours faithfullyPaul Bartlett. M.A.

Dear sir/madam

I am writing to object to this proposed development for the following reasons. I live locally and this is my second letter of objection.

Having looked at the revised plans, I don't think these address the concerns I originally put forward which related to the loss of 15 mature trees, the woefully inadequate car-parking provision, the fact that the proposed development is out of harmony with the historic architecture of this conservation area and that the sheer size of this development will result in this area becoming very congested.

In relation to the revised plans, little effort has been made to reduce the height of the development and the extent to which this number of dwellings will still be squeezed into a very limited space. I'm now also concerned about what seems to be the loss of pavement. As I said previously, this road is well-used by local people and visitors to the Downs and I object very strongly to any suggestion that pedestrians may be being forced to use the road if pavements become crowded - as they can, particularly at weekend and when events are taking place on the Downs. With regard to street congestion, I still consider it essential for all 65 dwellings to have a parking space, rather than the proposed 45 spaces. In addition, I have also come to understand that this site cannot be considered to be previously developed land which I believe would question the legality of the zoo's application. I believe your department would be better placed to thoroughly scrutinise whether this is the case.

We are in a climate emergency and I very much regret the fact that current government policy has not kept abreast of this emergency and made appropriate adjustment to

ensure that planning applications, and all other new developments and initiatives, reflect the dangerous situation we face. I hope that whatever powers and discretion that your department and the council can exercise will be used to protect the future as the planet, as well as our local environment.

Kind regardsPamela Trevithick

Dear All

I live near the Zoo in Clifton. There is pressure on parking and road use in the area, and I think this will increase if more dwellings are crammed into the Zoo's old car park. I would be grateful if you would register this email as an objection to planning application no 21/01999/F.

Regards

Mrs Helen Blenkinsop

To whom it may concern:

I objected to the previous planning application for the redevelopment of the West Car Park on the grounds that the scheme seemed to me to be fundamentally flawed, and the very minor changes which the new application makes to the scheme are still not sufficient to make me think that this plan will be of any benefit to our area. My objection stands.

Dorinda Offord,

Hello,

I made an objection the the original plans submitted by Bristol Zoo for the redevelopment of the car park.

Please note that my previous objection to the Zoo's original planning application still stands, as the new application only makes minor changes to a scheme which is fundamentally flawed and is totally inappropriate for our Conservation Area.

Best wishes

Amie Copley

ensured that what could have been a zero carbon (or carbon negative) development falls well short

of that objective.

That alone is sufficient to ensure that the application is refused.

The proposal needs to be substantially re-worked – again (the revision has done nothing to address

this matter) - to ensure that principles which the CCSPN requires to be applied are firmly integrated

within the design process rather than as an afterthought.

Although this alone is sufficient for the decision to refuse planning permission, I note also the

following:

1. The need for the development is not demonstrated as the Core Strategy targets for housing

are already being exceeded;

2. It is not clear that this site should be considered ‘brownfield’ – it does not appear on the City

Council’s Brownfield Land register;

3. The application undermines its case in respect of affordable housing by seeking the

minimum provision (which the revised application actually falls short of). Bristol City Council

cannot achieve the targets in its existing Core Strategy as long as developers proceed in this

manner (which is also out of step with what is set out in the Draft Policies Document);

4. The original planning statement claimed 20% affordable homes in the development. The

revised application, however, includes 11 affordable apartments on a development of 55

apartments and 7 houses. The affordable dwellings quotient is, therefore, below the 20%

required (the figure is 18%) for any fast-tracking of the application;

5. The Planning Statement selectively cites Policy UL2 in the Draft Policies Document in seeking

to support a densification of development. A full reading of the same UL2 suggests that in

areas where the character of the locality demands it, reduced densities are “essential”.

There is a marginal change in density as a result of the revised application, but it is trivial

relative to the scale of the issue that the development raises. The objection on grounds of

excessive density of dwellings retains its validity;

6. The proposal – neither the initial one, nor the revision - makes any attempt to comply with

the requirements of DM16, and it makes no reference at all to DM 14, which relates to the

Health Impacts of Development. In particular, the following features give rise to concerns

regarding the health of would-be occupiers:

a. The absence of space for children to play even though it is not difficult to imagine

the development, as it is proposed, to house more than 50, and potentially, 60

children;

b. The fact that dwellings will be unable to ensure that noise levels are below those

recommended by the WHO at night because of a combination of the prevailing noise

levels (even before one considers those generated at the site itself) and the thermal

properties of the dwellings. In addition, a number of bedrooms appear to be

adjacent to 6 air-source heat pumps (ASHPs), exposing them (notwithstanding the

improvements in noise characteristics of ASHPs) to night-time noise;

7. As well as the effects on the health of would-be occupiers, the application fails to consider

the effect of noise emanating from the development itself, whether from the occupants’

vehicles, or their use of the balconies, or any other source. Only the ASHPs have been

considered as potential sources of noise which could affect existing residents. It is obvious

that the development will be a source of noise, and that the change in night-time noise (and

traffic) in particular (the car park is not generally occupied at night) has the potential to

affect existing residents;

8. Last, but by no means least, and consistent with the absence of space for play, and the

failure of design to integrate environmental features, the loss of sixteen trees from the site,

some of which are at the perimeter of the site and could have been accommodated in an

alternative, more sympathetic design, is disappointing given the stated objectives of the

applicant. There is no rationale given for the proposals to fell the trees (other than that this

is what would need to be done if the development is as proposed). The logic is that the

proposal necessitates the felling, rather than the proposal itself being influenced by the

presence of the existing trees. The revised application increases the number of replacements

proposed on site from 10 to 17. On the one hand, this confirms the nature of the previous

objection: with minimal change in design, seven additional trees magically appear in the site

plan. Nonetheless, no effort has been made to avoid felling and no effort has been made to

increase the number of trees planted on site to the level that Tree Replacement Policy

suggests should be provided on site where possible. The revision does nothing to silence the

questions regarding why it would have been impossible to design the development so that

the necessary number of replacements were integrated into the development (this would

have provided an incentive to cut down far only what was absolutely necessary). The

question of where any replacements will go remains.

This site was, before the initial application was made, one where a housing development could have

been designed in any which way: that it has the form it has is the result of placing undue emphasis

on the uplift in land value that will follow if the application is granted, and insufficient emphasis on

the environmental characteristics of the proposed development, and considerations for the health

of its occupiers and those who are resident nearby. It is completely out of character with the

location. It is not at all surprising that amidst all this, the minimal and tactical changes made in the

revised proposal have led to a reduction in the level of affordable housing to less than 20%.

Supposedly

These issues are of course linked, and they indicate the failure of the applicant to make these

linkages, which is what quality design would be expected to do. The absence of space to play is a

direct consequence of the excessive density of development relative to the character of the location.

Similarly, the request to feel large numbers of trees, and the failure to deliver the expected number

of replacement trees also reflect this excessive density. The bizarre failure to come forward with a

zero-carbon, or carbon-negative (at least in operational terms) development is unfathomable – this

was a site where all things were possible. If it is not possible to develop zero carbon homes at such a

site, then where should it ever happen?

It is interesting to reflect on the issues which the Planning Statement raised as ones that remained

to be addressed by the application following pre-application discussions. It is entirely debatable that

any of these has been achieved with the possible exception of the reduction in height. That is not

sufficient to merit consent for this proposal.

More detail is offered below.

DETAILED SUBMISSION

I make reference to the following documents:

City Council Documents

Bristol City Council (2011) Bristol Development Framework: Core Strategy, Adopted June 2011.

I refer to this as The Core Strategy

Bristol City Council (2020) Bristol Residential Development Survey 2020, u.d..

I refer to this as The RDS

Bristol City Council (2014) Site Allocations and Development Management Policies: Local Plan,

Adopted July 2014.

I refer to this as the SADMP,

Bristol City Council (2019|) Bristol Local Plan Review: Draft Policies and Development Allocations –

Consultation, March 2019

https://www.bristol.gov.uk/documents/20182/34536/Local+Plan+Review+-

+Draft+Policies+and+Development+Allocations+-+Web.pdf/2077eef6-c9ae-3582-e921-

b5d846762645

I refer to this as the Draft Policies and Development Allocations, or Draft DPDA

Bristol City Council (2018) Affordable Housing: Practice Note, April 2018

I refer to this as Affordable Housing Practice Note, or AHPN.

Bristol City Council (2020) Climate Change and Sustainability: How to design low carbon and resilient

developments: Practice Note, July 2020

I refer to this as the Climate Change and Sustainability Practice Note or CCSPN

Bristol City Council (2020) Bristol: One City Climate Strategy: A Strategy for a Carbon Neutral, Climate

Resilient Bristol by 2030, https://www.bristolonecity.com/wp-content/uploads/2020/02/one-city-

climate-strategy.pdf

Documents Submitted by the Applicant

Barton Wilmore (2021) Proposed Site Plan, Revised Plan, published 22 July 2021.

I refer to this as the ‘the revised Site Plan’.

Barton Wilmore (2021) Schedule of Accommodation, Revised Plan, published 22 July 2021.

I refer to this as the ‘the revised Schedule of Accommodation’.

Barton Willmore (2021) Planning Statement: West Car Park of Bristol Zoo Gardens, College Road,

Clifton, Report on behalf of Bristol, Clifton & West of England Zoological Society, March 2021.

I refer to this as ‘the Planning Statement’.

PEP (2021) Proposed Residential Development: Bristol Zoo Garden’s West Car Park, College Road,

Clifton, Bristol. Transport Statement for Submission, Prepared for Bristol Zoological Society. March

2020

I refer to this as the Transport Statement.

Hydrock (2021) West Car Park, Bristol Zoo: Planning Noise Assessment Report For Bristol Zoo

Gardens, 26 March 2021

I refer to this as the Noise Assessment

Hydrock (2021) Bristol Zoo - West Car Park: Energy and Sustainability Statement for Bristol Zoo, 18

March 2021

I refer to this as the Energy and Sustainability Assessment

Silverback Arboricultural Consultancy Ltd (2021) West Car Park, Bristol Zoo: Arboricultural Report,

March 2021.

I refer to this as the Arboricultural Report

West of England Joint Spatial Plan

West of England Joint Spatial Plan, Publication Document, November 2017,

https://www.bristol.ac.uk/media-

library/sites/estates/documents/West_of_England_Joint_Spatial_Plan__Publication_Document_201

7%20(5).pdf

I refer to this as the Joint Spatial Plan (or JSP)

Central Government Documents

Ministry of Housing, Communities and Local Government (2019) National Planning Policy

Framework, February 2019,

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file

/810197/NPPF_Feb_2019_revised.pdf

I refer to this as the NPPF

BEIS (2019) Valuation Of Energy Use And Greenhouse Gas: Supplementary Guidance to the HM

Treasury Green Book on Appraisal and Evaluation in Central Government, April 2019,

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file

/794737/valuation-of-energy-use-and-greenhouse-gas-emissions-for-appraisal-2018.pdf

as well as associated data tables, downloadable from

https://www.gov.uk/government/publications/valuation-of-energy-use-and-greenhouse-gas-

emissions-for-appraisal

Others

Charity Commission for England and Wales (u.d.) Guidance: The essential trustee: what you need to

know, what you need to do,

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file

/866947/CC3_feb20.pdf

I refer to this as The Charity Commission Guidance

ANC and the Institute of Acoustics (2020) Acoustics Ventilation And Overheating: Residential Design

Guide, January 2020.

I refer to this as the AVO Guide

Energy and Sustainability

Energy

The Energy and Sustainability Assessment makes nods in the direction of sustainability but they are

perfunctory ones. Evidently, this is not helped by the fact that the proposed 2019 Plan has not been

adopted, and that as a result, the Energy and Sustainability Statement still makes reference to the

policies in the 2011 Bristol Core Strategy, albeit that it also references the Practice Note of July 2020

on Climate Change and Sustainability: How to Design Low Carbon and Resilient Developments. That

Bristol City Council’s latest adopted plan dates from 2011 is a matter of concern, not least given that

during the intervening years, the UK has signed up to the Paris Agreement, a legally binding

international treaty on climate change, and the Council itself has declared climate and ecological

emergencies, and has committed, in the One City Plan, to becoming carbon neutral and climate

resilient by 2030. It must surely be only a matter of time before local plans are challenged in respect

of their coherence with commits made under the Paris Agreement (let alone those which may be

made at the upcoming COP26). That this proposal has been submitted on behalf of an entity that

claims to have such matters at its core is lamentable: indeed, one has to question the sincerity of

those commitments.

Notwithstanding these points, the Climate Change and Sustainability Practice Note (CCSPN) indicates

that:

The following key principles apply to all Sustainability Statements:

1. Sustainability Statements should address both mitigation and adaptation as set out under

policy BCS13.

2. Sustainability Statements should engage with and address the energy requirements of

policy BCS14, the water management requirements of policy BCS16 and each of the key

issues listed in policy BCS15.

3. In respect of each of these issues, Sustainability Statements should set out what possible

measures have been explored, which measures have been adopted and integrated into the

design and, where relevant, why it was not feasible to incorporate certain measures into the

proposed development.

4. A failure to convincingly address each of these issues will result in a refusal of planning

permission.

5. If it is argued that including sufficient measures to meet the energy requirements of policy

BCS14 would render the development unviable, then the applicant will be required to submit

a full viability assessment.

The Energy and Sustainability Assessment claims that:

All guidelines [in the aforementioned Practice Note] throughout this document have been

adhered to in the production of this energy and sustainability strategy.

Whilst the Energy and Sustainability Assessment does indeed cover some of these matters, it does

so mainly in a perfunctory manner. The plans to make use of heat pumps are welcome, and lower U-

value materials as well, although the detail of how the demand will be matched by the supply from

the six heat pumps illustrated in the Plan in Block B of the development are not apparent (there is

zero transparency in the way the calculations have been made in respect of the climate change

performance of the different measures being proposed, not to mention, the baseline position – no

one could adjudicate sensibly on these figures as they have been presented currently). The effect of

the configuration on generation of noise for future occupants is also of concern (see above).

There is no provision made for any on-site generation of renewable electricity. This is because point

3 in the extract above from the CCSPN has not been adhered to. There is no reasonable exploration

of measures which could be adopted, let alone any rational argument as to why, for example, it

would have been unreasonable for rooftop PV to be in place in the development. Both solar thermal

and solar PV move from having potential, as per p.13 of the Energy and Sustainability Statement, to

being dismissed in the proposals. Table 7 in the Energy and Sustainability Assessment – the header

for which states that it has been taken from the CCSPN – as well as the supporting text, speak only in

general terms about how ‘consideration of conservation would need to be taken into account’, and

‘the benefit of solar thermal panels would need to be considered against impact to the local

Conservation Area and sedum roofs’.2 These are not justifications (let alone, adequate ones) for

overlooking the potential of solar PV. There are solar PV panels already on properties in Clifton in

Conservation Areas, several in close proximity to the site. Also, there is some evidence to suggest, in

respect of green rooves, that these can help improve output from solar PV because of their cooling

effect: furthermore, shaded areas might actually enhance the diversity of microclimates for wildlife.

The points made do not demonstrate why these are not viable options for inclusion in this proposed

development, which is what the CCSPN not only requires, but which, if absent, it clearly states that

the application will be refused. It follows that this application must be refused. Had this matter been

properly considered, the development itself might look rather different, for example, in respect of

orientation of the rooves. There is no reason why the provision of on-site renewable electricity is not

viable, and none has been given.

It is worth considering the overall impact of the proposed development in the light of our

understanding of the urgency with which action is required on climate change. If one reviews the

figures in the Energy and Sustainability Assessment, unsupported as they are by any evidence that

enables us to drill into the detail of the heat and electricity demand in the baseline, and with the

measures proposed in place, then one sees that using the SAP 2012 figures (see Table 1 in the

Energy and Sustainability Assessment), where the carbon intensity of electricity is relatively high, the

proposed measures associated with the proposal deliver a 33% reduction relative to residual

emissions. Note that these residual emissions are relatively high because the energy efficiency

measures are somewhat limited, notwithstanding the intent to use materials with a lower U-value

than under Part L of the Building Regulations – the measures achieve a 5% improvement relative to

what is required to comply with Building Regulations. The Energy and Sustainability Assessment does

not actually report how this Figure has been calculated other than through referencing U-values. No

materials are actually mentioned, the U-values are simply stated, with no reference to what it is that

delivers those lower U-values, and hence, what fabric is to be used. This is despite the fact that the

CCSPN is very clear, as per Table 1 in the CCSPN, that:

The summary table should be supported by a written explanation of the measures proposed

and a full set of calculations as set out under “Detailed Measures” below. Where relevant,

the proposed measures should also be shown on the application drawings.

2 As a separate point, in terms of the design of the proposed buildings, one might reasonably expect, when new developments are proposed, that whether in a conservation area or any other location, the design of the buildings might actually consider how beneficial attributes, such a rooftop PV, can be integrated so that they are acceptable. Instead, the possibility is described and then rejected out of hand.

