Dear Peter,

I see that an updated Arboricultural report has been published - 21_05164_F-NOVERS_HILL_TREE_SURVEY___TREE_PROTECTION_PLAN_REV_C-3410007. This makes material changes to the earlier version.

Whilst we can calculate the DM17 tree replacement requirements for the individualtrees, this is not possible for the nine sets of grouped trees.Can the applicant please be asked to provide the following information for each ofthe grouped trees:

1. The number of trees in each Group. If this is not possible, the area covered byeach group.

2. The number of trees in each Group which will be removed. If this is notpossible, the area of the trees being removed.

3. The stem diameter ranges for each group.

I also see that no new biodiversity net gain evidence has been produced eventhough this whole proposal has effectively been redesigned. The last version is, wesuggest, out of date as it is based on a UKHab survey undertaken nearly three yearsago in September 2020.

I also note that the Biodiversity Metric 2.0 (BNG 2.0) has been used even though twonew iterations of the Metric - BNG 3.0 & 3.1 have replaced it. These have not onlycorrected a number of known errors in BNG 2.0, but, with the publication of BNG 3.0,they also introduced a new Broad Urban habitat category - Urban tree Habitat. Thetrees on the development site clearly fall within the definition of Urban tree habitat:

Page 72 of the Biodiversity Metric 3.1 User Guide - attached.

Given the above and given that the trees on the site form an important element ofthe biodiversity on the site and fall to be designated as Urban tree Habitat, we askthat you require the applicant to undertake a new Biodiversity Metric calculationbased on BNG 3.1. If a new metric is published in the meantime, then they should berequired to use that.

You will be aware that Natural England's advice on adopting updated versions ofBNG, gives the LPA (the 'consenting body') a discretion whether or not to require anewer version to be used: "Projects currently using biodiversity metric 2.0 or version3.0 are advised to continue to do so unless requested otherwise by their client orconsenting body ..." - http://nepubprod.appspot.com/publication/5850908674228224.

If you decide not to require the applicant to recaste its BNG calculation using thelatest metric, can you please set out your reasons.

We look forward to hearing from you.

Regards

Chair - Bristol Tree Forum

Good Afternoon,

I am writing to ask you to save the western slopes by not allowing them to be built on.We need to preserve all the greenfield sites we can, especially as there are so fewremaining in our city.

There is an abundance of wildlife and mature trees on this site which, once gone, cannever be replaced here. The site is a lung for south Bristol, providing much neededoxygen and clean air for our residents amongst the pollution.

Hartcliffe way would not cope with the extra traffic, and the site is so steep that roads inwould be dangerous for service vehicles such as recycling lorries and ambulances.

It is not suitable for development and therefore please do not let anyone build on it, let itremain a wonderful, diverse place for nature and please build on brownfield sitesinstead (or redevelop empty buildings across the city).

Yours hopefully,

To whom it may concern

I am strongly opposed to the plans to build on Novers Hill / Western Slopes.Building on such a steep gradient does not seem logical with the amount the ground willneed be leveled. This means there will be a lot of destruction to the ground anddisruption to the wildlife around, let alone the release of greenhouses that will happenwhen the ground is dug up.The hill is a Greenfield site and requires protection for the thousands of speciesinhabiting it.

It is a natural space in an area that is becoming more and more developed and thecommunity are losing spaces where they can relax, play and connect to nature.We are in a time of an increasing need to save our planet and be more environmentallyfriendly and yet this development destroys these objectives.

Where will these species go when their habit is torn down and their once home built on?We need to focus on protecting our wildlife and environment so we can extend thelongevity of the planet. Without the planet, it will not only be the wildlife struggling to bealive, but us and our children.

It is important that we have natural spaces in South Bristol, where our children can learnand our community can grow. It is important for us to have clean places to play andbreathe and live, which will be taken away if you destroy the trees (hundreds of maturetrees), hedges, wildflowers. It will completely change the environment and the quality ofhealthy living.I see so many issues with access, not only for the public but also with the contractors.

Not only is the hill itself a muddy bank, access from Hartcliffe Way just isn't appropriateand will just cause even more congestion than there already is, resulting in even morepollution from cars at a standstill for us locals to breathe in.Public transport is very limited for residents. The area cannot handle more throughtraffic which unfortunately Parson St School children, parents and staff are alreadytaking the brunt off, being busy, congested and full of pollution which vegetation onNovers Hill / Western Slopes absorb due to their fantastic qualities of turning gases intooxygen for us.I think it is completely unethical and to build on this Greenland and believe there shouldbe more commitment to building on brownlands around the city.

I ask the planning committee to reject plans to build on this site and find appropriatebrownland for this development to be built.

To whom it may concern

I am strongly opposed to the plans to build on Novers Hill / Western Slopes.Building on such a steep gradient does not seem logical with the amount the ground willneed be levelled off. This means there will be a lot of destruction to the ground anddisruption to the wildlife around, let alone the release of greenhouse gases that willhappen when the ground is dug up.The hill is a Greenfield site and requires protection for the thousands of speciesinhabiting it.

It is a natural space in an area that is becoming more and more developed and thecommunity are losing spaces where they can relax, play and connect to nature.We are in a time of an increasing need to save our planet and be more environmentallyfriendly and yet this development does not appear to meet these objectives.

Where will these species go when their habitat is torn down and built on? We need tofocus on protecting our wildlife and environment so we can extend the longevity of theplanet. Without the planet, it will not only be the wildlife struggling to live, but us and ourchildren.

It is important that we have natural spaces in South Bristol, where our children can learnand our community can grow. It is important for us to have clean places to play andbreathe and live, which will be taken away if you destroy the trees (hundreds of maturetrees), hedges, wildflowers. It will completely change the environment and the quality ofhealthy living.

I see so many issues with access, not only for the public but also with the contractors.Not only is the hill itself a muddy bank, access from Hartcliffe Way just isn't appropriateand will cause even more congestion than there already is, resulting in even morepollution from cars at a standstill for us locals to breathe in.Public transport is very limited for residents. The area cannot handle more throughtraffic which unfortunately Parson St School children, parents and staff are alreadytaking the brunt of. This area is already extremely, congested and polluted whichvegetation on Novers Hill / Western Slopes absorb due to their fantastic qualities ofturning gases into oxygen for us.I think it is completely unethical and to build on this site and believe there should bemore commitment to building on brownfield sites around the city.

I ask the planning committee to reject plans to build on this site and consider findingmore appropriate brownfield sites away from south Bristol for this development to bebuilt.

Regards

This is total wildlife and biodiversity destruction. The local people don't want this, that'sclear and obvious.

The area is used by protected species of bats, along with birds on the RSPB conservation red list.

The council declared a climate emergency, so back it up with actions, not words.

I object to this current planning aplication, largely due the wanton destruction of over700 mature trees across the site. This is a habitat to lots of wildlife, and in a time of global warmingcrisis, we cannot afford to destroy this amount of wild space, a habitat for birds, plants andprotection of the landscape. Any offer of "Replacement trees" is no compensation for the maturesite that is already there. I appreciate that Bristol requires housing but with these planningapplications, we know they will change goalposts when given permission, affordable housing willbe squeezed over profit, with no real gain for the city.

It came to my notice that Bristol City Council are considering allowing the removal of awell established area of woodland for the purpose of it being replaced with dwellings.

I wish to object on the grounds of this creating an ecological disaster given the diverse nature ofthe tree species in question & the amount of wildlife & other biodiversity they support, whichshould be protected, definately not destroyed, especially when brown sites could be given over forthis building project.

I object to this development due to the proposed loss of mature trees and hedgerowswhich form habitat for countless species of birds, plants and animals. Britain is one of the mostnature depleted countries on earth so saving this plot of land in its current state is more importantthan bulldozing it for financial gain for a few and a small increase in housing.Please I implore you to stop this development so as to save this precious habitat for everyone toenjoy. There are plenty of brownfield sites that can be redeveloped.Thanks.

I had long-term plans to move to this area of Bristol later on this year, re-locating mycompany to the area too, providing many jobs for the local community. Unfortunately this 'de-forestation' and development has caused me to change my mind. If this action is indicative of theapproach and mindset of Bristol council it would be in direct conflict with the nature of mybusiness, which promotes ecological awareness and environmental and social sustainability. I callupon the Council to block this development.

Bristol is renowned for being a forward thinking, cool & green city. How can you justifythis in light of climate change? Build on brownfield sites, disused sites, regenerate existing sites -don't destroy an area of mature trees that are of huge benefit to the environment and also offerhome to varied wildlife. It's outrageous to allow development to take place here. Take note thatwhen a similar project went ahead in Plymouth, Twitter went crazy and councillors haveresigned/been sacked and there are now several court cases being pursued. This is not a decisionto take lightly as people are angry at the lack of protection for our environment and for wildlife.

I've come to learn of the destruction of a mature woodland on the edge of a muchbeloved city and would like to object this development. Nothing can replace the destruction ofmature trees such as hawthorns and oaks, which support an innumerable number of species.Replacement of these trees with younger equivalents *do not* replace the ecological niche thatthese hold. Bristol is seen as a green city- don't let a small number of houses take away a greenbelt that benefits everyone

At a time when we are facing a climate crisis, and our natural environment is beingdecimated, to approve a housing development in such a large area of woodland is abominable.

Do not approve this.

We cannot keep destroying our countryside. The habitat for wild species is an essentialpart of land management and this clear cutting to make way for unsustainable housing solutionsmust stop.

Bristol calls itself a green city - and it must do as much as possible to preserve greenspaces if it is to maintain its status thereof! The ancient hedgerows uphold thousands of species ofwildlife; it would be devastating to have them entirely killed in the name of 'development'.Replanting trees after demolishing this area will not help the fauna survive: they will already havebeen massacred. Do not let the beautiful biodiversity we are blessed with in Bristol die.

Losing more natural habitat when there are still many brown fields sites to build on inBristol is wrong.

I object

The destruction of this woodland should not be allowed, we need trees and more treesto combat climate change and bring a place to go for wildlife.

Why more woodland, more greenery, less room for wildlife when our city is supposed tobe a green city?Why not build on brownfield sites?How when we are facing mass extinction of wildlife are we doing this?Is this all about the money?

The proposed planning is a kick in the face to all residents of Bristol - myself included.

The devastation to wildlife will be catastrophic to this area if so many trees are to be felled,regardless of whether new trees will be planted, they take years to grow to a mature age wherethey can successfully benefit nature, wildlife and capture carbon. The housing is unaffordable tolocals and a giant eyesore in amongst what is now a beautiful setting of natural biodiversity.

The UK has recently been declared one of the most nature depleted countries on the planet andwith reckless plans such as this being put forward we'll soon be at the very bottom of the list.

I strongly oppose. As do my friends, family and coworkers who will also be signing.

Please do not allow this monstrosity to go ahead. It does not benefit a single person in the localcommunity, and it will negatively affect our wildlife and residents for years to come if it were to beapproved.

I am a resident of Novers Hill and enough is enough! Protect our green spaces!

Strongly object to the proposed destruction of this unique natural woodland environmentin exchange for housing. Yes we have an enormous housing shortage here in Bristol as well ascountry wide but it cannot continue to be at the expense of the natural environment. Brown field/exindustrial/poor quality farmland maybe but not well established urban green spaces cherished butthe community and essential to bird, insect and animal life alike. Build elsewhere and designatethe land as community land and as a conservation area now!

This ruins habitat's that cannot be replaced for years and years.

As someone who had lived and worked in Bristol and with family here, I strongly objectto trees and shrubs being ripped out. Yes, we do need affordable housing, but no, not in areas likethis. Plenty of inner city sites, but not nearly enough green spaces in Bristol. It is vandalism , andpeople will live to regret it.

The level of destruction to an important urban woodland that this development wouldbring leads me to strongly object to this proposal.

Absolutely abhorrent to consider this project going ahead and removing so muchwildlife.

This would be criminal, sacrificing yet more of children's future. This must not beallowed. You're using the %age of affordable housing as a smoke screen for profit making. Thereare numerous brownfield sites for (re)development in Bristol. BristolIs one of the greenest cities in the UK - you should be proud of it not part of its destruction. If youallow this you will be soooo regretful in the years ahead when every tree will count and £££s willbe worthless.

We need to preserve the ecosystem the woodland contains. It would be an ecologicaldisaster.

I object to this planning application. The land should be left as wild and no building ofdwellings should ever be allowed. The environmental damage to the existing wild habitat therecould not be condoned for building on. Once the established green space at Novers Hill is gone , itcan never be replaced.

It is an absolute disgrace that in the current well documented climate breakdown andbiodiversity crisis, you are considering the destruction of this vital habitat. We cannot continue tobuild houses in the way we do, we need taller buildings rather then semi detached and small flats.There will be soon nothing left apart from cement, roads, intensively farmed fields and overly tidytowns, parks, gardens and road sides. The removal of this green space will also cause anincrease in pollution and diseases such as of the airways and cancers. Not to mention the purposethese area represent for high winds and floods mitigation purposes. You have got the moral dutyto oppose to this shamble. If you don't you will be responsible for having failed nature and futuregenerations from a livable world . It is disgusting. Humans are not the only specie on this planet,which we, are running down. I hope you will make the wise choice to oppose to this trulydepressing catastrophe, which in no time will be classified as ecocide. On a final note, the UK isone of the most natural depleted countries on the planet. And this is evidenced by the like of thisproject. Criminal.

Best wishes

Michele

I believe this felling of trees is a travesty: unaffordable housing scheme for Bristol withthe loss of these historical trees. Climate change being ignored. We need these trees.

The area is an important habitat for much wildlife and provides a corridor to Manorwoods and Hengrove mounds. Blackthorn, hawthorn etc provide flowers for nectar in early springand berries for birds in autumn. There may not be many big trees but smaller shrubs are evenmore important for wildlife. Replacing established native shrubs with scattered trees does notreplace the wildlife habitat. Please do not build houses on this vital piece of wildlife habitat.

I object to this application on the grounds of the ecological damage that would besustained by killing the rich local habitat. It takes time for habitats to become rich and diverse.Every time we destroy growing natural spaces we set back the regeneration of nature. Bristol hasdeclared a climate crisis and now has a responsibility to protect and encourage sustainable,diverse ecosystems. I do not live in the direct area but have friends and family who do and I careabout the lives of my children and grandchildren. Please do not allow this planning application togo through. Please redirect the developers to a brown site. Thank you

I object to the destruction of nature for house building.

How can Bristol claim to be a progressive city that is prioritising the climate crisis andbiodiversity collapse if it rips out the 700 native Hawthorn, Blackthorn and Elder, known forsupporting hundreds of species of invertebrates and wildlife on this site?

More unaffordable housing being built in a city I cannot afford to buy in anyway. There isno way that these new houses will provide any meaningful value to the area, particularly whenweighed up against the destruction of green space ecosystems

Why are you proposing to tear down over 100 trees, when everyone is jumping up anddown over green issues?You say you will plant more to replace them,?How long will it take for them to do the job that is already being done,Plus where does all the wildlife go?Birds,mammals, insects etc,destroying their homes with no intention of replacing them,.I'm sure you can define other land to build your rabbit hutches on,Although someone probably has fingers in pies where they're not meant to be.You disgust me, as much as Plymouth council, and the cambridge council and their bloody busway,Big reset my arse,

A frequent visitor to the city of my birth, I am devastated to hear that a woodland isslated to be destroyed if this development goes ahead. A few replacements will be of no use to thewildlife already occupying the space. The UK is too nature depleted for woodland to be a viablesite for construction, particularly when woods and soil store carbon and we are in a climateemergency that has been acknowledged by the council. There are brownfield sites available. Ifthey are considered too expensive to redevelop, the value of woodland is set too low and does notaccount for its role in reducing heat and risk of flooding. I object to this development proposal.

Plymouth City Council will take a long time to recover the trust of its residents (my current nearestcity), and they cut down a fraction of what this development proposes.

As a Bristol resident, I object to this development on the grounds that it will destroy alarge natural habitat.

Over 700 native Hawthorn, Blackthorn and Elder, known for supporting hundreds of species ofinvertebrates and wildlife, will be ripped out.

It is claimed that replacement trees will be planted but this is a false equivalence. These trees willmost likely die because they will be inappropriately planted and not cared for. Planting them is allthe developer is obliged to do to offset the damage they do. Even if they do survive, they willalways lag behind the environmental benefits provided by the existing habitat.

Stop destroying these natural habitats when there are plenty of other options for providinghousing.

This site represents an urban woodland. The UK is already one of the most nature-deficient countries in the world; why destroy even more for housing, which could be located on abrownfield site of little conservation value?

What an abject disregard for the nature of the local area - as seen in the online episodeof David Attenborough's Wild Isles, more needs to be done to protect the ever depleting naturalwoodland. How about more is invested in renovating and occupying the almost 250 thousand longterm empty properties in the UK instead?

How can this be allowed to happen. I visit Bristol frequently and am always amazed howprogressive the city is. We need to hold onto British wildlife and biodiversity

The destruction of woodland and native hedgerows is absolutely unacceptable, andcannot be replaced by some minor tree planting (which will likely not end up taking place, as wehave seen elsewhere in Bristol). Whilst new housing is needed across the city, it is just asimportant to ensure that our public green spaces remain as they are - public green spaces, to beused by our communities. Building soulless housing units that will not actually be affordable tolocal people does not solve our housing shortage, and broadly makes the area less attractive.

We cannot destroy this natural area. There are many alternative areas, such asbrownfield sites, we simply cannot destroy this area. It is heartbreaking.

Absolutely horrific plans to destruct wildlife area, trees and habitat. DO NOT ALLOWTHIS TO HAPPEN!!

Under no circumstances should anything be removed.

Think of the environment for crying out loud. It's a habitat in a fragile ecosystem WE arepart of.

No tree replanting can replace the loss of existing habitat. Right when we need more ofnature to offset our own damage, we want to destroy more? I must object in the strongest possibleterms to this development.

This application is absurd and should not go ahead under any circumstances. You haveno right to tear down a natural habitat in this way, killing so many animals for your poor quality andunaffordable housing. Distasteful and disgraceful company.

we cannot keep tearing out established, mature woodland for the sake of more andmore houses, redevelop areas that are rundown or "brown field" sites. if we are serious aboutpreventing serious climate change we must look at the mass destruction of natural habitats andreplacing mature trees with saplings does not replace the established wildlife habitats that are lostor the CO2 capture from the atmosphere

Nothing can make up for loss of a woodland in a city, not even the supposed"replacement tree planting" as part of the development.

It should be the primary responsibility of Bristol City Council to protect the environment againstgreed and exploitation, especially where the natural habitat is already well-established andsupports a myriad of wildlife.

Yes undoubtedly, there is a need for cheaper housing but there are many other brownfield sitesthat can be used for this purpose without affecting the environment and the wishes of the peoplewho live within the vicinity.

I trust that the councillors responsible for the decision-making will look closely at figures readilyavailable of the considerable damage being done by housing developers not only to theenvironment but to the local infrastructure, lifestyle and social attitudes and adjudicate against inthis case.

It really is time for each one of us to stand up and say 'enough is enough and NO to greedydevelopers looking to exploit every little loophole and parcel of land for their already overfilledcoffers.

I remain

Yours sincerely,

Darryl Antonio

The value of native tree species to our already depleted biodiversity can not beoverstated. Please consider using land that is less valuable for wildlife.

Desecration of wild spaces and habitat should not be happening in 2023.

I do not live in Bristol now but grew up there. This project will be devastating for natureand should be withdrawn on environmental grounds. Bristol has been leading in Green issues andthis plan goes against all those principles. These trees and woodlands cannot be "replaced" in anyshort-term act and will have only a detrimental effect on the wider environment and quality of livingfor all those around.

This proposed development will impact on the wildlife & flora massively.Loads of animals live there & insects.No amount of post development reintroduced plants & shrubs can replace these once lost.

The development is also unnecessary as there are a huge number of other developments nearbyincluding a vast array of rental accommodation already earmarked for brownfield sites inBedminster. Some approximately 300 in East Street alone already being built opposite StCatherine's Place.

St Catherine's is also earmarked for further development. The roads within South Bristol & Theinfrastructure such as Dr & Denistry are already full.

There is also a very large development at the end of North St plus numerous other developments.

Constantly building on green field such as Novers also effects the absorption of water & willincrease the risk of flooding onto Hartcliffe way due to overrun.

I therefore strongly object to this as a local resident.

There are too few green field sites left in Bristol, and many brownfield sites to use. Thisis not an acceptable way of providing more housing.

The woodland should be preserved - new building plots should be made on brownfieldsites.

As a country, we are trying to maintain biodiversity, and call ourselves a nature leavingnation. How can that sit well with destroying established woodland, that takes decades to grow,and provides habitat for so many species of flora & fauna.Planting new trees is needed, yes, but not at the cost of established woodland.

If Lockdown taught us anything, it's that nature is absolutely vital to the well-being of humans, yetyou propose stripping it back to the benefit of no one except money-hungry property developers.

This destruction if wildlife habitats, and decades-old trees should never be a consideration.

Killing 700 trees, virtually an entire woodland and native hedgerows to build anotherugly housing estate is criminal. This site is a Site of Nature Conservation Interest and should bepreserved, for the sake of both wildlife and future generations to enjoy.

This site is home to 700 native Hawthorn, Blackthorn and Elder, known for supportinghundreds of species of invertebrates and wildlife.It is an established urban treee habitat, full of life.

Nothing can make up for loss of a woodland in a city, not even the supposed "replacement treeplanting". It takes 100's of years for trees to establish.

This would only devalue Bristol as a city, green spaces are vital for pur wellbeing and for theclimate.

Find a location that doesn't involve pulling down established trees for housing.

With the poor air quality and biodiversity in Bristol we cannot afford to lose further treesand hedgerows. This is detrimental to the city and environment.

Destruction of vital habitat. Loss of yet more woodland and bio diversity.

Leave the trees in the ground! We are in a climate crisis and the last thing we need isyet more ecocide, ripping up our remaining woodlands. The U.K. is one of the most naturedepleted countries in the world , this behaviour MUST STOP. Find somewhere else for yourhouses, which will cause less damage to our environment.

I have been watching developers eat up the land in the area (I am based in Southville)and I object to this particular plan as the decision seems to have been made by a planning officerwho has no idea what this space means to the people of the local area, as well as the naturehabitat that will be destroyed. I understand housing is needed, but there's an underlying air ofcorruption and foreign investment that has ZERO to do with building beautiful spaces for poeple tocall home.

Will ruin the local look of the area

This is an inappropriate use of green space. Bristol promotes how it is a green city, thiscontradicts that. Trees provide a buffer for the traffic noise and fumes, the wildlife needs itshabitats. There are plenty of other sites that are sitting abandoned which could be used. It isdisappointing that the council is so short sighted yet again

I object due to the removal of hundreds of established trees which are really importantas a break from urban space in a city. I would expect better coming from Bristol especially to buildmore houses that aren't affordable. The trees that will supposedly replace are just fragmentedsaplings that won't take as well or support no where near as much habitat.

Vital green space and animal habitats will be lost so I object.

Yet another application to destroy an area of importance to wildlife, biodiversity and thelocal area. Is there no more respect and understanding of the crucial role these areas ofestablished trees and hedges are to the health of us all? Planting new trees will take years to be ofbenefit - don't be hoodwinked by yet another developer. Protect your areas of woodland and givethem the value they deserve. Find a brownfield site somewhere else.

I object to this piece of environmental vandalism.

This is unacceptable, to be removing vital habitat that's is required for a healthy Bristol!This must not go ahead due to the destruction of vital habitat for EVERYONE

There is no second option of 'continuing as usual' in our current state. Scientists timeand time again are saying that we cannot continue in our current way of living, we HAVE tochange to avoid catastrophic consequences to our climate, people and planet. And yet, anotherhousing development is being planned that would remove a whole headland of native, establishedwoodland? Replacing trees by planting more elsewhere does NOT counteract this effect. It takesdecades and decades to establish networks of roots, fungi and wildlife to cultivate an establishedwoodland. You cannot tear one down and replace it somewhere else. We do not have that kind oftime.Bristol is a city I have always admired for being modern, inclusive and sustainable. Please do notchange this by building mostly unaffordable (70%) housing in an area that is vital to the protectionof the natural environment. Invest in brownfield sites. Invest in repurposing unused land. Do not bea part of the problem - we are only a few generations away from catastrophe, and we are alreadypast the turning point for change. You can limit the damage Bristol inflicts on the climate crisis byrejecting this proposal on the grounds of climate concerns.

Stop building on wildlife reserves there's plenty of brown field sites. Use a modicum ofsense.

Completely and whole heartedly object against the cutting down and removal of awoodland and habitat for wildlife. New tree planing cannot replace the habitat and ecosystems thatalready exist here. It's morally unacceptable to chop down woodland to build more houses.

leave nature spaces alone please, please build on a brown site and please stop cuttingdown our nature

I object to this application on the grounds of amenity value, and the loss of trees.This area of grassland and woodland is used by locals as a recreational area; this would be lost ifthis proposal goes ahead. The proposal does include some landscaped areas, but these do notinclude the semi-mature and semi-wild nature area which currently exists.There are a significant number of mature and semi-mature trees, which it seems would be felled. Icannot see how this can accord with the declaration of a climate emergency, even if supposedlymitigated by planting (young) trees elsewhere. Mature trees, within the city boundary, are a veryvaluable asset.

As someone brought up in Knowle and who still visits friends there, I find the proposal todestroy this part of the country in the city to be wrong for many reasons. I feel because it is KnowleWest and not Clifton means to some people that every bit of Green space can be built on to thedetriment of those already there.

Other = Bristol resident.

I am writing to object to the erection of 157 homes on Novers Hill.

I understand that this development would entail the destruction of a beautiful and vital woodland,comprising over 700 native Hawthorn, Blackthorn and Elder and known for supporting hundreds ofspecies of invertebrates and wildlife. Replacement tree planting cannot make up for the loss ofestablished woodland. The loss of wildlife in the UK since the 1970's is terrifying (see BBC articlebelow), and we must protect what is left.

I realise people need somewhere to live, but they also need spaces to walk, be around trees,connect with nature, relax. Given the mental-health crisis this is all the more important.

Developers need to be building on brown-field sites and refurbishing empty buildings. Bristol CityCouncil needs to take bold action, and use the Compulsory Purchase framework to acquire emptybuildings, in order to turn them into council houses.

Thank you for reading this.

Reference: https://www.bbc.co.uk/news/science-environment-58859105

Ruining natural, established habitats for unaffordable, profiteering development isentirely wrong. The green spaces this city has (soon had) is a major selling point soon to bewrecked by greed.

We absolutely have to stop destroying native wildlife habitats for housing, especiallywhere these contain large numbers of large native trees. There are so many disused brownfieldsites in and around Bristol which would be better for housing and closer to amenities etc butdevelopers/planners don't seem to want to use them. Why not? Please stop and think of whatwe're doing to the environment and how we can make better decisions to protect nature.

This is not acceptable, to destroy this amount of natural woodland, it's been woodlandsince before 1600 ad with semi natural woodland for recreation health culture and historicalinterest not to mention carbon capture and the fact none of these houses are affordableHistorical woodland should be left alone or nothing will be leftI am beyond sadness that this is even being considered

Stop putting profit over the environment

Please find an alternative site that doesn't require destruction of nature.

I refer to the seemingly relentless war on nature and the devastation of precious wildlifehabitat all over the UK. We are amidst a grievous biodiversity crisis. People just don't realise inthat humans cannot exist as a species without a rich diversity of flora and fauna. We have toprotect and preserve any existing pockets of precious habitat, areas such as this one. Please,please reconsider

Disgraceful application that needs to be thrown out immediately!

I am a resident of Bristol and object to the development plans due to the sheer amountof biodiversity in this area which will be lost if this goes ahead. Please, think of future generations.Our Earth and animals are precious.

Please can this be thrown out immediately

This habitat is important for wildlife and human population alike and should be protectedas a green lung of established trees and hedges

THIS IS DELIBERATE ECOCIDE. THE REPERCUSSIONS WILL BE MANY ANDIRREVERSIBLE. YOU WILL BE HELD ACCOUNTABLE. YOU ARE PROPOSING THEMASSACRE OF A VIBRANT, THRIVING ECOSYSTEM. FUTURE GENERATIONS, INCLUDINGYOUR OWN GRANDCHILDREN WILL SHUDDER IN HORROR AT WHAT YOU HAVE DONE.THEY WILL NEVER FORGIVE AND NEVER FORGET, WE WILL MAKE SURE OF THAT.

I lived near the site and in Bristol for 60 years until I moved down.This woodland is treasured not only by people but the innocent wildlife living there.

I have family who love near here and we've already lost so much biodiversity. It wouldbe awful to lose more

Object

Destroying the wildlife in this area is tantamount to environmental terrorism. We are inan ecological crisis. There is nothing more important than preserving trees and nature in the area.There are plenty of brownfield sights to build on. To bulldoze this beautiful area of conservation ismorally repulsive, greedy and an act of evil. History will not remember fondly the city that wouldcharge its people a fortune to drive in a clean air zone and indiscriminately bulldoze preciouswoodlands in the same breath. Do the right thing. Leave our green spaces ALONE. you are paidby us to represent us. Do the right thing for once.

I have lived in Bristol for over 60 years and feel very angry that Bristol Council agreed todestroy this very important woodland.

I live in north Bristol and have seen vital green spaces disappear at speed which isdetrimental to the health and well-being of those who live in these highly populated areas. Theremust be a change to protect a proportion of space to give the lungs to built up places in the widerBristol area.

Leave the trees alone. The wildlife will have nothing left and the houses are neveraffordable anyway!

DO NOT DESTROY ALL THE GREENERY. We NEEF plants and plantlife!!!

You need to be stopped from ruining this lands ecology! Greedy with no care for theenvironmental future for our children and beyond.STOP now

This seems like a scandalous destruction of wildlife and far from in line with a "climateemergency"?

I strongly object to this proposed development as this is an area of natural beauty, filledwith a huge variety of trees, supporting an enormous range of wildlife including rare species ofinvertebrates, insects, mammals and birds.Please reconsider these plans and look for an alternative brownfield site

Bristol is already seriously lacking in green space, and this development will onlyworsen that crisis for both people and our dwindling biodiversity. Furthermore, it will not alleviatethe housing crisis, as this is due to the rental market rather than absolute supply.

The loss of trees will cause an irreparable drop to air quality for the city, not to mentionthe loss of habitat. Tree removal of this scale is not acceptable, and can not be mitigated.

This is so short sighted and damaging. When will you realise that our ecosystems areinextricably linked? Have you not heard of climate change? Please, please, please reconsider thedestruction of such valuable life in the city I love!

In this climate crisis, with lack of animal and plant habitats and diversity, why are youtearing down an established woodland when you could build on brown site that is alreadydestroyed.

This is WRONG!

Commenter Type: Other

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:It is an absolute disgrace that in the current well documented climate breakdown and

biodiversity crisis, you are considering the destruction of this vital habitat. We cannot continue to

build houses in the way we do, we need taller buildings rather then semi detached and small flats.

There will be soon nothing left apart from cement, roads, intensively farmed fields and overly tidy

towns, parks, gardens and road sides. The removal of this green space will also cause an

increase in pollution and diseases such as of the airways and cancers. Not to mention the purpose

these area represent for high winds and floods mitigation purposes. You have got the moral duty

to oppose to this shamble. If you don't you will be responsible for having failed nature and future

generations from a livable world . It is disgusting. Humans are not the only specie on this planet,

which we, are running down. I hope you will make the wise choice to oppose to this truly

depressing catastrophe, which in no time will be classified as ecocide. On a final note, the UK is

one of the most natural depleted countries on the planet. And this is evidenced by the like of this

project. Criminal.

Best wishes

Commenter Type: Other

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:Nothing can make up for loss of a woodland in a city, not even the supposed

"replacement tree planting" as part of the development.

It should be the primary responsibility of Bristol City Council to protect the environment against

greed and exploitation, especially where the natural habitat is already well-established and

supports a myriad of wildlife.

Yes undoubtedly, there is a need for cheaper housing but there are many other brownfield sites

that can be used for this purpose without affecting the environment and the wishes of the people

who live within the vicinity.

I trust that the councillors responsible for the decision-making will look closely at figures readily

available of the considerable damage being done by housing developers not only to the

environment but to the local infrastructure, lifestyle and social attitudes and adjudicate against in

this case.

It really is time for each one of us to stand up and say 'enough is enough and NO to greedy

developers looking to exploit every little loophole and parcel of land for their already overfilled

coffers.

I remain

Yours sincerely,

These slopes are an important part of Bristol's ecological diversity. They must remainand brownfield sites or empty buildings used for house building instead.

This area is vital wildlife corridor. It is a particularly important habitat for a wide variety ofbirds, mammals and rare wildflowers. The proposals will destroy a critical area of maturewoodland destroying 700 trees and a mature hedgerow.. The consequential loss of habitats andspecies will be devastating.

Keep the woodland intact.

I object to this development due to the number of trees that are going to be cut down.We are in an ecological crisis and this area of trees provides vital habitat for local wildlife. Thetrees also help provide clean air in a city with toxic levels of pollution. They also help regulatetemperature which is desperately needed as our summers are getting hotter. I think to removethese mature trees would be a crime

Unbelievable that you would even think to cut down so many precious trees!! Should beunlawful.

I very much object to the destruction of mature woodland for housing. This is a climateand biodiversity emergency! I do not agree that replacement planting will mitigate these losses tonature and to the community.

The felling of trees and hedgerow is completely unacceptable, please please reconsiderthe way these homes are built and ensure this woodland area is not destroyed.

Object to the potential loss of much needed green space in south Bristol

I oppose this project because such a huge number of trees will be destroyed. Manyhousing developments have already been built all over the south of England and we are one of themost severely nature-depleted countries in Europe. The housing is not affordable and will not helpthose who work in the area.

To whom has planned this housing area, I ask of you, though not local to Bristol butconsiderate to the facts that our country is depleted of nature, to consider avoiding the senselessdestruction of the hundreds of trees and hedgerows that will fall victim to this planning system.

There is a group online who ask of you to be gracious and spare the woodland which is home tomany wildflowers and wildlife that thrive for survival from the rich eco source the wood provides.

We are in a state of a Climate crisis and emergency. The same for the Biodiversity; our Bees arein decline which is vital for crops to bring food to all. Other Pollinators are suffering and many havenoticed there is less activity of the insects. What makes them important is also the food chain;birds of many need insects as do we but we can't provide if we allow the felling of trees andcomplete removal of hedgerows.

Let me need remind you that every year from 1st March to 1st September is Nesting Season and itis ILLEGAL to fell any trees and hedgerows that birds will have chosen to build their nests. Thisgoes for the same to the public and should not be overlooked or ignorantly destroyed!

While wildflowers are being planted and people are demanding for their Councils to not mow thegrass verges that have been sown for the Pollinators, they have ignored this as well as ourpetitions. Our voices and protests have gone unnoticed but not by supporters.

Another problem is mitigation. While some areas agree to replace trees they've felled, the lack ofunderstanding that what grows is saplings that need over 10+ years to reach maturity; their

crowns are the sign of their ability to provide for wildlife as well as shelter from intense heat andclean the air of carbon emissions that is required for a healthier lifestyle is misunderstood.

So I ask of you to please spare this land of horrific destruction your idea of housing will inflict onthe land as well as distress for the wildlife and shock from the public that hundreds of trees aredown because of the lack of knowledge of what we're going through right now.

This is the group - please read and acknowledge their concerns.https://m.facebook.com/groups/2560966744207814/

The plans to uproot hundreds of trees and remove a home for countless mammals,birds, and bugs are abominable. This area is a habitat and plans to remove this will no doubt killthousands of organisms. This area might be a home for hedgehogs and birds that are in seriousdecline. This area is invaluable as it is a natural carbon storage as we try to reach net zero. It alsoprovides shade for nearby properties which is invaluable as temperatures are due to rise becauseof climate change. This is extremely unhealthy for the planet and outright murderous.Please think of the planet and not your wallets.

Having visited Bristol in the past I was impressed at the natural environment containedwithin and around the city. We are co stanrly being told that we need to protect our planet and thisproposal would appear to be the opposite of that. Many species will be destroyed if this goesahead.

I object to this application in the strongest possible terms. It would be utterlyreprehensible to allow this development to go ahead and as a result, cause the destruction ofcrucial wildlife habitats. Over 700 native trees currently live on this land and they must be leftalone. Retaining areas such as this is absolutely vital if we are to halt the environmental andspecies collapse currently taking place.Do NOT allow this development to go ahead.

There is no justification for developing a woodland site. We are in an ecologicalemergency, and climate change means that replacement planting is very likely to fail. Noreplacement planting can mitigate the loss of established woodland. There is no excuse fordeveloping this site. As an expert in EIA, I can only assume that the impact assessment is eitherincompetent or corrupt. This development must be stopped.

No , I don't live in the City but I object on the grounds of maintaining biodiversityTree planting elsewhere is greenwashing and doesn't replace the biodiversity generated by yearsas a natural environmentI visit the City and do realise that in Bristol and elsewhere there is a shortage of housing but thereare brownfield sites , redundant office and industrial buildings that are more suitableThis plan looks even worse than the devastation in Plymouth recentlyPlease reject

700 native trees and hedges would be cut down for this development. Utter destructionof a habitat that is crucial in fighting climate change and home to our wildlife. These establishedtrees cannot just be replaced. Shocking that an application has been made to build here and cutdown an entire woodland.

Ancient woodland is a rich diverse habitat that now covers just 2.5% of the UK. Much ofwhat we have left is being damaged and once it's gone, it can't be replaced. Building houses onthis land will be a disaster for biodiversity in the area.

Although I don't live in the area, I frequently visit friends there. I object to thisdevelopment because it will involve the destruction of important urban woodland. This area hasover 700 native Hawthorn, Blackthorn and Elder, known for supporting hundreds of species ofinvertebrates and wildlife. It is vital not only for the protection of nature, but also for the well-beingof the residents. Nothing can make up for loss of a woodland in a city, not even the supposed"replacement tree planting" as part of the development.

This application should be refused.

We are undergoing a climate catastrophe and nature is under threat and yet we still seeschemes such as these that appear to have no concept of the disaster that is impending. Naturesuch as this cannot be replaced. Replanting schemes are not the answer. These are ancient treesand bushes that are inhabited by birds and insects and mammals that will not cope with theplanned removal and vandalism of their habitats.

There's plenty of light industrial sites in the city which could be redeveloped for housingwithout destroying valuable green spaces and woodland. I strongly object to this proposeddevelopment.

This is an appalling idea.Horrific environmental vandalism at a time when this monstrously nature depleted country needsmore biodiversity growth than ever.This cannot be allowed to happen.

This is well established woodland containing a wide array of tree species and animportant habitat for wildlife. As the UK is one of the most nature depleted counties in the world,keeping established green spaces is vital. There is a climate emergency and green spaces needto be saved.

Destruction of hedgerows and trees is indefensible.

This project would destroy irreplaceable mixed woodland at a time when habitats likethis are vital in combatting climate change. Every tree is needed now, there has been wantondestruction by building contractors in Plymouth, we cannot afford to lose another habitat, and'replacement planting' no doubt with hundreds of birch saplings, is no replacement!!

To destroy native woodland and natural spaces for yet more development is criminal.The UK is already the most wildlife depleted Country in Europe, leave some spaces for nature andsay no to this planning application. Your children, your grandchildren and their children will thankyou for taking a stand.

Removing the trees for houses is wrong on every level. Think of the current and nextgeneration, the environment and climate change and what type of city you want, as well as yourlegacy as a council.

we shouldn't keep destroying nature for houses which people can't even afford - thereare other options but no to keep destroying nature and what's left of our beautiful planet.

As a bristolian, born in 1963, I'm delighted with so much positive change in Bristol toimprove the urban environment, however,this application is not a step in the right direction. We allknow the importance of natural habitats to support bees and a range of plants, trees, insects andanimals especially with climate change and the threats that poses. No amount of replanting a fewtrees amongst the concrete sprawl would replace this area. I strongly object to this planningapplication.

It is impossible to replenish trees in a city, we need a biodiversity of trees within citiesand there is important animal life there which would be destroyed for the selfishness of humans.

we need to leave alone nature and let it do it's thing - not keep building on it.

stop destroying nature for housing - there are other options.

Our planet needs every tree and more. There should be no consideration for theremoval of mature trees and shrubs in the middle of a climate crisis.

We are in the midst of a ecological and biodiversity crisis, and such habitat loss andspecies displacement will only compound this.Replanting is usually poor and unmanaged and would take years to recover and provide the food,shelter, corridor of passage and breeding grounds.Nature would be fighting for the already depleted UK countryside and tree cover, species wouldmove away and potentially not return as they would be outcompeted in a vastly reduced area.Visiting these areas of nature beauty would be ruined and residents would have a poorer natureexperience.Woodland is the beating heart of a food chain for millions of creatures, from top predators raptors,foxes to the bugs and insects that form the base from where it all thrives.The UK is already one of the poorest in Europe for tree cover and habitat loss this destruction issurely not needed and we can put nature first!What will your legacy look like?

Please do not murder the woodland and hedgerows. There is far too much ecocidehappening thanks to councils and planning departments not thinking about/ ignoring the impact onwildlife and environment.

There are plenty of houses- the trouble is too many are now owned for holiday purposes .

The proposed destruction of woodland, and the habitat that it provides for numerousspecies which are vital to the eco-system, is barbaric.

The only locations that should be considered for this housing development are brownfield sites.

An unforgivable disgrace of a decision if this atrocity goes through!

No amount of replanting or other schemes can replace the woodland that will bedestroyed by this development. This should be rejected based on the removal of habitats,woodland and the affect it will have on the climate emergency that has been established by thecouncil themselves.

Re: Proposed removal of woodland on Novers Hill for housing.

This country has already lost two-thirds of its wildlife since the 1970s, according to:https://www.oxfordmartin.ox.ac.uk/news/new-report-reveals-two-thirds-decline-in-wildlife-populations-on-average-since-1970/

I strongly object to the removal of mature woodland for housing. The housing ought to be builtelsewhere.

Replanting takes decades for plants to grow and support wildlife. It's not the answer. The housesneed to be built in areas where houses already dominate wildlife, rather than lose more wildlife.

To destroy such green spaces, especially in a city such as Bristol, is out and outvandalism.

Too much loss of nature and the character of the area. Learn from Plymouth andSheffield.

The loss of habitats that would he cleared would be devastating to the local wildlife.Replanting of trees is better than nothing but will not replace the habitats and the ecosystem whichis established, which will simply die. As am environmental scientist, I strongly object to thisdevelopment. And, if the development must go ahead, I implore those in charge to incorporate thisestablished ecosystem into their plans rather than destroying it.

I understand the need for new houses but please we need to protect the alreadyestablished woodlands. Don't tell me you will then spend money to replant some trees somewhereelse. Surely you can see this makes no sense at all.

There should be no more loss of nature. New planting does not replace old growth

In a climate and biodiversity crisis, we cannot be tearing down precious wildlife habitatsin order to build homes. The trees in this area will support a vast array of species, from plants,insects to birds. The root systems of our trees help slow the flow of water, they support insectsand a vast array of life which will take decades to hundreds of years to re-establish if the woodlandis cut down.

not even building a million houses could make up for destroying a habitat and all thosetrees. This is desecration and if this goes ahead it will be a very sad day for Bristol and the wholeof the UK. Insanity

Stop chopping down trees and damaging wildlife habitats purely for commercial gain.

Building should not be happening on this site because it is valuable for wildlife. We arein a climate crisis and we cannot afford to lose this type of habitat.

On ecological grounds - this would be a terrible retrograde step when we are in aclimate emergency. Pls consider brownfield sites first

It will be disgusting for all that green land to be used for housing. Ther is a lot of animalsthat use that green land and all the trees,bushes and green land is good for the animals and theair.All greenland should be kept and any housing built on free land where business have packed in. Iwrite to oppose the buildings as do all my neighbours who have asked to be involved

Dear Peter,

I object to the Novers Hill development. With so much brownfield around - underusedindustrial and retail parks, boarded-up shops in high streets, empty office complexes -there's no excuse - none - for taking out natural wild places and mature trees in aseverely nature-depleted country such as ours.

Sincerely,

It's absolutely criminal, cutting down well established trees and hedgerows, grasslands,wild flower areas. Knowle is home to hundreds of animal and insect species that need to beprotected! We are supposed to be in a eco city - It's an absolute joke! Not to mention managinglaws slip, subsidence and flooding! Our natural world are key to our present and our future! Whydon't you see it? Why do you put money above the lives of animals, insects, birds and humanbeings. Global warming is real, and BCC you are key contributors to it, you should be ashamed ofyourselves. We will have no green space left for future generations to enjoy and learn about.Schools use our green spaces to teach generations of kids about all sorts of vitally importantecological,environmental and social issues and you destroy it! What are you doing?! How can youjustify your behaviour? This can't continue, this has to stop now before it's you late and thedamage is irreversible.

The land cannot hold on to water if we concrete over it all. Yes everyone needs a hometo live in but we'll all be dead a few generations down the line if we don't stop paving over our wildspaces. These pockets of wilderness within cities are more vital than ever, for us and also all thenon-human lives that pass through it. Building on these spaces makes short term easy gain forhousing development businesses that priorities profit over well-being. Soon we will be drowning inthe waves of concrete we flood our world with, or the world will drown us out as we have upset thebalance of the eco system so much. The western slopes are a vital wildlife corridor - a spacewithin the house that is only to be passed through not lived in. We cannot squeeze houses into acorridor. It is unfair for all involved. Everyone needs a place to live but we need to reallyunderstand what a place to live really means and it doesn't just mean four walls for wealthyprofessionals new to the city.

I have already submitted my comments to the previous application and they haven'tchanged -I still strongly oppose the application for the following reasons;Novers is a calm natural space, contains much wildlife some of which, some of which is protected.For locals it's a gem in an already built up area, enjoyed by residents and wildlife. Green areas likethis are essential in terms of absorbing carbon, protecting wildlife and helping bring peace toresidents. It should be protected - all of it. Building in this location, if allowed, will also set aprecedent for other developments with the possibility of Novers becoming covered in housing.There are plenty of other options open to Bristol city council - I see them every day when drivingaround Bristol. It is a conservation issue, and it is morally wrong to ruin an area like this anddeprive wildlife of its habitat. I understand access to the site is also a problem for local residentsare strongly oppose this application

Hello Bristol City Council,

Thank you for sending me this letter informing me of the proposed 157 dwellings on thegreen space on the west side of novers hill.

Firstly I would like to point out that this letter "sent on 6th March" arrived on ourdoorstep today 20th March which is unacceptable when you are expecting all commentsby today - I would recommend you at the bare minimum extend the period forcomments so that the wider community affected by this proposal can comment.

Secondly my household object this planning proposal. We areobjecting as Bristol was supposedly the green capital of Europe in 2015 and since thenhas continued to build on green spaces. There are plenty of new builds in the area andthis would cripple the already struggling local services around it. What I wouldrecommend the council should propose is we stop building outwards, start protectinggreen spaces and instead build upwards on already derelict industrial spaces. Alsowhen building houses consider the impact on local services or ensure new localservices are part of the application.

Thirdly, how many times does an application on green space like this have to beobjected before the council step in and stop it from trying again.

Thanks,

Why are Bristol City Council allowing such an ecologically destructive proposal? It clearly has very little to do with the need for “affordable housing”, because the developer is now proposing even less - from 47 “affordable” homes, to just 43. We object on the basis that the developer is now providing even less affordable homes than first proposed and is still using these properties as a sound and odour buffer for the rest of the development.

This is a city that has introduced a Clean Air Zone. Parson Street junction, the second most polluted junction in the city, is less than half a mile from this development site. It is incomprehensible that alongside such declarations, the same council is potentially allowing a developer to do this to one of the city’s most species-rich wildlife sites. No amount of “affordable homes” or replacement trees can compensate for the loss of an ancient, established habitat such as that of Novers Hill.

We object to the increased loss of hedgerow, due to the change in access points for the development. This hedgerow is designated as a TVG and is clearly integral to the ecosystem of the site. Virtually none of the ancient hedgerow will remain, should this application be approved.

We are continually told that the city is striving for “Net Zero by 2030” and “managing at least 30% of land for nature”, so how exactly is removing this amount of tree cover and habitat aiding these declarations?

We object on the basis that the Landscape and Visual Impact assessment was incomplete. What was submitted, was not at the correct scale and omitted the visual impact of retaining walls, roads and had street signage being taller than the homes itself.

What was submitted, in February 2022, shows houses being shown not to scale and distinctly reduced in size in one photo, then floating above existing houses in another, along with some floating trees. Similarly, the visuals do not include any roads/hard surfacing and have clearly included meadow and trees which will not remain, with houses sitting amongst grass. (See appendix).

This is deliberately misleading. The inaccuracies of these submissions make a mockery of the planning process and the council should be holding the developer to account, not least because they have had two years for this process. It is absolutely disrespectful to the community to be potentially altering a prominent South Bristol landscape in such a destructive way and fail to provide local people with any accurate, realistic and honest visuals. And as usual, Bristol City Council remains silent on the issue.

We object because no new LVIA has been submitted to consider all the new changes that the developer has made.

We object on the basis that there are sufficient brownfield sites alongside this site which could be used instead. To the east of this site, is an old school site at Belstone Walk, on which the council are now planning to build at least 50 homes, with the majority being affordable. This would easily account for the same amount of affordable homes proposed by Lovell, thus highlighting that we do not need to be building on green space.

We object because the local community wishes to retain the green space of Novers Hill in recognition of the wildlife and precious habitats. The community here has had to fight for decades to protect Novers Hill and it is time we are listened to. This application should be refused. It should have been refused months ago.

The comment is in addition to our previous objection.

The Friends of the Western Slopes Novers Hill 19th March 2023

Appendix:

The wildlife and woods are healthy and plentiful. Any development will destroy these

There is lots of natural habitat around here it would be a shame to lose it!

This land is an important and much loved asset to the local community as a naturalspace. I object to the proposals as they currently stand on the basis they are inappropriate for thisspace, and would destroy a rare and rich habitat that has been protected by the local communityfor decades and would be impossible to replicate.

The area in this proposal is important for nature conservation. Once it is gone, it can notbe brought back or replaced. It is important to balance development and not just build in an area'because it's there'. We want intelligent development taking EVERYTHING into consideration.PLEASE DO NOT DEVELOP THIS AREA!!!!!

Absolutely shocked that this development is being considered. South Bristol is an urbanarea that is in desperate need to preserve its green sites for its residents physical and mentalhealth, exercise and the opportunity to be out in nature without having to travel. And for childrenand their children to grow up with the ability to have local and natural (not man made) green sitesto play. This plan is to destroy an essential area and sanctuary for an abundance of wildlife. Theimpact on destroying this in a time when we should be preserving our natural green areas will besuch a great loss to local people, South Bristol and wildlife. The wildlife surveys and impactstudies have not been thorough enough. To use affordable housing units as "sound barriers" iswrong. To offset biodiversity loss in Nailsea is ridiculous. It is too far away. But the comment saysit all "biodiversity LOSS".

We still object to this application.It is frustrating that the developer has been given so long to pursue this ridiculous application on asite of importance for nature conservation and we are dismayed to learn that even more trees andhedges will now be lost if this goes ahead, and even fewer affordable houses are being offered up.The application has not been improved on, and seems to be far worse in fact.It is shameful that a nature corridor might be built on, at so little gain for the local community (sofew affordable houses for example). The transport and infrastructure issues have not beenaddressed properly either.Please reject this damaging housing application.

I completely object to Novers Hill being built on, even more so now that there will beeven less affordable homes and more natural habitat lost with the amended plans.We see so much wildlife up there. The whole of Novers Hill needs to be left alone to protectvulnerable birds of prey and bats.I have lived here for over 30 years and it used to be so quiet. Now the traffic is increasing and weare getting lots of road accidents and it is only going to be made worse by this.I think it is madness that the Council is allowing this to happen on Novers Hill. I should also saythat the land is not stable round here, many of the houses have subsidence issues. The same willhappen to these new homes I am sure.I think it is a really bad idea.

I strongly object to any part of Novers Hill being built on, both the Council ownedsouthern end and the privately owned northern end (the subject of this current planningapplication). The whole site constitutes an important wildlife corridor and is very unsuitable forhousing.I am not sure why the developer has been given so much time and opportunity to amend itsproposal. The time allowed to the developer seems to be unusual and a bit concerning.Regardless, the new proposal is still extremely flawed and should be rejected, for the followingreasons.

1) Planning approval has been refused on this site five times previously, and the reasons for therefusal have still not been addressed by the current application. It has been refused on thegrounds of irreparable damage to wildlife; the negative affect of development on the prominenthillside; the sustainability and access of the site and the overall benefits of development beingoutweighed by the reasons for it not being built. These issues are even more relevant today.

2) Novers Hill is a Site of Nature Conservation Interest (SNCI) and a vital part of the MalagoWildlife Corridor. The SNCI status has been recently re-asserted by Bristol City Council. TheBristol Local Plan 2014 states that the site "is of city-wide importance to nature conservation".Bristol City Council's own Nature Conservation team has stated that if this site is used for housing"most of the habitat affected could not be recreated elsewhere within a reasonable timescale,there is no potential for appropriate mitigation, and the integrity of the Wildlife Network will beseverely undermined".

3) Novers Hill is also identified by the West of England Nature Partnership as being part of a"nature recovery network" encompassing "strategic grassland" and "woodland opportunities". BCChas itself endorsed this wildlife network strategy as part of the Forest of Avon action plan.

4) The golden motion to protect our vital green space passed at full Council, with not a singleCouncillor voting to oppose it. Novers Hill was specifically mentioned in this motion as one of thesites that must be protected. Nothing has changed at Council to change this.

5) The ecological crisis declared by Bristol City Council obviously still exists.

6) The CPRE have stated that up to 30,000 homes could be built in Bristol on brown field sites, sothis site should not even be considered for housing. There is an old brownfield school site just tothe east of Novers Hill that will have 50% affordable homes built and will make up for thescandalously small amount offered up by Lovell for the privately owned site (which is greenfieldand ecologically rich).

7) The developers amended proposal is to offer even less affordable homes than their previousproposal! And even greater loss of woodland and hedges! Most local people will not be able toafford these homes and will instead see even more of their much-loved green space taken fromthem.

8) The proposed Wildlife corridor is much too small. The development will not maintain theintegrity and connectivity of the wildlife network. Too many habitat units will be lost, with a largenet loss of biodiversity on this SNCI. Policy 2.19.15 of Site Allocations and DevelopmentManagement Policies states that "Sites of Nature Conservation collectively represent the city'scritical stock of natural capacity. In some areas of Bristol, SNCIs offer people their only valuablecontact with wildlife. Therefore, development proposals which would harm the nature conservationvalue of an SNCI will not be permitted". This point alone should be enough reason to stop thisapplication - the meadow, woodland and hedges are part of the SNCI and will be harmed bydevelopment.

9) The ecological survey commissioned by the developer is now hopelessly out-of-date. There hasbeen significant change to the meadows and other parts of the SNCI, given that the horses wereremoved in June 2021 and the previously overgrazed areas were growing abundantly in 2022.Otters have since been confirmed as using adjacent Pigeonhouse stream. The RSPB launchedtheir annual bird watch from Novers Hill and recorded lots of birdlife - egrets, sparrowhawks, andmany others. Peregrine Falcons have also been spotted flying over Novers Hill very recently. Thedeveloper has had plenty of time to commission a new survey, the fact that they have not meansthat this application should be rejected. Even the original survey failed to carry out an invertebrateand winter bird survey. Ethos did not carry out an invertebrate study because the grass was tooshort from horse grazing at the time of survey. The grass has since been allowed to grow, and anupdated survey for invertebrates must be undertaken. The out-of-date ecological report is also a

concern in regard to the large established badger colony, which we have had no recentinformation on.

10) A key finding in the ecology report was the presence of Greater & Lesser Horseshoe bats onNovers Hill. These are rare species that are in decline in the UK. The developer has claimed thatthey have left enough of a bat tree corridor to allow them to continue their commute through thesite, but I think this misses the point. These bats require meadows to do their foraging, notwoodland. It is these valuable meadows that Lovell is planning to bulldoze. What is more, theupdated proposal would see even more woodland and hedges removed, and the developer hasfailed to acknowledge the impact of street lighting on the new roads on a supposedly dark batcorridor.

11) The ecological mitigation measures suggested by the developer are inadequate, with themitigation site proposed being in Nailsea (not even in Bristol, adjacent or nearby). I am also veryconcerned that the BNG metric is also out of date, and version 3.0 has not been adopted. Thedeveloper has been given ample time to address this but has failed to do so.

12) In the Site Allocation and Development Management policies, DM17 2.17.3, the entirety ofNovers Hill is classed as "prominent green hillside". It states that "proposals which would harmimportant features such as green hillsides, promontories, ridges, valleys, gorges, areas ofsubstantial tree cover and distinctive manmade landscapes will not be permitted". Anydevelopment on Novers Hill would harm the important feature of Novers Hill being a green hillsideand therefore directly go against this policy. This point alone should be enough to stop thisdevelopment. The landscape and visual impact assessments offered by Lovell are verymisleading; the houses are drawn too small (not in scale with surroundings), and they also do notshow the new roads or the huge retaining walls!

13) My other main concern with this application is the increase in road traffic and pollution it willbring, particularly with the proposed road change. The area around Parson Street Primary Schoolis already one of most polluted areas in Bristol. This is not just about the 200 or so new cars, butthe fact that the one-way system will force many more existing vehicles onto Bedminster Road,Parson Street and the Hartcliffe Way, affecting the School and local people. There are too fewshops and employment opportunities in this area. Most local people travel elsewhere for thesethings. This is not a sustainable location because of the heavy reliance on car use. There is nopublic transport on Novers Hill, with the nearest bus stop being over 800 metres away and onlyaccessible up a very steep hill. In response to this the developer has not improved on its transportplan, perhaps because there is nothing that can be done. As stated previously, this site isunsuitable for housing.

In summary, this planning application is wholly inappropriate for Novers Hill. Building here willdamage the environment, the wildlife network and the health of local people. What's more, giventhe recent golden motion passed to protect this site at full Council, it will also damage people's

faith in local democracy. Instead, let's protect the entirety of Novers Hill and follow the call from thecommunity to get it protected once and for all as the Nature Reserve it should always have been.People here have had to fight this battle for over 40 years. The same issues of wildlife damage,access, effect on the landscape continually arise. Enough is enough, leave the Novers Hill SNCIalone.

The negative impact on green space is well documented. It would be a great shame tolose this area and somewhat contradictory at best, of the council, given the ecological emergencyin our area.The other more practical objection is on the infrastructure, or lack of, in our area.Doctors surgery's, schools, dentists and all other amenities are already stretched and addinganother population surge will not improve this outlook.The last "new build area" at Bridge Views opposite Camberley Road has caused nothing but trafficissues leading to confrontation between residents. Lack of available parking space in Bridge Viewshas spilled on to Novers Hill/Novers Lane and in to Camberely Road.

I live locally and am appalled that Lovell Homes are continuing with their application tobuild houses on Novers Hill.

This project will cause environmental harm and effectively destroy this nature rich and preciouswildlife rich site and green space.

It is contrary to Bristol Council's policy of reducing carbon emissions and also as it is currentlylooking at where and how more green spaces can be managed - I would suggest the first step issurely to stop destroying existing ones.

With the new alterations to the application it appears that even more hedgerow and trees will beremoved and if it goes ahead will result in the loss of meadow and the removal of an establishedbadger sett. This is a site of nature conservation., a valued local nature reserve and many birdsand other wildlife are present in this location and give local residents and visitors joy and apeaceful green space. We know green spaces are important for people's health and well being.

Most of the housing proposed is not even addressing the real need for council and affordablehousing but if it goes ahead will destroy a beautiful and important nature site for good.

Please do not allow Lovell Homes to build here.

To Bristol City Council

I am writing with my objection to planning notice 21/05164/F

I am not from the Bristol area but I have been closely following the planning regardingLand on West Side Of Novers Hill Bristol.

I am passionate about keeping our precious green areas which are full of wildlife, aswith other green fields it has a complex eco system. Novers Hill site has been enjoyedby local peopIe for many years and I can see no advantage of building of this land apartfrom the council backing down to developers . Why was this site even considered?Build on brown fields site first and protect our green fields.

Unfortunately after fighting to keep land what was suppose to be safe guarded by theGreenbelt status in my our local area, Tewkesbury and Gloucester county council neverlistened to local people and in their wisdom decided to build on this land which is on avery large floodplain, any concerns from local people were selfishly ignored.

Any housing developments should be planned on brownfield sitesI fully support the local people in the area that are fighting to save Novers Hill, Anydevelopment would seriously damage the ecosystem and habitat for many wildcreatures that currently live in and around this area, these creatures have as much rightto a home too. We can't keep destroying habitats, once it's gone it gone.

I appeal to Bristol County Council to see sense and turn down the revised application21/05164/F and protect this precious area from developers. I would like it to be

saved it from what can only be described as destruction of natural habitat which wouldbe a disaster for the wildlife and the local people who love this area,By making Novers Hill an official nature reserve it can enjoyed for years to come and forfuture generations to enjoy this wonderful area.

I look forward to hearing from you.

Over the whole of this application and other applications I have consistentlyOBJECTED, and feel proud that I represented local residents in support of Bristol City Council init's defence against Persimmon Homes's application to the Secretary of State to grant it'sapplication to build much fewer dwellings. This was back in 2001 or thereabouts and was lost bythe developer, which was further supported by the Secretary of State with his remarks beingbasically, why would anyone consider build on this GREENFIELD site.Please note .. absolutely NOTHING has changed in any way and moreover BCC has withdrawn itsown (Goram Homes) application for the immediate adjacent GREENFIELD site.As previously said this is a valuable asset for the citizens of South Bristol more for the immediatearea for it's local Residents and hopefully the workforce who pass through or in local work areas.The asset is in general health and also mental health.REMEMBER, THERE ARE A HUGE AMOUNT OF BROWNFIELD SITES .. SO APPLY FORTHOSE AND BUILD TO YOUR HEART'S CONTENT AND THAT OF YOUR SHARE HOLDERSPOCKETS.

Whilst this is a slight improvement on the previous plan with regards to the reducednumber of homes being proposed this is still adding to the total number of homes being proposedin the area:

34 on Kingswear Road71 on Leinster Avenue12 on Marshall Walk30 at Filwood Broadway (Cinema)50 at Western Slopes94 on Airport Road47 on Broadbury Road29 at Filwood Broadway (Swimming Pool)157 on Novers Hill (This application)

524 in total

Including those where planning permission has already been granted and work has started.

There shouldn't be a problem with new homes being built, but the complete lack of any criticalinfrastructure being planned for the local area means even more strain on the alreadyoverburdened schools, doctors, dentists and other vital services as they try to provide for thesenew residents.

This, along with the slow but steady removal of public transport links in the area, will only createmore issues both immediately and in the years to come.

I think the cumulative planning permissions being proposed and granted while ignoring the needfor basic amenities show a distinct lack of foresight and understanding of city planning which willbe to the detriment of both current and future residents.

We object to this planning application. There is already numerous housing developmentsites taking place in the surrounding South Bristol area. We need to preserve our green spacesand the bio-diversity of this area for everyone to enjoy. This is not a suitable location for housing.There are better suited brown sites for housing in Bristol. Let these green spaces benefit thehealth of the local residents.

I used to live in the area & its important to protect calm green spaces for the well-beingof residents & to preserve biodiversity in a terrible awful climate crisis. This is an important greenspace.

The proposed site on Novers Hill is an area of Special Scientific Interest and should notbe built on. Bristol City Council are supposed to be promoting green initiatives in this climateemergency but this development will destroy a vital wildlife corridor if allowed to go ahead. Despiteprevious objections and feedback from local groups the developers are now planning to destroyeven more trees and protected hedgerows than the previous proposal. This must be stopped toprotect the wildlife and the local air quality, which will also diminish if these trees are removed. TheWestern Slopes are a beautiful and vital landmark in South Bristol and once this area is gone it willbe gone forever.

This area is home to a tremendous amount of wildlife. Novers hill is also already subjectto an incredible amount of traffic. Adding more homes will only impact the environment, increaseair pollution and impact the local services such as the schools and doctors. Unless plans for newdoctors surgeries and schools are planned for the area, I don't see a benefit to having moreresidents when our current services are stretched well over capacity already. Local people havemade their feelings on the building on Novers Hill very clear and it is not wanted as there is noecological, economic or environmental benefit, only that of lining people's pockets!

This is an unsuitable area for development and would further reduce the amount ofbiodiverse, green spaces in south bristol

Don't build on green areas when so many othe non gree are available

I am against the building of homes on the western slopes and I think this would beextremely detrimental to the area. Not only is the site a nature reserve and provides a greencorridor which to remove would make bristol city council hypocritical in their claims to becomingmore eco friendly, the site would not be suitable to building due to the slope that this is on and thelack of infrastructure for access on the surrounding roads that would cause no end of disruption forresidents. Do not build on the western slopes and protect bristols green spaces

The land is totally unsuitable to build houses on. It's a very steep slope. There has beengarages on the Novers hill which has already suffered subsidence and collapsed. It's also a veryimportant ecosystem for the environment and gives plants and animals a very important home inBristol. The access to the houses would not be suitable, the road leading up the hill is too small forsuch heavy traffic. You can't keep building all these houses without putting in extra doctorssurgeries and schools and dentists. Where are these people supposed to sign up to such thingswhen everything is already full? Build the schools and the doctors surgeries, then maybe thinkabout houses on already brown land not the only bit of green space around this area

I live nearby to this proposed development in Bedminster Down. My objection is onenvironmental grounds.Novers Hill is an important green space which connects to Crox Bottom, Manor Woods, and theNorthern/Western Slopes to form a vital wildlife corridor. Thirteen protected species, includingotters and kingfishers, were found in the wider area during an ecology survey published in 2014.The land is currently used for grazing horses and enjoyed by locals as a vital green space for thecommunity.I understand the need to build more affordable housing in Bristol but strongly disagree with thishappening on vital greenfield spaces rather than exploring brownfield land as the first option.

This area of South Bristol is home to a huge amount of wildlife and the space is used bylots of the community for walks, classes and education. There is nothing within the submission thatadequately responds to the removal of green space or homes for wildlife. The submission alsodoesn't adequately cover the impact of the additional vehicles into that area, the surroundingroads already struggle with the existing population.

The revised application does not address any of the concerns put forth in my previousobjection, therefore I continue to object to the loss of valuable green space that providesthousands of people with access to exercise and improved mental health so that landlords canbenefit from the income from 157 rented flats.

This development will strip out highly valued naturalOpen land, which is massivelydetrimental to the welfare of localPeople and damaging to the environment. In my view, if thisdevelopment is to go ahead, it shouldonly do so ifit's 100% affordable. Bristol isbeing sacrificed to the needsofdevelopers and theirpockets, while the welfare of localpeople is trampled over.

I object to destruction of green spaces such as this at Novers Hill. My feeling is thathousing should be built on brown field sites as a priority. I also object to increase in number ofdwellings in that area without sufficient infrastructure being put in place first - food shops (asopposed to convenience stores), schools, GP surgeries, libraries, public transport.

Again Bristol City council are going to sell out to the devolopers.Not one word of the benefits for the local residents!We lose our green spaces and money talks, as usual.

It is of great concern that allocated land is being sold off and develop film. I stronglyobject to this, especially since I live in a local new build which was actually built upon oldcommercial land/brownfield

It is is completely ridiculous to use his land for this purpose when there is plenty of unusedbuildings and Brownfield available in the area

I wish to restate my objection, slightly amended, to this development made on 1November 2021.

Although the number of homes has been lowered by 13 it is not clear what the changes mean foreach of the two site allocations in the Local Plan that this application covers. It would have beenhelpful to have had a revised or amended Design and Access statement to make things clearer.

In the Local Plan the site allocation (BSA114) states that the potential housing is estimated to be50 homes.

This is the area of development immediately uphill of the Bristol Waste depot. I understand thatthis is the "northern allocation" in the application.

I am concerned that if agreed (and the number of homes to be provided is above that in theBSA114 allocation) the application creates an intensity of buildings and people not envisagedwhen the Local Plan was developed; but also sets a precedent for similar sites across Bristol to bedeveloped using figures that are significantly in excess of the Local Plan.

The site identified for this development isn't unused waste land or brown sites, it's a wellused bio-diverse nature reserve area tended to by community volunteers, relied upon by locals forwalking in nature whilst being in a city and kids playing and learning about wildlife in their localarea. This green space is crucial to the eco system of this area and if we lose it we will all beworser for it.

More homes are needed in Bristol but this is not the site for it. The proposal of destruction of somuch green space and the habitat of so many animals and insects and greenery is veryconcerning and not in the interests of local people.

Not to mention the local infrastructure is insufficient to cope with hundreds of more people living inthis area. Wherever you do build these 147 homes, a new doctors, dentist, pharmacy, nursery,primary school and post office must be built too in order to make it sustainable and feasible. Thissite can't accommodate that so why even pursue it as an option. It's not appropriate.

I objected after the first plans, and I still object now. I think the animals that are thrivingthere should be left to do so! I still believe that novers hill is not suitable for the traffic it holds at themoment, let alone more traffic. I still believe that even with the new plans, there are not enoughlocal amenities to suit the new houses. They are still using the social housing as a buffer for thenoise. We have lost so so so much green space round this way over the years. Please just let theanimals keep this bit!

The first thing to note is the lack of help in understanding all the changes to theapplication. No public consultation or events, the developers' website has been down for sometime, there are a mass of new documents uploaded to the portal but their numbering does notmatch the list provided by the developer.

Attention to detail does seem to be an issue for this developer, the boundaries on their maps moveabout all over the place, sometimes directly against the buildings on the Honeyfield and ETMproperties, other times it wanders metres away. The same happens on the top edge with the roadon Novers Hill, sometimes the hedge is in, sometimes out, the hedge that is Town and VillageGreen and protected for the people of Bristol. The boundary on the southern edge also wanders,with the developer sometimes counting trees not even on their land. There are still roads leadingto nowhere, definitely not needed now that the council has right announced it will not build on theslopes following ecological surveys.

Not enough has changed in the application and all the same planning and transport policy failingsremain. The ecological surveys are out of date and given findings on the council owned land mustsurely be held in some suspicion about their accuracy. Wildlife doesn't know about land ownershipand there is no significant barrier to prevent it crossing from one to the other.

The scheme will still cause significant destruction and change to a prominent hillside. The houseshave increased by a storey, being even more intrusive to the wide and steep green hillside. Theroads have been slightly widened on the corners to allow a rubbish truck to actually get aroundthem, but this relies on people not parking in the wrong places. And are the trucks driving all the

way down and reversing back out? These are two cul-de-sac estates. There also don't seem to beenough electric vehicle charging points.

If we look at the smaller extent of the Site of Nature Conservation Interest SNCI area (which ofcourse I don't agree to the reduced boundary, as there is nothing to document the change beingmade, as others have argued far more fully then I have), the works would significantly disturb anddamage the SNCI. There is a massive amount of disturbance to the SNCI; the building of a playarea and 'woodland' walk, the large drainage ditch from the upper estate to the lower, removal ofsome trees and the adding of trees to this meadow, relocating a badger sett, removing theJapanese Knotweed, unnecessary ornamental planting of non natives, the large embankment tosupport the road on the lower edge of the upper estate. Further large scale removal of trees andhedge is suggested for the ancient Town and Village Green hedge along the road of Novers Hill.

The site is so steeply sloped that the addition of new paths between housing and also puncturedthrough the TVG hedge in an attempt to make the site more accessible simply show howinaccessible the site is, as they have a large amount of steps. Anyone with mobility issues willstruggle significantly to move around these estates.

The social housing, even with it's amended design is the sound barrier between the industrialareas along Hartcliffe Way, including the recycling and reprocessing plant of ETM, and the privatehousing with it's views across to the Clifton suspension bridge.

No access to Hartcliffe Way is available, the most obvious route is through Honeyfield BusinessPark, but they seem stubbornly against providing access across their site (there is of course a linkin ownership between Honeyfield and the Novers hillside). Even so, suggested paths through hereor the ETM yard would involve paths across secluded, hidden areas with no overlooking housing.These are not paths that any sensible person will use, if they were ever to become reality which ofcourse no credible evidence of this possibility is given or presented in the public domain. The ETMland is on a long lease, with no indication they want to move, and no suggestion of how they couldsafely accommodate pedestrian across across a site busy with large trucks.

The drainage area has had a few changes, presumably for possible future path connection but allthis has done is present the possibility of dangerous dead end paths tucked behind housing,leading to nowhere. It's clearly not safe. Suggested tree planting locations have been moved to dothis and at times wander out of the site boundary, depending on the map you are viewing. Thislack of attention to detail is a worry.