These calculations are not presented. Without seeing these, and understanding the limited extent of

the demand reduction measures proposed, we cannot tell whether a less limited selection of

demand reduction measures might have reduced residual emissions: the higher the residual

emissions (i.e., the weaker the demand reduction measures), the easier it becomes for the applicant

to demonstrate a 20% reduction in their residual emissions (because the scope for doing so is,

somewhat perversely, increased). There is, therefore, a separate question to be asked as to whether

the energy hierarchy has been adequately respected.

Nonetheless, back to the issue of on-site generation from PV. The Energy and Sustainability

Assessment reports how residual emissions reduction would have been affected if the lower carbon

intensity figures featuring in the proposed update of the SAP had been used:

Using the SAP 10.1 carbon factors, it is anticipated that site emissions would reduce by a

total of c.82% from the building regulations baseline.

The main change here is that under SAP 10.1, the figure for the carbon intensity of electricity

generation is reduced from 519g CO2e / kWh to 136g CO2e/kWh. It doesn’t require too much

imagination to consider what change in emissions might have been achieved had the development

actually integrated itself on-site PV providing electricity at (close-to) zero g CO2e / kWh (and under

the current SAP approach, this might be even more significant because of the higher carbon intensity

of grid electricity that is assumed – we cannot tell because the calculations are not offered up, even

though, as mentioned above, the CCSPN is clear that they should be).

There is, furthermore a separate point regarding the appropriateness of the proposed update to the

SAP, not least in its alignment (or lack of it) with Government Guidance (from BEIS). The proposed

update to the SAP appears to be taking its cue from the Tables which BEIS published regarding the

Valuation Of Energy Use And Greenhouse Gas. These are published as Supplementary Guidance to

the HM Treasury Green Book on Appraisal and Evaluation in Central Government, and are used to

appraise policies and projects being considered by Government. The Guidance supporting the Tables

suggests that where one is considering small changes in demand for electricity, it is not the grid

average figures that should be used to understand the impact of the change (which is what the SAP

revision would imply). To quote the Guidance:

For estimating changes in emissions from changes in grid electricity use, analysts should use

the (long run) marginal grid electricity emissions factors in data table 1.

The aforementioned Table 1, accompanying the Guidance from BEIS, also states (in the relevant

Excel sheet):

Long-run marginal emissions factors should be used for measuring small changes in

consumption or generation. Grid average emissions factors are used for footprinting.

This is not a footprinting exercise: the aim is to understand the consequences of new development

that introduces a change in demand for electricity.

An extract from Table 1, from BEIS, is shown below.

Year

Long-run marginal Grid average

Consumption-based Generation-

based

Consumption-based Generation-

based

Domestic Commercial/ Public sector Industrial Domestic

Commercial/ Public sector Industrial

2010 0.389 0.382 0.375 0.357 0.501 0.492 0.483 0.460

2011 0.384 0.377 0.370 0.350 0.485 0.476 0.467 0.443

2012 0.377 0.370 0.363 0.343 0.532 0.523 0.513 0.485

2013 0.367 0.361 0.354 0.336 0.495 0.486 0.477 0.452

2014 0.360 0.354 0.347 0.328 0.441 0.433 0.425 0.402

2015 0.350 0.344 0.337 0.320 0.369 0.363 0.356 0.337

2016 0.340 0.333 0.327 0.311 0.291 0.285 0.280 0.266

2017 0.330 0.324 0.318 0.301 0.247 0.243 0.238 0.226

2018 0.319 0.313 0.307 0.291 0.180 0.177 0.174 0.165

2019 0.308 0.302 0.296 0.281 0.146 0.143 0.141 0.133

2020 0.296 0.290 0.285 0.270 0.141 0.138 0.135 0.128

2021 0.283 0.278 0.272 0.258 0.115 0.113 0.111 0.105

2022 0.269 0.264 0.259 0.246 0.107 0.105 0.103 0.098

2023 0.255 0.250 0.246 0.233 0.112 0.110 0.108 0.102

2024 0.240 0.236 0.231 0.219 0.104 0.102 0.100 0.095

2025 0.224 0.220 0.216 0.205 0.105 0.103 0.101 0.096

2026 0.207 0.203 0.200 0.189 0.099 0.097 0.095 0.090

2027 0.189 0.186 0.182 0.173 0.105 0.103 0.101 0.096

2028 0.171 0.167 0.164 0.156 0.100 0.098 0.096 0.091

2029 0.151 0.148 0.145 0.138 0.092 0.090 0.088 0.084

2030 0.130 0.127 0.125 0.118 0.083 0.081 0.080 0.076

2031 0.116 0.113 0.111 0.105 0.073 0.072 0.070 0.067

2032 0.103 0.101 0.099 0.094 0.061 0.060 0.059 0.056

2033 0.092 0.090 0.088 0.084 0.057 0.056 0.055 0.052

2034 0.082 0.080 0.079 0.075 0.049 0.048 0.048 0.045

2035 0.073 0.071 0.070 0.066 0.041 0.040 0.039 0.037

2036 0.065 0.064 0.063 0.059 0.041 0.040 0.039 0.037

2037 0.058 0.057 0.056 0.053 0.041 0.040 0.039 0.037

2038 0.052 0.051 0.050 0.047 0.041 0.040 0.039 0.037

2039 0.046 0.045 0.044 0.042 0.041 0.040 0.039 0.037

2040 0.041 0.040 0.039 0.037 0.041 0.040 0.039 0.037

2041 0.040 0.039 0.038 0.036 0.040 0.039 0.038 0.036

2042 0.038 0.038 0.037 0.035 0.038 0.038 0.037 0.035

2043 0.037 0.036 0.036 0.034 0.037 0.036 0.036 0.034

2044 0.036 0.035 0.034 0.032 0.036 0.035 0.034 0.032

2045 0.034 0.034 0.033 0.031 0.034 0.034 0.033 0.031

2046 0.033 0.032 0.032 0.030 0.033 0.032 0.032 0.030

2047 0.032 0.031 0.030 0.029 0.032 0.031 0.030 0.029

2048 0.030 0.030 0.029 0.028 0.030 0.030 0.029 0.028

2049 0.029 0.028 0.028 0.026 0.029 0.028 0.028 0.026

2050 0.028 0.027 0.027 0.025 0.028 0.027 0.027 0.025

The relevant column for the proposed development should be the second one: the long-run

marginal figure, consumption based, for the domestic sector. The proposed SAP figures are more

appropriate for a footprinting exercise, and are essentially what appears in the sixth column: grid-

average, consumption-based, domestic. Footprinting of a development which already exists (and so,

because it already exists, introduces no change in demand) is quite different from understanding the

impact of new development that introduces marginal changes in demand for electricity: that is the

case for this proposal, hence the relevance of the long-run marginal figures for the carbon intensity

of electricity used.3

Note also that whilst the figures in both columns are expected to fall between 2021 and 2030,

neither figure reaches ‘zero’ (or close to it) by 2030. Even without the details of the calculation being

provided, it is clear that this new development will not be zero carbon by 2030. This is of relevance

in respect of the One City Climate Strategy, to which the Energy and Sustainability Assessment

makes no reference. The One City Climate Strategy has two goals for ‘Buildings’, the first of which is:

2030 goal: All buildings in the city will be carbon neutral and use resources efficiently,

ensuring everyone can enjoy affordable warmth in winter and avoid overheating in summer.

The related objectives include the following (by 2030):

New buildings are carbon neutral and climate resilient (aligning heat provision to the city’s

heat decarbonisation programme).

There is no possibility of this new development meeting this objective as it has been proposed.

In terms of electricity generation, the One City Climate Strategy states:

Bristol will need to play its role locally in enabling this national grid decarbonisation. The

evidence demonstrates that the city can not generate within its boundaries enough zero

carbon electricity to meet its own electricity demand. So it will rely on new renewable

generation being installed elsewhere. But it can generate more ‘in area’ by realising

significantly more of the potential for rooftop solar PV on residential and non-residential

buildings across the city (estimated at 500MW at viable rates of return – only 28MW of

which has been realised to date).

The point here is that the performance of this development would have been significantly enhanced,

in terms of climate credentials, by inclusion of solar PV, and this is what would have been done to

bring the development into line with the One City Climate Strategy. There is, as noted above, no

reason not to do this, and the fact that none has been given should lead to the application being

refused, in line with the CCSPN.

It should also be considered that it may have been possible for the provision of on-site PV to have

rendered affordable homes ‘even more affordable’ by reducing the costs of electricity consumption,

these being likely to show some increase in future.

Given, therefore:

1. The obvious benefits of zero carbon sources of electricity in driving the emissions from the

development down;

2. The fact that the Energy and Sustainability Assessment offers no reasoning that would

indicate that such sources are non-viable;

3 What BEIS is essentially saying is that by adding new demand, the pace at which the grid is decarbonised is slowed down. This is entirely sensible. What the SAP approach should be doing is to ensure that the carbon factors used reflect the impact of the development on demand. Unless it does so, it is not consistent with the approach used by Government for policy and project appraisal, as indicated by Guidance prepared by BEIS, and used to inform assessments using the well-respected Green Book appraisal proposed by HM Treasury.

3. The fact that the CCSPN state that:

In respect of each of these issues, Sustainability Statements should set out what possible

measures have been explored, which measures have been adopted and integrated into

the design and, where relevant, why it was not feasible to incorporate certain measures

into the proposed development.

4. And that the CCSPN also states that:

4. A failure to convincingly address each of these issues will result in a refusal of planning

permission.

then the application for planning permission must be refused.

The Energy and Sustainability Assessment, and by extension, the application as a whole, does not do

what the CCSPN requires it do. There is no meaningful test of viability which has been ‘failed’ by the

obvious opportunity for the provision of solar PV.

Instead of achieving 33% reduction in residual greenhouse gas emissions (and 37% reduction against

a Building Regs compliant development – note, this figure is wrongly labelled in the Energy and

Sustainability Assessment), this ought to have been a zero carbon development, or at least very

close to it, if only it had followed what the CCSPN required it to do.

We note that the Planning Statement (7.51) reads:

The applicant wholeheartedly supports Bristol City Council’s commitment to becoming

carbon neutral and climate resilient by 2030.

The applicant – and its Trustees - need to be made aware, if they are not already, that this proposal

falls a long way short of demonstrating support for the Council’s commitments, whatever Barton

Willmore may claim. If the applicant really did wholeheartedly support the commitment to carbon

neutrality, then this application would be aligned with that objective: it is not. It must be rejected.

Trees

Trees are part of the green infrastructure that sites should, in accordance with various plan policies,

integrate into their proposals. This proposal does the opposite: it seeks permission to remove 16

trees, one of which is described as Category U. The Arboricultural Report notes:

Trees Identified for Retention and Removal.

It is proposed to remove fifteen trees, detailed below, to facilitate the proposed

development. T16 will be removed in accordance with good arboricultural practice.

Cat A Cat B Cat C Cat U

T02 T01, T04, T08, T09, T10, T15, T17, T18, T19

T03, T11, T13, T14, T22

T16

1 9 5 1

The Table below para 5.7 in the Planning Statement includes the following:

There are a number of good quality mature trees on the site that are to be retained, as they

are both ecologically important, and add to the distinctive character of the area.

Any smaller trees that are required to be replaced within the car park will be better

integrated into the development’s design layout in line with Bristol City Council’s Tree

Replacement Standard and enhance the ecological value of the site.

The inclusion of green roofs and living walls further support wildlife, and integrate the tree

planting with other spaces for wildlife to nest, forage and shelter.

The wording only obliquely references the loss of trees at the site. The tree planting referred to

relates to trees being replaced, this number being fewer, in the original application, than the

number for which permission to remove was being sought. The statement masked the fact that

more trees were to be lost than would be replaced. The suggestion in the above paragraph that

trees ‘required to be replaced’ are ‘smaller’ is less relevant than what is actually being lost. The

proposal for new trees, as per the original proposal, does not actually align with the Tree

Replacement Standard. In the revised proposal, with minimal changes to the design, the number of

proposed trees has been increased, but not in a manner that meets the Tree Replacement Standard.

Furthermore, three of the seven additional trees in the new proposal are squashed between parking

bays, a feat made possible by reducing (apparently, from the Site Plan) the size of the three trees

initially proposed. Exactly what has changed in the revision is not clear, but for all the world, it

simply looks like someone has shunted a few car spaces about to allow the applicant – Bristol Zoo –

to mitigate some of the embarrassment that it would be proposing a development with fewer trees

on it than are currently in situ. This is trumpeted in the design and Access Statement Addendum

(p.7):

Additional tree planting has been proposed within the development to improve to enhance

the ecology and biodiversity. This has been achieved through re-distributing parking bays

along the rear elevation of Block A, creating additional room for soft landscaping.

Where trees are being felled to enable development on the site, we are now proposing that

these are replaced on site with more proposed resulting in a net gain of two trees.

To be clear, once again, the ‘net gain’ of two trees is not aligned with the Council’s Tree replacement

Policy, and nor should the use of the term ‘net gain’ be confused or conflated with the requirement

to demonstrate biodiversity net gain as per the metric proposed by Defra and Natural England

(though it seems the applicants are seeking to achieve a 10% ‘net gain’ of tree numbers on site).

The revised application still seeks to remove the same number of trees as previously. Table from the

Arboricultural Report has been reproduced below, highlighting the trees surveyed, and indicating

(through the shaded polygons) the trees which the Arboricultural Report seeks permission to

remove.

There was, and still is, no exploration of why they necessarily need permanent removal: the report

moves easily into a straightforward proposal for removal. Para 1.3 of the report reads:

1.3 Specifically, this report and the accompanying information are supplied to:

• Identify the constraints that trees on and adjacent to the site present to the development

of the site, to inform the site design process.

But the report does not show evidence of this. The figures in the Appendices show that the nature of

the proposed development was already established at the time the report was being prepared. The

aim appears not to have been to identify constraints, and as a result, to inform site design: rather,

the report seems to have been prepared with the express purpose of indicating what trees should be

removed to facilitate an already well-developed proposal. The trees have not informed the fate of

the development: rather, the development appears to have informed the fate of the trees, or at

least, that is what the Report leads us to infer. We are all left wondering whether the removal of

trees could have been reduced, or rendered unnecessary, through a better design process where the

Arboricultural Report actually did inform the site design. Why, for example, do trees T01 and T02

and T13 and T14 have to go? Why could the development not have been designed to accommodate

them given they could easily have been at the perimeter of the development, alternatively

conceived? There is not logic or justification: the trees are condemned because the Report says they

need to be removed to accommodate this proposal. That cannot be considered an adequate way to

proceed, and is inconsistent with BCS9 (see below).

Notwithstanding the above, in the Arboricultural Report, there is recognition of the fact that

mitigation would be required in the event of removal:

6.4.1 Mitigation In accordance with Bristol City Council Tree Replacement Scheme (BTRS) the

removal of the afore mentioned trees will require either replacement tree planting on site or

a monetary contribution for replacement tree planting elsewhere in the area. The number of

replacement trees, or amount of the monetary contribution, is calculated on the stem

diameter of trees proposed for removal.

6.4.2 Calculations of the obligations for the removal of the trees are listed below. The

obligation can be fulfilled with a mixture of replacement trees and monetary contributions if

desired. In accordance with Bristol City Councils Tree Replacement Scheme the removal of

the aforementioned trees will require the planting of 28 x replacement trees or a monetary

contribution of £21,420.00

The implied assumption is that monetary contributions would be made at the rate for a tree in open

ground with no tree pit required. These, though, may be trees lost to the locality, and certainly, the

would-be residents.

In the Planning Statement, no mention to monetary contributions is made. At para 7.68, it notes:

7.68 Eight of the existing trees are to be retained, with replacement tree planting proposed

to mitigate against the loss of the trees to be removed.

The same statement appears in the Design and Access Statement. There is no mention of monetary

contributions, and no reference to off-site planting.

According to the Arboricultural Report, the removal of the trees as proposed would require 28 new

trees. Reviewing the Proposed Site Layout, I could count 10 proposed trees (not 28). There seem to

be 18 trees which have ‘gone missing’. In the revised proposal. There are 17 proposed trees. That

leaves, still, 11 that are missing.

The Planning Statement from Barton Wilmore on behalf of its client reads as follows regarding their

client:

As a wildlife and conservation charity, it also wants to give a helping hand to local wildlife.

Paragraph 2.1 of the Planning Statement notes:

The Society’s mission is saving wildlife together and their vision is for wildlife to be a part of

everyone’s lives and for people to want to, and be enabled to, protect wildlife now and for

the future.

This application does nothing to reflect that intention. The charity has five objectives as part of its

‘saving wildlife together’ strategy, and one of them is to engage with its public; another is to create

conservationists; and another is to sustain the environment. None of that is evident in this

application, made on its behalf. It may be that the Bristol Zoological Society felt that a revision in the

proposal was necessary to avoid the uncomfortable position it was in of proposing a net reduction in

trees on or around the site. Nonetheless, the revised application seems to have squashed in a few

more trees that might make opening a car door somewhat problematic, and relative to the tree

replacement standard, it is still missing 11 trees.4 We know little, or anything about what the species

of tree will be – this surely matters – this is not just ‘a numbers game’, but that seems to be how this

revision has been made. What are depicted in the initial application as large canopy specimens

adjacent to the parking bays have been ‘knocked down to size’ so as to squash in a few more trees

to ‘make up the numbers’.