There is no credible traffic solution suggested for Novers Hill (the road). No meaningful changesseem to be given to the suggested cycle and footpath, tucked behind the hedge - how they canget lighting here to help safety and not ruin the wildlife habitat/corridor of the hedge? Of course thehedge no longer acts as a wildlife corridor with the large holes suggested for two roads and a pathwith steep steps. Presumably in an attempt to make the lower entrance/exit to the path safer and

to give more visibility of traffic on the road of Novers Hill and coming out of the new estates, aneven larger and longer section of hedge is now suggested to be removed.

They are too many constraints on this site to make usable housing, with safe and accessibleroutes in and out. And the disruption and destruction of an valuable SNCI area is just too great.There's no offsetting or mitigation for the habitat loss made on the site or nearby. The onlysuggestion seems to be Nailsea which is much too far away. Currently the whole of this meadowand wooded hillside offers a large habitat and wildlife corridor from Hengrove Mounds and CroxBottom, through Inns Court along the side of Hartcliffe Way, and down along Pigeonhouse Streamand the Malago, to the Berry Maze, Northern Slopes and Knowle West Health Park.These areasare natural, existing heat sinks, carbon stores and flood prevention. Retaining these areas andlooking after them is far cheaper than actions to increase our tree canopy or habitats to meet OneCity Climate goals.

This site is not appropriate for housing, with it's current issues around lack of permeability, loss ofwildlife habitat, rare meadow and tree loss, and visual impact to a prominent green hillside, whichcan be clearly seen from the suspension bridge and Royal York Crescent in Clifton, and from thedescent into Bristol from Dundry.

We need truly affordable housing, but this site is not a reasonable place for it.

This has always been a green space between Knowle and Hartcliffe , a green belt thathas stopped urban spread. As a child I played on these slopes, always horses and wildlife there inbetween the council estates.Trees and hedgerows are important part of the ecosystem . Do we want to destroy a meadow andbadger set? Generation's have enjoyed this green space

The area does not support additional housing, the infrastructure is not in place,it cannot supportextra cars.

The site is still a Site of Nature Conservation! And developing this half of Novers Hill will impactthe ecosystem of the rest of it!

I object to this development. Save this green space for future generations to enjoy

It is important that natural spaces, particularly those contained within urbanenvironments are protected for the health and wellbeing of the local people, and to preserve theecology of the local area.

I object massively to this hideous desecration of a small green lung in the area in WhichI live however I will use some comments of younger members of my family. Being that we shouldbe building for their future - why are the trees being destroyed for bricks - they don't help us live ahealthy life. Why are they killing all the animals, where will they live - they can't live in a house. WillI be able to live there ? Well no is the answer because "affordable " is not "affordable" oraccessible to the majority. Parson Street school is one of the most polluted schools in Bristol thisnew development will make this increasingly worse with more traffic pollution being outside theclean air zone offers no protection from this. Give our children the opportunity of clean air youwere once afforded and now are setting out to take away from them.

Bristol is severely lacking open space for wildlife, building on this space would bedestructive for wildlife and our enjoyment of natural space. New building should be on brownfieldsites, and new facilities should be included (eg doctors surgeries, schools, parks, shops etc)

I live with my family in South Bristol. I am writing this statement to object to the planningapplication submitted by Lovell for Novers Hill- Western Slope.I would like to object to this planning permission based on below points:There are now, even more, hedgerows and trees being removed.The BNG LOSS is still massive! It's an embarrassment for a city trying to go "net zero" if thisapplication is approved!The BNG offsetting site is not even in Bristol.Social housing is still in the worst parts of the development and is used as a buffer for the openmarket, expensive housing.The actual roadway of Nevers Hill cannot cope with the extra cars.The complete loss of meadow and removal of an established badger settThe site is still a Site of Nature Conservation! And developing this half of Novers Hill will impactthe ecosystem of the rest of it!Bristol needs all the green areas for residents' health, mental well-being, and wildlife. These greenareas are crucial for our lives; both humans, and wildlife. What Bristol needs is not building morehouses by destroying the green areas. Building on green space is a backward method whichshould be left in the very past times.What Bristol needs is:1. Only build on brownfields.2. Making it compulsory for developers to allocate more and real affordable houses in theirprojects.3. Introduce the capping system on the renting rates. There are enough accommodations/houses/flats in Bristol. The high rate of rent makes it almost impossible for people to afford it.

4. Make sure that we all stand up and support and protect our green areas and wildlife. When theGolden Motion was passed with the support from all the councillors in 2022, it showed how muchBristol cares for green spaces and its positive impact on all our lives.Building on Green space for expensive houses on Western Slopes is just making rich minoritieswealthier and bringing more damages by the risk of bringing more floods and destroying thewildlife corridor. This is not something that people in Bristol want or need. Our older generation isagainst it; our younger generation is against it as they can see how it will impact their future too.I would like to ask the planning committee to show their full support and commitment to whatpeople and locals in south Bristol want and REJECT LOVELL'S PLANNING APPLICATION ONWesterns Slopes Bristol.

Kind Regards,Nasim Dumont

I am writing this statement to object to the planning application submitted by Lovell forNovers Hill- Western Slope.I would like to object to this planning permission as it is destroying all the precious wildlife on theWestern Slope.The planning application has so many issues, and it has been created only for profit- moneymaking. It has shown no care and compassion for the environment. The environment is one of themost important factors in everyone's life. As a retired member of society, I am extremelyconcerned that our green spaces in Bristol are disappearing one by one under the false name ofaffordable housing when we are all aware that the worst parts of the development have beenallocated to social housing and are used as a buffer for the open market, expensive housing. Inthis planning application, more hedgerows and trees are being removed. The BNG LOSS is stillmassive! It's an embarrassment for a city trying to go "net zero" if this application is approved!The BNG offsetting site is not even in Bristol. The actual roadway of Nevers Hill cannot cope withthe extra cars. The complete loss of meadow and removal of an established badger sett will beunreversible. The site is still a Site of Nature Conservation! And developing this half of Novers Hillwill impact the ecosystem of the rest of it.It is our responsibility to support green areas in Bristol. I object to this planning application andwant the Bristol city council planning committee to LISTEN to the objections, do the right thing,and reject the application.

To follow on from my previous objection in November '21, this area does not have thecapacity to cope with more homes and it is also an area which has a well established eco systemwhich needs protecting. Novers Hill is already a very busy road. Local schools and Health Centresare at full capacity. Bus service has been reduced.

I write in objection to the proposal to erect 157 dwellings on the west side of Novers Hill.If this application is granted the impact of this development will be wide ranging and felt long termby local people, protected species and Bristol's green credentials.

To support my objection:

1. There is now even more hedgerow and trees being removed in comparison to the originalproposal2. The social housing section of the proposal is still being used as a buffer between the rest of thedevelopment and the busy Hartcliffe Way, including the recycling centre and other businesses.The quantity of social housing to private housing is vastly skewed in favour of the open market,expensive housing.3. The BNG losss is huge. It's a huge setback for a city trying to go "net zero" if this application isapproved. The BNG offsetting site is not even in Bristol so no resident in the affected area or evenin the Bristol area will benefit.4. The proposal doesn't propose how the actual roadway of Novers Hill wil cope with the extracars.

5. The complete loss of meadow and removal of an established badger sett. A number of rare andprotected species have been found across the Northern Slope area, including otters, bats andbirds of prey.6. The site is still a Site of Nature Conservation. The impact of the development on this half ofNovers Hill will impact the ecosystem of the entire Hill.

Bristol has a number of brownfield spaces that I feel haven't been adequately explored beforeremoving another rare green space in Bristol. The site is of huge importance to local people,allowing access to a green space so scarce in the South Bristol area.

Keep green spaces available to local residents, redevelop brownfield sites and help Bristol hit itsnet zero targets.

I live with my family in South Bristol. I am writing this statement to object to the planningapplication submitted by Lovell for Novers Hill- Western Slope.I would like to object to this planning permission based on below points:There are now, even more, hedgerows and trees being removed.The BNG LOSS is still massive! It's an embarrassment for a city trying to go "net zero" if thisapplication is approved!The BNG offsetting site is not even in Bristol.Social housing is still in the worst parts of the development and is used as a buffer for the openmarket, expensive housing.The actual roadway of Novers Hill cannot cope with the extra cars.The complete loss of meadow and removal of an established badger sett.The site is still a Site of Nature Conservation! And developing this half of Novers Hill will impactthe ecosystem of the rest of it!Bristol needs all the green areas for residents' health, mental well-being, and wildlife. These greenareas are crucial for our lives; both humans, and wildlife. What Bristol needs is not building morehouses by destroying the green areas. Building on green space is a backward method whichshould be left in the very past times.What Bristol needs is:1. Only build on brownfields.2. Making it compulsory for developers to allocate more and real affordable houses in theirprojects.3. Introduce the capping system on the renting rates. There are enough accommodations/houses/flats in Bristol. The high rate of rent makes it almost impossible for people to afford it.

4. Make sure that we all stand up and support and protect our green areas and wildlife. When theGolden Motion was passed with the support from all the councillors in 2022, it showed how muchBristol cares for green spaces and its positive impact on all our lives.Building on Green space for expensive houses on Western Slopes is just making rich minoritieswealthier and bringing more damages by the risk of bringing more floods and destroying thewildlife corridor. This is not something that people in Bristol want or need. Our older generation isagainst it; our younger generation is against it as they can see how it will impact their future too.I would like to ask the planning committee to show their full support and commitment to whatpeople and locals in south Bristol want and REJECT LOVELL'S PLANNING APPLICATION ONWesterns Slopes Bristol.

I very much object to any of the Novers being built on. It's an important green space formany humans, animals, wildlife, meadow, hedgerow and trees. Although you say you replant, thisis not good enough. I am sick and tired of this excuse, we are supposed to be ecologically friendly.The whips that get planted will not do anything for the environment for at least 20 years and that'sif they survive. I am sick and tired of having our precious green space built on by profiteeringcompanies with very little affordable housing.There is so much green belt you could consider instead.

I am objecting again to this application, all my original reasons still stand. (Copiedbelow)I note that Nash/Pegasus have dumped around 50 revised documents on 01 03 23 with only 20days for people to read, understand and respond. This really isn't enough time.I think it's a sign of the lack of respect the developers have for the public.They also say in their covering letter that "As discussed, our revision suite will not be fully realisedin time for public consultation ahead of March committee with accompanying reports remainingbeing finalised"So if there isn't enough time for public consultation, time needs to be made.It's up to the developer to get accurate documents out and allow a reasonable time for them to beread.It's obvious from all these revisions that the original plans they put forward were badly thought outand ignored the basics of planning a project of this scale.Either they didn't get it right first time because they thought they would take a chance that theywould get away with ignoring regulations, or they don't really know what they're doing.Whatever the reason it makes me wonder what the build would be like if they actually gotpermission.They have already reduced the number of buildings to try and get this application through, I guessthey will try reducing the number until it is accepted.Is this the kind of developer you really want? Or would it be better to have an organisation thatlooks, listens and plans appropriately for the site instead of one that hopes it will "get away withit"?

Original objection:I am objecting to this application.There are a lot of practical reasons this site is not suitable for this development.The site is soft soils on sloping bed rock. I saw a lot of testing done, digging 10m deep pits , soilsamples, geophysics etc repeated.I think there is serious doubt that this is an easy or suitable site to build on from a technical point ofview.The development will destroy an important green area within a city, along with its wildlife.It will increase pressure on infrastructure and facilities in the local area.RoadsSchoolsHealthSewersIncreased local pollution -Parson st is regularly 200% of the government limit. School kidscampaigning to get people to turn off their engines.157 dwellings how many more school places?Will the new residents be able see a doctor/dentist or even register?Where will all the rain water and sewage go during extreme weather?The developers are suggesting doing work at Crox Bottom to offset damage caused by theirworks, to avoid breaching regulations.I don't believe this project has been well thought out.Yes we need houses, how many and where?

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:I live with my family in South Bristol. I am writing this statement to object to the planning

application submitted by Lovell for Novers Hill- Western Slope.

I would like to object to this planning permission based on below points:

There are now, even more, hedgerows and trees being removed.

The BNG LOSS is still massive! It's an embarrassment for a city trying to go "net zero" if this

application is approved!

The BNG offsetting site is not even in Bristol.

Social housing is still in the worst parts of the development and is used as a buffer for the open

market, expensive housing.

The actual roadway of Nevers Hill cannot cope with the extra cars.

The complete loss of meadow and removal of an established badger sett

The site is still a Site of Nature Conservation! And developing this half of Novers Hill will impact

the ecosystem of the rest of it!

Bristol needs all the green areas for residents' health, mental well-being, and wildlife. These green

areas are crucial for our lives; both humans, and wildlife. What Bristol needs is not building more

houses by destroying the green areas. Building on green space is a backward method which

should be left in the very past times.

What Bristol needs is:

1. Only build on brownfields.

2. Making it compulsory for developers to allocate more and real affordable houses in their

projects.

3. Introduce the capping system on the renting rates. There are enough accommodations/

houses/flats in Bristol. The high rate of rent makes it almost impossible for people to afford it.

4. Make sure that we all stand up and support and protect our green areas and wildlife. When the

Golden Motion was passed with the support from all the councillors in 2022, it showed how much

Bristol cares for green spaces and its positive impact on all our lives.

Building on Green space for expensive houses on Western Slopes is just making rich minorities

wealthier and bringing more damages by the risk of bringing more floods and destroying the

wildlife corridor. This is not something that people in Bristol want or need. Our older generation is

against it; our younger generation is against it as they can see how it will impact their future too.

I would like to ask the planning committee to show their full support and commitment to what

people and locals in south Bristol want and REJECT LOVELL'S PLANNING APPLICATION ON

Westerns Slopes Bristol.

Kind Regards,

As confirmed by the Avon Wildlife Trust, this is a VITAL WILDLIFE CORRIDOR.

"Avon Wildlife Trust recognises Bristol's Western Slopes as a vital wildlife corridor, and stands withthose people calling it to be protected from development.This area, located on the slopes between Novers Hill and Hartcliffe Way, is a particularly importanthabitat for a wide variety of birds, mammals and rare wildflowers. We recognise that there isconsiderable concern from local residents that it may be vulnerable to development, and we echotheir calls for it to be protected."https://www.avonwildlifetrust.org.uk/news/support-bristols-green-spaces

The ecological survey carried out by Ethos Environmental Planning shows that the slopes arehome to wildlife including badgers and many species of bats, including rare horseshoe bats.

https://novershillconsultation.co.uk/wp-content/uploads/2021/07/Novers-Hill-draft-ecological-assessment-with-location-of-badger-sett-redacted.pdf

There is no excuse for building on this green space when there are brownfield sites available,especially in a city that claims to be sustainable and wants to be net zero. This proposeddevelopment is completely at odds with the One City Ecological Emergency Strategy and One CityClimate Strategy. The Council continuing to approve such proposed developments undermines itsstance and makes the strategies look like all words and no actions. How can the Council wilfullyact in opposition to its own strategies? The Council's reputation is only one thing that would bedamaged should this development go ahead.

Most concerning is the proposed damage to a biodiverse wildlife habitat which has a wealth ofspecies, including protected ones. It is an invaluable wildlife corridor which is a treasure so closeto the city centre. It is so important to local residents who care deeply about preserving andenjoying the local flora and fauna. We the local residents are taking environmental concerns muchmore seriously than the Council - shame on you! Please show us we can still have some faith thatBCC will act in the best interests of Bristol's residents and Bristol's physical space. Our confidenceis rapidly dwindling.

Unsuitable place to build houses. We should conserve this green space for futuregenerations.

Dear Sir/MadamMy concerns relate to increase of traffic in the area. Without widening of Novers hill and thejunction of parson street and hartcliffe way, there will be longer ques of standing traffic causingmore pollution in an area where lots of school children will be affected ( even more children withthe extra people ). We have children travelling to Parson street primary and Bedminster downschools using the parson street / hartcliffe way junction and children going to Greenfield primarybeing effected at the other end of novers hill. Also with increase of traffic there also the increase insafety concerns with small children who are not always concious of how fast cars are moving.We have quite a lot of traffic already and feel the roads in the area are not fit for more.RegardsChris Rodd

Thank you for inviting my further comment on the proposed housing development on the WesternSlopes of Novers Hill.

You have said that my previous comments have been taken on board; which is good since theseraised various important concerns that I have; firstly, about the impact of the location of theproposed site on the movement of traffic and pollution levels around the direct and wider areas;and, secondly, about Lovell Housing's plans to mitigate the negative impact that the activities oflocal industry might have on the quality of life of those occupying their new-builds.

I have nothing to add regarding my comments on traffic flow. They remain the same.

My concerns about quality of life and noise pollution also remain unchanged, as I note from the'Noise Assessment' report put together by SLR Consulting, in February 2023, that, it is still thecase, at this point, that '...mitigation levels can only be outlined...'. I also note that 'trickleventilators' continue to be mentioned as a way of addressing the noise issue which will beexperienced in some of the builds.

I would like to add further comment though, as activity close to the proposed site has moved onsince my original observations and this has raised additional/associated concerns for me. Thisstems from the fact that at the time of making my previous comments there seemed to be muchless activity from the bigger industries in the area. However, between then and now, thosebusinesses have obviously continued to adapt, expand, and introduce new products. I noticed, for

instance, that in January 2022, ETM, which backs onto the proposed site and faces onto theHartcliffe Way, advertised the fact that they were 'now' offering concrete batching. This new facilitywas offered some time after Lovell's Homes sent their original proposals in to the City Council'splanning office.

I note that this facility's existence has been picked-up and acknowledged in SLR's recent updated'Noise Assessment' report but I cannot find it mentioned anywhere else. I do acknowledge that Imay have missed information when looking through all the documentation - but if this is not thecase, then I would like to state that I consider that the impact of this newly introduced concretebatching service on air quality should be taken-into-account along with all other dust releasingactivities, when considering pollution mitigation actions. I say this because I am aware thatconcrete batching activities clearly create particulate matter (to a greater or lesser extentdepending on the system used). Concrete and associated particulate matter can contribute toserious health issues in human beings or other creatures; causing - for instance - lung problems,cancer, and skin irritation. The potential for environmental damage from these particulates is ofcourse also extremely concerning.

Additionally, it appears that natural dispersal of airborne particulates from the area might beaffected somewhat by the position of the ETM site - which is relatively low lying - between thehigher locations of Knowle and Bedminster Down.

This raises further concerns for me about the position of Lovell's proposed site since it has two ofits borders abutted by local industry and the 'newer' arrivals have clearly gone on to either adoptnew practices or expand others as their businesses have settled-in and grown. This aim for growthwill, no doubt, see a future increase of airborne particulate matter in the area.

This observation brings me back to the use of trickle ventilators and pollution.

Although Lovell Housing seems to be considering trickle ventilators in some builds in order toaddress excessive noise pollution, basic research appears to show that their use will not beadvisable where outside air pollution levels are not good; because the ventilators let the outsidepolluted air into the building. At present, the housing plans show that the buildings which are mostlikely to have this kind of ventilation will be the ones situated closest to the industrial units soresidents there would possibly be most affected. However, where pollutants might not easily benaturally dispersed, perhaps because of the topography of an area, they will linger and potentiallyaffect all residents and users of the area - not just those residents in buildings close to the units,who are already obliged to keep their windows shut.

My observations, have led me to believe that projections based on present activities in relation topossible/probable future pollution levels, are not going to be good enough. Assessments of air-flow etc using different 'similar' sites are not going to be good enough. I have very major concernsabout the potential increase and dispersal of dust particulates around the area.

In conclusion, based upon the points discussed, I find the building of a housing developmentdirectly in the vicinity of, and abutting, industrial units worrying and of course unacceptable. Oncehoused, many people will have little option but to stay - regardless of the impact on their mental orphysical health that any changes to nearby industrial working procedures and practices mighthave. Because of this and the issues I previously raised which have not been addressed, Icontinue to be unable to support this application.

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:Dear Sir/Madam

My concerns relate to increase of traffic in the area. Without widening of Novers hill and the

junction of parson street and hartcliffe way, there will be longer ques of standing traffic causing

more pollution in an area where lots of school children will be affected ( even more children with

the extra people ). We have children travelling to Parson street primary and Bedminster down

schools using the parson street / hartcliffe way junction and children going to Greenfield primary

being effected at the other end of novers hill. Also with increase of traffic there also the increase in

safety concerns with small children who are not always concious of how fast cars are moving.

We have quite a lot of traffic already and feel the roads in the area are not fit for more.

Regards

The loss of hedgerow will have significant effects on drainage. Flooding is a majorconcern with heavier rainfall episodes. This could cause loss of soil and floodwater.Biodiversity is also under threat. Hedgerows are required for many birds, mammals and insects.More than ever we need to ensure there is no loss of habitat when the animal kingdom is underthreat.

It would destroy all wildlife thereIt is a lovely place and as been all my life taking my children and dogs thereA great quiet place for daily walks and to see the sun going down on eveningsLovely for young children to seeAlso great for people 2 wonder round and see many wildlifeHouses there would be a absolute eyesore

Will not reiterate previous objections by myself nor itemise all the technical details asthis has been well stated and documented.My objection runs along the line that there are a huge amount of brownfield sites available,including in South Bristol, why are we fighting to save a site which should be protected as an assetto the area and generally to Bristol. Another point I would like to put is taken from the IndianConstitution and is Article 51 which states that no human should preserve all living things by notadversely effecting all things nature viz forests, woods, trees, rivers and all living things there on.This has a knock on result which helps the wellbeing of the population in both regular health andmental health. I STRONGLY OBJECT TO THIS APPLICATION.

I am writing to restate my original objection on behalf of my household. We currently liveon Novers Hill and have been residents of South Bristol for over 10 years.

Having tried to review the re-submitted documents by the developer there are still significantexisting concerns and new ones from their planning application. Significantly, a revised Designand Access statement has not been submitted which made consideration of the revisions difficultto fit into context and examine in more detail what has happened.

In the January covering letter it is suggested that a 'full detailed response' would be provided toexisting concerns. The February letter contained only a summary of concerns and responses, thisis not good enough for a potential development that has such an impact on the natural and builtenvironment of Novers Hill/ Western Slopes.

Novers Hill/Western Slopes has always been held by us as an important wildlife corridor andvisual reminder of how valued these greenspaces are to the urban landscape. Bristol is meant tobe a city leader against climate change having declared an 'ecological emergency' so we needactions not just empty words and promises in protecting our valuable green spaces.

Ecology:Secretary of States 2003 appeal decision against Persimmon Homes' development of Novers Hillstill holds true in all its key arguments. The inspector of this report noted that the site had city wideimportance and the 'adverse and permanent effects of the built development would be sufficientlylimited to be offset.' The offsetting strategy outlined by Lovells continues to be very flawed. With

the removal of Crox Bottom as an option for providing off site mitigation, there is concern thatother parts of the West of England would be benefitting, while existing and future residents ofNovers Hill would not benefit from the development.

Novers Hill is an important section in a belt or chain of open grasslands, hedgerows and scrub -development would break and reduce the degree of ecological linkage with amongst othersNovers Common and Northern Slopes.

This linkage cannot be easily mitigated by modals andassumptions of how wildlife will react to the destruction of their habitats. Novers Hill is such a richmix of habitats and areas that it can support such a diverse range of species such as badgers,foxes and smaller mammals such as field mice, voles, moles and rare horseshoe bats. Birds ofprey including kestrels and buzzards are regularly spotted flying over the slopes.

Novers Hill was previously given the status of a Site of SNCI (Site of Nature Conservation Interest)- with citywide importance. This is why the writer of the Secretary of States report concluded that"It is its openness and its prominent 'natural' or undeveloped qualities that are in his view its mostimportant visual attributes. 'He goes on to comment that he does not consider this a degradedlandscape' but one which is obviously thriving.

What is also very concerning is that The Ecological Impact Assessment and Biodiversity Net GainAssessment have not been made publicly available. This is critical information bearing in mind thesensitivity of the habitats and species involved.

Traffic, Transport & Amenities:Access roads in newly submitted documents would further damage the protected ancienthedgerow and ruin connectivity - this situation has not changed since Oct 2021. The lack of anupdated Transport Assessment or Travel Plan means the public cannot comment on theimplications of the changes on these issues. Impact on the TVG is directly related to this lack ofupdated Transport Plan.

Even with the overall size of the development reducing to 144 dwellings in this development, withadditional traffic from other proposed developments in South Bristol (such as Hengroveairfield(1400 houses), BokLok (173 currently being built) as well as sites in Inns Court, BroadburyRoad, Health Park and the Youth Zone) the cumulative effect of all these developments wouldmean not only the traffic on Novers Hill increasing but also local roads in the area and Hartcliffeway would become even more congested than they already are. Quite simply the localinfrastructure cannot cope. Lovells have still not made a junction improvement to the bottom ofNovers Hill and Lynton Road.

There are highway safety issues related to all the increased traffic across the whole of Filwoodward as well as those neighbouring the development. Especially with Parson Street primary school

and Greenfield ACT primary school. The measured pollution levels are already dangerously highat both schools. There are obvious noise and light pollution aspects to also consider as well as theair pollutants from all the increased car use.

Bristol City Council even before the pandemic, struggled to make timely bin collections so addinga further 144 dwellings will only exacerbate this. Access around the site for 2 panel bin lorries ispoor and the gradients and corners involved are the reason the Transport department originallyobjected, a lot of these concerns still remain. The same can be argued for the increased demandson local medical services and school class sizes. Again the cumulative impact of developmentsacross the whole of South Bristol will make these issues completely unmanageable.

Proposed Site Housing Issues:Town and village green - TVG - from studying the map, I still do not believe this to be a trueequivalent and I certainly do not believe the equivalent by function can be achieved in the areasearmarked by Lovells. The enjoyment of the TVG space will not be equal for locals as well as allresidents of Bristol so Lovell's open space strategy is questionable.

It says part of the site is land locked and an existing access can't be used. This means Lovells arebreaching the planning policy of the protected TVG green space through the middle. It alsoappears they are double counting by providing the public open space POS within the safe guardedcorridor. Again this brings into question the validity of this application as TVG status changeshould have been approved prior to the application submission.

There is an important function performed by the site as recognised in the Secretary of State reportin separating residential development to the East of Novers Hill from the industrial and commercialdevelopment to north and west of the site.' This open space is a 'visual amenity even provides anoutlook, or variety in the urban scene. There is a definite visible impact of the designated openspace. From more distant viewpoints, such as the Clifton Suspension Bridge. There is also thevisible impact of a lost hillside. This is felt along and around the Malago greenway. Visible openspace affords a relief to the adjacent built up area.

It is a concern that Visuals (for example - Nash Partnership - Series 6001 to 6006) are critical forhelping local people understand what is happening to the landscape and the full impact of this -especially with the amount of cut and fill occurring on the slopes around the development. In theoriginal Design and Access statement 2D and "3D" pictures were provided; this has not happenedin the re-submission. There is reference to a 'fly through' in the cover letter but due to file size thiscould not be uploaded. It is essential that at least smaller files of visual stills from the fly thoughare uploaded to better understand visually how the development sits within the landscape.

Although Block 6 has now been moved from in front of 53-77 Novers Hill with 60 dwellings beingproposed on the slope to the left of these houses there are clear implications for loss of light andovershadowing for residents on Novers Hill. The sun sets behind Headley park and this is in the

direct lines of the development. This loss of light and over shadowing will impact all the residentialproperties from numbers 53-77 on Novers Hill. As well as a lesser extent, Haven House up tonumber 99 on Novers Hill. With these new dwellings being in an elevated position directly acrossfrom numbers 53-77 there are clear privacy issues with windows breaching the tree line andlooking directly across at these houses. Again a 3D would show this a lot more clearly but this hasnot been provided by the developer.

Alternative Vision:Ultimately, I do not feel this land should ever have been included in the outdated 2012 LocalRegeneration Plan. Regenerate brownfield sites, regeneration of a green field site is an oxymoron.This delicate eco-system can only be destroyed by a housing development.

This part of the city is relatively poorly provided with public parks in the local Filwood ward, and thelimited amount and distribution of the ward's publicly accessible space. So why not make thisunique site into what it is already in all but name - The Novers Nature Reserve.

Just like we all look back on disastrous post war town planning decisions, the next generation willnever forgive us if this decision goes against our precious green space to further harm andaccelerate the climate crisis.

I would like to restate my objection to the planning application concerning the WesternSlopes/Novers Hill.

This application goes against Bristol taking the lead in declaring the 'climate emergency.'Greenfield sites such as this one on Novers Hill provide important wildlife corridors supporting avast array of species from Badgers to Birds of Prey. Human impact of housing developments cannever be mitigated against.

Brownfield sites should be brought forward and prioritised and greenfield sites should be anabsolute last last resort. Novers Hill has a diverse mix of shrub, grassland and trees, there are noguarantees the installation of bat corridors and new badger setts will work, and if not, thesehabitats will be permanently disturbed and potentially lost.

Traffic around the Novers Hill site on neighbouring roads and especially Hartcliffe Way is alreadyat breaking point, standing traffic is resulting in very dangerous levels of pollution at Parson Streetschool. Another 157 homes alongside all the other developments in South Bristol will onlyexacerbate these problems which are already acute.

I'm concerned about flooding due to increased runoff into Pigeonhouse stream and along theMalago, and the steep gradients make me further worried about subsistence issues across thesite.

Ultimately an alternative use could be a nature reserve and city farm which would be a great asset

for residents of Knowle West who have limited access to green spaces and opportunities to benefitfrom the incredible green space that is Novers Hill.

My family and I still feel very strongly opposed to this planning application so would liketo restate our objection.

Greenfield sites such as this one need to be protected for future generations. This is such shortterm thinking to put up to 144 dwellings across this unique wildlife corridor. Lovells failed to buildhere 30 years ago and the site hasn't changed, it is even more valuable now as an ecology sitebecause so many green spaces have already been lost or are under increasing threat acrossSouth Bristol.

I also feel that much more public consultation should have be done with local people, feelingsamongst local residents across Filwood really haven't been listened to. There is a digital divideand digital exclusion which the developer has not taken into consideration. Knowle West and theFilwood ward is one of the poorest economically in Bristol so greater efforts should have beenmade to engage with all residents. Against this Knowle West has one of richest green spaceswhich needs to be preserved as an asset for them all and not the privileged few.

Let's be very clear 'affordable' housing is at 80% market value so it's a technical term rather than areality for anyone living local to the site on low wages. Illegal levels of pollution are regularlyrecorded at Parson Street street adding 157 houses initiallywill only add to this and the strained infrastructure around Hartcliffe Way. Impact of more houseswill affect air quality and light pollution will further accentuate these issues across South Bristol.

Please Bristol City Council take note of how Bristolians feel at large about building on green

spaces. Prioitise brownfield sites, only use any green spaces as an absolute last resort.

Protect this green space and make it into the south Bristol nature reserve it deserves to be.

I've been a resident of Novers Hill since 1968 and would like to re-submit by objection tothis destructive development.

The wildlife on the hill has been a constant source of fascination for all the family and should beprotected for many generations tocome. Any housing will destroy this delicate ecosystem.

Traffic is too heavy on the Hill as it is, 144 extra dwellings here, plus all the others across SouthBristol will mean traffic chaos. Pollution and littering is very bad on Novers Hill and this will getworse. I'm concerned council and healthcare services won't cope with the additional houses hereand across South Bristol. With primary schools at Novers Lane and Parson Street all the extracars and pollution is a worry for all the kids that travel to these schools.

I believe for large parts of the site local residents will experience loss of light, privacy and overshadowing due to the front of the Novers Hill houses all getting the afternoon/evening sun. Pleaseprotect this vital green space for all the people of Bristol.

NB: Due to my age my neighbour has kindly submitted this online application on my behalf but Ihave agreed to this in advance.

I strongly object to this planning application as this is in total opposition to the aims ofBCC trying to be carbon neutral by 2030. Destroying a Site of Nature Conservation is not the wayto achieve net zero. It will lead to a huge BNG loss which is not even being offset locally. Therewould be huge losses of hedgerows , trees ,meadows and removal of an established badger sett.The wildlife corridor into the city would be lost and the adjacent sites of the Northern Slopes andCrox Bottom and would be compromised. It would impact on Manor Woods Valley also as wildlifedoes not recognise boundaries.This is not acceptable given our shameful status as the most nature-depleted country in Europe.The social housing is still in the worst parts of the development and being used as a buffer againstnoise and pollution, for the open market, expensive housingThe actual roadway of Novers Hill cannot cope with the extra carsBuilding on established green spaces is not the way to solve the housing crisis.

I strongly object to the proposed development of the greenfield site to the west ofNovers Hill.

I have lived near this site for 23 years during which time I have seen buzzards,peregrine falcons. Kestrels and sparrow hawks on or near this open land and in mygarden. Also badgers and foxes.

If this site is tarmaced concreted over the wildlife will disappear and cannot be broughtback.

This site is a valuable resource for the health and wellbeing for the local community. Wedo not need more pollution on Novers Hill.

This part of South Bristol has already been overdeveloped with no regard toinfrastructure to support the additional population.

Let common sense prevail please stop the desecration of this beloved and needed opengreen space.

Subject: Concerns about proposed building project

Dear Sir/Madam,

I am writing this email to express my concern and opposition against the proposed building projectof 144 dwellings, including 43 affordable housing. While I understand the need for housing in thearea, I feel that this project is not being carried out in an environmentally responsible manner.

In particular, I am worried about the potential harm that this construction project could cause to thenatural environment. The proposed project fails to even meet 10% savings of its biological harmcaused by such a huge construction project. As a member of the community, I believe that it isessential for all new developments to be carefully planned and constructed in a way thatminimizes harm to the environment.

I would like to request that the project be thoroughly reviewed by an independent body to ensurethat it meets all applicable environmental regulations and standards. I believe that this isnecessary to ensure that the project does not have any long-term negative effects on the localecosystem or the quality of life of nearby residents.

I understand that there are many factors that must be taken into account when planning andconstructing new developments, but I think that it is important to consider the long-term impact ofthese projects on the environment and the community as a whole.

Thank you for taking the time to read my email. I hope that you will carefully consider my concernsand take appropriate action to address them.

Sincerely,

Nick Haskins

Dear Sir

I am writing this email to express my concern and opposition against the proposed building projectof 144 dwellings, including 43 affordable housing. While I understand the need for housing in thearea, I feel that this project should really take into account our concerns about the protectedancient hedge rows we have looked after for many years.

The hedge rows, which form an important part of our local ecosystem, have been home to severalspecies of birds and small animals. Moreover, they serve as essential habitats for insects andwildflowers, which are necessary for pollination and maintaining the biodiversity of our region.Therefore, any construction that would impact these hedge rows, particularly the ancient ones thatdate back many decades, would ultimately lead to their destruction and loss of biodiversity.

Additionally, when constructing the buildings, the project would entail heavy-duty machinery andlarge vehicles running through the areas that would further disturb the environment. The addedconstruction noise and increased traffic flow would also disrupt the peace and tranquility of thesurrounding residential areas.

I urge you to consider these concerns before moving forward with the proposed project. Ifpossible, I would like to set up a meeting to further discuss these issues and explore alternative

options that can benefit both the community and the environment.

Thank you for taking the time to consider my concerns.

Sincerely,

Nick Haskins.

Subject: Appeal Against Building of Dwellings and Affordable Housing Units on NoversHill Grounds

Dear Sir/Madam,

I am writing this email to express my concern and opposition against the proposed building of 144dwellings including 43 affordable housing units along with 2 access points from Novers Hill. Thisproject also includes the provision of 2 play facilities and public open space with associated workson the grounds of consideration.

As a member of the local community, I strongly believe that this construction project will lead toserious ecological harm, and I am therefore appealing against this development once again. WhileI am aware that the proposal provides for affordable housing, I am also aware of the need tobalance such benefits with the protection of our environment.

I strongly believe that the construction of such a large number of dwellings and the associatedinfrastructure will have a significant effect on the ecology of the area. The increased population willput additional pressure on the local environment, and this will have serious consequences for boththe flora and fauna in the area.

Furthermore, the proposed development could lead to an increase in traffic in the local area,resulting in road congestion and noise pollution. This will no doubt impact the quality of life ofresidents in the area and lead to further degradation of the environment.

I, therefore, appeal once again to the City Council to review this development proposal and takeinto consideration the potential ecological harm that may result from this project. I urge you toreconsider the decision to allow this development and explore alternative solutions that wouldpreserve the ecological integrity of the area.

Thank you for your time and consideration.

Sincerely,

Nick Haskins

Subject: Concerns Regarding Species Surveys

Dear Sir/Madame

I am writing to express my concerns regarding the recent surveys on species that have beenconducted by your organization. Upon review of the data collected, I strongly believe that thesesurveys were inadequate and have not been conducted appropriately.

As someone who values the conservation of our natural environment and the protection ofspecies, I am deeply disappointed in the lack of attention given to this matter. I feel that it isimperative that a proper survey be conducted to ensure that accurate and comprehensive data iscollected.

I would like to offer my suggestions for improving the surveys, which may help to ensure that theyare more effective in the future. Firstly, it is important to have a clear and concise set of objectivesfor the survey, which should be communicated to all involved parties. Secondly, the survey designshould be evaluated to ensure that it is appropriate for the species being studied. Finally, it isimportant to collect data from multiple sources to ensure accuracy and minimize bias.

I completely understand the challenges associated with conducting such surveys, but I believe thatmaking the necessary improvements will benefit all involved parties in the long run. I would behappy to provide further suggestions or input should you require it.

Thank you for taking the time to consider my concerns.

Sincerely,Nick Haskins.

Subject: Response to Your Report on Ecology of Novers Hill Site

Dear Sir

I hope this email finds you well. I wanted to touch base with you regarding your report on theecology of the Novers Hill Site. While I appreciate the effort and time you put into creating thereport, it has come to my attention that there are several errors and unsubstantiated claimsincluded in the document.

As you know, ensuring accuracy and credibility in any report is of utmost importance, particularlyin the field of ecology, where our actions can have a significant impact on the environment.Therefore, I would like to request that you review the report carefully and revise it as necessary toensure that all information included is supported by valid sources and accurately reflects the stateof ecology at the Novers Hill Site.

I understand that creating this report may have been a challenging task, and I appreciate yourdedication to the project. However, accuracy is crucial, and I am confident that, with someadditional time and effort, we can produce a report that meets our standards and accuratelyreflects the state of the ecology at the site.

I look forward to receiving your revised report and to continuing to work together towards the goalof protecting and preserving the environment.

Thank you for your hard work, and I look forward to hearing from you soon.

Best regards,Nick Haskins

Dear Sir, I wish to lodge my objection to the proposed building on the west side of theNovers.The addition of 157 dwellings in a place where air quality is already bad and next to a refuge sitecan only make the local environment much worse for people already living here and those whomight live in the newbuild.The access onto Novers Lane will also exacerbate a traffic problem that we have. Alsoconsideration should be given to wildlife that may suffer as a result of the build.I hope you will consider this objection

There are so many reasons to object this application. This whole area must bepreserved! The importance to wildlife can never be recreated once lost. How could BCC possiblyjustify the following being ok when also attempting to have green credentials and work onimproving Clean air?The leading concerns being:There is now even more hedgerow and trees being removed in these plans.The BNG LOSS is still massive! It's an embarrassment for a city trying to go "net zero" if thisapplication is approved!The BNG offsetting site is not even in Bristol!The social housing is still in the worst parts of the development and being used as a buffer for theopen market, expensive housing.The actual roadway of Novers Hill cannot cope with the extra carsThe complete loss of meadow and removal of an established badger settThe site is still a Site of Nature Conservation! And developing this half of Novers Hill will impactthe ecosystem of the rest of it!

How could you even consider this as an appropriate development site BCC?I whole heartedly object for the sake of the wildlife and the future of my children's lungs!

Bristol clearly needs more housing - though also clearly far more services for the newhousing - but this greenfield site is completely unsuitable given the intense ecological loss it wouldbring to the locality, city & wider area. It is an afront that this council should both declare anecological emergency & then try to sign off this destruction of an important pocket of nature.

Commenter Type: Amenity - Residents Group

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:Subject: Concerns about proposed building project

Dear Sir/Madam,

I am writing this email to express my concern and opposition against the proposed building project

of 144 dwellings, including 43 affordable housing. While I understand the need for housing in the

area, I feel that this project is not being carried out in an environmentally responsible manner.

In particular, I am worried about the potential harm that this construction project could cause to the

natural environment. The proposed project fails to even meet 10% savings of its biological harm

caused by such a huge construction project. As a member of the community, I believe that it is

essential for all new developments to be carefully planned and constructed in a way that

minimizes harm to the environment.

I would like to request that the project be thoroughly reviewed by an independent body to ensure

that it meets all applicable environmental regulations and standards. I believe that this is

necessary to ensure that the project does not have any long-term negative effects on the local

ecosystem or the quality of life of nearby residents.

I understand that there are many factors that must be taken into account when planning and

constructing new developments, but I think that it is important to consider the long-term impact of

these projects on the environment and the community as a whole.

Thank you for taking the time to read my email. I hope that you will carefully consider my concerns

and take appropriate action to address them.

Sincerely,

Commenter Type: Amenity - Residents Group

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:

Dear Sir

I am writing this email to express my concern and opposition against the proposed building project

of 144 dwellings, including 43 affordable housing. While I understand the need for housing in the

area, I feel that this project should really take into account our concerns about the protected

ancient hedge rows we have looked after for many years.

The hedge rows, which form an important part of our local ecosystem, have been home to several

species of birds and small animals. Moreover, they serve as essential habitats for insects and

wildflowers, which are necessary for pollination and maintaining the biodiversity of our region.

Therefore, any construction that would impact these hedge rows, particularly the ancient ones that

date back many decades, would ultimately lead to their destruction and loss of biodiversity.

Additionally, when constructing the buildings, the project would entail heavy-duty machinery and

large vehicles running through the areas that would further disturb the environment. The added

construction noise and increased traffic flow would also disrupt the peace and tranquility of the

surrounding residential areas.

I urge you to consider these concerns before moving forward with the proposed project. If

possible, I would like to set up a meeting to further discuss these issues and explore alternative

options that can benefit both the community and the environment.

Thank you for taking the time to consider my concerns.

Sincerely,

Commenter Type: Amenity - Residents Group

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:Subject: Appeal Against Building of Dwellings and Affordable Housing Units on Novers

Hill Grounds

Dear Sir/Madam,

I am writing this email to express my concern and opposition against the proposed building of 144

dwellings including 43 affordable housing units along with 2 access points from Novers Hill. This

project also includes the provision of 2 play facilities and public open space with associated works

on the grounds of consideration.

As a member of the local community, I strongly believe that this construction project will lead to

serious ecological harm, and I am therefore appealing against this development once again. While

I am aware that the proposal provides for affordable housing, I am also aware of the need to

balance such benefits with the protection of our environment.

I strongly believe that the construction of such a large number of dwellings and the associated

infrastructure will have a significant effect on the ecology of the area. The increased population will

put additional pressure on the local environment, and this will have serious consequences for both

the flora and fauna in the area.

Furthermore, the proposed development could lead to an increase in traffic in the local area,

resulting in road congestion and noise pollution. This will no doubt impact the quality of life of

residents in the area and lead to further degradation of the environment.

I, therefore, appeal once again to the City Council to review this development proposal and take

into consideration the potential ecological harm that may result from this project. I urge you to

reconsider the decision to allow this development and explore alternative solutions that would

preserve the ecological integrity of the area.

Thank you for your time and consideration.

Sincerely,

Commenter Type: Amenity - Residents Group

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:Subject: Concerns Regarding Species Surveys

Dear Sir/Madame

I am writing to express my concerns regarding the recent surveys on species that have been

conducted by your organization. Upon review of the data collected, I strongly believe that these

surveys were inadequate and have not been conducted appropriately.

As someone who values the conservation of our natural environment and the protection of

species, I am deeply disappointed in the lack of attention given to this matter. I feel that it is

imperative that a proper survey be conducted to ensure that accurate and comprehensive data is

collected.

I would like to offer my suggestions for improving the surveys, which may help to ensure that they

are more effective in the future. Firstly, it is important to have a clear and concise set of objectives

for the survey, which should be communicated to all involved parties. Secondly, the survey design

should be evaluated to ensure that it is appropriate for the species being studied. Finally, it is

important to collect data from multiple sources to ensure accuracy and minimize bias.

I completely understand the challenges associated with conducting such surveys, but I believe that

making the necessary improvements will benefit all involved parties in the long run. I would be

happy to provide further suggestions or input should you require it.

Thank you for taking the time to consider my concerns.

Sincerely,

Commenter Type: Amenity - Residents Group

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:Subject: Response to Your Report on Ecology of Novers Hill Site

Dear Sir

I hope this email finds you well. I wanted to touch base with you regarding your report on the

ecology of the Novers Hill Site. While I appreciate the effort and time you put into creating the

report, it has come to my attention that there are several errors and unsubstantiated claims

included in the document.

As you know, ensuring accuracy and credibility in any report is of utmost importance, particularly

in the field of ecology, where our actions can have a significant impact on the environment.

Therefore, I would like to request that you review the report carefully and revise it as necessary to

ensure that all information included is supported by valid sources and accurately reflects the state

of ecology at the Novers Hill Site.

I understand that creating this report may have been a challenging task, and I appreciate your

dedication to the project. However, accuracy is crucial, and I am confident that, with some

additional time and effort, we can produce a report that meets our standards and accurately

reflects the state of the ecology at the site.

I look forward to receiving your revised report and to continuing to work together towards the goal

of protecting and preserving the environment.

Thank you for your hard work, and I look forward to hearing from you soon.

Best regards,

I strongly object to this development on the grounds of bio diversity loss- the fact it stillis an SNCI makes this development illegal in planning policy.The offsetting in Nailsea as proposed is beyond insulting to the people of South Bristol, are we notworthy of wildlife and fresh air?This is an appalling proposed development.

No, this is our green belt, we live in an illegally polluted city and we need the green beltmore than we need this kind of development.There is no infrastructure in place, there are only a few local shops in walking distance, schoolsand doctors are already full.There are no bus routes that go close enough to the site to be a viable alternative.Novers Hill is too narrow to take extra traffic and there is no space for a footpath. Traffic aroundhere is already increased because the clean air charge forces people to drive around the south ofthe city rather than through it.

There is a beautiful hedgerow on the site which should be protected and the meadow itself is asite of nature conservation. There are badgers on the site, it has bat routes through it.The 'affordable' social housing is at the site that overlooks the refuse centre, buffering the moreexpensive houses from the reality of living next to a tip. That is disgusting planning.Planting young trees does not offset the removal of grassland, meadow and established trees andhedgerows. Please refuse this application, it will negatively impact upon all who live around it andwill not live up to any of the developers promises to prospective owners.

HIGHWAY SAFETY, TRAFFIC & PARKING ISSUES, NOISE:I object to this development on the basis firstly of the increased traffic from 157 new homes. BristolCouncil's own road experts have said: "Novers Lane too narrow to cope with the extra traffic"AMENITY:I also object in terms of amenity, not just for local residents but for all Bristol residents, who benefitfrom south Bristol's 'green lungs'- The wildlife-rich fields of the Western slopes provide a wonderful amenity to south Bristol, with itstrees, views and tranquillity- Bristol has huge challenges with the high level of traffic generating air pollution, causing anestimated 300 deaths pa, with an annual health cost to Bristol of £83m. City Mayor Marvin Reeshas said: "We have a moral, ecological and legal duty to clean up the air we breathe"- The western slopes - described as one of south Bristol's green lungs & visible from across thecity - make a significant contribution to air qualityLOSS OF WILDLIFE HABITAT:I object because of the wildlife habitat loss.- despite lowering the number of houses, Lovell's plan involves the destruction of more treesincluding 48 mature trees and more habitat space. The BNG loss is increased from 12% to 16%- This site is nationally significant for invertebrates- it is home to 11 out of 17 bat species including greater horseshoe bats- The ancient hedgerow adjoining Novers Hill which is a TVG will be destroyed- There are no updated species surveys- There is no winter bird survey or otter survey (despite otters being spotted in the stream onsite),and they spent just one day on a breeding bird survey. I myself have spotted buzzards soaring

over the treetopsCONSERVATION:- the development involves the destruction of a nationally significant nature site, a wildlife habitatwith rare bats in Knowle West, one of the poorest areas in Bristol, & paying a wealthy privatelandowner in a different council miles away, an offsetting site which would be inaccessible to theSouth Bristol community- Nailsea is in the 'Bristol, Avon Valleys and Ridges character area' so it looks like they are tryingto hide the fact that they do not have an offsetting site in Bristol- This looks like an example of 'pay to pollute'- They intend to plant more new trees onsite. However it can take 40 years or more for a tree tomake a significant contribution to air quality. To reduce traffic pollution it's more effective to reducetraffic than to plant new trees.DESIGN:Social housing flats to be used as a noise barrier for the market rate units. These residents wouldrequire 'alternative ventilation' because opening their windows will expose them to unacceptablenoise levels. Bristol MP Karin Smyth said: "... it is deeply alarming to read in the documentationthe three story apartment blocks which will contain many of these homes described as a 'noise-buffer for the rest of the development'" Mrs Smyth said she was 'surprised' someone was evenproposing houses on such a steep slope in the first place. "The consultation documents producedby Lovell Homes correctly identify other challenges to development including topography, limitedaccess and proximity to light industry," she said.I object in the strongest possible terms to this development, damaging not just to local residentsbut to the entire population of Bristol, now and into the future.

I have previously objected to this development but feel drawn to make another due tothe new 'revised' application which has not swayed my view at all. Over the past year there hasalso been major objections from leading wildlife campaigners, this has also been fuelled by the'Off Set' from the site that is in a totally different area to me, where I live!The fact that there is an offset proves that building this development would have a catastrophiceffect on the area not only with emissions but also the wildlife that I can clearly see out of mywindow on a daily basis from Badgers, Foxes, Hawks and the array of wild fauna and flowers.What was also highlighted to me was the spokesperson from Lovell homes on the group Teamsmeeting said that there would be no way he would have this built on his own doorstep and wouldobject himself! The only reason Lovell are pursuing this, is because they can, as there is still anoutdated order on the land that needs to be stopped now!The need to get to net zero targets and clean air with wildlife in the original habitat is much muchmore importance than building wherever developers think they can... Please Bristol council makethe RIGHT DECISION !!!

I continue to strongly object to the planning application submitted by Lovells. Theupdated plans involve the removal of even more hedgerows and trees, which would have acatastrophic effect on local ecosystems and constitute a further attack on nature.

The Mayor's Climate Action Plan of 2019, made a pledge to make the City carbon neutral by 2030.Green spaces store many tons of carbon - when a green space is disturbed, all this carbon isreleased into the atmosphere. We need to ask how can continually building on green spacespossibly support the pledge to make the City carbon neutral by 2030, when this adds to existinggreenhouse emissions? We also need to ask how developers can make any claim that aBiodiversity net gain can be achieved when a green space has its habitats destroyed, ancienthedgerows ripped up and oxygen-giving greenery is removed?

The Golden Motion passed in Sept 2021 stated that no green spaces should be built on and thatpriority should be given to brownfield sites. The removal of valuable hedgerows & trees cannot bepermitted under these circumstances and most certainly not to make a profit for developers.Furthermore, the ONLY housing that is required in Bristol is that which is truly AFFORDABLE orCOUNCIL HOUSING.......and there are sufficient brownfield sites in the city for this.

Bristol City Council was the first to declare a Climate Emergency, it was also the first to declare anEcological Emergency. Here is a chance for the planners at BCC to UNITE and set yet anotherexample to the rest of the United Kingdom.....by making a commitment to 'No more building ongreen spaces!'

I object to these proposals in the strongest possible terms.

Please stop cutting down our much needed green spaces , we need this not only to helpthe environment but to also cut down on pollution and help keep congestion down. Building newunaffordable houses that only the construction companies win and profit by is not helping Bristol ,it creates more road infrastructure , more congestion in and around that area and overload onparking.

I object to these proposals on the grounds that an important wildlife habitat will bedestroyed when Bristol has declared an Ecological Emergency.

Furthermore BCC's Golden Motion passed Sept 2021 states that no greern spaces should be builton & priority should be given to brownfield sites. The removal of valuable hedgerows & treescannot be permitted when we know nature needs our help more than ever.

We do not need any more homes being built in South Bristol, there is already significantbuilding applications already in progress and more to come. The relief roads were built to easetraffic and this has helped therefore adding more people increases more cars so we will be back tothe same congestion and even more than before. Schools, Doctors Surgeries social groups ,respite facilities are at bursting point so to bring more prople into the mix is ridiculous, the cinemais closing to build house, whitchurch airfield which is massively used everyday by hundreds ofpeople is being built on, where are we ment to go were encouraged to make use of green spacesduring covid which people did now your wanting to remove these spaces so where are localpeople ment to go with out resorting to using there cars or public transport to get there, addingmore pollution rather than be able to walk to what's on our doorstep. Hedgerows are beingdestroyed in England mile after mile and these are so important for all our wildlife, the house somemany pollinators within nature so we dhould not be destroying these areas . Use areas of land thatare derelict and not used. The old site for Filwood swimming pool is already concrete use that.You have to stop tear up green spaces, nature animals people we all need it to breath

Planning Application No.21/05164/f (Land On the west Side Of Novers Hill Bristol)I am writing to you to object to the above planning application on the following grounds:

- Traffic and transport:Clean air zone in Bristol only for chosen but no consideration to South Bristol residents who haveto deal with drastically increasing traffic volume completely not adapted to these streets. This willimpact local air quality and pedestrians' safety, particularly local school children.Novers Hill currently exists as a street with no footpath, used as a rat run by the South Bristolcommunity, with no investment from the council in improving surfaces and road conditions.In addition this planning application shows limited parking spaces, which means new owners willtake some spaces on a side road, which is already narrow. As this happened in recentdevelopment up the street on Novers Lane.

- Poor design:It's been highlighted by many rapports that are designed are very poor, narrow streets access onlyfrom Novers Hill, which is a small local road nor designed for a great volume of traffic. 30% ofaffordable houses are located in the most disadvantaged development areas, with the function ofnoise buffer to the more expensive part of this planning. Clearly, this is not an acceptable attitude.In addition, there will be a massive sacrifice of local wildlife in the process, and virgin green land,which, according to government and council policy, should be protected. As long those words areaddressed to all Bristol community, not only to selected areas where people who make thisdecision own their own houses.

- Proof of Need:Bristol has much more suitable areas for developing new houses than land with treasure wildlife. Ifwe cover all of Bristol in concrete, there will be no oxygen, only noise and car fume.

- The local impact:There is no existing local structure as schools, GP practices, and local transport, which havealready received any additional investment from the council and government, to be adapted toabsorb such a huge number of new households. The consequences will be painful for existing andnew residents.

- I also object to the application because the West Side of Novers Hill is still a Site of NatureConservation, and any development in this half of Novers Hill will impact the ecosystem of the restof it.

I am writing to express my strong objection to the updated planning applicationsubmitted by the Lovells. After reviewing the new plans it has become apparent that there are amultitude of significant issues, some pre-existing and some new.

Firstly, the updated plans involve the removal of even more hedgerows and trees, which will havea detrimental impact on the local environment. This is particularly concerning given that the site isdesignated as an SNCI, and developing this half of Novers Hill will have a significant impact on theecosystem of the rest of the area.

Secondly, the proposed development will result in a significant loss of Biodiversity Net Gain(BNG), which is already a major issue with the original plans. It is an embarrassment for a city thatis trying to go "net zero" if this application is approved.

Furthermore, the offsetting site for the BNG is not even in Bristol, which raises serious questionsabout the developer's commitment to sustainable development in the Bristol, let alone theimmediate local area.

Thirdly, the social housing is still located in the worst parts of the development and is being usedas a buffer for the expensive open market housing. This is a clear indication of the developer'sdisregard for the needs of the local community, especially those who are most in need ofaffordable housing.

Fourthly, the roadway of Novers Hill is already struggling to cope with the existing traffic, and the

additional cars generated by the proposed development will only make matters worse. This willhave a severe impact on the safety and quality of life of local residents.

Finally, the complete loss of meadow and removal of an established badger sett is a cause forconcern, and something that realistically cannot be resolved in the context of having a housingdevelopment in the area.

In conclusion, I urge you to reject the updated planning application. The developer has hadenough opportunities to submit revised applications, it's time to nip this in the bud completely.Protect the Western Slopes for us now and for future generations.

2

and Geology)4 (PROTOCOL, 2011). This protocol still applies. It confirms that: ‘The

Local Sites Panel [LSP] are the determining body for decisions on new Local Sites5, and

amendments or deletions to Local Sites, in accordance with the agreed criteria and

procedure.’ BRERC is responsible for maintaining a GIS data layer for each Authority

showing new sites, amended sites, and sites for de-designation.

1.4. The DEFRA 2006 guidance notes that SNCIs can be de-selected ‘if their nature

conservation interest deteriorates to such an extent that they no longer qualify as

Local Sites’ (para. 36) i.e., on ecological grounds. This is confirmed in PROTOCOL 2011.

These are the only grounds upon which an SNCI may be de-selected. The SNCI has not

been de-selected by the LSP, nor has BSA1114 or BSA1108 been removed from its ambit.

1.5. Consequently, as Bristol City Council confirmed in their response to a Freedom of

Information Request dated 24 October 20226 given on 16 December 2022, there has

been no change to the SNCI information for the entire SNCI. This includes the land

comprising BSA1114 & BSA1108.

1.6. The 2006 DEFRA guidance requires that ‘Local Development Frameworks [Development

Plans] should identify all local nature conservation areas on the proposals map’ (by

reference to PPS 12). This does not mean that LDFs or local plans designate SNCIs,

rather that they identify the SNCIs designated by the LSP. Similarly, the National

Planning Policy Framework (NPPF) at para. 179(a) states that ‘...plans should: identify,

map and safeguard components of local wildlife-rich habitats and wider ecological

networks …’. Designation is the responsibility of the LSP, identification is the task of

the LPA. They are two separate tasks.

1.7. Despite this wording, during the plan-making process, the Council mistakenly thought

that the plan-making process designated SNCIs rather than identifying the LSP-

designated SNCIs. The Policy Delivery section of BCS9 of the 2011 Core Strategy states

that ‘The Site Allocations & Development Management DPD and Bristol Central Area

Action Plan will designate important open spaces and Sites of Nature Conservation

Interest’, and, under the heading Nature Conservation, adds ‘The Site Allocations &

4 https://bristoltreeforum.files.wordpress.com/2022/08/designated-sites-protocolcriteria-v12-march-2011.pdf 5 As defined by DEFRA 2006. 6 https://www.whatdotheyknow.com/request/deregistration_of_the_snci_at_la

3

Development Management DPD and Bristol Central Area Action Plan will designate local

Sites of Nature Conservation Interest. The Proposals Map will also show international,

national and local biological and geological conservation sites designated outside the

development plan process’. This statement fundamentally misunderstands the

designation process set out in government and NPPF guidance (DEFRA 2006 and NPPF

para. 179(a)).

1.8. It is notable that the actual policy (BCS 9, p. 74) is silent about this and that paragraph

4.9.9 states that ‘In Bristol, Sites of Nature Conservation Interest are designated

through the Development Plan process as local sites’ (our emphasis) (p.76). The term

‘local sites’ is the term adopted in the 2006 DEFRA guidance for sites such as SNCIs

(Introduction at the 3rd paragraph, p. 3).

1.9. Furthermore, the December 1997 Local Plan policy, NE5 - which provided limited policy

protection to SNCIs - was not replaced until the SADM was adopted in July 2014 (more

than three years after the Core Strategy was adopted) when it was upgraded to the

stronger SNCI protection set out in SADM19.

1.10. As DEFRA 2006 makes clear, the Council does not have, and has never had, the power

to designate SNCIs. LPAs are required to identify sites designated as SNCIs taking the

requisite steps to maintain and enhance the sites (NPPF para.175). As the Council

confirms, the SNCI, including BSA1114 & BSA1108, remains a designated SNCI.

2. The Policies Map

2.1. The second question is whether, although the SNCI (including BSA1114 & BSA1108)

continues to be identified as an SNCI on the Council’s “Pinpoint” map (as well as on

two other publicly-available maps maintained by the Council and the GIS data

maintained by BRERC, the failure to show BSA1114 & BSA1108 as part of the SNCI on

the Policies Map has planning consequences.

2.2. The NPPF (para. 23) states that ‘Broad locations for development should be indicated

on a key diagram, and land-use designations and allocations identified on a policies

map.’ This requires a policies map, a requirement also set out in the Town and Country

Planning (Local Planning) (England) Regulations 2012, Regulation 9 which states that:

‘The adopted policies map must … illustrate geographically the application of the

4

policies in the adopted development plan.’7

2.3. As Regulation 9 indicates, the adopted policies map is not itself a planning document,

it is simply a geographical illustration of the ‘adopted development plan’.

2.4. Neither SA1 nor SADM19 altered the SNCI designations (they could not do so as SNCI

designations are the responsibility of LSPs). The policies map nevertheless represents

BSA1114 & BSA1108 as not being part of the SNCI. This is incorrect. Repeated caselaw

has indicated that if mistakes are made on the policies map, the map can be changed

to represent policy accurately.

2.5. The policies map is a geographic illustration of policies, it has no planning significance

of its own. This was confirmed by the Court of Appeal in Fox Land & Property v SSCLG

[2005] EWCA Civ 298, where Richards LJ held in relation to adopted policies maps: ‘28.

... The Proposals Map is not itself policy, but it illustrates detailed policies, to use

the term in section 36(6)(a) of the 1990 act. In particular, it identifies the

geographical areas to which the detailed policies apply. Just as the supporting text is

relevant to the interpretation of a policy, so the Proposals Map is relevant to the

geographical scope of application of a policy and thus to a proper understanding of

the policy. One looks at the supporting text and the Proposals Map not because they

are themselves policy - they are not - but because of their relevance to a proper

understanding of the policies properly so-called.’

2.6. This geographic status was also confirmed by Waksman J in Jopling v Richmond upon

Thames LBC [2019] EWHC 190 (Admin) who held that the proper scope of an AP map is

as follows: ‘14. By Regulation 2 (1) and (9) of the 2012 Regulations, an “adopted

policies map” is a map which, among other things, illustrates geographically the

application of the policies in the adopted development plan. It follows that the

adopted policies map itself is not a DPD. 15. The reason for this is clear, in my view.

The map is simply a geographical illustration or representation of policies themselves

contained in the local plan upon which it is parasitic.’

2.7. Most recently, the geographic nature of the AP map was confirmed by Lang J. in Bond

v Vale of White Horse District Council [2019] EWHC 3080 (Admin), holding that: ‘the

7 https://www.legislation.gov.uk/uksi/2012/767/regulation/9/made

5

AP Map does not form part of the Local Plan’. Lang J confirmed that the policies map

can be altered without following the statutory procedure for changing the

development plan.

2.8. The Council say that, for the purposes of Section 38(6) of the Planning and Compulsory

Purchase Act 20048 (PCPA 2004), BSA1114 & BSA1108 is not within the SNCI as

evidenced by the development plan Policies Map. This approach is flatly contradicted

by the caselaw. The policies map does not have this significance.

2.9. The policies in the Bristol development plan did not change the SNCI designation of

BSA1114 & BSA1108. They could not do so, as this is a task for the LSP rather than the

LPA (DEFRA 2006 & PROTOCOL 2011). The geographical representation of BSA1114 &

BSA1108 on the policies map is consequently faulty in so far that it does not show the

site as part of an ongoing SNCI.

2.10. While this mistake should certainly be rectified (and can be corrected without engaging

the statutory procedures, per Lang J in Bond v Vale of the White Horse District Council

[2019] EWHC 3080 (Admin), para. 58), even as the faulty map stands, it merely provides

a geographic representation of the plan’s policies, both SADM19 and SA1. No policy in

the development plan de-designated the site (they could not do so as de-designation

is solely a task for the LSP on ecological grounds only (DEFRA 2006, para. 36 &

PROTOCOL 2011)) and the adopted policies map has no planning consequence of its

own as is confirmed by caselaw.

3. Planning consequences of SNCI Designation & “Pricing In”

3.1. The third question considers the planning consequence of designating the site both as

an SNCI and allocating it for development. This ‘dual allocation’ means that both SA1

and the SADM policies identified by it apply in full to BSA1114 & BSA1108. Development

Plan policy SADM19 also states that: ‘Development which would have a harmful impact

on the nature conservation value of a Site of Nature Conservation Interest will not be

permitted.’

3.2. Can the site allocation negate the SNCI designation? There is no Development Plan

provision which allows for one policy to ‘trump’ another or for planning harm to be

8 https://www.legislation.gov.uk/ukpga/2004/5/section/38

6

‘priced in’ at the time of designation. A conflict between contemporary policies must

be determined as a question of planning balance.

3.3. Where there is a conflict between development plan policies, Section 38(5) PCPA 2004

requires that ‘If to any extent a policy contained in a development plan for an area

conflicts with another policy in the development plan the conflict must be resolved in

favour of the policy which is contained in the last document to become part of the

development plan’. Both the SADM19 and SA1 policies were adopted into the

development plan at the same time.

3.4. DLUHC Guidance - Determining a planning application (para. 012) adds that: ‘Conflicts

between development plan policies adopted, approved or published at the same time

must be considered in the light of all material considerations, including local priorities

and needs, as guided by the National Planning Policy Framework’.9

3.5. The balancing of policies remains a question of planning judgement, a point confirmed

by Eyre J in TV Harrison CIC v Leeds City Council [2022] EWHC 1675 (Admin) (06 July

2022), who held that: ‘the assessment as to whether different policies in the

development plan are in conflict is a matter of planning judgement. Section 38(5)

makes provision as to the way in which such a conflict is to be resolved but it does not

operate without more to effect the supersession of policies in earlier documents nor,

more significantly, does it remove the requirement to have regard to the terms of the

development plan and to consider whether particular parts of that plan are or are not

in conflict.’

3.6. In TV Harrison CIC, the LPA’s barrister had attempted to argue that ‘the tension’

between a structural allocation policy and playing fields policy ‘had already been

resolved in favour of the SAP’ (in other words it had been ‘priced in’). The judge, Eyre

J., held that ‘in his oral submissions Mr Tucker [the barrister] moved away from that

position and disavowed reliance on that provision. In my judgement he was right to

do so.’

3.7. Section 38(5) requires policies agreed at the same time to be balanced. In TV Harrison

CIC, Eyre J. held that when two policies applied, the Council had to ‘grapple’ with the

9 https://www.gov.uk/guidance/determining-a-planning-application

7

consequences of the competing policies. In this case, this would mean ‘grappling’ with

both the status as BSA1114 & BSA1108 1 and the effect of SADM19. Rather than

engaging with this balancing process, both the Appellant and the Council have asserted

that the site allocation supersedes the SNCI designation and consequently SADM19.

However, as both s38(5) and TV Harrison CIC confirm, one policy does not trump the

other, an allocation cannot be ‘priced in’. Balancing the policies is a matter of planning

judgement.

Bristol Tree Forum 10 March 2023

I totally object to the destruction of what little green space we have left. Not to mention adecimation of wildlife. With the UK being at the bottom of supporting wildlife habitats even morereason to object to this silly planning. Surely there are many more suitable brownfield sites morethan suitable for development. All we see is greed, ignorance, laziness and money. Nothingsupporting healthy living or our rapidly disappearing wildlife.No forward or sustainable planning or thought process.

This is an unacceptable attempt to extract as much value from the land at the expenseof valuable wildlife habitat. These tree and hedgerows are vital mature green corridors whichBristol city council claim to be so desirable. This is already one of the least green areas in Bristoland now this vital habitat is being targeted for profit. There is a complete lack of imagination todesign homes around existing wildlife habitat and once it is gone, it's gone.

Too much removal of natural habitat.

30 per cent affordable housing is not sufficient.

1. In Britain today, see report by CPRE, theres enough brownfield sites to build OVER 1MILLI0N HOMES.2 BRISTOL has more than enough of such sites to provided the proposed 157 HOMES (47 BEINGAFFORDABLE) so why destroy this cities ever dwindling green areas and their dependent wild lifefor the sake of profit to the contractors.3 This planet is on the cliff edge WE ALL KNOW THIS and how any person, city council,government, world wide, can allow any further destruction of this planets life blood, ie its greenspaces, forests, trees &hedgerows, oceans and the vital biodiversity this magics planet creates isA CRIME and INSANITY IF THE FUTURE IS TO EXIST & yr children & mine & their childrenHAVE A RIGHT TO LIVE IN A CITY/ COUNTRY /ON A PLANET THAT IS ALIVE, SELFGENERATIVE IF ALLOWED TO BE SO & not in a hell of fires, floods, chocking pollution causedby ever increading co2 as Nature is a sacrificial lamb to construction industrues greed basedslaughter.Co2 kills for example the regenerative green oxygenating spaces, the carbon absorbing oceansand so so much more destructive blind choices for profit such as plans like this one, one of manyin Bristol right now needlessly adds to the planets destrution. See I &2.4. BE BOLD, BE INNOVATIVE, BE AN EXAMPLE. BUILD BROWN NOT GREEN !

I object to Destruction last remaining wildlife habitats in Bristol that promote biodiversity,including, trees, hedges and scrub that provide shelter, protection, nesting and food for wildlife.That sequester carbon to reduce co2 levels, pollution and prevent flooding and offer green spacesfor local people and their mental health and wellbeing.

Hi there, just to point out this application has been shared on some Facebook groupswhich represent a minority of people who are motivated by fairly NIMBY objections. I am skepticalof the value of council comment portals for planning applications, as far as I can see every singledevelopment in Bristol gets brigaded by malcontents who would rather nothing changes thenproceed to complain about housing being expensive.

Please build some homes, please ignore the adoption of Green sloganeering about supposed"harms" to some meadows. We need more homes in Bristol and are building nowhere nearenough to combat the huge amounts of demand for housing the city attracts. If we want to create avibrant, diverse, and affordable city we need projects such as this one to be rapidly approved andignore the know nothing NIMBY brigade.

My only comment is that ideally the development would have some more apartment buildings toincrease the number of homes in the plot. Otherwise support the plan greatly!

Once again I write to request that this application be refused. Novers Hill is adesignated SNCI, so if this development is permitted, what message does this send out about theseriousness with which Bristol City Council views its self-declared Climate Emergency? Destroyingthis important green lung is in direct contradiction to the Council's stated aim of being carbonneutral by 2030. Please reject this application and protect the immense ecological value of NoversHill.

Please reconsider this development , this area has increased in wildlife and is enrichingfor the people who live in this area .There is plenty of brown field sites within South Bristol .Bristol city council has declared its belief supporting the environment , it would be wonderful if thisarea could become a designated area for wildlife . Bristol city council should look at building onbrown field areas and truly affordable housing .

Objectio to ERECTION of 157 dwellings, Novers HillI wish to raise objections to Lovell's amended proposals as(a) the number of houses is not sustainable in this area : schools are not designed to largeincreases of children, medical facilities will become over stretched, retail is insufficient.(b) the amended development, which shows removal of trees will affect air quality, damage to landby building plant, there will be increase in cars, are all detrimental to the area.(c) the price will be beyond the means of those who need housing most.

I am writing to object to the proposed housing development on Novers Hill. Theproposed development will have a significant impact on the rare bat species that reside in thearea. These bats are a protected species under the Wildlife and Countryside Act, and their habitatmust be protected at all costs.

Additionally, I am deeply concerned about the proposal to use the affordable housing flats as asound barrier for the rich units. This proposal not only shows a lack of concern for the residents ofthe affordable housing units, but it is also a clear example of social segregation. This developmentshould provide affordable housing options that are integrated into the wider community, not usedas a buffer for the wealthy.

The use of affordable housing units as a sound barrier is not a suitable solution for noisemitigation. It is essential to consider other options that do not have such negative impacts on thecommunity. The development should incorporate measures to mitigate noise pollution withoutaffecting the affordability or quality of life of the residents.

In conclusion, I urge you to reconsider this development proposal and take into account theimpacts on the rare bat species and the negative effects of using affordable housing units as asound barrier. We need to ensure that any development project is sustainable, equitable, andrespects the environment and the community it serves.

Thank you for your attention to this matter.