In the Planning Statement, as the authors run through relevant policies, they note:

Core Strategy Policy BCS9 sets out that green infrastructure assets include open spaces,

gardens, allotments street trees and planting. Development should incorporate new and/or

enhanced green infrastructure of an appropriate type, standard and size. Where on-site

provision of green infrastructure is not possible, contributions will be sought to make

appropriate provision for green infrastructure off site.

Going back to the previous point regarding the Arboricultural Report, and the fact that it constitutes

an ex post proposal (it cannot be termed ‘a justification’) for removing trees to facilitate a pre-

designed development, the proposal clearly fails to implement this policy. There is no reason at all

why an innovative design could not have incorporated new and / or enhanced green infrastructure.

There was nothing compelling the proposed density of dwellings from the outset: that was free for

4 As per my footnote 1, this is another example where the design trumps the sustainability concerns rather than being undertaken in such a way that the sustainability concerns are integrated into the site. It is unfortunate that neither the Arboricultural report nor the ecological report were required to advise on the nature / form / siting of the 28 replacement trees (though now completely comprehensible since it seems it was never intended to replace them). It does raise, then, the question as to whether the trees and their location are appropriate – the most information we have comes from the Ecological Report which states: ‘Elsewhere planting on the site will include species that are of value for wildlife, including priority species. These will include berry-bearing trees and shrubs; trees that are either native or are closely related to native species (such as ornamental Malus and Pyrus spp, which support most of the insects supported by native species; and nectar-rich herbaceous plants that are of value to pollinating insects such as bumblebees.’ There is not much by way of definitive strategy, other than reducing the number of trees.

the applicant to determine. There was nothing compelling the design to be exactly as it is proposed.

The proposal constitutes a failure to implement BCS9, and a failure in design.

It is difficult to square the stated mission of the applicant with the nature of this application. The

application to remove 15 + 1 trees and to propose a number of replacements of an undefined nature

is unfortunate. The Arboricultural Report gives options, but was clearly not appraised of the form of

development being proposed (had it been so, it would have been able to comment on the loss of

trees).

Noise

The Noise Assessment is inadequate, and nothing in the revised proposal changes that fact. It fails to

consider, in any meaningful sense, the contribution that a new development will bring to the existing

area. In this respect, it is non-compliant with Policy DM35 which clearly requires Mitigation to

consider ‘measures to reduce or contain generated noise’. It is rather bewildering that the new

dwellings are not considered, effectively, to be the source of any new noise, not least at night, when

the balconies, which are described as a feature of the development, might be used by residents

generating music and noise in their own right. This is in addition to any additional night-time

transport noise which the development would bring to existing residents.

In respect of the effect of noise on the development itself, it is worth quoting the text which

supports DM35 (which is due to be retained in a revised plan) in the SADMP:

2.35.4 Noise-sensitive development, including houses, hospitals and schools, should not

generally be located next to existing sources of significant environmental noise. Depending

on the level of environmental noise, the impact can in some cases be satisfactorily mitigated,

allowing the noise-sensitive development to proceed on the affected site. However, the

design of mitigation measures should have regard to the need to provide a satisfactory

environment for future occupiers and take account of other material planning considerations

such as urban design.

2.35.5 Applications for residential development in areas of significant existing environmental

and neighbourhood noise will not usually be permitted unless a robust scheme of mitigation

is put forward and the benefits of the proposal in terms of regeneration are considered to

outweigh the impacts on the amenity of future occupiers, for instance where the proposed

development would support investment in centres. In general, the following values will be

sought for residential development:

i. Daytime (07.00 - 23.00) 35 dB LAeq 16 hours in all rooms and 50 dB in outdoor living areas.

ii. Nightime (23.00 - 07.00) 30 dB LAeq 8 hours and LAmax less than 45 dB in bedrooms

The Noise Assessment states:

the night-time noise levels at College Road Façades will be 51 dB LAeq(free-field). Any

standard modern construction using double glazed windows and trickle vents is likely to

provide a composite sound reduction index of at least 25 dB Dw. Therefore, the recommend

internal noise limits from BS8233:2014 and BCC Policy DM35 (30 dB LAeq) will be achieved.

When windows are open to cool an overheating room, noise levels may be up to 6dB above

the recommended criterion.

The Assessment goes on to say:

This [i.e. a 6dB exceedance of the 30dB noise limit] is slightly above the level considered to

represent “reasonable” conditions according to BS8233:2014 but it is not a significant

exceedance and sleep is unlikely to be significantly affected. With reference to the AVO

Guide, night-time noise levels are of low significance and further assessment of the

overheating condition is not required

This point, regarding the exceedance ‘not being significant’, is the opinion of Hydrock, the authors of

the Assessment. The AVO Guide (not fully referenced in the Assessment – this is the Acoustics

Ventilation And Overheating: Residential Design Guide of January 2020, produced by ANC and the

Institute of Acoustics) may be being misrepresented. The AVO Guide does not constitute official

government advice.

Extracts from the Noise Assessment’s own Appendix confirm the fact that such an exceedance is not

of ‘low significance’:

Extract 1: Regarding BS 8233:2014 -Guidance on sound insulation and noise reduction for

buildings

Whilst BS 8233:2014 recognises that a guideline value may be set in terms of SEL or

LAFmax in bedrooms during the night-time to minimise the risk from regular

individual noise events that can affect sleep quality, a specific criterion is not

stipulated. Therefore, guidance on maximum night-time noise levels from World

Health Organisation (WHO) 1999: Guidelines for Community Noise are often used in

the UK, including within ProPG.

British Standard 4142:2014+A1:2019

a) Typically, the greater this difference, the greater the magnitude of the impact.

b) A difference of around +10 dB or more is likely to be an indication of a significant

adverse impact, depending on the context.

c) A difference of around +5 dB is likely to be an indication of an adverse impact,

depending on the context.

Contrary to the consultants’ views, therefore, this suggests a difference of 6dB may be considered a

significant exceedance.

Extract 2: World Health Organisation (WHO) Guidelines on Community Noise

When noise is continuous, the equivalent sound pressure level should not exceed 30 dB(A)

indoors, if negative effects on sleep are to be avoided. For noise with a large proportion of

low-frequency sound a still lower guideline value is recommended.

The consultants’ view that ‘sleep is unlikely to be significantly affected’ by a noise level of 36dB

(presumably, 51dB from traffic with 15dB attenuation from an open window) is flatly contradicted

by WHO Guidelines, which the authors themselves have helpfully cited.

It is worth cross-referencing the Energy and Sustainability Assessment’s ‘Overheating Analysis’. This

considers the susceptibility of the dwellings to overheating. It considers both CIBSE TM52 and TM59

assessments. My own understanding of these is that these assessments, of which only TM59 is

specifically for residential dwellings, deliver results which are dependent, in part, on the

assumptions made regarding ventilation strategies. Hence, whilst the Overheating Analysis delivers a

‘pass’ according to the consultants, it is unclear to what extent it does so contingent only upon

ventilation strategies implying that windows are kept open. Given the noise assessment, this is

especially true for the second criterion in TM59. In this respect, the Energy and Sustainability

Assessment states (Sn 7.2 fourth bullet):

An openable window strategy has been developed to reduce the risk of overheating in

summer in line with CIBSE TM59 methodology requirements

The interplay between these factors – the susceptibility to overheating and the exposure to noise,

especially at night-time, and given also that no account has been taken of the noise generated by the

development itself – deserves much closer consideration than has been given.

The plan for renewable energy generation – central to achieving the required reduction in CO2

emissions from the proposed development to comply with the requirements of the outdated

planning policy – is centred on the deployment of air-source heat pumps (ASHPs). The Energy and

Sustainability Assessment indicates that these will be housed as follows:

ASHP units would need to sit in either an acoustically treated external plant enclosure or

within a well-ventilated internal plantroom. The current architectural design allows for an

internal ground floor plant room in Block B with louvred wall to allow for suitable airflow.

A review of the floorplan for Block B indicates a plan for 6 Mitsubishi CAHV units (it is not completely

clear whether the room will enable their proper functioning – some of the dimensions look suspect

given the face to face / side by side nature of the layout). It is a peculiar design choice that these will

sit directly under the bedrooms of Flat 53 and Flat 58, and beside the bedroom in Flat 48. Perhaps

other considerations have trumped the issue of exposure of residents in the development to the

ASHPs: the Planning Noise Assessment considers the noise from ASHPs largely in respect of their

impact on nearby existing residential properties. Laudable as this is as a principle, it overlooks the

need to ensure that the development is also tolerable to those who will be living there in future. It is

difficult to imagine circumstances where the bedroom windows of the Flats mentioned would be

exposed to noise levels below those that British Standards and the WHO consider likely to be

injurious to sleep, and thence, to the health of residents.

There are, surely, better configurations of this proposal which would allow improved mitigation of

noise. There is no noise mitigation between the main source of noise – the road – and the

development itself. There is, in short, no mitigation other than the fabric of the building. The density

of development leads to a citing of the ASHPs which leads to a high likelihood of sleep disturbance in

the bedrooms of some of the flats. Not everyone can sleep with double-glazed windows closed

(even ones with trickle vents) at night. That is before one even considers the fact that the proposed

development might, itself, be a source of night-time noise, whether from residents on the many

balconies or from the additional night-time transport that the suite will undoubtedly generate.

Policy DM35 clearly states:

Development will not be permitted if mitigation cannot be provided to an appropriate

standard with an acceptable design, particularly in proximity to sensitive existing uses or

sites

On the above basis, and given the requirements of DM35, and given also the very likely impact on

sleep – casually and erroneously dismissed by the consultants - of having a window open at night at

the proposed properties, the development should not be permitted.

Is the Site ‘brownfield’?

The Planning Statement accompanying the application asserts (para 1.2):

The site is brownfield as it currently is a car park and provides ancillary storage. The site is

within the Clifton and Hotwells Conservation Area.

The site does not appear on the City Council’s Brownfield Land register. It may also be a moot point

that the car park qualifies as ‘previously developed land’ given the definition in the NPPF of

‘previously developed land’ (commonly referred to as ‘brownfield’). The NPPF definition is:

Previously developed land: Land which is or was occupied by a permanent structure,

including the curtilage of the developed land (although it should not be assumed that the

whole of the curtilage should be developed) and any associated fixed surface infrastructure.

This excludes: land that is or has been occupied by agricultural or forestry buildings; land that

has been developed for minerals extraction or waste disposal by landfill purposes where

provision for restoration has been made through development control procedures; land in

built-up areas such as private residential gardens, parks, recreation grounds and allotments;

and land that was previously-developed but where the remains of the permanent structure

or fixed surface structure have blended into the landscape in the process of time.

Although a car park could be considered to be ‘previously developed land’, it might not be so in all

cases: the West Car Park is essentially an area of hard-standing with minor ancillary structures. It

could be considered that the proposal for development represents the type of development – albeit

on a larger scale – that the exclusions in the NPPF were designed to prevent. This is especially

relevant given the planning history of the site – the proposed development is taking place on land

which was, in 2000, partly used for greenhouses. This is hardly land that has been subject to major

development prior to this application.

In any event, even if the site is ‘brownfield’, this is clearly not a reason to give the go-ahead for the

development. Nothing in the revised proposal detracts from the relevance of this point.

Need for the development

The Planning Statement also states (Table under para 5.7):

The Society is proposing the redevelopment of the car park to deliver much needed housing

on a brownfield site in a central location in line with principles of the NPPF and local planning

policy.

The suggested ‘much needed’ nature of the housing is at odds with the figures in the Council’s Core

Strategy. We demonstrate below that the identified need will be exceeded.

In the Core Strategy, BC5 stated:

The Core Strategy aims to deliver new homes within the built up area to contribute towards

accommodating a growing number of people and households in the city. Provision of new

homes will be in accordance with the spatial strategy for Bristol set out in this Core Strategy

and it is envisaged that 30,600 new homes will be provided in Bristol between 2006 and

2026. Additional provision which accords with the spatial strategy may be appropriate within

the plan period.

The minimum target will be 26,400 homes between 2006 and 2026. The appropriate level of

new homes will be reviewed within 5 years of the adoption of the Core Strategy.

The 2020 Bristol Residential Development Survey 2020 (The RDS) noted (see Table 1 in the RDS –

also, para 1.10):

Since 2006, 24,669 dwellings have been complete

This is the net figure.

The RDS also noted (para 1.3) that:

At 31st March 2020 there are 2,938 dwellings under construction, 8,902 with planning

permission not started and a further 910 dwellings on sites with planning permission subject

to the signing of a Section 106 agreement, totalling 12,750 – see Table 2.

Even if one takes into account only those dwellings under construction, then the target in BC5 is

exceeded.

Even the most conservative estimate of the rate at which sites with planning consent will lead on to

construction implies that the level of housing need which has been identified within the existing plan

will be far exceeded without any new planning consents.

That does not, in itself, indicate that no additional housing development should be granted: it does,

however, place the above comments in context. Against the policies in the Core Strategy, this cannot

be considered ‘much needed housing’. The need was identified in the Core Strategy and it has

already been exceeded. The argument regarding need has no merit in relation to Plan policies.

Housing density

Responding to the view that the density of housing proposed in the development was too high, the

Planning Statement (Table below para 5.7) stated:

As a charity the Trustees are legally required to obtain maximum value from the charity’s

assets to reinvest in its charitable objectives.

‘Value’ has never been synonymous with ‘price’: the whole basis of Government’s ‘Best Value’

regime for local government was partly designed to ensure that contracts would not be awarded

purely on price. The best value outcome might not be the one that generates the highest sale price

for the land for which the planning application has been submitted.

Nonetheless, this is somewhat different to the wording in the Charities Commission Guidance on the

matter, at para 7.6: 5

Most charities can buy, sell or lease land when they need to. When selling or leasing land,

trustees must try to get the best deal for the charity (unless they are making the disposal to

further the charity’s purposes).

One can argue the toss about the term ‘best deal’, but it might not be the same as ‘maximum value,

let alone, ‘highest price’. Yet on the matter of whether the disposal is being made to further the

charity’s purposes, the Bristol Zoo website includes the following:

5 Charity Commission for England and Wales (u.d.) Guidance: The essential trustee: what you need to know, what you need to do, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/866947/CC3_feb20.pdf

To safeguard the future of Bristol Zoological Society, we are relocating Bristol Zoo to the Wild

Place Project site to create a world-class zoo for Bristol and the West of England.

As part of the first phase of this new strategy, an application for planning permission has

been submitted for residential development of Bristol Zoo Garden’s West Car Park on College

Road. The sale of the West Car Park will provide a vital contribution to the funds required to

deliver the first phase of the new Bristol Zoo.

It would be difficult to argue against the view that these words indicate that the disposal is being

made to further the charity’s purposes (in which case, whatever the meaning of ‘best deal’, the

requirement might not even apply).

What is of concern, however, is how the Trustees’ responsibilities are invoked in part as an

explanation for the density of proposed development (in the Table in the original Planning

Statement that follows Para 5.7). On density of dwellings, the Planning Statement is highly selective

in its citing of draft policies. For example, the Planning Statement reads:

In the emerging Draft Policies and Development Allocations document the site is located

within the inner urban (more intensive) zone, where the minimum density is 120 dph (Policy

UL2 Urban Densities). Similarly, the adopted Urban Living SPD (2019) identifies a density

within urban settings of 120 dph.

Policy UL2 in the Draft Policies Document reads as follows:

For major development (including at least 10 dwellings), where specified by Table 6.2 below,

a higher minimum net density will be sought on suitable sites in each area.

In assessing the suitability of sites for these higher densities, consideration will be given to

the characteristics of the site and its context. Densities below the suggested minimum may

be acceptable where:

• It is essential to respect the character of the locality or protect the character and

setting of heritage assets;

• Where a proposal includes house types which result in densities below the minimum

but would otherwise make a significant contribution to the creation of mixed and

balanced communities; or

• Where market signals, local housing market trends and local housing needs

demonstrate that higher density forms of development are not viable

Evidently, the selective citation of draft policies is deliberate, and intended to indicate that the

application is responding to the requirements of a policy. The same selective citation occurs in

paragraphs 7.40 – 7.41 of the Planning Statement. In any event, the full reading of Policy UL2 that is

referred to would admit of the necessity – it actually uses the word ‘essential’ - of a much reduced

density of dwellings where the character of the locality demands it. There could not be a more

obvious application of the essential nature of that reduced density than in the proposed, and

revised, applications. The scheme proposed is akin to placing a housing estate on the edge of the

Downs, which under no reasonable interpretation of the adjective could be considered to be ‘urban’.

I note that a consequence of this ‘maximum value’ pursuit of density of development is that children

are expected to play in an area on the other side of a fairly major road, the A4176, or an 11 minute

walk away at an already well-utilised playground. The Planning Statement notes (para 7.50):

Children’s play space

7.50 Children’s play space is not provided on site, given access to a large area of public open

space immediately to the North of the A4176 Clifton Down. Children’s play equipment is

provided within an 11-minute walk of the site at Clifton Suspension Bridge Playground. Open

green space to play on Clifton Down, as well as informal recreation and a number of sports

clubs and activities is available within a 2-minute walk (150m).