Dear Sir/Madam,

I am writing to express my strong objection to the planning application for Novers Hill that hasbeen submitted to Bristol City Council. As a concerned citizen, I believe that this development willhave a detrimental impact on the local wildlife, particularly the greater horseshoe bats.As you may know, greater horseshoe bats are a protected species and are known to beparticularly sensitive to light pollution. This species is listed as "Near Threatened" on theInternational Union for Conservation of Nature (IUCN) Red List, which means that any negativeimpact on their habitat could have serious consequences for their survival.It is well documented that light pollution disrupts the natural behavior and migration patterns ofbats. In addition, bright lights can attract insects, which in turn attract bats, leading them to spendmore energy foraging and less time resting and reproducing. This can ultimately result in a declinein bat populations.Given the sensitivity of greater horseshoe bats to light pollution, it is imperative that Novers Hillremain dark, wild and undeveloped. I strongly urge you to reconsider this planning application andto work with local experts to find a solution with the landowner that protect this SNCI fromdevelopment and ensures the protection of this vulnerable species.Thank you for your consideration.

Dear Council,

I strongly object this planning.

West side of Novers Hill is a green space that should NOT be allowed to be built on. It is one ofthe last few green belts in South Bristol, it's natural habitat to many animals, provides fresh air andwalking areas to the local residents.

The BCC introduced the Bristol Clean Air Zone at autumn of 2022, with the aim to reduce pollutionin the city centre. We need the same in South Bristol in the residential areas.

None of the planning updates have been addressing previosuly riased concers of exisitngresidents. The roads are already congested and narrow. So many new houses and new occupantswill bring even more cars and traffic and pollution to an area that is already under pressure.

It's not considering the green belt, relocating nature is just not possible. Such major interruption tothe natural habitat of many species that live here is not recoverable.

Using affordable houses as a protecting area between industrial estates and the rest of the non-affordable houses is simply disgusting.

I am certain that more prosperous areas of Bristol such as the Clifton Downs would not be allowedto be built on, so we deserve the same!

I want the BCC to listen to the voice of their community and not to let this planning go ahead!

Bristol city Council should not be building on this beautiful wildlife haven. Build onbrownfield sites only. I strongly object to this and want to register my objection with you.

As a local resident I object to this development. We have a huge variety of flora andfauna living in the woodland and Green space including hedgehogs bats badgers slow worms owlsand variety of tits and other native birds. Plus a large variety of bees wasps butterflies anddragonflies. It would be an environmental disaster to build here

I strongly object to this application. There have already been objections to previousplanning applications. These have expressed serious concerns for the safety and very existenceof wildlife in a known wildlife corridor. The latest plans will still have a negative impact on thewildlife & destroy their environment. Reference to a nature area in Nailsea that they plan to use to"offset" the biodiversity loss is so laughably distant from the site of the actual development that I'msurprised it has even been proposed. Though the number of houses may have been reduced theroad infrastructure will not sustain the increase in traffic movements and is likely to increasequeuing at the ParsonStreet/Hartcliffe Way junction. This is already a "pinch point" with vehiclesqueuing back towards Novers Hill causing a negative impact on air quality and road safety at atime when families are walking to the local school. It also isolates and compromises the adjacentsites of the Northern Slopes and Crox Bottom and breaks the wildlife corridor into the city. The hillbecomes unstable once disturbedWe are in a climate and nature emergency - now more than ever we need to protect our preciousgreen spaces and areas of biodiverse richness before it is too late, not to mention an area ofessential green space for residents of Knowle West at a time when urban areas are so deprived ofnature. There have been too many applications and amendments, each, unsuccessfully, trying tocircumvent the overall concern of environmental impact. It is ludicrous to let this continue so,Please do not let this proposal go ahead and take action to protect all the land from any futurespeculative planning applications!

I strongly object to this application. There have already been objections to previousplanning applications. These have expressed serious concerns for the safety and very existenceof wildlife in a known wildlife corridor. The latest plans will still have a negative impact on thewildlife & destroy their environment. Reference to a nature area in Nailsea that they plan to use to"offset" the biodiversity loss is so laughably distant from the site of the actual development that I'msurprised it has even been proposed. Though the number of houses may have been reduced theroad infrastructure will not sustain the increase in traffic movements and is likely to increasequeuing at the ParsonStreet/Hartcliffe Way junction. This is already a "pinch point" with vehiclesqueuing back towards Novers Hill causing a negative impact on air quality and road safety at atime when families are walking to the local school. It also isolates and compromises the adjacentsites of the Northern Slopes and Crox Bottom and breaks the wildlife corridor into the city. The hillbecomes unstable once disturbedWe are in a climate and nature emergency - now more than ever we need to protect our preciousgreen spaces and areas of biodiverse richness before it is too late, not to mention an area ofessential green space for residents of Knowle West at a time when urban areas are so deprived ofnature. There have been too many applications and amendments, each, unsuccessfully, trying tocircumvent the overall concern of environmental impact. It is ludicrous to let this continue so,Please do not let this proposal go ahead and take action to protect all the land from any futurespeculative planning applications!

I strongly object to this application. There have already been objections to previousplanning applications. These have expressed serious concerns for the safety and very existenceof wildlife in a known wildlife corridor. The latest plans will still have a negative impact on thewildlife & destroy their environment. Reference to a nature area in Nailsea that they plan to use to"offset" the biodiversity loss is so laughably distant from the site of the actual development that I'msurprised it has even been proposed. Though the number of houses may have been reduced theroad infrastructure will not sustain the increase in traffic movements and is likely to increasequeuing at the ParsonStreet/Hartcliffe Way junction. This is already a "pinch point" with vehiclesqueuing back towards Novers Hill causing a negative impact on air quality and road safety at atime when families are walking to the local school. It also isolates and compromises the adjacentsites of the Northern Slopes and Crox Bottom and breaks the wildlife corridor into the city. The hillbecomes unstable once disturbedWe are in a climate and nature emergency - now more than ever we need to protect our preciousgreen spaces and areas of biodiverse richness before it is too late, not to mention an area ofessential green space for residents of Knowle West at a time when urban areas are so deprived ofnature. There have been too many applications and amendments, each, unsuccessfully, trying tocircumvent the overall concern of environmental impact. It is ludicrous to let this continue so,Please do not let this proposal go ahead and take action to protect all the land from any futurespeculative planning applications!

Planning developments on nature conservation sites when the city is trying to achieve"net zero" does not help a city achieve "net zero". There are plenty of brownfield sites to developon.

This alteration still doesn't address the effect that the extra parking requirements willhave on neighbours and businesses in the area (the 'ban on car ownership' that the developershave said they will put in place is very clearly unenforceable and cannot apply in the longer term).

There is no details on the size or layout of the proposed play area and 'public open space'. This,together with the fact that these alterations have obviously been put together at the last minute totry and push the plans through, doesn't give me any confidence in their public amenity value. Theoriginal theatre is still a far better option as a useful community space.

As a local resident who will be directly impacted by this development I strongly object tothis application. There have already been objections (myself included) to previous planningapplications. These have expressed serious concerns for the safety and very existence of wildlifein a known wildlife corridor. The latest plans will still have a negative impact on the wildlife &destroy their environment. Reference to a nature area in Nailsea that they plan to use to "offset"the biodiversity loss is so laughably distant from the site of the actual development that I'msurprised it has even been proposed. Though the number of houses may have been reduced theroad infrastructure will not sustain the increase in traffic movements and is likely to increasequeuing at the ParsonStreet/Hartcliffe Way junction. This is already a "pinch point" with vehiclesqueuing back towards Novers Hill causing a negative impact on air quality and road safety at atime when families are walking to the local school. It also isolates and compromises the adjacentsites of the Northern Slopes and Crox Bottom and breaks the wildlife corridor into the city. The hillbecomes unstable once disturbedWe are in a climate and nature emergency - now more than ever we need to protect our preciousgreen spaces and areas of biodiverse richness before it is too late, not to mention an area ofessential green space for residents of Knowle West at a time when urban areas are so deprived ofnature. There have been too many applications and amendments, each, unsuccessfully, trying tocircumvent the overall concern of environmental impact. It is ludicrous to let this continue so,Please do not let this proposal go ahead and take action to protect all the land from any futurespeculative planning applications!

As a local resident who will be negatively impacted by this development I strongly objectto this application. There have already been objections to previous planning applications. Thesehave expressed serious concerns for the safety and very existence of wildlife in a known wildlifecorridor. The latest plans will still have a negative impact on the wildlife & destroy theirenvironment. Reference to a nature area in Nailsea that they plan to use to "offset" the biodiversityloss is so laughably distant from the site of the actual development that I'm surprised it has evenbeen proposed. Though the number of houses may have been reduced the road infrastructure willnot sustain the increase in traffic movements and is likely to increase queuing at theParsonStreet/Hartcliffe Way junction. This is already a "pinch point" with vehicles queuing backtowards Novers Hill causing a negative impact on air quality and road safety at a time whenfamilies are walking to the local school. It also isolates and compromises the adjacent sites of theNorthern Slopes and Crox Bottom and breaks the wildlife corridor into the city. The hill becomesunstable once disturbedWe are in a climate and nature emergency - now more than ever we need to protect our preciousgreen spaces and areas of biodiverse richness before it is too late, not to mention an area ofessential green space for residents of Knowle West at a time when urban areas are so deprived ofnature. There have been too many applications and amendments, each, unsuccessfully, trying tocircumvent the overall concern of environmental impact. It is ludicrous to let this continue so,Please do not let this proposal go ahead and take action to protect all the land from any futurespeculative planning applications!

I just want to remind planning officers that you can't condition species surveys.Lovell/Pegasus have suggested this in their recent documents. The government information onthis states:

'Planning conditions:

You should not usually attach planning conditions that ask for surveys. This is because you needto consider the full impact of the proposal on protected species before you can grant planningpermission.

You can refuse planning permission if surveys:* are carried out at the wrong time of year* are not up to date* do not follow standard survey guidelines without appropriate justification* do not provide enough evidence to assess the likely negative effects on protected species'

Source:Protected species and development: advice for local planning authorities - GOV.UK

https://www.gov.uk/guidance/protected-species-how-to-review-planning-applications

It is very clear that this application should be recommended for refusal.

I strongly object to this planning application on the grounds that:

- it will destroy an essential wildlife area (for which insufficient studies have been performed);- the use of Nailsea to "offset" the loss of biodiversity is ridiculous - we should be protecting whatwe already have;- it will add to already congested roads in the local area, some of which are already toonarrow/dangerous;- it will increase both light and air pollution in an area with a high number of residents/schools; and- the use of affordable housing units as a noise barrier for the industrial businesses on HartcliffeWay is disgusting.

Please do not let this proposal go ahead.

Strongly object to losing even more Green space in south Bristol.

I object as it will cause a loss of green space, a loss of wildlife, an increase in pollutionand more congestion on local roads.

This is a vital green space to Bristol and the local area. Not only is it of great benefit tohumans for beauty and wellbeing, but by helping support an already polluted hartcliffe way withthe number of trees. To build on this area is an awful idea.

As mentioned, we need the trees for pollution management but what about the local wildlife, thishabitat is a pocket of safety for many species, and with nature threatened nationwide, we need tobe protecting it not killing it!

Furthermore, this area is already extremely heavy with traffic. Building more homes and bringingmore cars here is a very poor idea with the road systems in place, along with bringing morepollution to this area.

Lastly, this is obviously another purely profit focused scheme. 'Affordable housing' in this area isridiculous and far from affordable.

We don't want this building here. Find a brownfield site elsewhere. The slopes do not need this.

Apart from the following points, my main objection is that the roads can't cope with the traffic. Welive on Bedminster Road, in the one way system and have noticed huge increases in traffic outsideour house since first Malago Road was closed and the diversion goes past our house, andsecondly since the CAZ zone was introduced the traffic has got even heavier. Our cars andhouses are coated with a permanent film of dust and grit which cannot be good for our health. Addto this the cars that will join this route from Novers Hill and it will be a nightmare. I feel that BristolCouncil are happy to clean the air in the centre of town but don't care about where the pollutionends up. Parson Street School at the bottom of the hill already have really poor air quality and thiswill only get worse.

There are now even more hedgerow and trees being removed, which will not help the air qualityimprove.

The BNG LOSS is still massive! It's an embarrassment for a city trying to go "net zero" if thisapplication is approved!The BNG offsetting site is not even in Bristol

The social housing is still in the worst part of the development and being used as a buffer for theopen market, expensive housing

The actual roadway of Novers Hill cannot cope with the extra cars.

The complete loss of meadow and removal of an established badger sett

The site is still a Site of Nature Conservation! And developing this half of Novers Hill will impactthe ecosystem of the rest of it!

I object to this plan hugely. This plan results in the removal of yet more hedgerows andtrees, and green space and nature which is essential - especially within this poor and neglectedpart of the city. The local community need green space for their well-being, this site has uniquenature living on it from birds to animals, and it must be protected.aside from this there is hugedamage to the environment as a whole from this plan - increased traffic in a city already blockedup - and the end of biodiversity in this area. The "social housing" supply is also only in the plans toget the sign-off, and should not be used to offset unaffordable housing for more people toMove to a city already full. The roads already cannot tolerate traffic in that area, and we do nothave the infrastructure for more homes here.The loss of wildlife such as badgers and beautiful meadow spaces are unforgivable in a timewhere green space is rare. Anything done on this site will have irreversible damage to the ecosystem and in turn to the health of people living around it. This plan must be rejected.

This would adversely impact access to green spaces in the area, contribute to morepollution and generate more road congestion in an already very congested local area.If more developments like these are allowed to go ahead we will see all green spaces around usbeing developed on. Access to large public green spaces is critical for physical and mentalwellbeing.

This green belt is essential to the locality and is highly valued by the people who livealongside it and enjoy it. It shouldn't continously be threatened . You should not build on it

The slopes are extremely important to the eco system and health and well being to ahuge amount of people. Living next to one of them I hear owls, see badgers and hedgehogs,amongst a huge abundance of other more common species. There's constantly people visiting theslopes for pleasure, walking and running, taking pets and children for outside activities and toexperience nature on their door step is hugely important to help people appreciate and understandnature and the huge benefits it has and therefore helping the next generation to tackle climatechange.Infrastructure surrounding can not cope with the influx of more cars, services around are notcapable of supporting more people in the local community.I object any green spaces being turned in to concrete jungles when there is no clear need to crammore people in to an already bursting community.

We do not have the infrastructure in place to support the increase in the localcommunity. Lack of decent shops, unable to buy the simplest ingredients. It is near impossible toget a doctors appointment, if you do its over the phone. Schools are oversubscribed, lack ofsupport for those children who need additional help. It is shameful the lack of consideration forthose who have been struggling to improve the local community. The only time any money is putinto the area is when it lines the pockets of those who clearly do not need it. Invest in improvingthe area then we can welcome new neighbors.

We need spaces for wildlife too. As I understand the entire area (including NorthernSlopes / 'Bommi') serves as a wildlife corridor. We have currently a sparrow hawk visiting ourgarden, and regularly see Bussards and bats flying across. These wildlife heavens need to beprotected and treasured. Especially during the recent pandemic, these green spaces also servedfor peoples mental health. I understand the need for houses, but wildlife need spaces to live too.Surely, there must be spaces to build houses, that don't destroy an existing ecosystem and causesignificant damage to existing wildlife.

Monday 6th March 2023

I strongly object to he proposed building of 157 homes on this site for the reasons listed below.

The loss of important meadowland, hedgerows and trees and the removal of an establishedbadger sett is totally unacceptable.

The destruction of half of this wildlife area, which is much wanted and needed, will be detrimentalto the wildlife that thrives there, it will also be detrimental to the local population.

The site is still a Site of Nature Conservation, developing this half of Novers Hill will impact theecosystem of the rest of it.

The narrow roadway of Novers Hill, which is little more than a lane, is totally unsuitable for theextra traffic that this proposal will bring.

The suggestion to use out of Bristol Nailsea for the biodiversity net gain offsetting site is an insultto the people of Bristol.

The whole green area of Novers Hill and the Western Slopes must stay as it is for futuregenerations to enjoy.

There are many brownfield sites to consider before the wanton destruction of this environmentally

important site.

Therefore this planning application should definitely be rejected.

This area is rich in wildlife which cannot be offset off site. Building on grassland andcutting trees and replacing them with new plantings 10miles away still destroys the habitat forbirds, bat's and insects that rely on them. We have to find better ways to house people thanconstantly destroying nature to do so.

I strongly object to this planning application on the grounds that it will destroy anessential wildlife area, an area of nature and sanctuary for Knowle West residents, and becauseusing the affordable housing units basically as a "sound barrier" for the other housing is bothethically and morally repugnant. The relevant impact studies and wildlife surveys have not beencarried out to an adequate standard, and the nature area in Nailsea that they plan to use to"offset" the biodiversity loss is so laughably distant from the site of the actual development that I'msurprised it has even been proposed.We are in a climate and nature emergency - now more than ever we need to protect our preciousgreen spaces and areas of biodiverse richness before it is too late, not to mention an area ofessential green space for residents of Knowle West at a time when urban areas are so deprived ofnature. Please do not let this proposal go ahead.

The revised plans do not change my original objections, the revisions do not addressany of my original objections. I'd like to note my objection still stands following these revisions, asper my original comments.

This nature habitat is conducive to the health both physically and mentally for localpeople. It is a green lung sitting between busy and stinking cars and roads. Perhaps the moreprosperous areas of Bristol would like a glut of housing thrown into the mix of their natural andgreen habitats?

CPRE Avon & Bristol's reasons for objecting to this application include, but are notlimited to, the following:

Housing targets: at Bristol City Council's Full Council on 8 November, all four major parties votedunanimously to push back on government, to allow Bristol to set its own targets, based on landidentified within the city as suitable for house building. This was also reported in the Bristol Cable .Nationally, there have today been reports that national housing targets are to be scrapped.Needing to meet nationally-imposed housing targets could not, therefore, be an excuse forinappropriate development.

Housing: Bristol City Council's latest Housing Delivery Action Plan (July 2022) states that in 2021there were 13,508 dwellings with planning permission, or agreed subject to S106. As 1,350 homeswere completed in 2019/20 , a large number of homes are still to be built. How, therefore, can anyfurther planning application, especially to build on greenfield, be justifiable or necessary?

Housing / brownfield: CPRE has a clear, longstanding Brownfield First policy, and has, by workingwith partners across England, including Bristol, supported successful implementation of this policy. Bristol City Council's own Brownfield Land Register shows that there are at least 14 brownfieldsites in the BS4 postcode and 36 in the BS3 postcode with planning permission . This availabilityof brownfield land in the vicinity of Novers Hill suggests strongly that building on this greenfield siteis unnecessary.

Empty homes: according to data from 2022, Bristol has 1,727 empty homes ; or 1 in 50 of Bristol's

homes are currently empty - an increase of 56 per cent from 2021. We are trying to obtain abreakdown by postcode area of these homes, but, meantime, some food for thought: if we dividethe 1,727 figure by 34, the number of wards in Bristol, we get a figure of 52, i.e. fifty two emptyhomes per ward. We do not need to build houses on the Western Slopes or any other greenfieldor greenbelt sites.

Ecological emergency: Bristol's One City Ecological Emergency Strategy cites the importance of'protect[ing] remaining wildlife habitats and car[ing] for them better' as necessary in order toachieve the 30% by 30 target: for a minimum of 30% of land in Bristol to be managed for thebenefit of wildlife by 2030. We cite this as counter argument to any developers' intentions orobligations to incorporate wildlife enhancement into developments: leaving wildlife habitats as theyare, save for essential management, is better for wildlife than creating new ones. The (rare)Horseshoe bats and badgers that live on Novers Hill would be severely affected, possibly killed, bythis development.

Finally, we agree with all the reasons for objection published on Friends of Western Slopes' FBpage, namely: net loss of ecological diversity that would be caused by this development, protectedspecies on the site, no affordable housing being offered, the already dangerous levels of pollutionand noise in the area, the site's status as a Prominent Green Hillside, Valuable Urban Landscapeand a Site of Nature Conservation Interest.

ENDS

I object to this planning application. When you've just installed a Clean Air Zone,chopping down tress and destroying the natural habitat is absolutely ridiculous.

I would like to object to Lovell's application to build 157 homes on part of Novers Hill.This development goes against what the council voted for which is to prioritise brownfield sites. Iam a resident of Knowle West and know how important it is to stop these green spaces fromdisappearing. They are valuable to the local people but more importantly to all the wildlife that livethere. The idea that a colony of badgers can just be uprooted and moved to an artificial settbecause they 'in the way' is scandalous.

Building homes so near to the industrial units and new recycling centre cannot be good for anyfuture tenants health due to the noise and pollution. Social housing should mean housing withrents that local people can afford. Just 47 out of the total of 157 will be available for rent/sharedownership, this is not my idea of social housing, council housing is.

I would like to finish by saying that not enough notice was given to the local residents regardingany changes, as they were not made available at the public consultation stage.

BS3 is subject to ongoing overdevelopment fuelled by profit - this area will see a largeinflux of people with no additional infrastructure to support health and wellbeing. We are in a globalenvironmental crisis so to allow this green site to be lost to developers for profit would be an act ofenvironmental vandalism.

I heavily object to the application of houses on this plot of land. Avon Wildlife Trust havealso submitted an objection that its a wildlife corridor that links the area around Eastwood Farmwith Stockwood Open Space. In the middle of an ecological and climate emergency this is not awise move. Also considering the fact that the trees are vital for keeping the air in thatneighbourhood in South Bristol clean.I understand the pressures of housing on the community but I think building houses on Greenfieldland is not the way forward. Specifically ones that have been designated a Site of NatureConservation Interest.I ask that the organisation in charge of the decision on this plot of land think about the future of thiscity and its environmental impact upon future generations and the climate crisis.

The site represents a natural green space break between neighbourhoods. Justbecause it's an informal green space doesn't mean it's unimportant. Us residents of South Bristolare fed up with the council carving up, selling off and profiting from our beloved green spaces,handing them over to developers who have no investment in communities and little intention ofproviding housing that is genuinely affordable. We love the trees that have matured here, and thefact that they clean our air of the pollution from our very busy roads. We don't want to travel out ofSouth Bristol to find a tree, keep the well established green canopy that is already here, keep ourwildlife habitats on our doorstep and keep these filthy greedy developers from ruining our doorstepgreen havens.

I object on the grounds that this is a valuable green space which should be preserved.In the current climate and ecological crisis, what is the point of establishing a clean air zone whengreen spaces are being destroyed. There are alternatives to building on greenfield sites, whichshould be take seriously -e,g. compulsory purchase and refurbishing of existing empty buildings.

There would be a build up of traffic as road can't be widened,this Part of the hill isaccident black spot. The increase in traffic as in danger local children and residents. Traffic wouldqueue to be turning in and out of the road due to neighbours parking on access road due to lack ofdrive ways and space.

The Novers Hill is an open space and as such a valuable site as it stands. This is oneobjection to this development. Other objections are lack of ameties in the Filwood/Knowle Westarea to accommodate the influx of inhabitants in the area. Brownfield sites are acceptable fordevelopment.

Western Slope (both private and council part) must be allocate as 'Protected NatureReserve'. It is not for the profit making developers who only see money. Building on green areaspecifically on western slope will not benefit anyone, houses will not be affordable so only rich withso much money will be able to afford. It will destroy the natural habitat of all the wildlife living in itand will create an even more air and noise pollution to the area specially for 2 nearby schoolchildren and all the elderly residents in the area. No developer should be allowed to disrespect thisamazing and magastic land for profit. Please refuse the planning application and protect this landfrom any future greed.

I live on Parson Street and own a property on Novers Hill which is occupied by a youngfamily. The loss of the green fields will greatly impact on their and others personal environmentand mental health. The development will lead to a great increase in traffic further affecting thelocal environment. Novers Hill is a narrow Lane and not suitable for large numbers of vehicles andis likely to result in traffic queueing along Parson Street from the new light controlled junction withHartcliffe way. This further impacts on my and other neighbours along Parson Street. It will alsoimpact on the safety of children walking to Parson Street School.I am also concerned about the heavy traffic needed to service the development as Novers Hill isnot suitable for this type of traffic.

I have already mentioned that Novers Hill is a narrow Lane and the siting of access points on theHill will be further hazard to residents and other road users. Particularly at busy commuter times,morning and evening.

The designated area is a haven for many types of wild life and it's development would have adetrimental effect on their sustainability.

As a former resident of BS3 who regularly exercised on Novers Common, I stronglyobject to any attempt to stop this important area from offering its existing benefits to wildlife andlocal people.

I used to be able to go to the end of my street (Stanley Street South, BS3) & see green hills, this isso important for well-being. One of my favourite running routes was to cross the railway, thenMarksbury Rd & run up the steps to Nover's Common - I got so much mental & physical benefitfrom this & I know many other runners do too.

There is so much brownfield land in south Bristol which remains undeveloped, these areas shouldbe explored long before the important green spaces which provide countless benefits to wildlifeand local people are destroyed. Once these habitats are lost they cannot be restored.

Green spaces have also been shown to provide important mental health benefits for local people,from a place to exercise pets to a way to get away from it all. The wildness & semi-unkempt natureof Novers Common is vital for those living in a city to feel they can escape, it's completely differentto the relatively manicured feel of local parks.

Please preserve this important space for the benefit of local people and wildlife for many years tocome. We know green spaces have a positive impact on air quality which is a big issue in Bristol.The houses can go somewhere else.

2

mitigation implemented as part of development.

As this report’s purpose is ‘to promote sustainable development through better integration of sustainability considerations into the preparation and adoption of plans’ (para. 1.3.1), it follows that these descriptions set the benchmark by which proposals to develop these allocation sites ought to be judged.

It is notable that this document makes no mention of the SNCI status of the other site allocation

on this SNCI, BSA1119 - Land to east of Hartcliffe Way, south of the Waste Depot.

Even though this report formed part of the documents submitted to the Site Allocations Inspector, their report of 2 April 2014 (Report on the Examination into the Bristol Site Allocations and development Management Policies Local Plan (PIN/Z0116/429/5)) makes no mention that they had appreciated that the sites were in a designated SNCI. It is odd that they said nothing about the ecological/environmental significance of these sites, even though it had been pointed out in the Sustainability Appraisal Main Report.

Instead, the Inspector wrote the following:

BSA1114: Land at Novers Hill, adjacent to industrial units

119. In the Site Allocations and Development Management Policies Local Plan, land at Novers Hill, adjacent to existing industrial units, is allocated for housing and business

purposes. Questions have been raised concerning the need for further business land bearing in mind also potential access, topographical and visual problems.

120. To my mind, the proposed allocation would reflect the Council’s aspirations for economic development and regeneration in South Bristol as set out in Policy BCS1 of the Core Strategy. I can conceive of acceptable solutions to the perceived development problems. The allocation in its proposed form is entirely appropriate.

Furthermore, in their report there is no mention of site allocations BSA1108 or BSA1119, nor any indication that the Inspector knew that any of these three sites formed part of an SNCI.

The emerging Local Plan

Nonetheless, the sites were adopted as suitable for future housing allocations. Whilst we do not contest this, we disagree that they should have been so allocated at the time. The recent

announcements that the Local Plan Working Group has thought better of this and decided to remove the remaining site allocations on the Western Slopes, which are not the subject of this application, only confirms our view. We have been advised that this decision will form part of the Local Plan public consultation when it is published later this month.

This announcement is therefore a material consideration because it can be treated as ‘emerging plans’ under paragraph 48 of the National Planning Policy Framework (NPPF), which states:

Local planning authorities may give weight to relevant policies in emerging plans according to:

a) the stage of preparation of the emerging plan (the more advanced its preparation, the greater the weight that may be given);

b) the extent to which there are unresolved objections to relevant policies (the less

significant the unresolved objections, the greater the weight that may be given); and

c) the degree of consistency of the relevant policies in the emerging plan to this

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Framework (the closer the policies in the emerging plan to the policies in the Framework, the greater the weight that may be given).

Applying DM19 - Development and Nature Conservation

However, whether or not this is accepted, we have seen no evidence that these site allocations lost their SNCI statuses as a result. We have already commented on this issue but wish to develop these arguments more fully to demonstrate that this proposed development falls to be

considered under DM19 Development and Nature Conservation because of its SNCI designation.

DM19 policy provides detailed criteria for the consideration of proposals affecting nature conservation sites and features of value in Bristol. It recognises that:

2.19.3 Local nature conservation sites help to ensure the habitats, species and features of value are adequately protected and allow for appropriate public access to nature. Local nature conservation sites in Bristol include Sites of Nature Conservation Interest (SNCIs), Regionally Important Geological Sites (RIGS) and Wildlife Corridors. These sites provide a refuge for flora and fauna; contribute to national biodiversity and geodiversity targets; add to the local character and distinctiveness of an area; contribute to quality of life; enhance the natural processes that support quality of life by maintaining air, soil

and water quality; and can also reduce the effects of flooding and pollution.

2.19.4 Together the SNCIs and connected sites in Wildlife Corridors form the Bristol Wildlife Network. This network strengthens the resilience of species and habitats to changes in the built and natural environment, including rising temperatures and flood risk associated with climate change. It also encourages public interaction with wildlife and an appreciation and understanding of nature conservation which makes a positive contribution to the quality of life in Bristol.

2.19.15 Although they do not receive the same legal protection as international or national nature conservation sites, Sites of Nature Conservation Interest (SNCIs) collectively represent the city’s critical stock of natural capacity. In some areas of Bristol, SNCIs offer people their only valuable contact with wildlife. Therefore,

development proposals which would harm the nature conservation value of an SNCI will not be permitted.

Where loss of nature conservation value would arise development will be expected to provide mitigation on-site and where this is not possible provide mitigation off-site.

Development on or adjacent to sites of nature conservation value will be expected to enhance the site’s nature conservation value through the design and placement of any green infrastructure provided.

Whilst local nature conservation sites, SNCIs and RIGS are designated and shown on the Policies Map1, these sites are also shown on the “Bristol Nature Conservation Map”2 which gives ‘gives an overview of habitats and species on each SNCI’. This, along with more detailed information from the appropriate survey and assessment, should inform any development proposal that may

impact upon an SNCI to ensure harm is avoided. This information is available on request from the Bristol Regional Environmental Records Centre (BRERC).

1 Bristol City Council Local Plan Policies Map - https://maps.bristol.gov.uk/policies/ 2 An option found in the Environment and Planning tab in Pinpoint - https://maps.bristol.gov.uk/pinpoint/

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DM 19 also states:

2.19.7 For land to be given SNCI status strict criteria have to be met. These criteria establish the site as having substantive value for nature conservation due to the presence and condition of particular species, habitats and features.’

The alleged ‘deregistration’ of the SNCIs

This criteria is governed by Defra’s 2006 Local Sites - Guidance on their Identification, Selection and Management, which was adopted by the Council and its ecologists in the 2012 Protocol for the designation and review of Local Sites, which is used for designating and deselecting Bristol’s SNCIs.

The Defra guidance about the deselection of SNCIs states the following:

• De-select sites which no longer qualify

36. The partnership can de-select sites if their nature conservation interest deteriorates to such an extent that they no longer qualify as Local Sites. De-selection proposals may be prompted by an individual or picked up during monitoring. If sites are proposed for deselection, owners and other interested parties should be notified and given the opportunity to make observations. Formal de-selection, once agreed by the partnership, should be notified to owners and other interested parties.

37. In considering whether to de-select a site, the partnership should consider any implications for the provision of contact with nature and the availability of sites for educational use. The potential for restoring the site’s features of interest should also be a consideration. This is particularly relevant where a site has been deliberately damaged, or degraded through neglect or inappropriate management.

There is no evidence that this site met any of these criteria, which would have justified the removal of the SNCI status of these two site allocations. Furthermore, no evidence has been provided to show that the LSP approved the deregistration of these sites.

It does not lie in the power of the LPA unilaterally to deregister an SNCI merely by allocating all or part of it for future development in its Local Plan or by altering the SNCI’s boundary on the Policies Map to exclude the site allocation area.

Dual Allocation – does SA1 override DM19?

The Bristol LPA argues that these sites have been dual allocated: designated both as an SNCI and allocated for development (SA1). The Council’s view is that policy DM19 does not apply to SNCI sites designated as SA1.

However, we have been shown no evidence that this is the case. We can find no mention of this in any of the local plan documents. In fact, it would appear that DM19 has priority over SA1 because DM19 states: ‘development which would have a harmful impact on the nature conservation value of a Site of Nature Conservation Interest will not be permitted’.

It is also notable that a number of recent planning applications have recognised the existence of an SNCI within a site. For example:

1. BSA0402 fell partly within the Bonnington Walk SNCI, and yet the Planning Statement

submitted with the application noted: ‘Whilst the application red line extends around the SNCI, only a very small portion of SNCI is intended for development, to enable access from Bonnington Walk. No buildings are proposed within its designation.’

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2. BSA1205 fell partly within St. Anne’s Valley SNCI: throughout the planning process, documents submitted acknowledged that the SNCI designation remained. For example, the Planning Statement said that: ‘The area of grassland to the north-east of the youth centre and the woodland … fall within the St Anne’s Valley Citywide Site of Nature Conservation Interest (SNCI).’

We also refer to the anonymised comment made in the pending Brislington Meadows application

dated 17 October 2022, which we have extracted in the addendum below. This is relevant in this case because, among other things, this reports the approach of other Local Environmental Record Centres and some local authorities in England to the allocation of development sites on SNCIs.

While it may be possible as a matter of planning judgement to disapply DM19 policy to an individual site when deciding a planning application, this would have to be expressly undertaken and could only be justified in accordance with the criteria set out in Defra’s 2006 guidance and the LSP’s protocol.

Conclusion

As a consequence, this proposed development falls wholly within the Pigeonhouse stream and adjacent meadows SNCI. It therefore must be tested against the strict standards required by DM19, which states that ‘development which would have a harmful impact on the nature conservation value of a Site of Nature Conservation Interest will not be permitted.’ The applicant’s plans, by their very nature, will result in damage to this SNCI.

Bristol Tree Forum

10 November 2022

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Addendum

Extracted anonymised comments made in the pending Brislington Meadows application

‘… Various Local Environmental Record Centres and some Local Authorities in England were emailed to ascertain their approach to de-designating Local Wildlife Sites if allocated in the Local Plan. Below are extracts of the responses, each from a different region:

• Local authorities are required to protect habitats and species as per their responsibilities under the NERC Act 2006: “Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity". Therefore a LWS should not be identified for a possible housing development in a local plan.

• Local Wildlife Sites cannot simply be deregistered by a local authority. Also all sites which qualify under the LWS the criteria should be treated in planning terms as Local Wildlife Sites regardless.

• Housing development should not normally be permitted on a Local Wildlife Site.

• Deselection of a site would be something we would try to avoid and discourage as all sites are based on evidence and should have been adopted into each authorities local plan as a material consideration in planning and also a component of the local authorities Biodiversity Duty.

• The process of de-selection would be the same regardless of whether the site had been identified for a possible housing development in a Local Plan.

• The process of selection, modification, amendment or de-selection of a Site of Nature Conservation Importance is the responsibility of the Surrey Local Sites Partnership.

• deselecting a site should only happen because the site no longer meets the criteria for which it was selected and is unlikely to recover.

• the designation (and de-designation) of sites is the responsibility of local planning authorities, such as London Boroughs. These must follow a process including a site review, public consultation and a review by the London Wildlife Sites Board (LWSB), who provide guidance to ensure consistency and a process which is compliant with various policy frameworks.

• While non-statutory, SINCs are still afforded a high level of protection within the planning system. Development that negatively impacts a SINC will only be permitted in exceptional circumstances and where mitigation can be proven from the beginning.

• If a CWS is likely to be affected by development the views of some of the CWS partners is normally sought as part of the consultation process.

• In general deletion of SNCIs is based on survey data and the decision is made by the SNCI Panel at a formal panel meeting …. The process would remain the same if the site is allocated for development although of course we will object strongly to any such allocation and work with local authorities to ensure that this isn’t the case. If despite all our efforts an SNCI is developed, it will have been effectively destroyed and would be deleted subsequently. It is very unlikely that any site would be deleted based on the prospect of future destruction which hasn’t yet occurred.

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• LWS site are considered by planners with applications and if sites contain priority habitat the LWs designation is trumped by that. Sites that are in a local plan are not removed from the list unless destroyed

• If a SINC was identified as a possible housing site in a Local Plan, the SINC would remain in situ until such time as the site is developed and the interest lost.

• The presence of a Local Wildlife Site would be a material consideration if a proposed development e.g. for housing, was submitted for planning permission. In this instance the site would not be de-designated and policies 30 and 31 of Doncaster’s Local Plan would be used to guide the decision making.

• A Site of Importance for Nature Conservation would only be removed if it had been destroyed with no hope of restoration. The Isle of Wight Council would then remove it from the maps and site register and inform me here at the IWLRC. To my knowledge, this has never happened. We have only ever had slight modifications to any of our designated SINCs.