The Downs is a tremendous amenity, but occupants of dwellings on the site would have good reason

to be concerned for the welfare of smaller children, if their intended play area is either on the other

side of the A4176, or an 11 minute walk away at the Suspension Bridge (already well-utilized). The

absence of on-site space for this is incredibly disappointing and suggests the outcome will be the

construction of dwellings that entrench ill-health, notwithstanding the proximity to the Downs. It is

also true that any ecological features incorporated onsite – and these have the character of an

afterthought (see below) – would be unlikely to be incorporated in a manner that could inspire the

next generation of conservationists (which the Zoo’s strategy indicates that it seeks to do).

If one makes an assumption that, in each proposed dwelling, one child is in each bedroom above and

beyond the first (and admittedly, this might not be correct), then there would be around 60 children

housed on the site (based on the revised application). The issue here, perhaps, is not the proximity

of alternative space, but the potential number of residents who have no direct access to play space.

In a development that could house 60 children, is that an acceptable form of design? Should any

development with 60 children on site be designed with no access to play space?

The proposal makes no attempt to comply with the requirements of DM16, and it makes no

reference at all to DM 14, which relates to the Health Impacts of Development. Development

Management Policy 14, which we understand to be retained in proposed revisions to the Local Plan,

reads as follows (see the SADMP):

Development should contribute to reducing the causes of ill health, improving health and reducing health inequalities within the city through:

i. Addressing any adverse health impacts; and ii. Providing a healthy living environment; and iii. Promoting and enabling healthy lifestyles as the normal, easy choice; and iv. Providing good access to health facilities and services.

Developments that will have an unacceptable impact on health and wellbeing will not be permitted. A Health Impact Assessment will be required for residential developments of 100 or more units, non-residential developments of 10,000m² or more and for other developments where the proposal is likely to have a significant impact on health and wellbeing. Where significant impacts are identified, measures to mitigate the adverse impact of the development will be provided and/or secured by planning obligations.

Whilst it is clear that a health impact assessment is not required in this case, it is questionable that

the development could claim to contribute much by way of improving health within the city, given

its apparent dismissal of the need for provision of any on-site locations for play, or even, locations

where – consistent with the professed concerns of the applicant – the next generation of nature

enthusiasts could be fostered. This is a massive missed opportunity for the applicant: there can be

few locations in Bristol which would have been as well suited for this. Yet the trade-off has been

made clear: “density of development trumps health”, when it comes to maximizing the uplift of the

value of land if it achieves planning consent.

The Council should consider this matter carefully. As the Core Strategy notes:

4.21.11 The built environment should be designed to deliver safe, secure, attractive, healthy,

comfortable and convenient places in which to live, work, play and spend time. Development

should take the opportunities available to improve the quality and appearance of an area

and the way it functions. The built environment should be inclusive, respecting how people

experience the city and addressing the needs of all in society

We doubt this can be said of this development. Why are so few of the trees which are proposed for

removal being replaced on the site? Why is there so little green infrastructure on the site? The

densification is not only inappropriate to the location: it is ‘designing in’ ill health.

Traffic

In relation to traffic, the same Table under para 5.7 notes the response as follows:

The assessment by PEP has identified hourly traffic flows through the College Road/Cecil

Road during the day as a result of the development would be around six vehicles. This

equates to one vehicle every 10 minutes which would also not be a material increase. The

increase in traffic identified above would also only be temporary until Bristol Zoo Gardens

closes in late 2022.

The proposed redevelopment Annual Average Daily Traffic (AADT) is predicted to be 159. The

existing trip generation, for when the site was operating as a car park, was 206 AADT. Traffic

flows are therefore predicted to decrease.

There seems little acknowledgement of the influence on night-time traffic flows and noise: there is

very little of this at present from the Car Park’s existing use. Indeed, a search for the term ‘noise’ in

the Transport Statement reveals zero hits. In other words, there is no acknowledgement of what

impact the change in the timing of use of cars in relation to the proposed development could have.

This is an important omission, both for the prospective residents and those who reside in the

vicinity. The ‘traffic’ is not merely a matter of ‘who parks where?’, but also, one of when the traffic

occurs, and what additional night-time noise is generated by the site.

This (omissions) is consistent with the approach in respect of noise more generally where there is

scant regard for the impact that the development might have on noise generation. In the Noise

Assessment, there are few references to ‘transport’, mainly to the make the point that noise levels

have dropped as a result of COVID-19. Noise is mainly considered in respect of the impact of other

sources on the development, not the impact of the development on nearby receptors. The only

exception is the air source heat pumps: ironically, the impact of these on would-be occupants seems

to have been overlooked (see below).

It is very difficult indeed to argue (and perhaps this is why no attempt was made) that the

development will increase night-time noise in the vicinity. This is generally a quiet area at night. The

proposed development has the potential to alter its character significantly in that important regard.

We refer again to DMP 14, to proposed UL2 and other relevant policies in the plan that should

clearly indicate that a development of this density, with the planned-for number of vehicles,

replacing a ‘development’ (is this really brownfield?) which generates little if any night-time noise,

and when it does so, within confined hours.

Affordable Housing

On affordable housing, the same Table under para 5.7 in the Planning Statement notes:

Twenty per cent of the housing is proposed to be affordable. This is in line with Bristol City

Council’s Core Strategy Policy BCS17, and the requirements set out in the Affordable Housing

Practice Note 2018 for proposals in the ‘inner west’ part of the city, responding to the

significant need in Bristol

In the revised application, the Schedule of Accommodation indicates that there will be 11 affordable

apartments in a development of 55 apartments and seven houses, giving a figure not of 20%, but

slightly less than 18%.

BCS17 in the Core Strategy states:

Affordable housing will be required in residential developments of 15 dwellings or more. The

following percentage targets will be sought through negotiation:

• 40% in North West, Inner West and Inner East Bristol;

• 30% in all other locations

The AHPN (Affordable Homes: Practice Note) released in 2018 by Bristol City Council suggested

alternative means of complying with policy on affordable homes:

This new guidance 2018 introduces a ‘threshold’ approach to provide developers with a fast

track route for processing of planning applications if they are prepared to offer at least 20%

on-site affordable housing on sites located in Bristol’s inner west and inner east zones. To

take advantage of this, developers must start work on schemes within 18 months of planning

consent being granted. The Council will still be encouraging developers to deliver policy

compliant 40% affordable housing provision by considering grant applications from

registered providers to make up any shortfall on the Council’s planning policy requirement.

The above Guidance is strange given that the Council is currently falling well short of even the 20%

figure now being offered as a basis for fast-tracking (a lower proportion of) affordable homes, let

alone its own targets in BCS17. The legitimacy of the AHPM must be called into question.

The RDS indicates that, of the 24,669 net dwellings constructed since 2006:

3,557 affordable dwellings (net) were completed comprising 2,441 through housing

association/local authority schemes, plus 1,116 through planning agreements within private

developments.

This amounts to 14.4% of the total.

It is clear (see above regarding the need for new homes) that the Council is well on track to exceed

targets in the Core Strategy for new dwellings: yet it is way off track when it comes to delivering

affordable homes as per the same Core Strategy. The effect of the AHPN – to consent to a 20%

minimum figure, and make this eligible for fast-tracking – is odd, to say the least, not least given the

shortfall in affordable dwellings, and the apparent intention to adopt the affordable homes Policy in

the West of England Draft Spatial Plan (see below).

The point to be made is that in the context of the current performance against the policies in the

Core Strategy, notably BCS17, then the Council should be seeking to maximise contributions to

affordable housing (it does not require a mathematical genius to see that a fast-track process

requiring a minimum threshold of 20% affordable housing is not going to deliver the outcomes

envisaged in BCS17 – indeed, it is actually impossible to do so, and the legitimacy of the AHPN

deserves to be challenged for that reason). Given the current proportion of affordable housing in net

dwellings, the average proportion of affordable dwellings in new dwellings would need to be well

above the 20% target to compensate for the currently low proportion. This is all the more important

given the (in the circumstances, unsurprising) content of developments with planning permission as

of end March 2020 as indicated in the RDS:

Table 6 sets out details of affordable dwellings with planning permission, including dwellings

approved subject to a Section 106 agreement at 31st March 2020. 2,063 dwellings (16.2% of

total net permissions including S106) are affordable.

In passing, and reflecting further on the selective nature of the citations in the Planning Statement, it

is worth noting that, as indicated above, the Planning Statement sought to engender support for its

proposed density of dwellings though reference to (at 6.17-6.19) the Draft Policies and Development

Allocations. The same document indicates, with regard to affordable housing, that:

JSP Policy 3 will become the development plan policy for affordable housing in Bristol when it

is adopted later this year.

The policy on affordable homes being referred to stated (from the West of England JSP (Joint Spatial

Plan)):

On residential developments delivering 5 or more dwellings or sites larger than 0.2ha,

whichever is the lower, a minimum target of 35% Affordable Housing to be delivered on site

is required. This applies to both C3 and self-contained C2 residential developments, including

older persons and student accommodation.

Suffice to say, the current application would be far from compliant with that wording. If the density

of dwellings is to be justified through reference to the Draft Policies and Development Allocations,

then the requirement for affordable homes should be treated in the same way. Furthermore, if the

proposed development seeks to be adjudicated against the DPDA policies, it should say so: the

requirement to pay compensation for above-zero carbon emissions would then, presumably, also

apply (see below).

In short, the application is using selective citation of existing and draft policies to seek to maximise

the number of dwellings, whilst minimizing the number which are affordable.

In any event, the fact that only 11 of 62 dwellings will be affordable places this development below

the 20% figure – the figure is 18% - that would be required for any form of fast-tracking process. It

follows that there must be no fast-tracking of this application.

I have objected already to the above application - 21/01999/F - but I am writing again to reiterate how strongly I object.

It is not legally possible, contrary to the Applicant's assertion, to regard the site as previously developed land.

The planned development does not fit in with the landscape and it fails to preserve the character of the Conservation Area of Clifton.

It has been brought to my attention that the Council wishes to avoid the cost of planning appeals making it difficult for local residents to oppose planning applications. I sincerely hope that that is not applicable in this situation.

Yours faithfullyAmanda Davis

Please note my previous objection is the zoo's application still stands as the new application only makes very minor changes to a scheme that is totally inappropriate for our conservation area

Please note that my objection to the Zoo's original planning application still stands.

The new application makes only minor changes and does not address the objections which I raised.

In brief the application is fundamentally flawed and totally inappropriate for our Conservation area.

I do hope you will take note of the objections raised and act accordingly.

Annette Young

Dear Sirs

I am writing to object to the latest plans for the redevelopment of the Zoo West car park.The alterations made to the plans are minimal and still are out of keeping with this conservation area. It is sad to see the opportunity for good architecture missed again. The plans as they stand will blight the area and I hope the committee will search longer to find the right use of this site.

Kind regards

Rachel Wilson

Hello

My name is Reuben Harford and I live at 60 Pembroke road BS8 3DX. I am writing to oppose these revised proposals.

These revised proposals represent the developer's attempt at getting his original proposal through without making much attempt to understand why his original proposal was turned down. The changes made are token changes and minimal in the scale of things.

The buildings density proposed will still be much too great for the site, and completely out of keeping with the rest of Clifton. The spec and the layout of the "affordable housing" are a particularly poor joke.

The application is clearly not previously developed land and, if built, would materially and adversely affect a wide area of Clifton near the Downs.

Please refuse the application in its entirety.

Yours sincerely

Reuben Harford

Second opposition letter to West Car Park Planning Application 21/01999/F

Dear Case Officer,I wish to oppose the latest variation of the Planning Application made by the Zoo to sell off theirWest Car Park for development.There are many comments made by local residents explaining why this site must not beadulterated by a poor architectural design.This area of Clifton has in the most part not been changed by the design of the buildings for wellover 150 years.To allow a design of architecture that will be in total contrast to the beautiful large Villas in CliftonDown (which have Rear gardens nearest to the site and the more modest Terraced buildings onCollege Road nearest to the Zoo West Car Park Site.I wish that my first planning opposition letter is added to this latest one, as I believe thearchitectural changes are not an improvement and in fact solely dictated by maximising the valueof the development and not taking into account the fact that Clifton is a Conservation area wherepotential new builds must be in keeping and add to the area.These revised plans do not add anything to the existing beauty of the old Gothic and Italianatebuildings.In conclusion the latest revisions are not an improvement and I do wish that the City CouncilPlanning Office listen to the opposition commentary made by the residents who have written inand make sure whatever plans are submitted by the Developers are in keeping and able to blendinto the neighbourhood.If some developers can do this then the plans for the College Road Zoo West Car Park cancertainly do so as well.

Having looked at the revised application, I detect little difference. My original objectionsof the 29 June 2021 still stand. This proposed development would foist an eyesore on the currentconservation area and would be a terrible precedent for developments to come on the larger Zoosite.

I am writing to object to the application.For the purposes of the National Planning Policy Framework the entire site of the BristolZoological Gardens, including its 'car park', should be considered to be a Park. The Bristol TreeForum have objected to the proposals, agreeing that 'this 'car park' is an integral part of the BristolZoo Gardens'. It sits within the setting of 8 listed buildings, including the houses facing on toClifton Down. In 1999 the land to the rear of 4 of these was in use by the Bristol ZoologicalGardens for horticultural and other ancillary uses. The NPPF explicitly excludes from its definitionof previously developed land 'land that is or has been occupied by agricultural or forestrybuildings'. It is therefore not legally possible, contrary to the Applicant's assertion, to regard theApplication site as previously developed land. The Application is for high density housingcomprising 55 flats and 7 houses, 62 units in total, with just 45 car parking spaces. Assuming carownership at 1.75 cars per household, some additional 60 vehicles would need to be parked onlocal streets.A five storey block of flats is proposed to face onto College Road directly opposite the CliftonPavilion. Although most houses in this suburban part of Clifton have ample landscaped frontgardens, this building is set back only between 0.7m and 1.4m from the pavement. The eaves ofthe roof are some 3m higher than the parapet level of the adjoining houses. Although thearchitecture here is neo-classical and gothic with painted stucco, the architects have opted to'reflect' the very much later rubble stone vernacular found in other parts of Hotwells and Bristol.When compared with the scale and density of the existing housing in this part of the ConservationArea, the same area of land would have been originally developed with about 7 detached or semi-detached villas capable of conversion into a maximum of 28 flats. All car parking would have beenprovided within the curtilage and not on the street. By this measure, the density of the proposeddevelopment is some 130% greater than the historic fabric of this part of the Clifton

ConservationArea. Such high urban densities are probably not found in any other part of Bristol,let aloneClifton.As a direct consequence, the proposal utterly fails to preserve the character of theConservationArea as required by Planning Policy and by Planning Law.The elegant garden citycharacter wouldbe irreparably harmed.In addition to the incongruous layout and form of thedevelopment, the architectural language iscompletely alien and inappropriate.Further, the 'affordable' housing element comprises one blockof 14 flat, designed to absoluteminimum floor areas, with the ground floor flats facing onto a roadwithout any form of private openspace.

I am writing to object to the application.For the purposes of the National Planning Policy Framework the entire site of the BristolZoological Gardens, including its 'car park', should be considered to be a Park. The Bristol TreeForum have objected to the proposals, agreeing that 'this 'car park' is an integral part of the BristolZoo Gardens'. It sits within the setting of 8 listed buildings, including the houses facing on toClifton Down. In 1999 the land to the rear of 4 of these was in use by the Bristol ZoologicalGardens for horticultural and other ancillary uses. The NPPF explicitly excludes from its definitionof previously developed land 'land that is or has been occupied by agricultural or forestrybuildings'. It is therefore not legally possible, contrary to the Applicant's assertion, to regard theApplication site as previously developed land. The Application is for high density housingcomprising 55 flats and 7 houses, 62 units in total, with just 45 car parking spaces. Assuming carownership at 1.75 cars per household, some additional 60 vehicles would need to be parked onlocal streets.A five storey block of flats is proposed to face onto College Road directly opposite the CliftonPavilion. Although most houses in this suburban part of Clifton have ample landscaped frontgardens, this building is set back only between 0.7m and 1.4m from the pavement. The eaves ofthe roof are some 3m higher than the parapet level of the adjoining houses. Although thearchitecture here is neo-classical and gothic with painted stucco, the architects have opted to'reflect' the very much later rubble stone vernacular found in other parts of Hotwells and Bristol.When compared with the scale and density of the existing housing in this part of the ConservationArea, the same area of land would have been originally developed with about 7 detached or semi-detached villas capable of conversion into a maximum of 28 flats. All car parking would have beenprovided within the curtilage and not on the street. By this measure, the density of the proposeddevelopment is some 130% greater than the historic fabric of this part of the Clifton

ConservationArea. Such high urban densities are probably not found in any other part of Bristol,let aloneClifton.As a direct consequence, the proposal utterly fails to preserve the character of theConservationArea as required by Planning Policy and by Planning Law.The elegant garden citycharacter wouldbe irreparably harmed.In addition to the incongruous layout and form of thedevelopment, the architectural language iscompletely alien and inappropriate.Further, the 'affordable' housing element comprises one blockof 14 flat, designed to absoluteminimum floor areas, with the ground floor flats facing onto a roadwithout any form of private openspace.

I wish to object to this schemebecause:1. The development is over intensive.2. The buildings are out of keeping with the surrounding buildings.3. The buildings are too tall and remain so even with the revised plan.4. There is inadequate amenity space.5. This development fails to enhance the Conservation Area and is inappropriate.6. There is inadequate provision for parking for this plan.7. Too few trees.

As has been objected to by others, our main concerns with the proposed redevelopmentare listed below.

We believe that all of our objections could fairly easily be incorporated into a revised design whichwould then allow the development to be beneficial for the zoo owners, the local residents and thewider community. We welcome change, but in the right way.

1. Overbearing on street scene. The site is 5 storeys on the College Road side which will dominatethe surrounding houses. If the development was 4 storeys this would be resolved. The building isalso set back less from the road than surrounding houses which will create a domineering feelingto the road. This is also the case from the Cecil Road side with the proposed apartment blockbeing significantly deeper than the surrounding houses. This sets a dangerous precedent for thelarger zoo site that if developed in a similar way would change the nature of the Clifton area.

2. Parking - the proposal includes 45 car parking spaces for 62 units which is not sufficient. Iunderstand the council have stated there will be no RPZ spaces allocated to this development, butwhat guarantees do we have that this will not change? No consideration seems to have beenmade for visitors to this development and where they will park which will provide further pressureon the surrounding area which is already under stress for poor parking with all the multi-let studentproperties.

3. Trees - The development includes the felling of 15+ mature trees. The proposal to replace theseis insufficient and sets a dangerous precedent for the broader zoo site.

As has been objected to by others, our main concerns with the proposed redevelopmentare listed below.

We believe that all of our objections could fairly easily be incorporated into a revised design whichwould then allow the development to be beneficial for the zoo owners, the local residents and thewider community. We welcome change, but in the right way.

1. Overbearing on street scene. The site is 5 storeys on the College Road side which will dominatethe surrounding houses. If the development was 4 storeys this would be resolved. The building isalso set back less from the road than surrounding houses which will create a domineering feelingto the road. This is also the case from the Cecil Road side with the proposed apartment blockbeing significantly deeper than the surrounding houses. This sets a dangerous precedent for thelarger zoo site that if developed in a similar way would change the nature of the Clifton area.

2. Parking - the proposal includes 45 car parking spaces for 62 units which is not sufficient. Iunderstand the council have stated there will be no RPZ spaces allocated to this development, butwhat guarantees do we have that this will not change? No consideration seems to have beenmade for visitors to this development and where they will park which will provide further pressureon the surrounding area which is already under stress for poor parking with all the multi-let studentproperties.

3. Trees - The development includes the felling of 15+ mature trees. The proposal to replace theseis insufficient and sets a dangerous precedent for the broader zoo site.

The renewed application differs little from the previous one, and is subject to the sameobjections - unsympathetic to the neighbouring properties, out of scale, and likely to cause traffic/parking problemd

This plan is totally out of keeping with the Victorian flavour of this part of Clifton. Exitfrom College Road to Upper Belgrave Road is already difficult and hazardous and this will getworse with the increase in traffic caused by the development.The development is too dense and atleast one storey too high.There should be a planting scheme between any development andCollege Road.

I am writing to object to the application.For the purposes of the National Planning Policy Framework the entire site of the BristolZoological Gardens, including its 'car park', should be considered to be a Park. The Bristol TreeForum have objected to the proposals, agreeing that 'this 'car park' is an integral part of the BristolZoo Gardens'. It sits within the setting of 8 listed buildings, including the houses facing on toClifton Down. In 1999 the land to the rear of 4 of these was in use by the Bristol ZoologicalGardens for horticultural and other ancillary uses. The NPPF explicitly excludes from its definitionof previously developed land 'land that is or has been occupied by agricultural or forestrybuildings'. It is therefore not legally possible, contrary to the Applicant's assertion, to regard theApplication site as previously developed land. The Application is for high density housingcomprising 55 flats and 7 houses, 62 units in total, with just 45 car parking spaces. Assuming carownership at 1.75 cars per household, some additional 60 vehicles would need to be parked onlocal streets.A five storey block of flats is proposed to face onto College Road directly opposite the CliftonPavilion. Although most houses in this suburban part of Clifton have ample landscaped frontgardens, this building is set back only between 0.7m and 1.4m from the pavement. The eaves ofthe roof are some 3m higher than the parapet level of the adjoining houses. Although thearchitecture here is neo-classical and gothic with painted stucco, the architects have opted to'reflect' the very much later rubble stone vernacular found in other parts of Hotwells and Bristol.When compared with the scale and density of the existing housing in this part of the ConservationArea, the same area of land would have been originally developed with about 7 detached or semi-detached villas capable of conversion into a maximum of 28 flats. All car parking would have beenprovided within the curtilage and not on the street. By this measure, the density of the proposeddevelopment is some 130% greater than the historic fabric of this part of the Clifton

ConservationArea. Such high urban densities are probably not found in any other part of Bristol,let aloneClifton.As a direct consequence, the proposal utterly fails to preserve the character of theConservationArea as required by Planning Policy and by Planning Law.The elegant garden citycharacter wouldbe irreparably harmed.In addition to the incongruous layout and form of thedevelopment, the architectural language iscompletely alien and inappropriate.Further, the 'affordable' housing element comprises one blockof 14 flat, designed to absoluteminimum floor areas, with the ground floor flats facing onto a roadwithout any form of private openspace.

I am writing to object to the application.For the purposes of the National Planning Policy Framework the entire site of the BristolZoological Gardens, including its 'car park', should be considered to be a Park. The Bristol TreeForum have objected to the proposals, agreeing that 'this 'car park' is an integral part of the BristolZoo Gardens'. It sits within the setting of 8 listed buildings, including the houses facing on toClifton Down. In 1999 the land to the rear of 4 of these was in use by the Bristol ZoologicalGardens for horticultural and other ancillary uses. The NPPF explicitly excludes from its definitionof previously developed land 'land that is or has been occupied by agricultural or forestrybuildings'. It is therefore not legally possible, contrary to the Applicant's assertion, to regard theApplication site as previously developed land. The Application is for high density housingcomprising 55 flats and 7 houses, 62 units in total, with just 45 car parking spaces. Assuming carownership at 1.75 cars per household, some additional 60 vehicles would need to be parked onlocal streets.A five storey block of flats is proposed to face onto College Road directly opposite the CliftonPavilion. Although most houses in this suburban part of Clifton have ample landscaped frontgardens, this building is set back only between 0.7m and 1.4m from the pavement. The eaves ofthe roof are some 3m higher than the parapet level of the adjoining houses. Although thearchitecture here is neo-classical and gothic with painted stucco, the architects have opted to'reflect' the very much later rubble stone vernacular found in other parts of Hotwells and Bristol.When compared with the scale and density of the existing housing in this part of the ConservationArea, the same area of land would have been originally developed with about 7 detached or semi-detached villas capable of conversion into a maximum of 28 flats. All car parking would have beenprovided within the curtilage and not on the street. By this measure, the density of the proposeddevelopment is some 130% greater than the historic fabric of this part of the Clifton

ConservationArea. Such high urban densities are probably not found in any other part of Bristol,let aloneClifton.As a direct consequence, the proposal utterly fails to preserve the character of theConservationArea as required by Planning Policy and by Planning Law.The elegant garden citycharacter wouldbe irreparably harmed.In addition to the incongruous layout and form of thedevelopment, the architectural language iscompletely alien and inappropriate.Further, the 'affordable' housing element comprises one blockof 14 flat, designed to absoluteminimum floor areas, with the ground floor flats facing onto a roadwithout any form of private openspace.

I wish to oppose this application. The plan is to develop the site in a way that is totallyout of keeping with the surrounding neighbourhood. It is disappointing that the zoo directors seemhappy to maximise the income from sale of this site, without consideration for what they leavebehind.Specific reasons for objection--Too many units in the plan. The reduction from 65 to 62 is risible.-Not enough affordable housing.-Not enough car parking built into the scheme. Assuming the owners have one car per unit, wherewill 17 cars find space to park, knowing that all of Clifton has a problem?-The scheme does not have enough open space built into it, as a result of the density of thebuilding.-The design lacks imagination, and has no architectural merit, in a part of Bristol which is full ofinteresting and well-designed properties.

This revised application seems little different to the first. It's too high, too big for thespace and very unsympathetic to the area - a conversation area, too. My objections submitted on30th June still stand and this objection is to support my earlier one.

I have read the revised variation of the original Planning Application. Since the changessuggested are relatively minor I continue to object to this scheme for the reasons set out in myprevious comments made on 24 June 2021, which are repeated below:

Comments for Planning Application 21/01999/FApplication SummaryApplication Number: 21/01999/FAddress: Former Car Park College Road Clifton Bristol BS8 3HXProposal: Erection of 65 dwellings with associated parking, new vehicular access, and associatedinfrastructure and landscaping.Case Officer: Peter WestburyCustomer DetailsName: Mr Brian Carr Address: Clifton Down BristolComment DetailsCommenter Type: NeighbourStance: Customer objects to the Planning ApplicationComment Reasons:Comment:I wish to object to this scheme for the following reasons:1. The current proposals would result in an over-development of the site2. 65 dwellings on this site is too many and the height of Block A should be reduced by at leastone storey. Also its design is not in keeping with the existing buildings in College Road and otherbuildings in the vicinity3. The current proposals fail to preserve the character of the Clifton Conservation area and theplan is not consistent with the Zoo's stated vision ' to respond sensitively to the setting and context

of the site'4. The parking provision is inadequate and the proposed access could result in traffic issues5 There is insufficient amenity space and attractive green landscaping

I have read the revised variation of the original Planning Application. Since the changessuggested are relatively minor I continue to object to this scheme for the reasons set out in myprevious comments made on 24 June 2021. Please refer to those comments.

Dear Sir/Madam,

I wish to object to the revised Planning application.-

1) The proposed massive Block A of high density homes is totally out of keeping with the area and the neighbouring terrace of houses. It would be an overpowering block. The proposed development is over-intensive and too tall.

2) The poor design is not compatible with the surrounding buildings and this Conservation area. The objective should be to maintain or enhance the character of this Conservation area.

2) Access to the new site should be, as now, from College Road. This point of access has worked for many years. It will help to achieve the redesign required by points (1) and (2) above and it will avoid the many traffic and community problems that would arise if access is from Cecil Road.

3) The density of homes proposed is inappropriate for this area and would set a bad precedent for the future redevelopment of the zoo site.

4) Enforcing point (3) above, the assumption of 45 cars and car parking for 62 homes seems unrealistic. We think the number of cars and traffic impact on the area would be much higher from so many homes and a real problem for the area and student/resident safety.

5) The proposal has inadequate amenity space and reduces the number of mature

trees.

For the above reasons this planning application should be refused.

Regards,

David Wells

I wish to object to the revised Proposal on the following grounds:

1. The development is over intensive with inadequate car parking and amenity areas.The height of the building on College Road is higher than the Victorian houses next door and the design is not at all in line with a conservation area.

2.. Will cause a large increase of traffic in Cecil and College Road therefore causing higher levels of pollution in the area.

3. A number of mature trees will be lost which is great cause for concern.

The proposal should be refused..

Patricia Wells

To whom it may concern I object to the latest application for development as it remains unsympathetic to the area, especially in terms of buildings height and density of occupation.

Andrew Paten

I feel that this greedy over development proposal is a gross infringement in this conservation area which unfortunately will meet the low standards we have come to expect from Bristol Planning Department and its officers.Situated among some of the most elegant and expensive housing in Bristol, most of which is in single occupancy, and to inflict it upon those living nearby also those of us who cherish what there is which makes Clifton unique is tantamount to a criminal act.This being only a small portion of the proposed development of the Bristol Zoo site it does not bode well regarding future planning applications because, if allowed, precedence will have been set for ultra high density residential building on the rest of the Zoo site which will become a blot on the Clifton landscape.The planning department needs to man up and totally resist this application taking it to appeal and beyond if necessary. If they feel they cannot do so they should resign and let others with more backbone take their place.

Dr. D. Shapland,

I am very against this proposed development of the Bristol Zoo's west car park. To startwith the planned buildings are too high and extremely ugly and not at all in keeping with thesurrounding Victorian architecture. Secondly far too many dwellings are being crammed into thelimited area with the resulting lack of any appreciable garden spaces. The site will not be able tomanage the increase in traffic and required parking spaces. The proposals do not preserve thecharacter of this Conservation area of Clifton. In my opinion the architects have designedsomething which is totally inappropriate and their plans should be binned immediately!

As an owner of a flat in College Road and having worked for many years in Clifton I feelstrongly that this application is over-development of the site.

As the zoo's latest planning application is virtually the same as the original, with only minorchanges, my original objection still stands.

As joint owner with my wife of a flat in College Road, I feel strongly that this latestapplication is still over-development of the site.

As the zoo's latest planning application is virtually the same as the original, with only minorchanges, my original objection still stands.

Dear sir/ madam,

I would like to object to the above proposed development.

My concerns are;

The design is out of keeping and unimaginative in a Conservation area.The whole of the zoo gardens and carpark development proposals should be considered as one.The density, height and scale fail to preserve the local character of this area of Bristol.The loss of a local and popular amenity to housing.The extra car parking required on the adjacent streets coupled with potentially more parking again with the zoo garden site (as yet unknown).I feel the attractive wall on College Road should be retained with access to this development off College Road and not Cecil Road.

Many thanks for the opportunity to comment.

Yours faithfully,

Antony Vallance

Although I am a supporter of the Bristol Zoo, I am very disappointed by the proposalsput forward for the West Car Park site.1. The density of housing units, even with the revised reduction to 62 from 65, is still much toohigh.2. Coupled with this, the provision of only 45 parking places is too small. Comparable to those whoplan new hospitals - never enough beds, based on unrealistic premises, the notion that theoccupants in the new houses will forgo having cars because of the meagre provision of parking iswishful thinking. The cars that cannot be accommodated on site will add to those on thesurrounding streets, to the aggravation of current residents.3. The designs presented are neither in close sympathy with the nearby buildings nor are theyimaginative but different - as is the case with the extension to St. George's. Even with the revisedlower height of the block on College Road, this structure is much too close to the road, has afacade that is not in keeping with its neighbours and will still create an oppressive feel. Some newbuildings nearby such as 46 / 48 Canynge Road harmonise with their surroundings; much of theproposed scheme, especially block A, does not.4. At present the trees and space within the site give it an open character which integrates with thesurrounding areas. This will be lost by the density of the proposal.5. Affordable housing is included, but the provision per unit is mean.Overall, this is a scheme that does no credit to Bristol Zoo, does not achieve what should be for aconservation area, and shoukd be rejected.

The proposed changes have not made me change my mind from my previouscomment. I feel that this development is inappropriate for such a prime site, and is out of characterfor the Conservation Area in which it is located.The site will be over developed, with little provision for onsite parking, which will have adetrimental effect on the available parking in the surrounding area.

I still object to this planning application. The size and style of buildings do not fit in withthe local area. Clifton is an important conservation area and this development would change thispart of Clifton. The number of parking spaces is completely unrealistic for the planned number offlats, and the total number of flats is much too great for this site anyway.I am very aware that Bristol needs more housing but this is not the way to do it. We also needaffaordable housoing, but these are small and mean with minimal size of living space.I strongly advise the council to reject this application.

I am objecting on a number of grounds:

- The number of dwellings is still too great.- The scale and density of the buildings are not in keeping with their surroundings.- The block of flats is particularly inappropriate architecturally.- the proposed development will have a deleterious effect upon the Conservation area- The loss of trees is especially concerning given the Zoo's wish to be environmentally responsible- The development will lead to parking problems.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Dear Sir or Madam

I understand there have been minor revisions to the above scheme which make no material difference to the original scheme and therefore I wish to reconfirm my objection.

The principle of over development of an important site within a Conservation Area has still been completely ignored. The design has no synergy with the surrounding buildings or the greater Clifton area. There is inadequate on-site parking and the additional vehicles of the development's residents will only exacerbate currently restricted parking on the surrounding roads.

It is appalling that the Zoo is showing no regard for what is part of an important and historic site. While appreciating that the trustees have an obligation to maximise revenue that could be achieved by opening the design to competition whereby a scheme could be picked that met good design practice and also produced a high value.

Please re-register my objection.

Yours faithfully

Brian Hanson CBE FRICS

Further to my previous objection to the scheme for Bristol zoo car park west, I continue to hold the view as stated before, and that the minor "modifications" to the design do nothing to address its poor architectural quality. It would offer its residents a poor quality environment, particularly the so- called low cost flats, hard up against the road and with no outside space whatsoever.The materials are a dreadful hotch potch which in no way resemble the make- up of the local houses and the density of the scheme verges on the inhuman.Gillian Woodman-Smith

Commenter Type: Area resident

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I find it ironic that the Zoo is moving so that the animals can have more space and abetter environment but have put in an application for a cramped environment for people, some ofwhom will have no private outdoor area - not even a balcony.