• It is likely that Cornwall Wildlife Trust would object to a housing development within a CWS on the basis that these are core areas for wildlife in Cornwall and an important part of the Local Nature Recovery Network…

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The Site Allocations Inspector’s report of 2 April 2014 makes no mention that he appreciated that the sites were in a designated SNCI. The Inspector wrote:

“BSA1114: Land at Novers Hill, adjacent to industrial units

119. In the Site Allocations and Development Management Policies Local Plan, land at Novers Hill, adjacent to existing industrial units, is allocated for housing and business purposes. Questions have been raised concerning the need for further business land bearing in mind also potential access, topographical and visual problems.

120. To my mind, the proposed allocation would reflect the Council’s aspirations for economic development and regeneration in South Bristol as set out in Policy BCS1 of the Core Strategy. I can conceive of acceptable solutions to the perceived development problems. The allocation in its proposed form is entirely appropriate.”

There is no mention of site allocation BSA1108, nor any indication that the Inspector had any knowledge that either of these sites formed part of an SNCI.

The ecological experts who sat on the Local Site Partnership had designated it as a Local Site that should be protected for local nature conservation and BRERC had registered it as such. If the Inspector knew this, it is reasonable to assume that he would have addressed the SNCI designation. And if the Inspector did not know that the sites allocated for housing were designated on an SNCI, the SA1 allocation stands on very shaky ground.

While we cannot know what was in the Inspector’s mind, the written evidence does not suggest that he approved the SA1 allocations for Novers Hill knowing that the sites had been designated as an SNCI. This was not clearly spelled out for this site in the submission documents.

Consequently, BSA1114 & BSA1108 were, to my mind, misallocated for housing as the correct procedures for identifying the site as an SNCI were not followed.

2. Dual Allocation – priority between SA1 or DM19?

BCC’s position is that these sites have been dual allocated: designated as an SNCI and allocated for housing. The Council’s view (as expressed in emails from the planning department) is that policy DM19 does not apply to SNCI sites designated as SA1.

However, there is no mention that SA1 should effectively “trump” DM19 in any of the local plan documents. If anything, DM19 would appear to have priority over SA1, as it states that “development which would have a harmful impact on the nature conservation value of a Site of Nature Conservation Interest will not be permitted” (DM19).

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While it may be possible as a matter of planning judgement to disapply the Council’s DM19 policy to individual sites, this would have to be expressly undertaken and should be justified on both ecological and social grounds.

BRERC list the sites as SNCIs on ecological grounds on behalf of the LSP. I have seen no indication from them that the site should be de-designated.

3. Mapping and Transparent Decision-making

While the Pinpoint map accurately reflects SNCI boundaries, echoing BRERC’s map, the local plan map shows only a partial SNCI. The designation underneath the SA1 allocation does not appear when the site allocation layer of the map is removed – all that remains on the map is a truncated SNCI.

If it is BCC’s position that Novers Hillis dual allocated (for both SA1 and as an SNCI), then both allocations should be visible on the local plan map. At the moment only the SA1 designation is visible on the local plan map, which is consequently inaccurate. This matters as informed and transparent decision-making cannot take place with an inaccurate map.

Local plan map for BSA1114 & BSA1108 with site allocations layer

switched on.

Local plan map for BSA1114 & BSA1108 with site allocations layer switched off – the sites

should be hatched to show that they are designated as an SNCI.

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An accurate local plan map is critical to fair and transparent decision-making. The current map does not accurately reflect the SNCI designation and so cannot be relied upon by decision-makers.

4. Lack of Acknowledgement of SNCI status

Novers Hill was not de-designated as an SNCI site (one recent confirmation of this is the map submitted to North Somerset LPA as part of a scoping opinion, 22/P/2218/EA2). Yet this information is not included in the constraints section of BCC’s website for this planning application. It is also clear that agents acting on behalf of the developer suggest that the site was de-designated, without public correction from BCC, for instance, by way of a press release. How are decision-makers to know that they are determining applications on a site designated as an SNCI if this is neither included on the constraints section or included on the local plan policies map? Such an omission raises fundamental questions of procedural fairness.

5. The Social Context: Access to Greenspace and (Im)mobility

The social context for development should be taken account when deciding whether or not to give planning permission for development. While this is not a formal ground, there is increasing understanding of the health and wellbeing benefits of spending time in greenspace and nature. (see for instance, Public Health England, 2020) The ward report for Filwood indicates that a over a third of all residents have no access to a car or a van. Consequently, the only way in which these citizens can access greenspace independently is to walk, cycle on tricky roads or – if they can afford it – take relatively expensive and unreliable public transport.

The social context and access to greenspace are issues that we must factor into decision-making. If spending time in nature benefits health and well-being, should people who lack access to a car, often through economic circumstances, be unable to access these benefits? While Bristol’s previous (2008) Greenspace strategy used ANGSt standards to try to assess relative access to greenspace, these criteria appear to have disappeared from the Council’s decision-making processes.

While the West of England Nature Partnership (WENP) are mapping access to nature, their use of the OS greenspace layer conflates green spaces that are not accessible (allotments and playing fields) with green spaces that are (such as Novers Hill). We need accurate data to understand how people can access greenspace and nature, particularly larger areas,

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where traffic is no longer audible and nature connectedness is possible. These are critical concerns for people who lack the economic resources to drive to dedicated greenspace sites (such as Ashton Court, Blaise Castle and Leigh Woods).

The NPPF provides significant support for policies that protect access to nature. Paragraph 92 states that “Planning policies and decisions should aim to achieve healthy, inclusive and safe places which … c) enable and support healthy lifestyles, especially where this would address identified local health and well-being needs – for example through the provision of safe and accessible green infrastructure…”. Paragraph 98 emphasises that “Access to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities, and can deliver wider benefits for nature”. While habitat sites are distinguished from local nature sites, plans should (according to paragraph 175) “allocate land with the least environmental or amenity value, where consistent with other policies in this Framework” as well as “take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries.” As it seems that the SA1 allocation for Novers Common was mis-allocated (see point 1), these provisions still apply. Housing should not be built on a designated SNCI in a ward where access to nature and greenspace is so important for local people, many of whom will rarely be able to leave their locality.

6. The Presumption in favour of sustainable development

The consequences of the latest housing delivery test clearly pose a challenge for BCC. However, paragraph 11 of the NPPF is clear that while the presumption operates, it is not determinative. The NPPF states that development need not be approved where “[i] assets of particular importance [provide] a clear reason for refusing the development proposed; or ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in [the] Framework taken as a whole.” This means that SNCI policies are still applicable – the NPPF is a material consideration but does not dictate that applications for development have to be approved.

The implications of the housing delivery test clearly raise broader questions for BCC and other decision-makers to grapple with. Logic dictates that we cannot permanently build new housing within city boundaries without building on greenspace land. However, while green field sites are cheaper for development, social, spatial and ecological context – including the socio-economic conditions of neighbourhoods as well as ecological designation – are relevant to decision-making.

As noted by Bristol CC planning officer, socially rented and affordable flats areconcentrated in the northern corner of the development. These individuals will be left isolated atthe bottom of a steep hill with no alternate access and long walks to any public transport routes.Overall the prdestrian access to the site is poor and insufficient and will leave residents locked inand isolated from the wider community.Buffer margins labelled as ecological corridors and habitat around the majority of the site are sothin as to provide no real benefit other than to add surface area to the developers' BNGcalculation.

The council should respect the Green spaces motion it passed last year and focus onbrownfield sites for new developments.Green spaces are needed to support mental and physical health and general well being. This is agreen field site and it's development in this way will be devastating for biodiversity.

The council must respect the Green spaces motion it passed last year and focus onbrownfield sites and protect this area.

The council must respect the Green spaces motion it passed last year and focus onbrownfield sites and protect this area.

We need to keep our green areas that we have left green.

I object to the planned development of 157 new homes based at Novers Hill. Mygrandparents live near by and I have many special memories of being taken for walks down in thebeautiful green spaces of Headley Park and Novers Hill.

Apart from my personal nostalgia for the site I also object on the grounds that people need thesewild, green places for their mental health, there is already far too much concrete and depletednatural land around Bristol when there is derelict brownfield sites much more suitable fordevelopment, which Bristol City Council I believe have said are the only places considered fordevelopment and green spaces to be left alone.

Possible development will be devastating for biodiversity in a time where quite frankly we cannotafford any more losses and is irresponsible to the natural health of South Bristol, depriving futuregenerations the simple health and wellbeing they get from being in wild places.

Regards,Alex

Traffic and parking : There are very few shops near Novers Hill, and no pubs, so theamount of traffic on Novers Hill, Novers Lane, other surrounding roads and especially HartcliffeWay will increase significantly, adding to noise and toxic levels of air pollution and danger for localchildren who walk to school at the E-Act Academy from the surrounding streets.Highway safety : City Transport Development Management submitted an application response inDecember 2021. The local authority transport development manager felt the proposed walking andcycling enhancements on Novers Hill were 'unacceptable' for safety reasons.Amenity : The land is a 'prominent green hillside' so can't be altered. Policy DM17 identifiedImportant Open Space which mandates that "development on part, or all of an Important OpenSpace as designated on the Policies Map will not be permitted".Wildlife : The site is a Site of Nature Conservation Interest- The development will cause unacceptable ecological harm to a nationally rare habitat and wildlifecorridor, and fails to meet 10% biodiversity net gain onsite- Access roads would damage a protected ancient hedgerow and destroy connectivity of thewildlife corridor- The Council's Motion to Protect the Green Belt and Bristol's Green Spaces, passed unanimouslyat full council meeting on 7 September 2021 specifically mentions this site and dictates its removalfrom the local plan

12. City Design Group has objected

13. This land is listed as ‘prominent green hillside’ and therefore can’t be altered to the extent this application is proposing

Health and Safety 14. Surface water and drainage is a serious concern

15. Transport Development Management has objected

16. This site is meters away from the Air management zone and would increase the already toxic levels of Air pollution

Sound 17. Alternative ventilation has to be used for the affordable flats because they are being used

as a sound barrier for the market rate housing

18. The sound survey which found noise levels to be higher than allowed was done in during peak lockdown and before the recycling centre was built

Other Concerns (which aren't material considerations but worth noting) 19. There are several instances of incorrect information in the applicant’s planning documents

20. The site has viability issues that may lead to the applicant backing out of their affordable housing obligation

The Western Slopes/Novers Hill, Bristol

Ecology

1. Unacceptable ecological harm to a nationally rare habitat/wildlife corridor

We are in the middle of a climate and ecological crisis that has reached emergency status. 97% of our grasslands have already been destroyed because developers have argued that each species-rich meadow is ‘just a field.’ ‘Ecological enhancement’ is always promised but recent data shows their mitigation is not working. This proposal is a perfect example of the mitigation myth in action.

Am I biased against development on Novers Hill? Of course, but no more so than the applicant is biased towards development. That’s why you should listen to the subjective voices and experts in this debate like Avon Wildlife Trust, The local authority’s ecologist, the Environment Agency, Goram

Homes and Chris Packham. And here is what they have to say:

Bristol City Council’s ecologist surveyed the sites being proposed for housing in the local plan and this was her professional opinion about this allocation: ‘The site has a large area that has been recorded as Priority Habitat, lowland meadow (see figure 1), which is a material consideration in the preparation of Local Development Documents (ODPM Circular 06/2005 – Biodiversity and Geological Conservation – Statutory Obligations and their impact within the planning system). This habitat according to the UK BAP is in decline across the UK and contains a large amount of the UK’s scarce or severely rare species of invertebrate. The cover of calcareous species rich lowland meadows has suffered a sharp decline in extent over the last 50 years. I am therefore opposed to the above allocations on this site. They will clearly have a significant impact on the value and integrity of this site, and therefore on the wider Wildlife Network. Whilst it is understood that allocations on this site will contribute to wider objectives within the Core Strategy, most of the habitat affected could not be recreated elsewhere within a reasonable timescale. There is therefore no potential for appropriate mitigation, and the integrity of the Wildlife Network will be severely undermind.’

Avon Wildlife Trust also objected to the allocation being included in the local plan along with the Environment Agency:

‘The Environment Agency considered the allocation would be likely to create an unacceptable impact on riparian habitat. They thought it would contravene Core Strategy policy BCS9. They also considered the removal of the allocation would be unlikely to significantly impact on the core Strategy’s minimum housing target. Avon Wildlife Trust considered the allocation will result in a marked loss to the Site of Nature Conservation Interest and ecological network that currently exists.’

Today Avon Wildlife Trust keeps the same position: ‘Avon Wildlife Trust recognizes Bristol’s Western Slopes as a vital wildlife corridor and stands with those people calling it to be protected from development.

This area, located on the slopes between Novers Hill and Hartcliffe Way, is a particularly important habitat for a wide variety of birds, mammals and rare wildflowers. We recognise that there is considerable concern from local residents that it may be vulnerable to development, and we echo their calls for it to be protected.’

The ecology consultant acting on behalf of Bristol City Council for the application has said: ‘the loss of any urban green space in Bristol is unwelcome (arguably it is contrary to local policy, viz. BCS9 and the One City Ecological Emergency Strategy) and will have a wider, long-term ecological impact’

The current mayor of Bristol Marvin Rees has mentioned the importance of the Western Slopes:

‘We need to tackle the housing crisis in Bristol, but it shouldn’t be at the expense of our commitments to confronting the climate and ecological emergencies.It’s now clear that Western Slopes is a hugely important wildlife corridor and ecologically significant site.’

Bristol City Council’s development company Goram Homes has made the following statement:

‘As a result of the findings of the most recent ecological report, and in discussion with Avon Wildlife Trust, plans to build homes on Western Slopes have been scaled back to protect the important wildlife corridor and meadow and grassland habitats.’

Naturalist and television presenter Chris Packham CBE has called for the allocation to be removed from the local plan: ‘Western Slopes is a wildlife corridor, home to birds, animals, insects and plantlife. It should be taken off the local plan’

Sources: https://www.avonwildlifetrust.org.uk/news/support-bristols-green-spaces https://www.itv.com/news/westcountry/2022-02-02/mayor-scales-back-south-bristol-housing-plans-after-campaign https://www.bristol.gov.uk/newsroom/mayor-pledges-to-protect-important-ecological-site https://democracy.bristol.gov.uk/documents/s70334/Appendix%20A1%20and%20A2%20Goram%20Homes%20Pipeline%20180122%20v7.pdf https://www.facebook.com/groups/2560966744207814/permalink/2628124497492038 https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=QZSL00DN0DG00 https://twitter.com/ChrisGPackham/status/1434923278959890435 Back to list

2.The development fails to meet 10% biodiversity net gain even with the outdated metric used and they have not found a suitable site to offset their biodiversity loss.

2a. Outdated Biodiversity Net Gain

The applicant has used Biodiversity 2.0 which is now outdated despite claiming to use 3.0 in the updated report (January 2022). Natural England published the following about the upgrade to 3.0:

‘Biodiversity Metric 2.0 has been updated and replaced by Biodiversity Metric 3.0 which was published on the 7th July 2021.Biodiversity Metric 3.0 introduces a number of improvements and corrects some issues associated with metric 2.0. The new Biodiversity Metric 3.0 will be the metric that underpins the Environment Bill’s provisions for mandatory biodiversity net gain in England, subject to any necessary adjustments for application to major infrastructure projects.’

On page 7 section 3.2 of the Biodiversity Net Gain Results document Ethos, the consultancy Lovell hired, claim to have used Biodiversity Metric 3.0 as you can see here:

And again here:

However when you scroll down to the actual BNG calculation on page 39 their table says ‘Headline result from the DEFRA metric 2.0’

Whether this is an honest mistake or deliberately misleading it’s completely unprofessional.

Sources: https://pa.bristol.gov.uk/online-applications/files/45F988B3B8DC572CC229AD03335F8905/pdf/21_05164_F-NOVERS_HILL_BNG_ASSESSMENT_JANUARY_22-3136313.pdf http://publications.naturalengland.org.uk/publication/6049804846366720

https://committees.parliament.uk/publications/6498/documents/70656/default/ https://www.gov.uk/government/news/biodiversity-30-metric-launched-in-new-sustainable-development-toolkit https://naturalengland.blog.gov.uk/2021/07/21/biodiversity-metric-3-0-a-milestone-moment-for-biodiversity-net-gain/

2b. The development fails to meet the 10% biodiversity net gain requirement

This development will cause a Biodiversity net loss of 46%. Bristol policy as stated in the recent ecological emergency report requires a net gain of 10%:

‘Biodiversity Net Gain of 10 per cent net gain will become mandatory for housing and development, meaning habitats for wildlife must be left in a measurably better state than before the development. Developers must submit a ‘biodiversity gain plan’ alongside usual planning application documents. The local authority will assess whether the 10 per cent net gain requirement is met.’

The BNG assessment included in this application admits that this development has drastically failed to meet the biodiversity net gain requirements. The National Planning Policy Framework (NPPF) states:

‘Planning policies and decisions should contribute to and enhance the natural and local environment by: d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;’ (NPPF 174d)

Sources: https://www.bristol.gov.uk/documents/20182/5572361/Ecological_Emergency_Action_Plan.pdf/2e98b357-5e7c-d926-3a52-bf602e01d44c?t=1630497102530 https://bristoltreeforum.files.wordpress.com/2021/11/novers-hill-development-btf-further-comments.pdf https://www.devonwildlifetrust.org/sites/default/files/2022-02/Objection%20Checklist%20Feb%202022%20FINAL.pdf https://www.gov.uk/guidance/national-planning-policy-framework

2c. No suitable site agreed in Bristol for offsetting

Continuing from the previous paragraph on biodiversity net gain Bristol planning policy states:

‘If net gain is not achievable on-site, off- site habitat creation/enhancements will have to be agreed.’

Lovell originally claimed on their application that they are considering Crox Bottom for offsetting but this was found unsuitable by the council. Lovell now have no options in Bristol and have mentioned they are considering a private landowner in Nailsea, North Somerset. No offsetting plan has been agreed on by the local authority as of when this document was written.The ecology consultant for this application has said:

‘the viability of securing off site biodiversity units needs to be reviewed. I am aware that no agreement has been reached about using Crox Bottom SNCI for this purpose or for securing such gains via planning obligations at this or any other site. And I would advise that the application should not be determined until more certainty is offered.’

The NPPF also declares this is grounds for refusal:

‘When determining planning applications, local planning authorities should apply the following principles: a) if significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused’ (NPPF 180a)

Sources: https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=QZSL00DN0DG00 https://www.bristol.gov.uk/documents/20182/5572361/Ecological_Emergency_Action_Plan.pdf/2e98b357-5e7c-d926-3a52-bf602e01d44c?t=1630497102530 https://www.gov.uk/guidance/national-planning-policy-framework Back to list

Wildflowers in summer on the Western Slopes/Novers Hill

3. Damage to the Ancient Hedgerow

Lovell claim ‘The hedgerows on site are being retained and enhanced within the proposals’ but this is incorrect because two access roads are being built through the ancient hedgerow.

This Hedgerow has been confirmed by the Local Authority to be ‘ancient’ and ancient hedgerows have their own legal protections. According to government regulations a hedgerow is protected if it’s on or next to:

✓ land used for agriculture or forestry ✓ land used for breeding or keeping horses, ponies or donkeys ✓ common land ✓ a village green

This means Lovell do not have the legal right to issue any works that would damage the protected ancient hedgerow. Their development completely relies on two access roads which cut the hedgerow into sections destroying its connectivity. This is enormously significant because hedgerows are essential to our ecosystem and they have to maintain their connectivity to be usefully as a wildlife

corridor. I asked one of the country’s leading hedgerow experts, Megan Gimber, her opinion on whether the access roads would cause permanent damage to the biodiversity of the hedgerow and she kindly responded:

‘Absolutely. Hedges provide 3 wildlife functions: habitat, food/shelter, connectivity. Fragmenting the network like this can impact on at least 2 of these. Connectivity is vital for bats, flying insects, mammals such as dormice etc. Fragmentation is limiting factor to distribution of some species and even a threat of extinction to others. Connecting habitats up should be a real priority, & given hedges combine elements of woodland, scrub and pasture, they can accommodate, as well as facilitate the movement of species from each.’

Sources: https://www.gov.uk/guidance/countryside-hedgerows-regulation-and-management https://yorkshiretimes.co.uk/article/The-UKs-Hedgerows-Need-Our-Help https://www.surreywildlifetrust.org/events/2022-02-16-lifecycle-hedgerow-megan-gimber https://twitter.com/favcolour_green/status/1447645253952065543?s=21 Back to list

4. Species Surveys are insufficient, inaccurate and/or out of date 4a. You can refuse an application based on surveys

The government has instructions for local planning authorities on how to assess a planning application when there are protected species on or near a proposed development site. The following is all quoted from Natural England and Department for Environment, Food & Rural Affairs (DEFRA)’s ‘Protected species and development: advice for local planning authorities’ guide(2022):

‘Local planning authorities (LPAs) should use this guide to assess whether a planning application would harm or disturb a protected species. It will help you decide if you can give planning permission.

‘You can refuse planning permission if surveys:

• are carried out at the wrong time of year

• are not up to date

• do not follow standard survey guidelines without appropriate justification

• do not provide enough evidence to assess the likely negative effects on protected species’

You should not usually attach planning conditions that ask for surveys. This is because you need to consider the full impact of the proposal on protected species before you can grant planning permission. You can add an ‘informative’ note to the planning permission to make it clear that a licence is needed.’

It is clear to even the most untrained eye that ecological assessment done by Ethos does not meet Bristol City Council’s strict criteria. The report is riddled with typos, missing required data, full of unsubstantiated claims and contains surveys that have already expired.

When considering the following errors and omissions I’m about to show you it is apparent the applicant’s ecology report undeniably does not meet the criteria for approval.

Source: ‘Protected species and development: advice for local planning authorities’ guide (2022)

https://www.gov.uk/guidance/protected-species-how-to-review-planning-applications

4b Species surveys are out of date

Ethos published their report on July 21, 2021 but if you read deep into the report you’ll see most of the species surveys were done in the summer of 2020. The very last species survey was done in September 2020.

According to Chartered Institute of Ecology and Environmental Management (CIEEM) standards (which are linked to under ‘advice on the valid age of data’ on the government site) these surveys are not valid due to being out of date.

They are well past the 12 month mark and four of the five CIEEM scenarios which determine a need for updated surveys apply:

✓ Otters have been found within the required distance since sept 2020 but no otter surveys were done

✓ 11 species of bats were found as stated in the report

✓ A main badger sett is onsite

✓ grazing has stopped since the last species report was done.

Here are all the scenarios for reference:

Most of the surveys will be over 18 months old by April which is when this will go to the development control committee.

A planning inspector ruled in 2019 in favour of the council when out of date surveys were concerned so there is a precedence in planning that providing up to date species surveys is a reasonable requirement for approval. The appeal case reference is APP/P1133/W/18/3205558.

Sources: https://cieem.net/wp-content/uploads/2019/04/Advice-Note.pdf (2019) https://www.bristolpost.co.uk/news/bristol-news/exciting-discovery-otters-living-south-6522459 https://www.csaenvironmental.co.uk/2020/06/19/what-is-the-shelf-life-of-an-ecology-survey-a-recent-

appeal-case-in-devon-provides-a-useful-precedent/ https://novershillconsultation.co.uk/wp-content/uploads/2021/07/Novers-Hill-draft-ecological-assessment-with-location-of-badger-sett-redacted.pdf

4c The ecology report is stuck in 2018

The Ethos report also thinks it’s currently 2018 as it states on page 45:

‘A draft NPPF 2018 has been prepared which consolidates proposals from various Government consultation documents in recent years. The draft NPPF has undergone consultation and is due to replace NPPF 2012 imminently in 2018.’

The latest update to the NPPF was published in July 2021, and I am writing this in March 2022 so they are three years behind. The previous updates were published in February, 2019 and July 2018.

None of the references they site in the report are more recent than 2017.

Sources: a Calendar https://www.gov.uk/guidance/national-planning-policy-framework https://cieem.net/wp-content/uploads/2019/04/Advice-Note.pdf https://novershillconsultation.co.uk/wp-content/uploads/2021/07/Novers-Hill-draft-ecological-assessment-with-location-of-badger-sett-redacted.pdf

4d. No winter bird, owl or sufficient breeding bird surveys were done

No winter bird or owl surveys were done and their breeding bird survey was only done over one day which does not meet CIEEM requirements. For a breeding bird survey to be valid the official Bird Survey Guidelines for assessing ecological impacts states: ‘The default position of these guidelines is that a minimum of six survey visits should be carried out during the breeding season, unless a robust justification can be made as to why fewer or a greater number of visits are required.’No justification was given to why no winter bird or owl surveys were done let alone a robust one.

There is equally no evidence provided to support why they did a breeding bird survey over one day instead of six.The applicant’s report stated that a breeding bird survey was required:

‘The range of habitat onsite provides ample foraging and nesting opportunities. The hedgerows, woodland and scrub are key areas although there is also some potential to support ground-nesting

birds. For this reason, a breeding bird survey will be required.’

Then they admit to only recording one day of results on the 30th June 2020. It’s worth noting that early July is the end of the appropriate season for breeding bird surveys.They then make a claim that there were low numbers bird recorded but fail to point out that they did not meet the time and date requirements for a sufficient breeding bird survey:

‘The bird survey recorded surprisingly low numbers of breeding birds with activity focused on the eastern hedgerow within the established trees. And within the patches of scrub. Species recorded included nesting magpies, chiff chaff, great tits, kestrel, swifts and large flock of approximately 30 gold finches. As there are habitats of value for breeding birds on site, these species are discussed further in section 7 of this report.’

However in section 7 these bird species are never mentioned again as you can see:

‘The breeding bird survey showed relatively low bird activity on site and relatively few species, however, it is clear the scrub and woodland habitats are important for foraging and breeding birds. The retention and enhancement of the grassland/scrub/woodland mosaic will be important in allowing birds to continue to forage and nest on site. It is not considered that any further compensation for breeding birds is required, however, section 8 makes recommendations for mitigation for birds during construction and outlines opportunities for enhancements for breeding birds.’

Section 7 is basically just repeating the same unsubstantiated claims and the species mentioned are never discussed further despite the report claiming they would be. Let’s try section 8 then…

‘it is suggested that a detailed plan for the type and location of the se bat boxes is include within the LEMP or a separate bat and bird box plan. Birds: Any areas of scrub or trees that require removal to enable the development will be undertaken outside of the bird besting season (i.e. avoiding the months March – August inclusive)’.

What is bird besting season? What are ‘the se bat boxes’? Did the applicant not have a proofreader? This is a very poorly written report laden with errors. The decision to add 50 birds boxes has no evidence in the report to back it up and they never specify what species they are mitigating for. It is also concerning they have said:

‘If this cannot be avoided a breeding bird check will be undertaken by an ecologist prior to vegetation removal.’ It is a crime under The Wildlife and Countryside Act 1981 under subsection 1 to ‘take, damage or destroy the nest of any wild bird while that nest is in use or being built. …It is an offence to intentionally disturb a species, listed under Schedule 1 of the Act, which is at, on, or near an active nest site. Those who intend to visit the nest of a species listed under Schedule 1 must first obtain a licence from the relevant statutory nature conservation organisation.’

So in other words if a nest is found Lovell would need a license from Natural England not just a ‘breeding bird check’ by a consultant and they would need to stop working in that area until the nest is no longer in use. They should have mentioned this in the report.

To be fair to the applicant I could not find any legislation relevant to bird 'besting' season so if this is not a typo then I trust the ‘besting’ mitigation requirements have been met.

Sources: Bird Survey & Assessment Steering Group. (2022). Bird Survey Guidelines for assessing ecological impacts, v.0.1.0. https://birdsurveyguidelines.org https://birdsurveyguidelines.org/methods/survey-planning/ https://www.gov.uk/guidance/wild-birds-advice-for-making-planning-decisions#survey-methods Wildlife and Countryside Act 1981 (as amended by the Countryside and Rights of Way Act 2000)

4e. Horses were blamed for the lack of sufficient invertebrates and reptile surveys

exhibit a: The alleged mat-eaters

The applicant has claimed in their limitations section of the ecology report that they could not conduct a proper reptile or invertebrates survey because horses ate their mats. Is this the ecologist’s version of the dog ate my homework?

This was their reasoning:

‘The presence of horse grazing on the site resulted in damage to the grassland which may have resulted in some botanical species being under recorded. The horses also disturbed and damaged some of the reptile mats which was a limitation on this survey. The impacts of the horses from disturbance and grazing also limited the ability to undertake invertebrate surveys.’

Horses are capable of damage to reptile mats but an experienced ecology team would 100% know that and should have fenced off the horses so they couldn’t tamper with the mats. These surveys should have been redone before an application was submitted. Manor Woods Valley Group founder and retired MCIEEM ecologist Peter Loy-Hancocks BSc(Hons) feels their assessment about invertebrates is wrong altogether which is corroborated by the council’s ecologist. Here is his professional opinion:

‘The assessment that “The current management regime of habitats on site was assessed to be sub optimal for invertebrate species” is wrong. It might be sub optimal for some species, but will be optimal for others e.g., dung beetles (on which the larger bat species, including Greater Horseshoe bats, thrive) and those species requiring a short grass sward.’

Sources: https://novershillconsultation.co.uk/wp-content/uploads/2021/07/Novers-Hill-draft-ecological-assessment-with-location-of-badger-sett-redacted.pdf Manor Woods Valley Group Statement

4f. Two of the bat detectors used stopped working for ‘unknown reasons’

In section 3.5.2 of the applicant’s ecology report they mention:

‘Two static detectors (4 and 5) failed to record during the survey period for unknown reasons. It was assessed that the amount of usable data obtained during the active season was sufficient to make a robust assessment of the site for bats, despite the failed recordings.’

As a member of the BS3 bat group I’ve been on many bat surveys and can say with confidence that two detectors failing to work should constitute a redo of the bat survey in order to get an accurate reading. The fact that this wasn't done is very concerning considering the claims of low numbers of horseshoe bats later made.

Sources: https://novershillconsultation.co.uk/wp-content/uploads/2021/07/Novers-Hill-draft-ecological-assessment-with-location-of-badger-sett-redacted.pdf https://www.devonwildlifetrust.org/what-we-doour-projects/devon-greater-horseshoe-bat-project

4g. Otters and water voles were labeled as amphibians

On page 31, section 6.8, the report incorrectly lists otters and water voles under ‘Amphibians’ which either shows a terrible understanding of basic zoology or reveals that whole sections of this report are simply cut and pasted from other text prepared for completely different projects by the consultant.

Sources: https://study.com/academy/lesson/characteristics-of-amphibians-lesson-for-kids.html https://novershillconsultation.co.uk/wp-content/uploads/2021/07/Novers-Hill-draft-ecological-assessment-with-location-of-badger-sett-redacted.pdf

4h. The ‘Redacted’ badger text is readable because it was just highlighted in black

The information about badgers in the ecology report was ‘redacted’ for the supposed safety of the animals. However whoever did the ‘redacting’ just changed the background colour to black so if you copy and paste the text in a new document you can read everything. For example here is the redacted badger information (typos included for accuracy) on page 38 (no details of sett locations were included):

‘No works can take place within 20 metres of the badger setts (see figure 6) without consulting the ecologist; • In advance of works commencing on site, in particular the eradication of the Japanese Knotweed, an artificial badger sett will be constructed in the location shown on figure 9 below; • The sett can only be closed once planning permission has been granted and a license from Natural England is in place; • Sett closure is only permitted during the months of July to November inclusive; • A detailed sett closure method statement will be provided as part of the license application to Natural England; • The sett closure will comprise the use of one way badger exclusion gates to exclude badgers from their existing sett. These will be in place for a period of 21 days or until it can be demonstrated that badgers are no longer using the seta dn evidence that they are using the artificial sett;

• Badgers will be encouraged to the artificial sett with food placed between the existing and artificial sett and food placed in and around the artificial sett’

Source: https://novershillconsultation.co.uk/wp-content/uploads/2021/07/Novers-Hill-draft-ecological-assessment-with-location-of-badger-sett-redacted.pdf

4i. No Environmental Impact Assessment was done

Natural England wrote in the pre-planning documents that their recommendation that an Environmental Impact Assessment (EIA) was not needed was based on the site not having SSSI or AONB status. They said they had no knowledge of the site other than that. It clearly states that they should be contact the local authority again after an ecological survey is done if any protected species were found so they could reevaluate their decision. Here is their exact response:

‘Natural England does not hold information on the location of significant populations of protected species, so is unable to advise whether this proposal is likely to affect protected species to such an extent as to require an Environmental Impact Assessment (EIA). The developer must provide sufficient information for your authority to assess whether protected species are likely to be affected and, if so, whether appropriate avoidance, mitigation, or compensation measures can be put in place. Further information is included in Natural England’s standing advice on protected species.

Furthermore, Natural England does not routinely maintain locally specific data on all environmental assets. This development proposal may have environmental impacts on priority species and/or habitats, local wildlife sites, soils and best and most versatile agricultural land, or on local landscape character that may be sufficient to warrant an EIA. Information on ancient woodland, ancient and veteran trees is set out in Natural England/Forestry Commission standing advice.

We therefore recommend that advice is sought from your ecological, landscape and soils advisers, local record centre, recording society or wildlife body on the local soils, best and most versatile agricultural land, landscape, geodiversity and biodiversity receptors that may be affected by the proposed development before determining whether an EIA is necessary’

As we know eleven bat species were found in the survey including two rare species. All bats are protected species and require a mitigation license. There is no evidence on the planning portal to suggest the local authority were ever given ‘sufficient information’ about the impact of this development on protected species prior to the EIA screening decision. We know that Avon Wildlife Trust were never contacted and there is no evidence to suggest any other local advising organizations were consulted either. This would suggest Bristol City Council issued their decision to waive the EIA prematurely.

Pegasus mention the EIA criteria in their request for screening opinion letter: ‘The relevant ‘Schedule 2 criteria’ provided in the online guidance for Section 10 (b) Urban development projects, including the construction of shopping centres and car parks, sports stadiums, leisure centres and multiplex cinemas, are: (i) The development includes more than 1 hectare of urban development which is not dwellinghouse development; or (ii) the development includes more than 150 dwellings; or (iii) the overall area of the development exceeds 5 hectares.’

Sources: https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=QMZHD4DN00J00 https://www.gov.uk/guidance/protected-species-how-to-review-planning-applications Back to list

5.The Ecology report made unsubstantiated claims. It was also kept from the public until after the consultation meeting was over.

5a. The ecology report claimed finding 11 bat species was ‘not unusual’ for an urban green space

The (CIEEM) states that all claims made in ecology reports need to be supported with substantial evidence provided in the report for easy reference. The applicant’s report alleges that finding 11 out of 17 total UK bat species including the rare greater horseshoe bat is ‘not unusual’ in the area. However no reference or evidence is ever mentioned in the report to substantiate these accusations. Their report states:

‘The presence of eleven species of bat recorded on static detectors is not unusual for this part of Bristol, and the low numbers of lesser and greater horseshoe bats is also not unexpected.’

In order for the applicant to justify these claims they would need to include the following information in their report:

• other development sites in the area with 11 or more species of bat

• the average number of both lesser and greater horseshoe bats in the area for comparison

• the average number of bat species recorded in the area

• a measurable definition of ‘this part of Bristol’

Without those facts there is no way to verify the allegations made. That is unacceptable for a statement of this nature which could influence the decision of this planning application.

Not only are there are no sources listed on the report to support this claim but the consensus among ecologists, including Manor Woods Valley ecologist Peter Loy-Hancocks, is that finding horseshoe bats in an urban green space is quite remarkable and is a significant consideration for any development. His professional advice is:

‘The potential impact on bats, especially on Horseshoe bats, have been largely ignored or down-played in the ecology report. It is noted that there were 28 detections of Lesser Horseshoe bats during the survey; this is not an insignificant number.’

Sources: https://novershillconsultation.co.uk/wp-content/uploads/2021/07/Novers-Hill-draft-ecological-assessment-with-location-of-badger-sett-redacted.pdf https://cieem.net/wp-content/uploads/2019/04/Chartered-Ecologist-Code-of-Professional-Conduct.pdf Manor Woods Valley Group Statement https://www.devonwildlifetrust.org/sites/default/files/2021-01/Greater-Horseshoe-Bat-Planning-Guide.pdf

5b. Important documents were kept from the public until after the consultation was over.