In my letter of 21stJune I wrote: 'Many of those who support the application live outside Bristol andsome say that they have been connected with the Zoo in a capacity such as a trustee. Of the 25letters of support: 3 had no text shown. Ten made no mention of the proposed buildings. Tenthought the proposed buildings would be appropriate. Two went into more detail about the Zoomoving but not about the plans. This application is for a specific development on the site thereforethe twelve that do not comment on the proposed buildings are not relevant and should bediscounted'At that date there were 58 letters opposing the plan. Between 21st June and 10th August therehave been three more letters of support and 197 opposing either the original plans or the revisedones. This means that just over 90% of those who have sent online letters object to the currentapplication. These are not all from residents in the immediate locality but come from other areasas well, which shows the concern of people that if the site is to be for residential use, then it shouldbe an attractive one fitting to its surroundings.

I am objecting to the application for the following reasons:

1. The density of the housing, the height of the blocks of flats and, the lack of open space.

2. The site is in the Clifton and Hotwells Conservation Area and in no way does the design of theblocks of flats enhance the area nor blend in with adjacent houses many of which are listed. The

small revisions to the original application make insignificant difference to this.

3. The proposed provision for parking is inadequate. It is not acceptable that a new developmentdoes not provide at least the same number of parking spaces as dwellings. Residents may be ableto walk, go on two wheels or use public transport to go to and from a place of work but most willwant a vehicle for leisure pursuits.

4. The detailed survey by the Tree Forum shows the lack of concern by the architects toincorporate many of the trees into their plans - they are to be felled.5. I appreciate that the Zoo needs funds but feel strongly that this site and the main site should belooked at together. They are complementary now and could be in the future.

The latest changes to the Block A proposal actually manage to make the situationworse for my property! While there has been a token reduction in height, Block A has been movedback from College Road, thus making the visual intrusion on our property from the block evenmore obvious.

What makes it worse is that nothing has been done to alleviate the dreadful Soviet-style aestheticsof the block itself. Is Block A and the rest of the West Car Park development really meant toenhance what is a conservation area and a garden suburb? It's not much of a legacy for the zoo toleave behind but it's something their former neighbours will be stuck with for a long time.

The development involves cutting down trees, erecting a very ugly building blockinglight for residents and encouraging even more traffic congestion to the area- there are better usesbeing put forward for the site.

How is it that Bristol Zoo can contemplate leaving, as its legacy to the community ofwhich it has been a part for the past 185 years, a development as inappropriate to ourconservation area as that currently proposed? Surely they must understand that profitmaximisation is not the only driver they should use, in shaping the buildings they leave behind?How can they be content to leave such a crowded development with such an 'incongruous layoutand form*', 'completely alien and inappropriate architectural language*', and such an egregiouslack of parking provision, given the current parking difficulties experienced by residents?

Michael Woodman Smith, in his appraisal of the Zoo's scheme on behalf of local residents'groups*, asserts that, because some of the land comprising the west car park was formerly usedfor horticultural purposes, it is, in the NPPF's framework, 'land that is or has been occupied byagricultural or forestry buildings', and therefore, contrary to the assertion of the planning applicant,it is not legally possible to regard the site as previously developed land. He states that the west carpark needs to be regarded as integral to the park comprised by Bristol Zoological Gardens.

The proposed block of flats facing onto College Road has effectively no front garden, its eaves are3 metres higher than the parapet level of the houses adjacent, and the high density of proposeddevelopment is 'probably not found in any other part of Bristol, let alone Clifton*'. The recentchanges are effectively meaningless as modifications.

To quote again, 'the proposal utterly fails to preserve the character of our conservation area, asrequired by Planning Policy and Planning Law*'.

Ref: 'Bristol Zoological Park - Development Proposals for the Western Car Park 21/01999/F -

Summary scheme Appraisal for Local Residents' Groups, by Michael Woodman Smith.

How is it that Bristol Zoo can contemplate leaving, as its legacy to the community ofwhich it has been a part for the past 185 years, a development as inappropriate to ourconservation area as that currently proposed? Surely they must understand that profitmaximisation is not the only driver they should use, in shaping the buildings they leave behind?How can they be content to leave such a crowded development with such an 'incongruous layoutand form*', 'completely alien and inappropriate architectural language*', and such an egregiouslack of parking provision, given the current parking difficulties experienced by residents?

Michael Woodman Smith, in his appraisal of the Zoo's scheme on behalf of local residents'groups*, asserts that, because some of the land comprising the west car park was formerly usedfor horticultural purposes, it is, in the NPPF's framework, 'land that is or has been occupied byagricultural or forestry buildings', and therefore, contrary to the assertion of the planning applicant,it is not legally possible to regard the site as previously developed land. He states that the west carpark needs to be regarded as integral to the park comprised by Bristol Zoological Gardens.

The proposed block of flats facing onto College Road has effectively no front garden, its eaves are3 metres higher than the parapet level of the houses adjacent, and the high density of proposeddevelopment is 'probably not found in any other part of Bristol, let alone Clifton*'. The recentchanges are effectively meaningless as modifications.

To quote again, 'the proposal utterly fails to preserve the character of our conservation area, asrequired by Planning Policy and Planning Law*'.

Ref: 'Bristol Zoological Park - Development Proposals for the Western Car Park 21/01999/F -

Summary scheme Appraisal for Local Residents' Groups, by Michael Woodman Smith.

Objection to the revised development plans for the following reasons:- it's still over intensive- it's out of keeping with the conservation area and existing historic buildings- the buildings are too tall- insufficient individual garden areas and/or a community 'town garden'- destruction of existing mature trees.

Any proposed development of the Zoo's West car park area needs to reflect the historic legacy ofthe Zoo Gardens, with a high proportion of green space, gardens and trees.

The revised development plan fails to preserve the character of Clifton's leafy green ambiance,historic buildings and Clifton's Conservation Area.

The revised proposals present minimal changes to the previous plan and are stillunacceptable in terms of too great mass, obtrusive space and a style entirely wrong for thecharacter of this historic setting.

I have read with great alarm the proposed plans for erection of 65 dwellings with associated parking, new vehicular access, and associated infrastructure and landscaping/Former Car Park College Road Bristol.

Over the years I have been a visitor to the Zoo and surrounding areas, this proposal will really ruin this area without the impact on the surrounding properties. An immense change to residents in that area.

M Jones

Dear Sirs,I write to lodge my complaint about this scheme put forward by Bristol Zoo.The application is for much too dense housing without nearly enough parking allocated. The area of each flat is the absolute minimum allowed by law, the ground floor flats open straight onto the street (Clifton Park), the height of the block of flats is much higher than the present street highest level, the quality of building is vastly inferior to the present locality. This proposal utterly fails to preserve the character of this area as required by Planning Policy and Planning Law.This whole site is NOT "previously developed land" but "agricultural buildings and land" and therefore not eligible for the purposes planned.Please reject this planning accordingly.

The latest planning application is virtually the same as the original. I objected to theoriginal application and my first set of comments still stand.

In addition, I have since discovered that the proposed site is not previously developed land andthe proposal may therefore be illegal.

It is assumed that car ownership can be estimated at 1.75 cars per household. This will lead to anadditional 60 vehicles needing to be parked on local streets. This will clog up traffic flow,particularly if the site entrance is to be in Cecil Road, a quite unnecessary and ridiculoussuggestion.

The proposal fails miserably to preserve the character of the Conservation Area as required byPlanning Policy and by Planning Law.

As the latest planning application is virtually the same as the original, with only a fewpaltry changes, my original objection still stands.

In addition, I have since discovered that the proposed site is not previously developed land andthe proposal may therefore be illegal.

It is assumed that car ownership can be estimated at 1.75 cars per household. This will lead to anadditional 60 vehicles needing to be parked on local streets. This will clog up traffic flow,particularly if the site entrance is to be in Cecil Road, a quite unnecessary and ridiculoussuggestion. The present entrance and exit onto College Road have always been effective andshould be retained from the point of view of safety and efficient traffic flow.

The proposal fails miserably to preserve the character of the Conservation Area as required byPlanning Policy and by Planning Law. It represents over development on a massive scale and thedesign is not conducive to retaining the appearance that the people of Bristol have always enjoyedwhen visiting this area of Clifton.

The latest planning application is virtually the same as the original. I objected to theoriginal application and my first set of comments still stand.

In addition, I have since discovered that the proposed site is not previously developed land andthe proposal may therefore be illegal.

It is assumed that car ownership can be estimated at 1.75 cars per household. This will lead to anadditional 60 vehicles needing to be parked on local streets. This will clog up traffic flow,particularly if the site entrance is to be in Cecil Road, a quite unnecessary and ridiculoussuggestion.

The proposal fails miserably to preserve the character of the Conservation Area as required byPlanning Policy and by Planning Law.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I understand that the above application has been revised. I would like to lodge my objection to these new proposals too, please, on the grounds that they are still high density and not in keeping with the style of the street.

Yours faithfully

Marina Milner

I object to the revised application on the followinggrounds - Overdevelopment of the area resulting in parking problems(only 49 spaces for 65 dwellings), and pressure on local roads andservices. Design of proposed new buildings doesn't fit or blend withexisting local architecture, important anywhere but particularly in aconservation area. The 5 storey block proposed is too tall, looking outof keeping with its surroundings and spoiling the view for visitors to thearea as well as residents. It is wrong to fell 15 mature trees when thecouncil's duty is to preserve the natural environment for the benefit ofall. Overall the revised proposal fails to enhance or preserve aconservation area and represents a serious loss of amenity for Bristolwhich would adversely affect current and future populations.

I have updated the objection that I lodged against the first public version of the plans -April 2021 - in the light of the latest revision (fall back 01?) - July 2021. Please take this as myobjection to the plan as revised.

I particularly noticed the top floor change to Block A. My reading is that this has been achieved bythe 2 Bed Types i, ii and iii in Block A being made smaller, and total units in the same block beingreduced by 3.

____________________________________________

Detail:Block A Three fewer units (1x 3F Type i deleted, 1x 3F Type i moved to Type ii; 4F 2x Type iiideleted, 1x 3 Bed moved to 2 Bed Type ii, 2x GF Type iii moved to Type ii)

Block B - unchanged apart from the revamp of flat 44 (Totals of 1 Bed presumably 4 rather than 2shown on 30418_-_WEST_CAR_PARK_-_AS-01-P2_-_SCHEDULE_OF_ACCOMMODATION-2999949.pdf)

Mews - unchanged____________________________________________

I have added to my previous objection using [square brackets].

As a nearby resident I wish to object to this application. [Still stands.]

To me the mock-up of the dominant building in the proposal (Design Access Statement Pages 90-91) gives the impression of a blueprint calibrated to maximise the profit of the developers, withlittle weight given to long term liveability. The details in the application confirm this. An example isthe intention to create 58 flats, with only 35 car parking spaces between them. The shortcomingsare not countered by any of the lipstick-on-a-pig embellishments. Day-to-day deliveries,maintenance call-outs, visitors, car cleaning and waste collection will struggle with the crampedlayout. Over the years Clifton has absorbed space-limited infills, typically of 4-5 units or fewer, buta hit of 65 units in one plot is way OTT.[Although the number of flats has reduced to 55, and so the number of units to 62, my commentstill stands. The planting frontage to Block A is still mean. To me the change in the top floors doesnot change the uninspiring appearance of the block. There is nothing that one would want to copyelsewhere.]

I agree with other public comments that the scheme exemplifies over-development, and wouldsignificantly detract from the setting of the surrounding listed buildings. Setting aside anyaspiration for a Pevsner to be able to enthuse over 'a perfect piece of architecture', a much betterdesign, commanding some admiration now, and in the future, would not come amiss.[Still stands.]

Without questioning the worthy causes to which the sales value will be applied, giving approval tothis site's development independently of a plan for the main site is rather like trying for a quick winby selling off the original frame of an old master painting without considering the future of thewhole composition. Planning consent at this stage would, in effect, prejudge options for the mainsite.[Still stands.]

In the light of the above please refuse the application.[Still stands.]

I maintain my objections to the very slightly amended scheme. The minor adjustmentsare insignificant - reducing the number of dwellings by just 3 whilst the unsightly block on CollegeRoad is only marginally altered and the entrance via Cecil Road remains.The new proposals replicate what has been correctly described as the 'totalitarian' or 'Easternbloc' or 'Communist era' nature of the earlier scheme. Sadly, as has been the case throughout, theapplicants have ignored the legitimate concerns of the objectors and, in their concern to maximisetheir commercial return to the exclusion of all other public benefit considerations, demonstrated asurprising ignorance of their duties as trustees. it is abundantly clear for the reasons explained bythe many, many objectors that the proposals, whether in their original or amended form, utterly failto preserve the character of the Conservation Area.

Moreover, it has now emerged that the land in question site may not be a brownfield site at all.This requires proper investigation.

My earlier objections remain:

The scheme for which the Zooseeks approval is wholly inconsistent with the basic principles of conservation. As Historic Englandhas noted in its submissions, the National Planning Policy framework defines 'conservation' as 'theprocess of maintaining and managing change to a heritage asset in a way that sustains and,where appropriate, enhances its significance.' The scheme comes nowhere near satisfying thatbasic principle.

There are well over 200 people objecting to the scheme - some 95% or so of those who have

made submissions. The proportion would be greater if the Zoo had not inflated the numbers infavour by ensuring that certain of its directors made submissions in support (without indicatingeither their status or that they had an obvious interest in the success of the application).

In essence, the objectors make the same or similar points in complaining about the scheme. It canbe no coincidence that so many people have reached the same conclusions nor that, crucially,their objections are reinforced in the recent submissions of Historic England.

Helpfully, Historic England has drawn attention to the 'combination of formal Gothic architectureand mature planting [that] are an essential focus of this part of the conservation area [and the]liberal use of rubble limestone and Bathstone dressings on both building and walls [that] alsopredominates and [so] creates a consistency between buildings and their settings.' The proposalsmake no concessions whatsoever to this highly relevant context in which the development isproposed - a unique Conservation Area of national significance.

The common features of the huge number of objections are these:

1. The proposals constitute over intensive development. In the words of Historic England, 'theproposed layout, massing and design fails to respond to the character and appearance of theConservation Area'.

2. The buildings are too tall, especially those proposed on College Road and are out of keepingwith surrounding buildings. As Historic England puts it, '[the] robust rhythm of weighty Victorianvillas, constructed predominantly from dressed rubble and Bath stone detailing, is certainly theoverriding built form and the concept of a terraced approach of this scale alongside the existingshort terrace is of considerable concern.'

3. The poor design and over-massing would damage the settings of surrounding buildings.

4. The parking provision is hopelessly inadequate.

5. Amenity space is inadequate.

6. A significant number of trees would be lost.

7. There is no conservation merit in creating a vehicular entrance to the site from Cecil Road whenthere already exists a perfectly satisfactory entrance from College Road.

8. The proposals fail altogether to preserve or enhance the character of the Conservation Area. Infact, they would do the opposite: significant damage.

We agree with all these objections. The applicants have made no attempt to ensure that the

scheme is appropriate for the Conservation Area. As Historic England has explained, 'While theexisting car park does not contribute positively to the Conservation Area, its open aspect andenclosure behind the high stone wall of College Road is indicative of the juxtaposition of rows ofsubstantial villas against substantial, open spaces'.

The proposals should at the very least have taken notice of the positive contribution to theConservation Area of this wall and the need to comply with the Conservation Area Appraisal, bothof which Historic England has emphasised. As it has explained: 'If development were to be furtherset back into the site, the impact of the development could be reduced and the boundary wallcould be retained in a more meaningful and contextual way.'

There is a further matter of concern. On their website, the Zoo claims that 'We have been througha very rigorous process to explore a number of options as well as taking independent professionaladvice from a range of sources to ensure we are taking the best possible course of action for theSociety's future.' It maintains that 'As part of our extensive review in 2020, we explored otheroptions for the Clifton site, which included other types of visitor attraction and other types of zoos.Working with professional advisors we do not believe that any will be viable or sustainable overthe long-term on the Clifton site.'

It has not however made public the other options that it considered.

The reason for this lack of transparency has to be a matter of conjecture but one possible reasonmay be apparent from a letter which its Chief Executive wrote on 8 April to those who respondedto its initial proposal in which he stated that 'As the Society is a charity, the Trustees are legallyrequired to obtain maximum value from the charity's assets to reinvest in its charitableobjectives...'

That, regrettably, is a misconception. It takes no account of the obligation to ensure that indischarge of its charitable purposes the trustees pay appropriate regard to the overriding need toensure a public benefit of its activities. It is clear that the trustees are instead determined simplyand solely to maximise the development potential of the site to the wholesale exclusion of anyother considerations. The failure to appreciate, let alone give effect to, their wider social andfiduciary responsibilities is concerning.

In their submissions, Historic England conclude that 'your authority would be justified inrecommending ... refusal'. They ask that 'the applicants ... bring forward a wider masterplan for thesite to allow [the] proposals to be considered in a wider context.'We ask that in their present form the proposals be rejected and that the applicants consider amore imaginative scheme for the site that will produce a reasonable commercial return yet payproper respect to the setting of the site in a Conservation Area of national significance.

I maintain my objections to the very slightly amended scheme. The minor adjustmentsare insignificant - reducing the number of dwellings by just 3 whilst the unsightly block on CollegeRoad is only marginally altered and the entrance via Cecil Road remains.The new proposals replicate what has been correctly described as the 'totalitarian' or 'Easternbloc' or 'Communist era' nature of the earlier scheme. Sadly, as has been the case throughout, theapplicants have ignored the legitimate concerns of the objectors and, in their concern to maximisetheir commercial return to the exclusion of all other public benefit considerations, demonstrated asurprising ignorance of their duties as trustees. it is abundantly clear for the reasons explained bythe many, many objectors that the proposals, whether in their original or amended form, utterly failto preserve the character of the Conservation Area.

Moreover, it has now emerged that the land in question site may not be a brownfield site at all.This requires proper investigation.

My earlier objections remain:

The scheme for which the Zooseeks approval is wholly inconsistent with the basic principles of conservation. As Historic Englandhas noted in its submissions, the National Planning Policy framework defines 'conservation' as 'theprocess of maintaining and managing change to a heritage asset in a way that sustains and,where appropriate, enhances its significance.' The scheme comes nowhere near satisfying thatbasic principle.

There are well over 200 people objecting to the scheme - some 95% or so of those who have

made submissions. The proportion would be greater if the Zoo had not inflated the numbers infavour by ensuring that certain of its directors made submissions in support (without indicatingeither their status or that they had an obvious interest in the success of the application).

In essence, the objectors make the same or similar points in complaining about the scheme. It canbe no coincidence that so many people have reached the same conclusions nor that, crucially,their objections are reinforced in the recent submissions of Historic England.

Helpfully, Historic England has drawn attention to the 'combination of formal Gothic architectureand mature planting [that] are an essential focus of this part of the conservation area [and the]liberal use of rubble limestone and Bathstone dressings on both building and walls [that] alsopredominates and [so] creates a consistency between buildings and their settings.' The proposalsmake no concessions whatsoever to this highly relevant context in which the development isproposed - a unique Conservation Area of national significance.

The common features of the huge number of objections are these:

1. The proposals constitute over intensive development. In the words of Historic England, 'theproposed layout, massing and design fails to respond to the character and appearance of theConservation Area'.

2. The buildings are too tall, especially those proposed on College Road and are out of keepingwith surrounding buildings. As Historic England puts it, '[the] robust rhythm of weighty Victorianvillas, constructed predominantly from dressed rubble and Bath stone detailing, is certainly theoverriding built form and the concept of a terraced approach of this scale alongside the existingshort terrace is of considerable concern.'

3. The poor design and over-massing would damage the settings of surrounding buildings.

4. The parking provision is hopelessly inadequate.

5. Amenity space is inadequate.

6. A significant number of trees would be lost.

7. There is no conservation merit in creating a vehicular entrance to the site from Cecil Road whenthere already exists a perfectly satisfactory entrance from College Road.

8. The proposals fail altogether to preserve or enhance the character of the Conservation Area. Infact, they would do the opposite: significant damage.

We agree with all these objections. The applicants have made no attempt to ensure that the

scheme is appropriate for the Conservation Area. As Historic England has explained, 'While theexisting car park does not contribute positively to the Conservation Area, its open aspect andenclosure behind the high stone wall of College Road is indicative of the juxtaposition of rows ofsubstantial villas against substantial, open spaces'.

The proposals should at the very least have taken notice of the positive contribution to theConservation Area of this wall and the need to comply with the Conservation Area Appraisal, bothof which Historic England has emphasised. As it has explained: 'If development were to be furtherset back into the site, the impact of the development could be reduced and the boundary wallcould be retained in a more meaningful and contextual way.'

There is a further matter of concern. On their website, the Zoo claims that 'We have been througha very rigorous process to explore a number of options as well as taking independent professionaladvice from a range of sources to ensure we are taking the best possible course of action for theSociety's future.' It maintains that 'As part of our extensive review in 2020, we explored otheroptions for the Clifton site, which included other types of visitor attraction and other types of zoos.Working with professional advisors we do not believe that any will be viable or sustainable overthe long-term on the Clifton site.'

It has not however made public the other options that it considered.

The reason for this lack of transparency has to be a matter of conjecture but one possible reasonmay be apparent from a letter which its Chief Executive wrote on 8 April to those who respondedto its initial proposal in which he stated that 'As the Society is a charity, the Trustees are legallyrequired to obtain maximum value from the charity's assets to reinvest in its charitableobjectives...'

That, regrettably, is a misconception. It takes no account of the obligation to ensure that indischarge of its charitable purposes the trustees pay appropriate regard to the overriding need toensure a public benefit of its activities. It is clear that the trustees are instead determined simplyand solely to maximise the development potential of the site to the wholesale exclusion of anyother considerations. The failure to appreciate, let alone give effect to, their wider social andfiduciary responsibilities is concerning.

In their submissions, Historic England conclude that 'your authority would be justified inrecommending ... refusal'. They ask that 'the applicants ... bring forward a wider masterplan for thesite to allow [the] proposals to be considered in a wider context.'We ask that in their present form the proposals be rejected and that the applicants consider amore imaginative scheme for the site that will produce a reasonable commercial return yet payproper respect to the setting of the site in a Conservation Area of national significance.

I maintain my objections to the very slightly amended scheme. The minor adjustmentsare insignificant - reducing the number of dwellings by just 3 whilst the unsightly block on CollegeRoad is only marginally altered and the entrance via Cecil Road remains.The new proposals replicate what has been correctly described as the 'totalitarian' or 'Easternbloc' or 'Communist era' nature of the earlier scheme. Sadly, as has been the case throughout, theapplicants have ignored the legitimate concerns of the objectors and, in their concern to maximisetheir commercial return to the exclusion of all other public benefit considerations, demonstrated asurprising ignorance of their duties as trustees. it is abundantly clear for the reasons explained bythe many, many objectors that the proposals, whether in their original or amended form, utterly failto preserve the character of the Conservation Area.

Moreover, it has now emerged that the land in question site may not be a brownfield site at all.This requires proper investigation.

My earlier objections remain:

The scheme for which the Zooseeks approval is wholly inconsistent with the basic principles of conservation. As Historic Englandhas noted in its submissions, the National Planning Policy framework defines 'conservation' as 'theprocess of maintaining and managing change to a heritage asset in a way that sustains and,where appropriate, enhances its significance.' The scheme comes nowhere near satisfying thatbasic principle.

There are well over 200 people objecting to the scheme - some 95% or so of those who have

made submissions. The proportion would be greater if the Zoo had not inflated the numbers infavour by ensuring that certain of its directors made submissions in support (without indicatingeither their status or that they had an obvious interest in the success of the application).

In essence, the objectors make the same or similar points in complaining about the scheme. It canbe no coincidence that so many people have reached the same conclusions nor that, crucially,their objections are reinforced in the recent submissions of Historic England.

Helpfully, Historic England has drawn attention to the 'combination of formal Gothic architectureand mature planting [that] are an essential focus of this part of the conservation area [and the]liberal use of rubble limestone and Bathstone dressings on both building and walls [that] alsopredominates and [so] creates a consistency between buildings and their settings.' The proposalsmake no concessions whatsoever to this highly relevant context in which the development isproposed - a unique Conservation Area of national significance.

The common features of the huge number of objections are these:

1. The proposals constitute over intensive development. In the words of Historic England, 'theproposed layout, massing and design fails to respond to the character and appearance of theConservation Area'.

2. The buildings are too tall, especially those proposed on College Road and are out of keepingwith surrounding buildings. As Historic England puts it, '[the] robust rhythm of weighty Victorianvillas, constructed predominantly from dressed rubble and Bath stone detailing, is certainly theoverriding built form and the concept of a terraced approach of this scale alongside the existingshort terrace is of considerable concern.'

3. The poor design and over-massing would damage the settings of surrounding buildings.

4. The parking provision is hopelessly inadequate.

5. Amenity space is inadequate.

6. A significant number of trees would be lost.

7. There is no conservation merit in creating a vehicular entrance to the site from Cecil Road whenthere already exists a perfectly satisfactory entrance from College Road.

8. The proposals fail altogether to preserve or enhance the character of the Conservation Area. Infact, they would do the opposite: significant damage.

We agree with all these objections. The applicants have made no attempt to ensure that the

scheme is appropriate for the Conservation Area. As Historic England has explained, 'While theexisting car park does not contribute positively to the Conservation Area, its open aspect andenclosure behind the high stone wall of College Road is indicative of the juxtaposition of rows ofsubstantial villas against substantial, open spaces'.

The proposals should at the very least have taken notice of the positive contribution to theConservation Area of this wall and the need to comply with the Conservation Area Appraisal, bothof which Historic England has emphasised. As it has explained: 'If development were to be furtherset back into the site, the impact of the development could be reduced and the boundary wallcould be retained in a more meaningful and contextual way.'

There is a further matter of concern. On their website, the Zoo claims that 'We have been througha very rigorous process to explore a number of options as well as taking independent professionaladvice from a range of sources to ensure we are taking the best possible course of action for theSociety's future.' It maintains that 'As part of our extensive review in 2020, we explored otheroptions for the Clifton site, which included other types of visitor attraction and other types of zoos.Working with professional advisors we do not believe that any will be viable or sustainable overthe long-term on the Clifton site.'

It has not however made public the other options that it considered.

The reason for this lack of transparency has to be a matter of conjecture but one possible reasonmay be apparent from a letter which its Chief Executive wrote on 8 April to those who respondedto its initial proposal in which he stated that 'As the Society is a charity, the Trustees are legallyrequired to obtain maximum value from the charity's assets to reinvest in its charitableobjectives...'

That, regrettably, is a misconception. It takes no account of the obligation to ensure that indischarge of its charitable purposes the trustees pay appropriate regard to the overriding need toensure a public benefit of its activities. It is clear that the trustees are instead determined simplyand solely to maximise the development potential of the site to the wholesale exclusion of anyother considerations. The failure to appreciate, let alone give effect to, their wider social andfiduciary responsibilities is concerning.

In their submissions, Historic England conclude that 'your authority would be justified inrecommending ... refusal'. They ask that 'the applicants ... bring forward a wider masterplan for thesite to allow [the] proposals to be considered in a wider context.'We ask that in their present form the proposals be rejected and that the applicants consider amore imaginative scheme for the site that will produce a reasonable commercial return yet payproper respect to the setting of the site in a Conservation Area of national significance.

We feel that this new housing development would negatively affect our staff, studentsand visitors. Parking provision is absurdly inadequate. No allowance has been given to familyvisitors or tradesmen on the development unless parking in Cecil Road or along the Promenade isenvisaged. Cecil Road will become a total bottleneck. There are not enough parking spaces withinthe scheme which will then cause parking issues on the adjacent streets, especially: thePromenade, where we are located.

The entrance onto Cecil Road will mean cars accessing what will be single lane traffic. Theproposal will have a detrimental effect on traffic flow. The present access to the site opens ontotwo lane traffic and has been perfectly adequate for decade.It should also be stated that the conservation area would not be preserved or enhanced by theover intensive developmentthat is proposed. There are too many dwellings proposed for the site and the buildings are too tall.Also, plans to remove 15 lovely trees would be a detriment to the area.

The overall size and design of this development is not in keeping with the area, and Block A onCollege Road is ugly, oversized and looks like a city centre block of flats, which definitely shouldnot be built.

I write to object to the revised scheme. I am a local resident.

My objection is based on:

1. the housing density of the development is exceptionally high and totally inappropriate for the site and wider area 2. the design is unappealing at best, and the proposed construction materials are at odds with the surrounding buildings and streetscape. I cannot see how the design chimes with the character of the Conservation Area in which it is located, and assume therefore that the application seeks for an exception to be made to current planning policy? This should be resisted.3. there is insufficient provision for within-development car parking, with accordingly a high risk of enormous vehicle overspill parking onto already congested streets 4. despite revisions, the proposal sets an unwelcome precedent for high density development for the Zoological site as a whole.

The proposal appears to be led by the commercial need to cram as many units as possible onto the site, at the lowest possible cost in terms of materials and design, in order to make the project stack up for the developers. This should not be permitted to happen in an historic conservation area.

Yours faithfully

Carrie Sage

Sirs,

This is to record our objections to this deplorable planning project. We endorse all the strong criticism sent to you in relation to this application.

Jeremy Baines

Commenter Type: Area resident

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Commenter Type: Area resident

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Commenter Type: Area resident

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Commenter Type: Area resident

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment: I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems (only 49 spaces for 65 dwellings), and pressure on local roads and services. Design of proposed new buildings doesn't fit or blend with existing local architecture, important anywhere but particularly in a conservation area.The 5 storey block proposed is too tall, looking out of keeping with its surroundings and spoiling the view for visitors to the area as well as residents. It is wrong to fell 15 mature trees when the council's duty is to preserve the natural environment for the benefit of all. Overall the revised proposal fails to enhance or preserve a conservation area and represents a serious loss of amenity for Bristol which would adversely affect current and future populations.

I strongly object to this proposal which is little changed from the original proposal that Iobjected to. I entirely concur with the submission from CHIS.

I object to the scarcely revised plan for the development. The mass of housing is still fartoo big for the site. The block of flats planned for College Road is out of proportion with the presentbuildings and will create a canyon effect. Those buying the "affordable" housing will still be payingfor living in Clifton but for minimum floor area. Too many dwellings, too few car parking spaces,too little communal space.

I see nothing in the Zoo's latest planning application to make me change my mind. Myoriginal objections still stand.

1. This site is in the Clifton & Hotwells Conservation Area but the design of the building shows noacknowledgement of this. The large prison-like block of flats on College Road, in particular, istotally out of proportion to the rest of the area. The design of the buildings on the site in generalshows no relation to the architecture of the surrounding houses.

2. The entrance to the site should be, as at present, in College Road. Cecil Road is essentially aone-lane road. During the rush hour it is popular as a 'rat run' to avoid the difficult junction ofClifton Down Road and The Promenade. It is also busy, of course, during the - fairly lengthy -'drop-off' and 'pick-up' times of Clifton College and Clifton High School.

3. The number of parking places is still totally inadequate. Even those who are able to cycle or usepublic transport to travel to work will still need a car for shopping or leisure pursuits.

4. The pandemic has proved how important it is for people to have access to their own outdoorspace. The planned over-development of this site, however, shows that this human need has notbeen considered in this proposal.

The application should be rejected.

Objection: 21/01999/F - Erection of 65 dwellings with associated parking, new vehicularaccess and associated infrastructure and landscaping.

It is our view that the revised proposals remain to be harmful to the setting of our home which isone of the Listed Buildings that faces Clifton Down. It will result in detriment and harm to thecharacter of the conservation area. The proposed buildings are 33m from our mews house raisingconcerns regarding overlooking, loss of amenity and privacy concerns.

The new application for a total of 62 units appears immaterially different to the original planningapplication, only 45 car parking spaces are planned. With the average number of cars perhousehold In the south west being 1.35 (data from https://www.nimblefins.co.uk/cheap-car-insurance/number-cars-great-britain) therefore there is a shortfall of 39 parking spaces. Theseexclude visitors and therefore will result in the surrounding streets being incredibly congested withparked cars.

The prominent location, massing, size, scale, form and appearance of the development is suchthere will be an adverse effect on the character of the conservation area, the setting of Clifton andthe listed buildings on Clifton Down. Likewise the development with have a detrimental effect onthe outlook from the listed villas and surrounding properties including the Clifton Pavilion.

It is also our view that this development proposes a significant loss of historic fabric that includesbut is not limited to the rear garden wall fronting college road and the outbuilding once within thecurtilage of Avonbank. The loss of these two structures will cause irreparable damage to the streetscene.

The proposed mews houses A will be circa 35m from our property. Avonbank and it's mews enjoya high level of privacy with no dwellings looking directly into habitable rooms or private amenityspace. A series of 3 storey properties will significantly impact that privacy. We note on our ownapplication for planning permission of the Mews house we were restricted to a 2 story height with aflat roof. To allow the development of 3 storey buildings mere meters away shows a significantreversal of the decision made in 2013.

The impact is all the more harmful due to the fact our property Avonbank has no buildings causingany overbearing impact. This proposal will have a significant overbearing impact upon our privategarden harming the amenity of our garden and the mews house.

For these reasons the current application should be refused.

We fully accept the need to find a new future for the land following the closure of the Zoo and donot oppose development in principle but this reapplication still odes not respect the setting of thelisted buildings harming the conservation area.

Clifton is as as was once remarked by the Poet laureate "the handsomest suburb inEurope".Bristol Zoo have been an integral part of Clifton over the last 150 years.It is evident however that the car park and attached buildings are not in keeping with aConservation area.I would have hoped that any much needed redevelopment would have been in keeping andsympathetic to the environ of this area.The proposed development is neither and will seriously detract from the Clifton conservation area.The design itself is extremely poor and ill conceived and can be considered to be a massiveblunder both by the architect concerned and Bristol Zoo.It would be unfortunate that the Zoo will leave the site in Clifton with this development which willblight the area over the next 150 years.It is also likely that the proposed development is not legal under NPPF guidelines as this land waspreviously utilised for horticultural purposes.Whilst welcoming thoughtful development of this site to improve the aesthetics of the area, I wouldreiterate that this is NOT the case and the proposed design is totally unacceptable in both scaleand position lacking any imagination or innovation. The density of housing is also substantiallybeyond that recommended for development and is certainly beyond that of the remainder ofClifton.In particular the scale and position of the monolithic block on College Rd is reminiscent ofbrutalistic architecture of the 1970's and is out of keeping with the area.The design needs to settle organically into the area and not to be oversized. Landscaping andpreservation of flora, especially trees are paramount as well as preserving access to light for thesurrounding properties.Similarly the realities of off road car parking have been ignored and further street congestion will

inevitably be bound to follow.I would suggest that the Zoo should abandon the current proposals and engage an innovativearchitect with expertise to produce a sustainable and aesthetic development which will provide alasting and beneficial legacy to the zoo's presence in Clifton.Currently this is not it and the proposed revision remains similarly flawed!