The ecology report was not published until after only public consultation so residents and exerts were given no opportunity to ask questions about any of the essential information on this report. The applicant has also refused to answer any questions regarding the ecology report and declined our request to hold a follow up meeting to discuss it. This lack of transparency is concerning.

Source: https://novershillconsultation.co.uk/

Random, completely unrelated sidenote posted here for no particular reason:

In November 2021 SomersetLive published an article mentioning ‘The ecologist who wrote the Ethos report, Jim Phillips, was found to have breached CIEEM’s Code of Professional Conduct in relation to his assessment’ for a controversial planning application on greenfield land. The article states:

‘Residents have previously raised objections to the ecology report attached to the application, based on the fact that only a portion of the proposed site was surveyed. They noted that part of the site missed in the report is registered under the Somerset Wildlife Trusts as a local wildlife site.

The residents subsequently lodged a complaint with the Chartered Institute of Ecology and Environmental Management (CIEEM) regarding the Ethos Environmental Planning report, which has been upheld.

The ecologist who wrote the Ethos report, Jim Phillips, was found to have breached CIEEM’s Code of Professional Conduct in relation to his assessment for the Kithill planning application.

Sally Hayns, chief executive officer of CIEEM, noted in a statement that Mr Phillips has “acknowledged that some of the information he relied on that was provided by other ecological consultancies was inaccurate”.

She said: “The subsequent report and recommendations did not, on this occasion, meet the standards expected.”’

Figure 1: A Greater Horseshoe Bat's face after reading the comments about him in Ethos's report

This is not a material planning consideration and for legal reasons is unrelated to this application beyond both involving Ethos and Jim Phillips.

Source: https://www.somersetlive.co.uk/news/local-news/call-wildlife-protection-150-home-6224269 Back to list

6. The Golden motion to protect Bristol’s green spaces that was unanimously passed on Sept 7th in full council specifically mentions this site and dictates its removal from the local plan.

On September 7th, 2021, a motion was brought forward to full council from Conservative Councillor Richard Eddy with a friendly amendment from the Green Party. This cross party motion adds protection for Bristol’s green spaces and greenbelt land and specifically mentioned the Western Slopes (aka Novers Hill), the land that the applicant is attempting to build over.

‘The council ought to be prioritising “brownfield” re-use before considering destroying our precious “green belt” and “green-lung” open spaces.Unless the mayor signals a radical change here, unique environmental assets such as Yew Tree Farm - Bristol’s last working farm - and the beautiful Western Slopes could disappear forever under the bulldozer.’

Introducing the Green amendment, Green Councillor for Windmill Hill Ed Plowden said:

‘Everyone in the biodiversity and wildlife profession agrees the single most important thing we can do, first and foremost is to protect and preserve the quality natural spaces we already have. The pace and density of current development means that more than ever we need to protect our existing biodiverse green spaces in the City and in the Green Belt. They cannot be retrofitted.’

The amendment states: ‘Council calls for 1. To call for a halt to the proposed redevelopment of or incursion into any remaining productive wildlife rich agricultural land. Furthermore, 6. To assign or instruct officers to consider adopting the Western Slopes and Brislington Meadows as Local Green Space as provided for within NPPF guidance, providing similar planning protection as for the Green Belt.’

This motion was unanimously passed. By submitting this application Lovell have made it clear they do not respect the will of the Bristol people and it’s elected officials. Approving this application would send the message to residents that voting doesn’t matter since private companies are above democracy. It would be a poor choice and could potentially result in direct action.

Sources: https://democracy.bristol.gov.uk/documents/b28296/Amendment%20Golden%20Motion%20-%20Green%20Group%2007th-Sep-2021%2018.00%20Full%20Council.pdf?T=9 https://www.bristolpost.co.uk/news/bristol-news/yew-tree-farm-call-preserve-5852380 https://bristolgreenparty.org.uk/bristol-green-party-amendment-to-protect-bristols-green-spaces/ Back to list

7.WENP has designated this land as ‘core grassland’ and high biodiversity space which should be

protected from development

West England Nature recovery network labels this site as the best or 'core' areas of grassland. Their map states:

'The brown areas show the ‘core’ areas of grassland. These are areas greater than 0.5ha which are the most species and flower rich areas in the region. The orange areas show the land that supports the core areas and enable species to move from one core area to another, helping make coherent and resilient networks. Why is this ecosystem important?Grassland is particularly important for maintaining pollinator species which are crucial for many food crops.'

Allocation B1114(aka Novers Hill) is both brown and orange on the WENP map. The WENP map also lists Novers Hill as a ‘Multiple Ecosystem Service’:

' Different ecosystem services have been overlaid to show where the land is delivering multiple ecosystem service provision. It shows the areas that contribute to good water quality, areas that are providing natural flood defences and areas that are part of an ecological network. The darker the colour indicates where more services are being provided. Why are these ecosystems important? Areas that are providing multiple services are helping improve the regions overall resilience. The darker areas are the most ecologically important areas that should be protected to ensure they can continue providing multiple services.'

So the map is clearly saying this land needs to be protected because of its importance to nature.

Sources: https://www.wenp.org.uk/nature-recovery-network/ https://wenp.org.uk/maps/ Back to list

8. The whole site is still a Site of Nature Conservation Interest (SNCI) The Local Plan - Site Allocations and Development Management Policy DM19: Development and

Nature Conservation11 states that ‘Development which would have a harmful impact on the nature conservation value of a Site of Nature Conservation Interest will not be permitted’.

The entirety of the Western Slopes/Novers Hill is a SNCI according to the current Bristol Regional Environmental Records Centre (BRERC) maps. This is contested by council officers who instructed the BRERC to remove parts of the Pigeonhouse stream and adjacent meadows SNCI in November 2021. There is no record of the designated procedures for altering an SNCI being performed when the site was allocated in the local plan.

There is proof however that Avon Wildlife Trust, the Environment Agency and the Local Authority’s appointed ecologist all objected to the entire site allocation because of the ecological damage housing would cause to a nationally rare habitat.

In fact the council’s ecologist specifically said the whole allocation meets criteria for an SNCI at the time the local plan was in review:

‘Recommendations on site status and site boundaries:

• The site appears to meet the criteria for an SNCI • A number of boundary extensions were proposed.’

Bristol Tree Forum and Friends of the Western Slopes have published an official complaint about this issue. Their report gives a more through explanation and examination.

This quote from the Planning Inspector from the 2003 appeal document is also relevant. Keep in mind that this application was for half the amount of homes Lovell are proposing on the same site:

‘The field also appears to have some potential for use by mobile species that are known to use the appeal site: for example badgers and a range of birds and invertebrate fauna, including species of particular interest. It is reasonable to view the SNCI as a dynamic whole, parts of which at any one time may be of less intrinsic interest due to prevailing management practices. This should not mean that those parts are unworthy or expendable: they may act as an area of future potential or as a buffer, absorbing pressures that might otherwise have a more damaging effect on the wildlife interest of the SNCI.’

Sources: https://bristoltreeforum.files.wordpress.com/2021/12/complaint-re-change-of-snci-boundary.pdf?fbclid=IwAR0weN9rHuo425xGdmt0_N6mLbgjRQwF5w5wgRLdlIf1hotIGqPZ_9h7QOs https://maps.bristol.gov.uk/pinpoint/ https://maps.bristol.gov.uk/arcgis/rest/services/ext/datagov/FeatureServer//206 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/69600/p%20b13824-nia-criteria.pdf https://maps.bristol.gov.uk/policies/ https://pa.bristol.gov.uk/online-applications/applicationDetails.do?previousCaseType=Property&keyVal=0202388P&previousCaseNumber=I92D3GDNFA000&previousCaseUprn=000000299793&activeTab=summary&previousKeyVal=I92D3RDNFA000 https://www.facebook.com/groups/2560966744207814/permalink/2628124497492038 Back to list

Local Policy Constraints 9. Novers common has Town & Village Green status which would require deregulation for the access roads

Novers common is one of only 28 Town and Village Greens (TVG) in Bristol. To put that in perspective Bristol has 35 wards. TVGs are designated as such in order to protect them from

development so an application to deregulate would only be granted in exceptional circumstances. Lovell do not have the exceptional circumstances or the acceptable replacement space to warrant an acceptable deregulation of TVG status. An ecologically barren turf in the middle of a housing development is no replacement for an ancient hedgerow which holds over 2,000 species and serves as an essential wildlife corridor. The numbers don’t even add up and Lovell are offering less space than they are taking away. Most importantly though, Lovell have not applied for the deregulation of TVG status yet but they plan to start building before the TVG application is decided. What happens if they start building and the application is refused? This is a very likely scenario considering the amount and type of land they are offering in return is inadequate and central government have recently announced a preference for brownfield development. This means the land will be bulldozed, killing essential invertebrates and damaging the ecosystem for absolutely no housing gain. We will be left with an unusable wasteland and there is no doubt Lovell will use this threat to add considerable weight to their deregulation application to the Secretary of State.

Source: https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=QZSL00DN0DG00 https://www.bristol.gov.uk/planning-and-building-regulations/town-and-village-greens https://www.bristol.gov.uk/documents/20182/0/Novers+Common.+Village+Green+Register.+VG7 https://www.oss.org.uk/what-do-we-fight-for/village-greens/ Back to list

10. The allocation in the local plan for BSA1114 is for 50 houses and this application exceeds that by 50%

Lovell are attempting to fit 50% more housing than the amount designated in the local plan for the BSA1114 allocation. The report by Pegasus states:

'While the target yield of 50 dwellings is more than met within the proposal, this must be considered in the context of the extensive escalation in housing need.'

If we are going to allow updates in the local plan targets based on changes since the plan was adopted in 2014 then the council is equally free to apply that same logic to remove sites that are contrary to the climate and ecological emergency policies. Bristol City Council is either strictly bound by the local plan or they are not, you can’t have it both ways.

Source: https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=QZSL00DN0DG00 Back to list

11. Previous planning decisions spanning at least 60 years have all refused development on this site including appeals.

Planning permission has been sought for this exact site many times before. It’s unsettling that Pegasus mention in their pre-application document that there is no planning history on this site because there have been at least six applications submitted and refused over the past 60 years. In the main application they only mention the details of the most recent refusal in 2002/2003. The references for the applications we know of that are not listed by Pegasus are: 65/00769/P_U 75/03278/P_S

81/01337/P_S 02/02388/P 00/02464/P/S

These applications were all refused for reasons that are all still relevant today. The fact that this land is allocated in the local plan does not override those material planning considerations which were legitimate reasons for refusal. It is worth noting the most recent application also lost its appeal proving that it isn’t just politics, the independent planning inspector agreed that the council had valid grounds for refusal. Previous planning decisions are a material planning consideration as they establish a precedent of refusal which would take a serious change to overcome. Lovell has failed to provide this change in circumstances so the precedent for refusal should be upheld.

Here is the pre-application mention from Pegasus where they claimed there was no planning history:

Source: https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=QMZHD4DN00J00 Back to list

12.City Design Group Objection

The City Design Group objected to the application in November 2021. They mentioned they ‘raised a range of concerns in relation to the previous pre-planning application most of which still apply to the current scheme…The scheme as it is currently presented as it is contrary to DM26, DM27, DM28, DM29, and key objectives found in the Urban Living SPD.’

Their full objection comments can be found on the planning application documents page on the Bristol City Council planning portal

Source: https://pa.bristol.gov.uk/online-applications/files/D645DBE3AF5868552318CC33F0405372/21_05164_F-

COMMENTS_FROM_URBAN_DESIGN_TEAM-3079549.docx https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=QZSL00DN0DG00 Back to list

13.This land is ‘prominent green hillside’ so can’t be altered

Policy DM17 Development Involving Existing Green Infrastructure states:

'Whilst the Site Allocations Policy was introduced after the publication of the NPPF (2012), the Site Allocations Policy DM17 added further definition to Policy BCS9 and details the approach for its application in Development Management. With regards to Open Space, Policy DM17 identified Important Open Space which mandates that ‘development on part, or all, of an Important Open Space as designated on the Policies Map will not be permitted.’

The objection report from Bristol Tree Forum goes into this further so I recommend reading it. https://bristoltreeforum.files.wordpress.com/2021/10/novers-hill-development-btf-comments.pdf

and this document gives a physical representation which shows the inaccuracies of Lovell's attempt to refute the DM17 violation.

Others Sources: https://www.bristol.gov.uk/documents/20182/34536/Local+Plan+Review+-+New+protection+for+open+space+-+Web.pdf/6b443275-293f-e56e-7009-764c4122fc59 Back to list

Health and Safety 14. Surface water and drainage is a serious concern

Drainage is listed under the constraints section of this application for a good reason. Slopes are an important part of flood management since the water is absorbed through the soil which also filters out the pollution. If Lovell succeed in their pursuits to concrete over this slopped land it will cause irreparable damage to the aquifer which will lead to water quality problems, poor drainage and increased flood risk. These slopes need to remain green if we don’t want our water brown.

The council’s Principal Flood Risk Officer had the following concerns about the drainage:

1. ‘The drainage strategy shows the surface water system to be adopted by Wessex Water. Confirmation is required that they will also adopt the proposed basin and underlying storm water storage crates. We can’t have a public sewer discharging to a privately maintained basin / tank that itself then drains back in to the public sewer

2. Feasibility of the basin / crates arrangement. It’s difficult to see from drawing 101-2 Drainage Strategy Sheet 2 how the arrangement will work. Section drawings are needed to show levels of the basin and underlying crates, and their relationship to existing and proposed ground levels and invert levels at S21 and S21a

3. The proposals are based on an end of pipe SuDS solution. Source control and other upstream measures should also be incorporated, which should help reduce the volume of water to be stored

4. A land drain is proposed but no commentary around this is provided in the supporting drainage strategy document, this needs explanation’

Sources: https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=constraints&keyVal=QZSL00DN0DG00 https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=QZSL00DN0DG00 Back to list

15. Transport Development Management objection

City Transport Development Management submitted an application response in December 2021. Their initial holding response is an objection. No update to this has been made public so the objection hold.

The local authority’s transport development manager felt the proposed walking and cycling enhancements on Novers Hill was ‘unacceptable’ for safety reasons and mentioned a similar housing application was rejected for this. This is the exact quote: ‘A similar proposed width on a housing site nearby was rejected by planning committee in favour of meeting TDM’s requirement for safe and attractive cycling facilities that segregate pedestrians from cyclists, with both of these groups segregated from vehicular traffic.

Proposing that pedestrians share a carriageway with vehicular traffic (as now) is wholly unacceptable on Novers Hill regardless of any other interventions. This is further compromised by suggesting this is also shared by cyclists. If the carriageway is to be narrowed to support a one-way order and enhance safety, this should be done so physically. Painted surfaces have very little impact on driver behviour and one of the primary reasons why LTN 1/20 was devised, precisely to prevent designs such as this.’

I also felt this comment from was particularly interesting since it shows an example where the applicant has provided ‘wholly misleading’ information:

‘Accessiblity of Site

• The reference in the TA (parag 5.19) to walkable neighbourhoods quotes Manual for Streets’ definition as being “a range of facilities within 10 minutes (up to about 800m) walking distance”. As confirmed in Tabe 5.1, and with the exception of a primary school, the adjacent trading estates and a health centre, nothing else lies within this distance.

• The TA Table 5.1 subsequently attempts to argue this to be acceptable by using the National Travel Survey (NTS) average trip distances to facilities throughout the UK as a yardstick and therefore setting the bar unacceptably low. The NTS calculations will include considerably remote locations, which culminates in average distances of 5km to schools, 8km to healthcare facilities, 6km to retail and 14.7km for commuting. Table 5.1 is therefore wholly misleading as a determinant of accessible development in an urban area.’

Source: https://pa.bristol.gov.uk/online-applications/files/861D2C18FE9878F25235CC84E28F495F/pdf/21_05164_F-TDM_HOLDING_RESPONSE-3123500.pdf

Back to list

16. This site is meters away from the air management zone and would increase the already toxic levels of Air pollution.

Five people die a week from the air pollution levels in Bristol resulting in £170,000,000 in costs to the NHS a year. This study was done in 2019, after the western slopes were allocated for housing in the local plan in 2014. The western slopes are merely 180 meters from the current air quality management boundary.

The mayor was even quoted on the issue saying: ‘We have a moral, ecological and legal duty to clean up the air we breathe. This research emphasizes how vital it is that we act quickly to improve health and save lives in Bristol.’

Did you know the greatest contributor to the toxic level of emissions is personal cars? I’ve done a rough estimation and if just 150 of the 157 planned homes owned a car that would add 690 metric tons of CO2 to the area a year. This is all in addition to removing one of the last spaces we have in South Bristol that actually filters this deadly pollution. No housing shortage no matter how severe is worth people dying over.

Sources: https://www.theguardian.com/environment/2019/nov/18/air-pollution-kills-bristol-health https://www.theguardian.com/world/2020/sep/26/escape-country-covid-exodus-britain-cities-pandemic-urban-green-space https://airqualitynews.wpengine.com/2019/12/03/green-spaces-can-prevent-premature-death/ Back to list

Sound

17. Alternative ventilation has to be used for the affordable flats because they are being used as a sound barrier for the market rate housing.

Because the sound levels were too high Lovell was required to provide mitigation for this excess in noise. I consulted a top acoustical engineer, George Spano, and his professional opinion is that the bare minimum solution would be to build a sound wall to manage the surplus noise. Instead of doing this Lovell have used the flat buildings which are mostly comprised of the social rent units, as a sound barrier for the rest of the development. I don’t need to explain further why this is distressing and poor practice.

City design has objected to this as well:

‘The flats in the north west corner of the side are subject to high noise levels…The recommendation for all habitable rooms to be positioned on the opposite side of the buildings has not been followed.’

Sources: https://www.bristolpost.co.uk/news/bristol-news/anger-social-housing-described-noise-5761189 https://pa.bristol.gov.uk/online-applications/files/D645DBE3AF5868552318CC33F0405372/21_05164_F-COMMENTS_FROM_URBAN_DESIGN_TEAM-3079549.docx https://pa.bristol.gov.uk/online-

applications/applicationDetails.do?activeTab=documents&keyVal=QMZHD4DN00J00 Back to list

18. The sound survey which found noise levels to be higher than allowed was done in during peak lockdown and before the recycling centre was built

The applicant’s sound report shows mitigation for excessive sound levels are required. Despite claiming otherwise during the public consultation on zoom, the applicant has conducted their sound survey in June 2020 which was the height of lockdown. Traffic levels would have been lower than any other time in history due to lockdown measures being implemented to prevent spread of the COVID-19 virus. This means the sound readings on the report do not reflect the actual levels of noise from the traffic on Hartcliffe Way and the noise from the nearby industrial estates.

Sources: https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=QZSL00DN0DG00 Back to list

Other Concerns (Which aren't material considerations but worth noting)

19. There are several instances of Incorrect information in the applicant’s planning documents.

19a. The imaginary pub

On the original consultation website Lovell claimed the extra people their development would add would bring an increase of money to nearby pubs and shops and create 10 new jobs. As anyone who lives in Knowle West knows there are no pubs in the area and very few shops are within walking distance of Novers Hill (this is mentioned in the transport objection above). Its disconcerting that Lovell would make a claim like this without checking the area first. Where did they get the 130 jobs number from? How can you create a job at a pub that doesn’t exist?

They have since taken this down from their consultation page but luckily it still survives in screenshots and is mentioned in the press:

Sources: https://www.bristol247.com/news-and-features/features/residents-hit-out-at-plans-for-157-homes-on-south-bristol-fields/ https://twitter.com/DanicaPriest/status/1414696355075956738?s=20

19b. Too much trust in Google Maps

In the community engagement document they tried to remedy the imaginary pub mishap by saying there is a Spar 10 minutes walk away from the development site. It’s true that if you look on google maps this is the case but that is actually outdated and there hasn't been a Spar there for years. It's a Londis now. They have managed to cover their mistake with another mistake.

Source: https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=QZSL00DN0DG00 Back to list

20. The site has viability issues that may lead to the applicant backing out of their affordable housing obligation.

Lovell have mentioned many times that their original plan was for 188 homes but they were forced by the council to scale back to 157 due to height requirements. They use this as the reason why they can’t reduce the number of housing claiming they are already stretched to their limit financially. This is worrying because developers have a history of using viability as an excuse to get out of their affordable housing requirements. Here is an example where Lovell has done this in the past when the affordable requirement was far less than 30%: https://www.shropshirestar.com/news/property/2017/10/30/work-on-telford-development-currently-unviable-says-developer/

Back to list

Conclusion

For too long developers have used the housing crisis to expand their profits at the expense of people and the climate. You just have to look at the cladding scandal and our ecological emergency to see proof of that. It’s time we stopped treating developers like charities and held them to the same ethical and legal standards we hold other companies. No one is above the rules so we shouldn’t be giving special treatment to Lovell and Mr. Patch. Planning policy should apply to them in the same way it does for everyone else.

Thank you for reading this far I really appreciate it. If you have any questions or want to discuss anything here further feel free to email me DanicaMayPriest@hotmail.co.uk

Local Plan Housing Delivery Test 30% Affordable Housing

1. nationally rare habitat/wildlife corridor 2. 46% biodiversity loss 3. ancient hedgerow wildlife corridor 4. Species surveys are insufficient 5. ecology report is full of errors 6. green spaces motion 7. WENP designation 8. SNCI 9. Town & Village Green 10. BSA1114 is for 50 houses 11. Previous planning decisions 12. City Design objected 13. ‘prominent green hillside’ 14. Surface water and drainage 15. Transport objected 16. Air pollution 17. Alternative ventilation for the

affordable flats 18. The sound survey

Refuse Approve

The ‘Titled Balance’ of this application

Terrible place to position more homes, there isn't alot of green space for us localresidents to walk anymore and view, with the expansion of the retail parks (Hengrove area ) Ithought the old airport would be more appropriate with excellent transport links to the centre andshopping areas, motorways the roads around novers Hill and the area in general are alreadyovercrowded with housing, I understand its a business and the BS4 postcode is more attractive forprofitable reasons but it really will have a negitive impact to our area, Thanks Dave

I'm writing about the late inclusion of mocked up views of what the development on Novers Hill may look like for application 21/05164/F. The views selected are not representative of the scale of the green hillside. They are from low down on Manor Park, over in Headley Park and on Hartcliffe Way. A much more representative view of the scale of the prominent green hillside would be from Bedminster Down, Ilchester Crescent, Brooklyn Road, Lewis Road etc. The photos are taken in high summer when leaf cover is greatest. It looks very different now in winter with bare branches. The new recycling centre on Hartcliffe Way is now further on in construction. Buildings are newly created and a large amount of trees removed for vehicle access. Some of the trees will be replanted but it will be many years before they cover the view of the recycling centre buildings. None of the images seems to include both of the proposed estates. The northern most estate nearest to the Parson Street end is not included. This feels misleading and very unhelpful. The prominent green hillside that is Novers Hill breaks up the large industrial units on Hartcliffe Way and the housing on Novers hill (the road).

Hartcliffe Way, large areas of trees removed and new buildings now in place.

Northern estate not shown (very misleading and inaccurate), trees now removed and new recycling centre buildings visible.

Recycling centre buildings and missing trees not shown, northern estate not shown. A view from Ilchester Crescent would look more directly into the northern estate and the prominent green hillside.

Please can you seek more recent photos that reflect the changes to the recycling centre and trees not in leaf. And seek a view from Ilchester Crescent that actually includes the whole proposed

development, not just one part of it. Many thanks Tony Pitt

These green spaces have been a life saver for so many, we need to respect and protectthese amazing spaces.

Hello Council and Developers

I strongly object to this wild land being developed for housing or any other use.We need wild corridors of land for insects and pollinators to live and recover after decades ofdeclineThe Council have declared quite sensibly an ecological emergency. The Council need to stand bythat declaration and the initiatives they pledged including green field wild sites .The Bristol Council will have no positive reputation and the elctorate will have no trust in them ofthey go back on thisThere are 1000s of brown site areas in the city including unused Council properties which can beconverted to social housing which is affordable.None of the development will be affordable for the majority of those needing socia;l housing.Please see sense and abandon this development and instead redevelop the grotty brownsitesespecially along the Feeder Road areaThank you and God Bless

I object to this development. I object for a number of reasons, predominantly the impacton the local wildlife and environment. I understand the need to build new housing, however it is soimportant to protect our local environment for our children and future generations.More and more green spaces in South Bristol are being earmarked for development.Please can you consider the impact on wildlife, the environment and our children enjoying thesegreen spaces.Also in South Bristol, we have huge problems accessing services, such as GP surgeries. Are newGP surgeries going to be put in place for all of these new developments? We cannot even getappointments and wait for 1 to 2 yours on the phone to get through to someone at the surgery.

I done the to the proposal on the grounds of it causing significant irreversible damage tolocal ecosystem by destroying ancient hedgerows and tree systems. The need for 'market rate'houses isn't a good enough reason to destroy our ecological heritage for the profit of the few.

We need to build on existing build on land.

The proposals to build on green areas such as the western slopes grossly contradictsthe mayor's messages on protecting the environment. Previous pledges on 'affordable housing'have been utterly deceiptful.

If Bristol is serious about attempting to be carbon neutral then stop allowing buildings onour rich green meadows and build on derelict sites instead

In this age of climate change it is more important than ever to leave areas of greenspace for wildlife to flourish and for people to enjoy.

I object to a builder who doesn't come from Bristol developing more buildings on theGreen space we have at Novers Hill, there is so much undeveloped city space that could be usedfor development, and I suspect a small percentage of this development will be affordable housingproject property, we dont need further development in that area of Bristol where the roads are notable to deal with such a large development programme.

It's disgraceful to build on green virgin land. There isn't enough facilities/services for thecurrent population.

It would be a real shame for the community to lose this green area

I object to building on the Western Slopes and the Knowle West Health Park on thegrounds of the additional numbers of cars increasing pollution in areas where traffic polution isalready above a safe limit; lack of facilities for an increased population; the fact that greenfieldsites are being used once more in an area where we have lost a large amount of open spacerequired for wildlife and for human relaxation.

1) To be as Carbon neutral as possible as a city we should conserve as many trees aspossible...lungs of the earth2) we need to build good quality social housing on brownfield sites3) South Bristol has had numerous green swathes of land already repurposed away from nature tohousing. South Bristol, still a very needy area, does not need it's future children to be starved ofgreen space.4) please do your homework. Look at the history of the area regarding flooding etc. This is not landto build on.

Maintaining the wildlife corridor is more important!

Climate emergency and mental health dictate that this should be rejected. Explorehousing options on empty High Street shops and brown sites..

The area should be left as a habitat for the local wild life as these type of places arebecoming less and less. There is to much building of new houses in South Bristol and it needs tobe reduced

If this project goes ahead all the numerous people who have objected to it will lose hopeand faith that the green lungs of Bristol can be saved, in spite of the Council's declaration of anEcological Emergency. We need to prioritise the protection of our natural resources and not buildon them. This is an area which is clearly loved by local residents, important for nature, fresh air,exercise, and mental health and its loss would have severe impacts on the local environment,including the human residents. It is clear that the mitigation proposals are inadequate and illthought out. In the face of the crises we face which threaten everyone on Earth it is our naturalhabitat which has to be prioritised. Please, please, please reject this proposal and protect thisland.

No point in writing what I object to as you won't read it anyway. So keep it simple ... IOBJECT...Many houses are being built in this area. More pressure for schools, Doctor surgeries. I wantsome wildlife in my life. I want some trees and grass in my life . I OBJECT.

I live locally and am very concerned about the environmental impact of a developmenton this valuable green space.

I live locally and am very concerned about the environmental impact of a developmenton this valuable green space.

I object to 157 homes to be built on this site for many reasons, including the destructionof habitat of wildlife and plants. Just because a green space is not currently easily accessible tothe public that does not detract from its value as a greenspace - as a green lung separatingharcliffe way and knowle reducing air pollution, as a greenspace creating a visual separation ofbuilt areas, visible from across the city. Simply being able to see a green space in a sea ofbuildings has a positive effect on mental health.The proposal to make Novers Hill one way ( regardless of direction) would be a disaster. It is awell used access road for the people of knowle to go to town via bedminster and from town toknowle, hartcliffe, Whitchurch, imperial park shopping centre etc. It is used as a shortcut instead ofgoing via hartcliffe way, which is already a heavy traffic route. The addition of cars from 157 newhomes plus one direction of traffic diverted from Novers Hill will make Hartcliffe Way moregridlocked than it already gets. People already want to avoid hartcliffe way. Making a section ofNovers Hill one way will drive traffic through Knowle instead, Redcatch Road, Wedmore Vale etcwill become the new 'shortcut' leading to increased traffic through knowle, a residential area.Please do not allow 157 homes to be built with no improved infrastructure to cope with the peopleand traffic. The new recycling centre on Harcliffe way will already lead to increased traffic. It isunrealistic to think that everyone will use the propsed cycle lane on Novers Hill instead of drivingtheir cars. Please do not allow the natural habitats to be destroyed and allow another band ofgreen land to dissappear. Please encourage building on brownfield sites instead.

As someone who recently moved away from the area but whose parents still live onNovers Lane, I oppose this application. Too many of our green spaces and wildlife havens arebeen taken for the sake of homes, let alone homes which the local people cannot afford to buy butinstead being constructed to further line the pockets of the rich whilst being rented to those lessfortunate. There are already homes recently built on Hengrove Way with more currently beingerected on Airport Road.I know from my own experiences of the wildlife in this area which will be destroyed; hedgehogs,foxes, rabbits, squirrels, birds etc, not to mention insects. With COP26 currently ongoing and theneed for more trees and fauna, I feel taking away what we already lack, especially in cities is notthe correct thing to do. Let us think of our planet and not our pockets.

I grew up around knowle and the slops are good for you're mental health if you need toget out and go for a walk, plus the wildlife you get up the slops are amazing to see ..!!

I think it's an absolute disgrace building on this land. Far too much has been taken awayfrom us for housing.

The land is an important green space for nature in the city. The council has agreed thatwe should not be building on green field sites. Green spaces are key to having a pleasant city.Bristol should be leading the charge for better nature and climate awareness. This building projectsends the wrong message.

There are many reasons why consent should not be granted to this development.

The Western slopes is a vital Wildlife corridor (as noted by Avon Wildlife Trust in their report.

https://www.avonwildlifetrust.org.uk/news/support-bristols-green-spaces

We need to protect our wild spaces. As stated in the report:

"Avon Wildlife Trust recognises Bristol's Western Slopes as a vital wildlife corridor, and stands withthose people calling it to be protected from development. This area, located on the slopesbetween Novers Hill and Hartcliffe Way, is a particularly important habitat for a wide variety ofbirds, mammals and rare wildflowers. We recognise that there is considerable concern from localresidents that it may be vulnerable to development, and we echo their calls for it to be protected."

Nature matters. It matters for the climate crisis, for the well being of the citizens of Bristol and forthe legacy that we impart to our children and our children's children.

The ecological survey carried out by Ethos Environmental Planning shows that the slopes arehome to wildlife including badgers and many species of bats, including rare horseshoe bats.

https://novershillconsultation.co.uk/wp-content/uploads/2021/07/Novers-Hill-draft-ecological-assessment-with-location-of-badger-sett-redacted.pdf

Bristol City Council needs to work on a joined up strategy for development that strengthens theCouncil's net zero commitment and declaration of a climate emergency. Of course development isrequired. But Bristol has a lot of Brownfield sites that are available for development but are lyingunused. As long as planning consent continues to be provided for Greenfield sites, developers willalways dispute the financial viability of Brownfield development. But if Councils and governmentup and down the country starts to take a stand against the degradation of our green spaces, it willforce the developers to change their approach. But it is vital that local government commits to astrategy of protecting green spaces.

Local residents really care about this space. I remember the first time I really saw the WesternSlopes, when I was exploring Manor Valley Park for the first time and looked across to see horsesgrazing on open grasslands. The value of this is huge.

I would urge the council to consider the profound implications of granting planning permission onNovers Hill. This is bigger than one piece of development. Every time a green space is lost itsends a message that such natural amenities are not valued by our leaders and those in power.That message is amplified and the inevitable consequence is the loss of more of the naturalhabitats that improve all of our lives.

Bristol is one of the best cities in the world. I was brought up here and returned in my early 20sbecause Bristol is a beautiful place to live. The green spaces of the city are one of the vitalcomponents of that.

We also mustn't kid ourselves that developer managed wild spaces are any such thing. Oncedevelopment occurs on a wild space, biodiversity is always lost. It is tokenism and greenwashwhen a developer claims that their actions will not cause fundamental and far-reaching harm. Youcan not develop a site without this occurring.

Please do your bit for preserving this beautiful and immensely valuable natural resource for thecitizens of Bristol, today, tomorrow and long into the future. Go and visit for yourself. Stroll acrossthe fields. Spend spend time watching the bird of prey that hunt over the grasslands. Observe thebadgers at dusk. Just spend half an hour watching the bats as the sun goes down. Then you canstart to really appreciate the value of this space.

I am not anti-development full-stop. I recognise the need for housing. But this needs to support thefuture sustainability of the city not forever take away forever the natural green spaces that helpmake Bristol the great city it is.

Thank you for your consideration and I really, really hope that the council will make the rightdecision on this and refuse the planning application for Novers Hill and in doing so send a clearmessage to local residents, developers and the wider world that Bristol values the natural world,recognises the vital part it plays in everybody's lives and will ensure its preservation for future

generations.

Wildlife:In declaring a climate and ecological emergency, the city council has a goal of 30% of land to bemanaged for the benefit of wildlife. Permitting development on this or any greenfield site wouldreduce the amount of green space in the city, reduce the amount of land available to wildlife, andreduce biodiversity.

In addition, this is an ecologically important area; it has been deemed a vital wildlife corridor byAvon Wildlife Trust, with a rich habitat that's important for many species including rare and legallyprotected horseshoe bats and a large clan of badgers.

Other:I also have concerns regarding:- the resultant increase in traffic, air pollution, and noise,- the low proportion of affordable housing in a development in a deprived, low income area of thecity,- the way the affordable housing is placed in inferior positions on the site and used to screen themore expensive housing (discrimination),- building more housing in a deprived area and not instead focussing on improving the area andamenities for the people that already live there,- and the high costs of the housing.

No to losing our green belt!

I often pass by this pretty area on our way out of Bristol, and am shocked at what will bethe destruction of this important area for both wildlife and local residents. What will happen tocreatures such as badgers which do not take well to being forcibly relocated ?The benefit of such green spaces on human mental and physical health needs to be considered,as well as the ecological emergency. Only a small minority of proposed dwellings are 'affordable'.and even less are social housing. It is social housing which is needed to bring down social housingwaiting list, so proposal will have little social benefit.

We need green space in a big city like Bristol. Filling every inch of a city with peoplecondensing them in adds to pollution increased pressure on services. Where is the balance. Weneed to keep green space to keep nature and wildlife more in balance as green spaces effectmental health. Green space is scientifically proven to improve health - car fumes and masspopulation doesn't. There is no more room in Bristol we have to spread out not ruin what we have!

I object

We object to the construction of 157 new homes on an established wildlife corridor onour doorstep. We regular have foxes, owls and songbirds in the garden and would be such ashame for them to lose their habitat.

Any new residents would be car dependent as the public transport links in the area are notsuitable or accessible. Our child has suffered from asthma since an early age and has beenhospitalised multiple times. By replacing the expansive green space with more homes andincreased traffic would be detrimental to his health. The dust generated by the construction workwould also be of concern.

I cycle daily on Novers Hill, often with my son onboard, which has no form of traffic calming and isincreasingly dangerous due to vehicles speeding. The road is also in a very poor state of repair.An increase in traffic for construction workers and HGV deliveries would make it completelyunsuitable to cycle.

There are a number of brownfield sites across the city which would be far better suited to thisscale of development.

Dear Sir or Madam,

I would like to strongly object to the proposed development of Novers hill application number21/05164/F.

Green spaces are crucial for maintaining people's mental health not to mention biodiversity.Therefore, developing green spaces such as Novers hill will be detrimental both to mine and myneighbours health and Bristols ecology.

Please consider developing brown field sites instead of this beautiful green urban gem.

Yours sincerely,

Katy M

I am horrified by the proposal to build houses on this green area. Surely we, as a city,should be protecting green areas as nature reserves for the benefit and well -being of not only thislocal community but the future generation as well. I can't see any benefit to this proposal and injectwhole heartedly. It is a short sighted plan and will not address the housing crisis as claimed. It willonly diminish the quality of life for those living in the area, and set a precedent for futuredevelopment on green field sites.