Dear Sir/Madam,

I refer to the above application and specifically the amendments made to the original submission. Having considered the revisions I believe my objections submitted on 28th June below are still relevant as the revisions do not meaningfully address the design and massing concerns that I expressed on 28th June. The site is in a Conservation Area and the scheme lacks sensitivity and is inappropriate for such a location.

Yours faithfully,

David Burston FRICSDirectorBurston Cook

Dear Sir/Madam

Further to your letter dated 26 July 2021, I wish to object to the revised details you received on the 22 July 2021 regarding the Application No 21/01999/F. My objection is that the revised plans do not address my comments in the email below, which I sent to you on the 28 June 2021.

In short, I oppose the proposed development based on the revised details, because it does not address my original comments

Sincerely

Charles Ross

Comment from 28th June 2021

Dear Sir/Madam

I wish to object to the above proposed development for the following reasons:

:a. The proposals constitute over-intensive development.b. The buildings are too tall - over 4 storeys..c. They are out of keeping with surrounding buildings.d. The poor design and over massing would damage the settings of surrounding listed buildings and other unlisted buildings of merit.

e. The proposed parking provision with only 45 spaces is totally inadequate. Even those who walk/cycle/bus to work/shop still have cars for family excursions.f. Amenity space is lacking.g. 15 mature trees will be lost.h. This development would fail to preserve or enhance the character of the Conservation Area. It would seem that the sole aim of this application is to render this site as profitable as possible. It fails to have any regard whatsoever for local amenity, surrounding residents, local architecture, the conservation area or the environment generally. If this application is granted it would set a dangerous precedent for the redevelopment of the main zoo site.

As stated, I oppose the proposed development for the above reasons

Sincerely

Charles Ross

Dear Planners, I wish to object to the revised proposals for development on the Western Car Park portion of the Bristol Zoo site in Clifton. I attach a Summary Scheme Appraisal prepared bylocal residents' groups, which sets out my views very clearly. In summary: 1. The car park is an integral part of the zoo site in the Conservation Area and

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Dear Sirs

I write yet again to request you refuse this application. It is totally out of character for the. Clifton Conservation Area and comprises far too many housing units (130% greater density than the rest of the Area apparently) with far too few parking places which will cause untold misery for present residents, their guests and other visitors to the Village.

As the name suggests Bristol Zoological GARDENS is a public amenity and the development should preferably be for the use of locals and tourists to enjoy not for a few householders crammed into a far too small and unsuitable development.

Let's have something that pleases the eye, does not stick out like a sore thumb and will be an asset for the area.

RegardsGeraldine Davies

Hello

I'd like to add my objections to the new application for the zoo car park. I say 'new' but it is almost exactly the same as the original - still too many homes, still too tall, still out of character with the area. Please throw this out and let's have some sensitively designed homes with sufficient space around them.

Rosemary Chamberlin

Sir/Madam,

I am writing regarding the revised details which were received by the council on 22.7.21. The alterations in the revised application are minor and insignificant. My objections as stated in my e mail of 28.6.21 are unchanged.

Yours sincerely,(Dr) Geraldine Badger

A five storey block of flats is proposed to face onto College Road directly opposite the Clifton Pavilion. Although most houses in this suburban part of Clifton have ample landscaped front gardens, this building is set back only between 0.7m and 1.4m from the pavement. The eaves of the roof are some 3m higher than the parapet level of the adjoining houses. Although the architecture here is neo-classical and gothic with painted stucco, the architects have opted to 'reflect' the very much later rubble stone vernacular found in other parts of Hotwells and Bristol. When compared with the scale and density of the existing housing in this part of the Conservation Area, the same area of land would have been originally developed with about 7 detached or semi-detached villas capable of conversion into a maximum of 28 flats. All car parking would have been provided within the curtilage and not on the street. By this measure, the density of the proposed development is some 130% greater than the historic fabric of this part of the Clifton ConservationArea. Such high urban densities are probably not found in any other part of Bristol, let aloneClifton. As a direct consequence, the proposal utterly fails to preserve the character of the ConservationArea as required by Planning Policy and by Planning Law.The elegant garden city character wouldbe irreparably harmed.In addition to the incongruous layout and form of the development, the architectural language iscompletely alien and inappropriate. Further, the 'affordable' housing element comprises one blockof 14 flat, designed to absolute minimum floor areas, with the ground floor flats facing onto a roadwithout any form of private open space.

A five storey block of flats is proposed to face onto College Road directly opposite the Clifton Pavilion. Although most houses in this suburban part of Clifton have ample landscaped front gardens, this building is set back only between 0.7m and 1.4m from the pavement. The eaves of the roof are some 3m higher than the parapet level of the adjoining houses. Although the architecture here is neo-classical and gothic with painted stucco, the architects have opted to 'reflect' the very much later rubble stone vernacular found in other parts of Hotwells and Bristol. When compared with the scale and density of the existing housing in this part of the Conservation Area, the same area of land would have been originally developed with about 7 detached or semi-detached villas capable of conversion into a maximum of 28 flats. All car parking would have been provided within the curtilage and not on the street. By this measure, the density of the proposed development is some 130% greater than the historic fabric of this part of the Clifton ConservationArea. Such high urban densities are probably not found in any other part of Bristol, let aloneClifton. As a direct consequence, the proposal utterly fails to preserve the character of the ConservationArea as required by Planning Policy and by Planning Law.The elegant garden city character wouldbe irreparably harmed.In addition to the incongruous layout and form of the development, the architectural language iscompletely alien and inappropriate. Further, the 'affordable' housing element comprises one blockof 14 flat, designed to absolute minimum floor areas, with the ground floor flats facing onto a roadwithout any form of private open space.

A five storey block of flats is proposed to face onto College Road directly opposite the Clifton Pavilion. Although most houses in this suburban part of Clifton have ample landscaped front gardens, this building is set back only between 0.7m and 1.4m from the pavement. The eaves of the roof are some 3m higher than the parapet level of the adjoining houses. Although the architecture here is neo-classical and gothic with painted stucco, the architects have opted to 'reflect' the very much later rubble stone vernacular found in other parts of Hotwells and Bristol. When compared with the scale and density of the existing housing in this part of the Conservation Area, the same area of land would have been originally developed with about 7 detached or semi-detached villas capable of conversion into a maximum of 28 flats. All car parking would have been provided within the curtilage and not on the street. By this measure, the density of the proposed development is some 130% greater than the historic fabric of this part of the Clifton ConservationArea. Such high urban densities are probably not found in any other part of Bristol, let aloneClifton. As a direct consequence, the proposal utterly fails to preserve the character of the ConservationArea as required by Planning Policy and by Planning Law.The elegant garden city character wouldbe irreparably harmed.In addition to the incongruous layout and form of the development, the architectural language iscompletely alien and inappropriate. Further, the 'affordable' housing element comprises one blockof 14 flat, designed to absolute minimum floor areas, with the ground floor flats facing onto a roadwithout any form of private open space.

A five storey block of flats is proposed to face onto College Road directly opposite the Clifton Pavilion. Although most houses in this suburban part of Clifton have ample landscaped front gardens, this building is set back only between 0.7m and 1.4m from the pavement. The eaves of the roof are some 3m higher than the parapet level of the adjoining houses. Although the architecture here is neo-classical and gothic with painted stucco, the architects have opted to 'reflect' the very much later rubble stone vernacular found in other parts of Hotwells and Bristol. When compared with the scale and density of the existing housing in this part of the Conservation Area, the same area of land would have been originally developed with about 7 detached or semi-detached villas capable of conversion into a maximum of 28 flats. All car parking would have been provided within the curtilage and not on the street. By this measure, the density of the proposed development is some 130% greater than the historic fabric of this part of the Clifton ConservationArea. Such high urban densities are probably not found in any other part of Bristol, let aloneClifton. As a direct consequence, the proposal utterly fails to preserve the character of the ConservationArea as required by Planning Policy and by Planning Law.The elegant garden city character wouldbe irreparably harmed.In addition to the incongruous layout and form of the development, the architectural language iscompletely alien and inappropriate. Further, the 'affordable' housing element comprises one blockof 14 flat, designed to absolute minimum floor areas, with the ground floor flats facing onto a roadwithout any form of private open space.

A five storey block of flats is proposed to face onto College Road directly opposite the Clifton Pavilion. Although most houses in this suburban part of Clifton have ample landscaped front gardens, this building is set back only between 0.7m and 1.4m from the pavement. The eaves of the roof are some 3m higher than the parapet level of the adjoining houses. Although the architecture here is neo-classical and gothic with painted stucco, the architects have opted to 'reflect' the very much later rubble stone vernacular found in other parts of Hotwells and Bristol. When compared with the scale and density of the existing housing in this part of the Conservation Area, the same area of land would have been originally developed with about 7 detached or semi-detached villas capable of conversion into a maximum of 28 flats. All car parking would have been provided within the curtilage and not on the street. By this measure, the density of the proposed development is some 130% greater than the historic fabric of this part of the Clifton ConservationArea. Such high urban densities are probably not found in any other part of Bristol, let aloneClifton. As a direct consequence, the proposal utterly fails to preserve the character of the ConservationArea as required by Planning Policy and by Planning Law.The elegant garden city character wouldbe irreparably harmed.In addition to the incongruous layout and form of the development, the architectural language iscompletely alien and inappropriate. Further, the 'affordable' housing element comprises one blockof 14 flat, designed to absolute minimum floor areas, with the ground floor flats facing onto a roadwithout any form of private open space.

A five storey block of flats is proposed to face onto College Road directly opposite the Clifton Pavilion. Although most houses in this suburban part of Clifton have ample landscaped front gardens, this building is set back only between 0.7m and 1.4m from the pavement. The eaves of the roof are some 3m higher than the parapet level of the adjoining houses. Although the architecture here is neo-classical and gothic with painted stucco, the architects have opted to 'reflect' the very much later rubble stone vernacular found in other parts of Hotwells and Bristol. When compared with the scale and density of the existing housing in this part of the Conservation Area, the same area of land would have been originally developed with about 7 detached or semi-detached villas capable of conversion into a maximum of 28 flats. All car parking would have been provided within the curtilage and not on the street. By this measure, the density of the proposed development is some 130% greater than the historic fabric of this part of the Clifton ConservationArea. Such high urban densities are probably not found in any other part of Bristol, let aloneClifton. As a direct consequence, the proposal utterly fails to preserve the character of the ConservationArea as required by Planning Policy and by Planning Law.The elegant garden city character wouldbe irreparably harmed.In addition to the incongruous layout and form of the development, the architectural language iscompletely alien and inappropriate. Further, the 'affordable' housing element comprises one blockof 14 flat, designed to absolute minimum floor areas, with the ground floor flats facing onto a roadwithout any form of private open space.

A five storey block of flats is proposed to face onto College Road directly opposite the Clifton Pavilion. Although most houses in this suburban part of Clifton have ample landscaped front gardens, this building is set back only between 0.7m and 1.4m from the pavement. The eaves of the roof are some 3m higher than the parapet level of the adjoining houses. Although the architecture here is neo-classical and gothic with painted stucco, the architects have opted to 'reflect' the very much later rubble stone vernacular found in other parts of Hotwells and Bristol. When compared with the scale and density of the existing housing in this part of the Conservation Area, the same area of land would have been originally developed with about 7 detached or semi-detached villas capable of conversion into a maximum of 28 flats. All car parking would have been provided within the curtilage and not on the street. By this measure, the density of the proposed development is some 130% greater than the historic fabric of this part of the Clifton ConservationArea. Such high urban densities are probably not found in any other part of Bristol, let aloneClifton. As a direct consequence, the proposal utterly fails to preserve the character of the ConservationArea as required by Planning Policy and by Planning Law.The elegant garden city character wouldbe irreparably harmed.In addition to the incongruous layout and form of the development, the architectural language iscompletely alien and inappropriate. Further, the 'affordable' housing element comprises one blockof 14 flat, designed to absolute minimum floor areas, with the ground floor flats facing onto a roadwithout any form of private open space.

A five storey block of flats is proposed to face onto College Road directly opposite the Clifton Pavilion. Although most houses in this suburban part of Clifton have ample landscaped front gardens, this building is set back only between 0.7m and 1.4m from the pavement. The eaves of the roof are some 3m higher than the parapet level of the adjoining houses. Although the architecture here is neo-classical and gothic with painted stucco, the architects have opted to 'reflect' the very much later rubble stone vernacular found in other parts of Hotwells and Bristol. When compared with the scale and density of the existing housing in this part of the Conservation Area, the same area of land would have been originally developed with about 7 detached or semi-detached villas capable of conversion into a maximum of 28 flats. All car parking would have been provided within the curtilage and not on the street. By this measure, the density of the proposed development is some 130% greater than the historic fabric of this part of the Clifton ConservationArea. Such high urban densities are probably not found in any other part of Bristol, let aloneClifton. As a direct consequence, the proposal utterly fails to preserve the character of the ConservationArea as required by Planning Policy and by Planning Law.The elegant garden city character wouldbe irreparably harmed.In addition to the incongruous layout and form of the development, the architectural language iscompletely alien and inappropriate. Further, the 'affordable' housing element comprises one blockof 14 flat, designed to absolute minimum floor areas, with the ground floor flats facing onto a roadwithout any form of private open space.

Thank you for your notification dated 26th July re. revised details.

We have the following objections.

General.

1. It contravenes the Heritage and Conservation status of Cliftion.

2. Contravenes Permitted Development Guidlines.

3. Style inconsistent with surrounding listed buildings.

4. Proposed development is too dense and congested leading to traffic/ parking in adjacent roads.

5. Does not respect the privacy of neighbours especially with regard to overlooking.

Specific to Auburn House.

As in our letter dated July 13th sent to Mr Peter Westbury by recorded delivery, copy below.

Mr Peter Westbury, Auburn HouseDevelopment Management, Clifton Down,Bristol City Council, Bristol, BS8 3HTPO Box 3399Bristol BS1 9SE

Dear Mr Westbury July 13th 2021

Bristol Zoo West Car Park proposed development.

1. Our property abuts the proposed development. Would you please advise whether the planning advice given in 2011 will be maintained or reversed (enclosed copy) with respect to the setting of a heritage asset. The proposed development according to this advice is incongruous. too high, and involves felling of trees. See enclosed Ministry of Housing letter.

2. There are safety issues with excavations abutting the base of the party wall which is old, historic and about 3m. high. This should be given serious consideration at the design and planning stage rather than trusting a developer to obey the rules. A previous developer of adjacent Sutton House, did not obey the rules causing considerable distress and hassle over a period of two years in the time of Planning Officers Mr J. Bishop and Ashley Grant. Partial retrospective action was taken.

See enclosed site map copy

3. A power cable extends along the surface of the party wall powering the green house and the gate that gives access to our property. This cable has been there for over 20 years when the property belonged to Clifton College. See enclosed site map copy.

We would value your reply and a site visit by planning officers would be welcomed, The enclosed Bristol planning advice was included in our email sent on June 4th where other issues were also raised such as overlooking, congestion etc. As yet we have had no response.

Yours faithfully

David and Ruth Slinn

Enclosedo Copy of 2011 Bristol Council Planning advice re Auburn House.o Site map illustrating wall positiono Ministry of housing advice re. duty of care of heritage sites

SUMMARY SCHEME APPRAISAL FOR LOCAL RESIDENTS' GROUPS BY

MICHAEL WOODMAN SMITH

I am sure you have received a copy of the above. I also received, by post, a copy and would like to make the following comments. There are seven paragraphs and I am inclined to support all of them, adding some emphasis of my own.

1st paragraph

The Clifton Conservation Area is very special.

2nd paragraph

It is not possible to regard the site as previously developed land.

3rd paragraph

Some additional 60 vehicles would need to be parked on our local streets.

4th paragraph

The density of the proposed development is some 130% greater than the historic fabric of this part of the Clifton Conservation Area.

5th paragraph

The proposal utterly fails to preserve the character of the Conservation Area.

6th paragraph

The architects have chosen not to follow the exemplar of a number of successful new buildings in Clifton. These units are designed to absolute minimum floor areas and the ground floor flats all face directly onto a road without any form of private open space.

7th Paragraph

Sir John Betjeman was probably right. Please don't make another carbuncle.

Yours faithfully

Barry Ryder

I object to the revised application on the following groundsOverdevelopment of the area resulting in parking problems ( only 49 spaces for 65 dwellings), andpressure on local roads and servicesDesign of proposed new buildings doesn't fit or blend with existing local architecture , importantanywhere but particularly in a conservation areaThe 5 storey block proposed is too tall,