Bristol City Council need to stop building on green space and use the brownfield sites.There is a a lot of wildlife and trees on this site that help filtering the air.

To have free, woodland areas for local people to use need to be cherished not built in.

I would like to object to this built as this is a beautiful area that should not be built on.Use brownfield sites not green areas, that need to be protected in central Bristol. Yes we do needmore housing but this is not the way to go about it.

Bristol City Council passed a motion on September 7th 2021 to protect our greenspaces and prioritise brownfield sites. Since then, PM Boris Johnson used his 2021 ConservativeParty Conference speech to announce intentions for what appears to amount to a brownfield firstpolicy. While both motions and speeches have yet to become formalised, the council could besetting an example and acting knowing they are coming - protecting this green space.

Our local plan in Bristol is currently under review. We should wait until that review process iscomplete, and national policy has been updated before approving any planning permissions onsuch precious spaces. Until then we should prioritise brownfield sites, Bristol's current list containsnearly 250 such sites.

Bristol city council has previously declared a climate and ecological emergency and adopted a onecity plan - both of which should lead to less building on green spaces. Green space soaks upcarbon and water, provides space for nature and enhances the quality of life for Bristol residents.This site is an important local amenity for many reasons and should be protected.

As well as being one of Bristol's green spaces. This area:- Is a site of nature conservation interest (SNCI).- Is a prominent green hillside (DM17).- Contains a town and village green, which itself contains an ancient hedgerow (HedgerowRegulations 1997) - both of which are protected and would be affected by this development.- Has many mature trees, which should be protected rather than cut down.

It seems that the proposed site can only deliver a biodiversity net gain, if another council-ownedsite (Crox Bottom) is "enhanced". Many would argue Crox Bottom is already in a good state anddoes not need enhancement. It is also already an SNCI. An alternative point of view is BCCshould manage its existing site (Crox Bottom) better, if necessary, without the need to build 157homes on a nearby green space.

Moreover, the biodiversity net gain calculations seem to have been made using the outdatedversion 2.0, not 3.0. The application was submitted in October this year, and yet 3.0 was launchedin early July.

It is unclear how suitable it is to build new housing so close to nearby established and new localindustry sites. If these sites will be noisy to the new residents and will prevent them from openingtheir windows or enjoying their outside spaces, is it sensible to grant permission for this housingdevelopment? In the pre-application, the developers seemed to be suggesting that they weregoing to use the social housing on the site as a "noise buffer" for the privately-owned housing.This received coverage in the local press (https://www.bristolpost.co.uk/news/bristol-news/anger-social-housing-described-noise-5761189). It seems important that the council ensure that peopleshomes are not used in this manner, and that sound level disturbance is minimised for any and allpotential residents while at the same time ensuring all residents are able to open the windows oftheir accommodation without being unreasonably disturbed by noise.

The ecological surveying and reporting carried out by the applicants appears to be inadequate atthis time. It is, as yet, unclear the extent of and what will happen to the protected and otherspecies found on this site, including the bats.

The development seems to considerably exceed the amount of housing allocated for it in the localplan (BSA114 - July 2014). The estimated number of homes for the site was 50 - with the listingdocumenting the city-wide importance of the site for nature conservation. There must be a concernthat increasing the number of dwellings on the site to 157 will damage the lands natureconservation value.

At the same time, the number of affordable homes that are being proposed is disappointingly bareminimum. Other sites in South Bristol are showing how development can contain up to 100%affordable homes. The council could be demanding and enforcing more from the developers.

The development will likely add to pressure and demand on local amenities, including alreadyover-subscribed primary schools.

For all of the above reasons I object to the proposal.

The land is an important wildlife corridor which connects many open sites from the outercity through to the inner city sites and would compromise colonies of species therein.The land in question is at the end of an escarpment which has proved to be unstable and subjectto movement in wet and dry weather patterns.The site holds water, breaking into it will cause problems with flooding and drainage.Any development in the area should not be allowed to damage or compromise the Common Landadjacent, or the ancient protected hedgerow. As an historically undisturbed site any archaeology isunknown.Fresh Air - development of the site will block the airflow of the prevailing westerlys bringing freshair into city areas.Many trees will be felled, replanting with saplings will not mitigate the removal of mature trees andshrubs for many years thereby a negative carbon exchange.As this land has been regularly grazed the site has a unique eco culture and types of wild animals,bats in particular, dependant on it will diminish or disappear.Highway safety - the proposed layout will present hazards for the proposed usage of cycles andscooters.Climate Change - this proposal goes against the Mayors statements on climate change and theenvironment.Units already under planning in Bristol - there are many units in planning on brownfield sitesacross the city the numbers meeting the required quota without using up greenfield sites.Previous planning applications for this area have been rejected in the past.

I absolutely object to this development. This is a very important untouched area forwildlife and more. Bristol is always claiming to be a council that wants to protect green spaces andprides itself on wanting to be a green city. This development and others go completely against thatand contradict everything ever claimed. If this development goes ahead I will for sure be movingme and my family from the area and probably even Bristol. For this to even have been consideredI feel council planners of Bristol need to take a good hard look at themselves and really considerwhat they want for this city.

Not happy with this application, save our conservation area!!

The roads are not safe for housing dye to traffic and we really don't need housing there

I strongly object to these plans for multiple reasons:

- the infrastructure to support current residents, for South Bristol, is already over stretched &building more houses will make this even worse. I have a tough job getting a prompt doctorsappointment as it is. Where are the plans to build more schools, doctor surgeries, dentists etc?

- building on the land will result in a net loss of habitat to many species, including protectedhorseshoe bat's & badgers

- it will not create enough social housing

- it goes against a recently council passed motion to protect our green spaces

I object for climate change reasons, this will cause more carbon, pollution and traffic.If the council really are green they should be stopping all house building in Bristol, it's becoming aconcrete jungle with no open spaces for nature

I object to this land being built on as I believe its is of great importance to the wildlife inthe area. I often see kestrels and buzzards hovering over this area. We are losing so much todevelopment in bristol when there are plenty of areas that could be developed that would havelittle impact on wildlife.

I am objecting in the strongest terms on environmental grounds. This area is anenvironmental haven for plants, wildlife and people. It forms part of a wider network of greenspaces. Bristol city council has declared an ecological emergency. If ever there was a test of thispolicy it's this planning application. Housing should be built on brownfield sites.

Development should not be allowed on this important natural site in Bristol. Loss ofgreen space in this area should be considered regarding its impact on the environment.

No do not allow what us left of our green space to be taken up by more houses whichwill lead to more cars and pollution in an over populated area already.

I strongly object to these houses being built for various reasons. The first is the lose ofgreen space in a historically deprived area of Bristol. Many people here do not have the luxury ofgetting in a car for day trips and to have a huge green space built upon would impact localresidents. The is also a huge range of animals that have made the Weston Slopes their home,animals don't tend to do so well when they only have a wildlife corridor to live in instead of a hugespace. Being in a slope will make the built more difficult and longer and I'm not sure residents willwant to be so close to the new waste incinerator currently being built on the Hartcliffe Way.As a resident of Novers Hill I will live directly opposite the new development, which may take upsome of the natural light that we currently get having no buildings opposite us. I would also beworried about the increase in traffic the one way system would introduce, on a road that is alreadyworn down and in terrible condition.

Wrong development in the Wrong place. In the climate emergency as declared byBristol City Council every blade of grass matters. Western Slopes is a wildlife haven in an urbansetting and should be protected. Pollution from nearby Hartcliffe Way and Bedminster Road/Parson Street area has to be absorbed somewhere and the trees on the Slopes do that; ifremoved and replaced with brick and mortar already illegal pollution levels will increase. In theweek of COP26 Bristol must follow the global pledges and reject this unwanted development. Wehave a planet to save.

No more houses affordable or not we do not need it in knowle.

I would like to place my objection to this application as it is totally inappropriate to thearea and the present climate. Our Mayor and council have declared a ecological emergency andyet are planning to remove the very thing that could help. There are many trees and shrubs alongthis plot of land which help to absorb the CO2 produced by the nearby Hartcliffe way which attimes can be extremely busy.I also notice that many organisations with vested interest in trying to reverse the effects of theecological emergency are also objecting to the application. There are many plants and animalsthat are quite rare living in this area and this will all be destroyed never to return.There are many many brownfield sites that should be used first before attacking and destroyingour precious greenfield sites, these sites will be needed during the oncoming emergency.I just find the council and Mayoral attitude confusing and not logical to attack sensitive ecologicalsites before unused and vacant brownfield. Then of course there is the extra vehicular trafficaround Hartcliffe Way and Knowle that can handle the present volume of traffic never mind amajor increase. The traffic lights at Parson Street cannot handle the current volume of vehiclesand Novers Lane and Novers Hill just cannot handle more traffic. Then again the extra vehicleswill add more pollution to an already high level.

Too many green spaces being taken up for development in South Bristol, leaving noleisure areas, in what is already widely known as as deprived area. Inadequate facilities for thearea as it is. This will only benefit a favoured few

I visit this site with my grandkids, who live on Novers Lane. They enjoy the horses.This is a deprived area with few green space amenities.Build these in Clifton!

A detestable attempt do dump housing on another green space in south BristolThere is no point in adding more reasons for my objection many others have already done thisIt is obvious to Bristol council and the house builders that this was to be astupid attempt to remove from the community a required green space andwould be shouted down by Knowle West as a wholeAlso note the attempt to aquire TVG protected land as part of the processthis request to steal protected land should be totally rejectedThe TVG land belongs to the local community that is why it is protected, wewill decide what happens to our protected areasA TVG should be give to the Western Slopes to stop any future developments.

We have very few facilities in the area and more housing and people will put more of astrain on the services in the area i.e. doctors, schools. Our green space is getting used up, whynot try building more housing the other side of town instead of taking up what little we do have!

This is a wildlife sanctuary which should be protected for future population of thiscrowded and busy city Homes should be on existing built up land areas

Protection of Green SpaceThe recent success of the Golden Motion at Full Council demonstrates the overwhelming desire toprotect green spaces and the green belt - together with previous declarations of a climateemergency and ecological emergency - there is a clear priority to protect green space.The Western Slopes, Novers Hill, is mentioned in this - for removal from the local plan during thecurrent review stage and granted Nature Reserve status, because of its' contribution to wildlife andbiodiversity.The Avon Wildlife Trust have long stated that Novers Hill should be protected from developmentbecause of its' ecological importance and contribution to wildlife for the city.

Building over the Western Slopes would damage the environment and in my view is not a"sustainable" development.

The Western Slopes/Novers Hill green space is vital to sustainability in that it provides keyecological and environmental function benefits in an urban area.

The wildlife corridor will be greatly impacted by this development. The value of this site is in theconnectivity with nearby green areas. The amount of green space left (from this proposeddevelopment) is not sufficient to maintain this connectivity, in particular the width of the greencorridor is too narrow. Proposed mitigation measures do not appear to be anywhere nearadequate.

Developing brownfield sites

Permitting appropriate development on suitable brownfield sites - in contrast to green spaces -would help ensure that the housing needed is achieved. It is estimated that circa 12,000 housesalready have planning permission in Bristol, awaiting development. Why develop on green space?

There is also an opportunity to repurpose offices and shops, turning them into homes and toprioritise social housing, especially for local people, which this development does not seem to do.

NoiseIt is very worrying that some properties situated close to the industrial sites will need alternativeventilation, due to noise levels. The developer states that "predicted noise levels across thecentral area of the site are expected to meet the upper limit of 55dB". This appears unacceptableand raises the question of actual readings of noise levels for all areas of the site.

It is very concerning that the developer has admitted that "further mitigation may be required forthe ...properties which would overlook the recycling centre". This highlights the unsuitability of theproposed development, given it is surrounded by industry on two sides. It is highly questionablewhether it is appropriate to subject residents of new builds to such daily disturbances, given likelyimpacts on health.

Air QualityParson Street School is just 0.6 miles from the development site. It has the fourth worst level of airpollution in the city and often exceeds the World Health Organisations' upper limits for pollution.The developer's proposals mean that even more vehicles will be using Parson Street andBedminster Road as a route onto Hartcliffe Way. They will pass this hotspot at the junction ofBedminster Road and Parson Street School. This is unacceptable, given the already dangerouslevels of pollution in this area and additional cars that will inevitably come with this development,impacting on the health of local people. It shows how unsuitable this site is for development.

Affordable HousingThe proposed development is for 157 properties: 110 open market; 11 shared ownership; 36social rent (only 15 of which are houses). (30% affordable - of which 77% social rent and 23%shared ownership).Unfortunately, he affordable will not be affordable to the majority of first-time buyers with pricescurrently in excess of £280K in 2021 for a house in South BristolThe "affordable housing" will do little to deal with the level of family homelessness in Bristol. 1000families currently living in temporary accommodation (reported in Bristol 24/7 - 1st Nov).

Nature ReserveI agree with the alternative vision proposed by The Friends of the Western Slopes, Novers Hill,that the site of Novers Hill should be a Nature Reserve for the people of South Bristol. The wildlife;the biodiversity; the landscape; the connectivity to nearby wildlife corridors makes it perfect for thisuse. They have a great vision of turning this into a site for the local community, contributing to the

future health, well-being and resilience of future generations.

This proposed development does not tackle the housing crisis - the majority will beneither shared ownership nor socially rented, and does not align with the recent motion passed atFull Council to prioritise brownfield sites over greenfield in the local plan. It also contradictsBristol's Ecological Emergency Strategy, destroying a Site of Nature Conservation Interest andresulting in an loss of ecological diversity that isn't mitigated by the developer's plans.

The Council must prioritise building council houses, improving air quality and protecting wildlife. Allof these priorities are at odds with approving destructive, private profit-led developments such asthis.

This development seems excessively large for the limited space.It will remove valuable inner city green space that is important for recreation, health (both mentaland physical), carbon capture and wildlife.Many local residents lack the ability or means to visit green spaces outside of the city, so the onesinside the city are of great importance.Allowing these green spaces to disappear will have detrimental effects for future residents of thearea.

I believe that more houses are needed, particularly affordable ones, but surely this should happenthrough expanding the city rather than squeezing more into the existing boundaries.

The building of these houses will be detrimental to our community. People use the landon a daily basis to exercise, socialise and enjoy a space normally impossible to access in a city. Itshould be the right of the residents to make the decision on this matter and that has clearly beenignored in the name of so-called progress. Housing will be overpriced and unobtainable to many.This is being done purely to meet housing targets, but it doesn't take into consideration the localcommunity, please reconsider.

There are so many reasons why I object to the proposed building work on the landoutlined in this proposal.

Firstly, this is an area of natural beauty and home to wildlife. Daily we see hawks and manydifferent birds flying overhead and know that in a mostly suburban area, the green space isintegral to biodiversity and maintaining areas of outside space for residents to walk in and enjoy.

The additional homes will also add pressure to local services - we already see bad traffic,oversubscribed schools and doctors surgeries - how is this going to be dealt with if more servicesaren't created to reduce demand?

I wholeheartedly object this planning application and do not understand why the council wouldchoose to build on green hillside when there are plenty of brown sites across the city which arealready easily accessible and so not require the destruction of nature

My family and I feel very strongly opposed to the this planning application. Greenfieldsites such as this one need to be protected for future generations. This is such short term thinkingto put up to 600 houses across this unique wildlife corridor. Lovells failed to build here 30 yearsago and the site hasn't changed, it is even more valuable now as an ecology site because somany green spaces have already been lost or are under increasing threat across South Bristol.

I also feel that much more public consultation should have be done with local people, feelingsamongst local residents across Filwood really haven't been listened to. There is a digital divideand digital exclusion which the developer has not taken into consideration. Knowle West and theFilwood ward is one of the poorest economically in Bristol so greater efforts should have beenmade to engage with all residents. Against this Knowle West has one of richest green spaceswhich needs to be preserved as an asset for them all and not the privileged few.

Let's be very clear 'affordable' housing is at 80% market value so it's a technical term rather than areality for anyone living local to the site on low wages.

Illegal levels of pollution are regularly recorded at Parson Street street adding 157 houses initiallywill only add to this and the strained infrastructure around Hartcliffe Way. Impact of more houseswill affect air quality and light pollution will further accentuate these issues across South Bristol.

Please Bristol City Council take note of how Bristolians feel at large about building on greenspaces. Priotise brownfield sites, only use any green spaces as an absolute last resort.

Protect this green space and make it into the south Bristol nature reserve it deserves to be.

In February 2020 Bristol became the first major city to declare an 'ecologicalemergency', yet just over 18 months later a building site is being proposed on a vital wildlifecorridor . Thirteen protected species, including otters and kingfishers, were found in the wider areaduring an ecology survey published in 2014, undertaken as part of the Knowle West RegenerationFramework. In 2010, local waterways including Pigeonhouse Stream were found to have"exceptionally rich arrays of woodland floor plants", including rare and uncommon species.Residents report seeing bats, badgers, buzzards, kestrels, owls and sparrowhawks. While theproposed building does not extend to this area it will undoubtedly have an impact, most likely anegative one, with increase in local noise and ground disturbances all of which wildlife is verysusceptible to. There a number of brownfield sites across the city that would be better used forhousing rather than disrupting an established green field site. It has already been proposedin2019, is to designate the Western Slopes as a Local Green Space or Reserved Open Space,offering protection from 'most forms' of development, subject to regular review but yet BCC saythis is not expected to be adopted until late 2023, too late for this well loved and used wild greenspace. Also Bristol experiences poor air quality, Clean air is essential for health and helps to makethe city a pleasant place to live. "We monitor air quality around the city and are working to improveit." taken form BCC website. The western slopes are vital in supporting clean air in the South ofthe city, it is an area that doesn't need any alteration and improvement .

I would like to object to the building of the new dwellings as this would destroy animportant wildlife corridor in Bristol. That area is home to numerous wild species from mice topheasants and foxes. The dwellings would also creat issues regarding schools and GPs as thearea is already overloaded and the delays on the building of the new school are extending.

Why destroy more of our disappearing green spaces..Why do we have to be held hostage by greedy developers and why is the council always on thereside...well that's what it looks like

The destruction of our green spaces and the increasingly belligerent approach by theMayor in first railing against objections and subsequently ignoring them is disgusting.

I wish to object to this planning application. Loss of green spaces across Bristol arecontributing to the ecological emergency we are all facing and which this city was proud ofdeclaring.

Novers Hill is an untouched wildlife haven, and any on paper environmental off setting in planningreports cannot realistically mitigate the significant harmful impact this would cause on these fragileecosystems this space supports.

Hartcliffe Way is already one of the busiest and most polluting roads in the city which is fringedwith industrial and light industrial buildings. Removing this green lung would have a detrimentaleffect not only on South Bristol but Bristol at large. The decrease in air quality from alreadydangerous levels of air pollution particularly recorded outside Parson Street school can only bemade worse by an additional 157 houses on this site.

Filwood ward needs these green spaces for the benefit of future generations who have come fromsome of the most impoverished backgrounds in the city.

So please do not take this natural landscape away from them with approving this planningapplication.

As a resident that lives directly opposite the proposed, (21/05164/F | Erection of 157 no.dwellings, including 47 no. affordable housing units (30%), along with 2 no. access points fromNovers Hill, the provision of play facilities and public open space with associated works. (MAJOR).| Land On The West Side Of Novers Hill Bristol), I strongly object to this proposed housingdevelopment. The land is one side of a vital 'green lung' corridor that goes from Dundry, all theway through to Avon Gorge. You are prosing to squash 157 homes between the Hartcliffe Way upto my front door, stripping out the grassland and destroying millions of protected habitats. Thesehouses would be stacked up from the road, behind the newly sited recycling centre for the South,adjacent to an industrial park, bus depot and major A road junction. This corner of Bristol, close toParson Street school is already highly polluted with vehicle emissions. If you take away theoxygen produced by stripping out the green belt land this will become diabolical. The WesternSlopes should be protected by the council, bought back off Lovell Homes and nurtured as adiamond in the rough for future generations to continue to breath!

I would like to register my disapproval of planned housing on novers hill. I am a residentof Bedminster and feel strongly against these latest plans. Already the air is highly polluted aroundour local school (parson st) and traffic highly congested. There is already shortage of amenitiesand green space for wildlife. Please rethink and consider local residents

I object to this development on the following grounds:

EcologyThe harm caused by this development would outweigh the proposed mitigation. It would be abiodiversity net loss and contrary to the eco objectives of the City Council. The proposeddevelopment would sever the wildlife connectivity / corridor to the Northern Slopes. Uniquemeadows along with rare mammal, reptile and insect habitats would be lost forever.

Health & WellbeingThe 'green lungs' of South Bristol are necessary to provide clean air to residents, many of whomsuffer lung complaints (only exacerbated by the recycling plant, bus depot and increased vehicleuse from the multiple local housing developments being approved and built in the area). Thisdevelopment would not only increase pollution but remove the green eco system that cleans it.

TransportCumulative traffic impact reports (which consider this development along with approveddevelopments as well as future developments in the area that are likely to receive permission inthe next three years) do not seem to have not been carried out - contrary to National PlanningPolicy Framework. The proposed one way along Novers Hill, which supports this application,hasn't been consulted upon with the community.

Consultation

Furthermore the community consultation for this housing application was rushed, an afterthoughtand a box ticking exercise. The proposed housing isn't necessarily suitable to the needs of localpeople. Whilst doctors and schools may continue to take on new patients and pupils, the servicesare nonetheless strained (try making a doctors appointment here!). Therefore this applicationwould only exacerbate the issues faced by a severely undervalued community in Bristol.

In summary this proposed development would remove a vital green space and provide little for thecommunity in return. The effects would be immeasurable lasting damage to the vegetation, wildlifeand people of the area.

Reasons for Objections:1. Loss of green space without even retaining the minimal 10% for an essential wildlife corridor.2.Further loss/damage of greenspace to enable site access.3. Significant increase in housing without any space for services of community support.4.Paultry offer to improve surrounding green space using section 106 contribution which is justwrong.5. Further creation of basic off the peg designed housing that will continue the mindset of the areabeing a place people live in because it is their only choice.

We have lived here for over 30 years and during that time have seen planningpermission for houses on this site refused on a number of occasions due to the value The WesternSlopes has for wildlife and we believe that it should be protected not built on. We see so manybirds and other wildlife on the slopes, in the spring and summer it is full of wildflowers and we alsolove seeing all the people come to see the horses, it really should be made a nature reserve andleft alone.We also concerned as our house backs on to the slopes and although it is not part of the Lovellsplan to build at the back of me right now I am very worried if that get the go ahead then the councilare then getting Goram homes to build 400+ more houses and road right at the back of my fence.The problem with this is all the houses that back on to the slopes already have subsidenceproblems which are only going to get worse, then what ? it'll be bad enough to lose this wonderfulgreen hill to housing but what about people losing their homes or having to shell out for expensiveremedial works, We are retired and very worried about this as it has been bought up in the pastthat this land is not stable enough to be built on and the council knows it.This area is already short of GP's & dentists and the schools who are already struggling to copewith enough places for kids already in the area not to forget more traffic, more pollution in an areathat already has very high pollution levels, it is just not a good idea. As for affordable homes, thatis a complete joke, none of the homes that are being built in this area are affordable and neitherwill these proposed houses be affordable at least not to local people. At the moment it seems inthis area where every you see a piece of green space houses are being put up, soon there will benothing left.We are appalled that once again there are plans to build here and we object to any building on thewhole of the Western Slopes and agree with the majority of people who have objected to this that

this needs to be made a nature reserve and stop taking all the green spaces away in south Bristol.

RegardsTerry & Sandy

Please don't ruin where we live.

I object to this proposal for a number of reasons:Climate Change - we are currently hearing so much about striving to become carbon neutral thatis unbelievable that instead of preserving our precious green spaces the council is consideringbuilding on them - they should be planting more trees on this area rather than building houses andas a whole creating more green spaces across the city.Wildlife- with the demise of green spaces comes a loss of wildlife crucial to the sustainabledevelopment of our city.Lack of local amenities - more housing equals more strain on already pressured doctors surgeriesand schools.With more housing, and alongside the new recycling centre on Hartcliffe Way, comes increasedtraffic - also adding to climate change issues.

I strongly object to this initiative.

I feel strongly that this initiative is wholly unsuitable and should be rejected. The lack ofaffordable housing is a travesty, especially during a period where house prices and cost of livingare increasing while consistently outstripping wage increases. Moreover, the destruction of a wellloved and important habitat which is undoubtedly home to numerous animal species for the sakeof 147 houses and to line the pockets of property developers is unacceptable

We need to protect our green belts!Reuse existing empty buildings.

Western slopes is a critical wildlife corridor between Novers slopes and Manor WoodsValley & Crox Bottom. We have a ecological and biodiversity crisis so this development on greenfield land does not make sense. The pandemic has also shown how we need more green spacesfor the good of our communities' mental wellbeing.

I support developments on brown field sites like Hengrove airfield, as long as there are suitableamenities for that housing provision. This meets neither very basic requirement.

I am also extremely disappointed with the way in which the "low quality" land next to the plannedBristol waste centre is where all the so called "affordable" housing is. We need housing, but highquality council housing.

I do not object to the application in principle, but am concerned that maximumopportunity is taken to provide:

1. affordable housing;2. public access to, and benefits from, the land.

At present, as far as I can tell, public access is very limited (one path always seems blocked) ornon-existent.

Also, that there should be minimum negative impact to nature conservation on the site; balancedalongside the above.

I object to this planning proposal and any further proposed housing on this establishedand wonderful green wildlife corridor, all of this area, from the new recycling centre all the waydown to past Imperial Park down towards Hengrove on both sides of Hartcliffe way, needs to begiven the protected status it deserves, for now and for the future.After Bristol City council declared an ecological emergency AND then a motion was passed at cityhall to save our green spaces I am saddened that I even need to be summitting this objection aspromises have been made and nothing has changed, shame on you.I could write more but I believe all the reasons I STRONGLY object to have already been laid outclearly and in details in the other hundreds of objections submitted.I will also like to add I am not anti-housing or anti development however I feel that the mayor andBristol city council would be best served keeping to the promised they made and instead ofwasting time going head to head with it's own citizens use their time in finding alternative solutionsto the housing crisis. The housing crisis is always at the fore front of any come back regardingbuilding on green spaces but do you seriously think that the people in Knowle West and Filwoodare unaware of the housing crisis or the need for affordable homes.Do some research, look to other countries for solutions, anything but a change needs to be madeby the people that have the power to do so, so do it now as honestly time is running out.

I object because it does not fit with the existing area. The plans are not in keeping. Theydestroy a meadow and the animals and green plants. It kills nature and provides no infrastructure.Just years of misery while a poor build project disrupts the lives of people. A one way road systemfor Novers Lane with access at two points is a joke. It adds dangerous levels if traffic. Thehorrendous amount of parked cars on this single carriage lane from the tiny housing at the top hascaused awful congestion and danger to pedestrians. The loss of birds of prey and bat habitats isevil just for houses and profit and quotas. This should not even be at this stage. The land is not forbuilding on. If this does get built those living near will lose a quality of life, those building it andgranting permission won't. That is why this shouldn't get built. The people with the power haveabsolutely no interest here just their own personal gain.

The local area is congested, the traffic infrastructure is already inadequate. There arelittle or no routes currently available to walk or cycle without being by a main road and being nextto cars sitting in traffic. This development would worsen the issue.There are few areas of green space that have an abundance of wildlife like the slopes. Thedevelopment would create an urban jungle destroying natural habitat but also taking away greenspace from an already deprived area. Over the 16 years I have lived in Bristol I have lived in manydifferent areas, and loved the green spaces that each has, whether in St Pauls, Westbury onTryme, Cotham. I have valued that the city seems to try and provide an equality of green spacesregardless of the demographic of the residences or the wealth of an area. This development feelslike the sense of equality for a living environment has been disregarded.

The local area is congested, the traffic infrastructure is already inadequate. There arelittle or no routes currently available to walk or cycle without being by a main road and being nextto cars sitting in traffic. This development would worsen the issue.There are few areas of green space that have an abundance of wildlife like the slopes. Thedevelopment would create an urban jungle destroying natural habitat but also taking away greenspace from an already deprived area. Local schools would be subjected to more road pollution.What is the point of pushing pollution out of the city centre to only create pockets of pollutionelsewhere.

I believe this development will be detrimental to the local area, and to the wildlife andgreen space that is needed.

The whole area is being over developed without taking into consideration the needs of the localcommunities that surround the proposed building plot.

I object to this planning application for the below reasons;

- I live opposite the planning site and this will impact on my privacy and loss of light. The view isbeautiful from our back garden and it attracts different wildlife which is unheard of living in Bristol.

- The extra impact on the surrounding roads to support more cars will be dreadful. We are alreadyat a disadvantage because of the recycling centre. if you approve this the roads will be evenbusier! not to mention the extra parking issues.

- Bristol is lacking in green space. This is one areas of Bristol which is untouched and we need tosee more spaces like this to encourage wildlife and natural gases to flourish.

I object to this planning application for the below reasons;

- I live opposite the planning site and this will impact on my privacy and loss of light. The view isbeautiful from our back garden and it attracts different wildlife which is unheard of living in Bristol.

- The extra impact on the surrounding roads to support more cars will be dreadful. We are alreadyat a disadvantage because of the recycling centre. if you approve this the roads will be evenbusier! not to mention the extra parking issues.

- Bristol is lacking in green space. This is one areas of Bristol which is untouched and we need tosee more spaces like this to encourage wildlife and natural gases to flourish.

The number of new homes being built on green space in the Knowle area is a disgrace.Especially when there are numerous unused commercial and industrial spaces in South Bristolthat could be repurposed. There don't appear to be any plans for infrastructure to support the newhomes either, where are the schools, play spaces and gp surgeries needed for these newresidents?

Totally oppose against housing planning on The Northern Slopes. The area should beperceived as a nature reserve with the luscious green belt that attracts a lot of wildlife and home tomany species. Environmentally it will help reduce all the carbon in the air from cars that havemassively increased and continue increasing with the high percentage of houses being built inSouth Bristol. Long term it will have a detrimental impact on our environment taking away all thegreen belt in communities that will impact health and long term extinction of wildlife because theirhabitat is being unearthed and destroyed by man.

Green spaces in the city need to be protected the western slope is a vital wildlifecorridor. Bristol council have declared both an ecological and climate emergency in recent years.Approving this project is not in line with Bristol's long tern plans to be a green and sustainable city.

There is not enough infrastructure in this area to support another development of thistype. You can't just keep adding homes without also providing schools, doctors, dentists etc.The wildlife corridor will also be greatly damaged if building is allowed here. It's just not worth therisk, especially considering that the new builds will not be affordable in the true real sense (veryfew people in the area will be able to afford even the cheapest ones).

WHaM response for application 21/05164/F

Erection of 157 no. dwellings, including 47 no. affordable housing units (30%), along with 2 no.access points from Novers Hill, the provision of play facilities and public open space withassociated works. (MAJOR).

WHaM strongly objects to this development on the following grounds:

1. The site is specifically identified as a prominent green space within Bristol City Planningdocumentation, which states that development should not occur on this site unless the use isancillary to the open space use. The use as a housing development is definitely not this.2. It is also registered as a park and open green space, and as such should not be built on.3. As Bristol has declared a biodiversity crisis, it would not be fitting with any aim of tackling thecrisis to allow a major development on a greenfield site that identifies a net biodiversity loss.Making up for this elsewhere will not be acceptable if the existing biodiverse situation is notreplicated.4. National planning policy has recently been rewritten to emphasise the need to protectdevelopment and improve biodiversity. This development clearly does neither.5. The green space provides many recreational benefits to Bristol, contains many old trees and ispopular with families. This development will harm these characteristics. The upcoming local planyet to be released would offer the chance for further protection of this green space and we wouldurge the planning department to refrain from making decisions on major developments with

significant implications for green open spaces until such planning policy is in place as it clearlybelieved improvements were necessary when the document was put out to consultation in 2017.6. Given the slope of the site, the development will be prominently visible from south Bristol andwill contribute to a wall of development.7. We are also concerned about the recycling centre proposed to be built locally and theimplications concerning the suitability of this site for long term habitation in such close proximity,and the likelihood of nearby vermin, odours and other hazards that could arise.8. We note that there is a well thought out sustainability statement but worry that the strategy doesnot go far enough. The rejection of gas boilers is commendable but in today's market of highpriced energy, we worry that more should be done to provide higher levels of onsite energy tooffset the gains for using heat pumps. We also think that given that heat pumps work optimallywithin well-sealed and insulated buildings, that performance criteria should be set for the envelopeto ensure that they are effective.

Don't let the title which is chock full of promises like an overstuffed burrito fool you- thisapplication is undeniably problematic and should be refused.

The applicant's main defense is that this site is allocated in the local plan. However planninglegislation states that the local plan allocations do not override planning policy and an applicationshould not be accepted if there are 'material considerations that indicate otherwise' and boy doesthis application have material considerations that indicate otherwise!

Below I will list just a few of the many material planning considerations that prove this applicationis not consistent with planning policy and therefore needs to be rejected. These are not just myopinions they are proven facts that will hold up to the scrutiny of planning inspectors. You don'thave to take my word for it, many of these points are also listed under 'constraints' on the BristolCity Council application page.

1. Novers common has Town & Village Green status which would require deregulation for theaccess roads

2. Those access roads would damage a protected ancient Hedgerow and ruin the connectivity ofthe wildlife corridor

3. The applicants used an old metric to determine biodiversity net gain.

4. The development fails to meet Bristol planning policy requirements of 10% biodiversity net gain

even with the outdated metric used.

5. They have not found a suitable site to offset their biodiversity loss.

6. No winter bird surveys were done and their breeding bird survey was only done on one daywhen the minimum requirements is three days.

7. No sufficient Invertebrates and reptile surveys were done

8. Two of the Bats detectors used in the applicants surveys stopped working for 'unknownreasons'

9. They violated CIEEM principles by incorrectly claimed finding 11 bat species was common foran urban green space

10. No Environmental Impact Assessment was done

11. The Golden motion to protect Bristol's green spaces that was unanimously passed on Sept 7thin full council specifically mentions this site and dictates its removal from the local plan.

12. Sound levels for this development are higher than the legal limit

13. The sound survey was done in June 2020 (during peak lockdown) and before the recyclingcentre was built

14. Alternative ventilation has to be used for the affordable flats because they are being used as asound barrier for the market rate housing.

15. There are several instances of Incorrect information in the applicant's planning documents.

16. Important documents were kept from the public until after the consultation was over.

17. The site has viability issues that may lead to the applicant backing out of their affordablehousing obligation.

18. There is a well documented Subsidence risk

19. Previous planning decisions spanning at least 30 years have all refused development on thissite including appeals.

20. WECA has designated this land as 'core grassland' and high biodiversity space which shouldbe protected from development

21. Surface water and drainage is a serious concern

22. This land is listed as 'prominent green hillside' and therefore legally can't be altered to theextent this application is proposing

23. This site is meters away from the Air quality management zone and would increase thealready toxic levels of Air pollution.

24. The allocation in the local plan for BSA1114 is for 50 houses and this application exceeds thatby 50%

1. Town and Village GreenNovers common is one of only 28 Town and Village Greens (TVG) in Bristol. To put that inperspective Bristol has 35 wards. TVGs are designated as such in order to protect them fromdevelopment so an application to deregulate would only be granted in exceptional circumstances.Lovell do not have the exceptional circumstances or the acceptable replacement space to warranta lawful deregulation of TVG status. An ecologically barren turf in the middle of a housingdevelopment is no replacement for an ancient hedgerow which holds over 2,000 species andserves as an essential wildlife corridor. The numbers don't even add up and Lovell are offeringless space than they are taking away.

Most importantly though, Lovell have not applied for the deregulation of TVG status yet but theyplan to start building before the application is decided. What happens if they start building and theapplication is refused? This is a very likely scenario considering the amount and type of land theyare offering in return is inadequate and central government have recently announced a preferencefor brownfield development. This means the land will be bulldozed, killing essential invertebratesand damaging the ecosystem for absolutely no housing gain. We will be left with an unusablewasteland and there is no doubt Lovell will use this threat to add considerable weight to theirderegulation application to the Secretary of State. The application should be refused on thesegrounds alone.

2. Damage to the Ancient Hedgerow

Ancient hedgerows have their own protections. According to government regulations A hedgerowis protected if it's on or next to:land used for agriculture or forestryland used for breeding or keeping horses, ponies or donkeyscommon landa village greenSource:

https://www.gov.uk/guidance/countryside-hedgerows-regulation-and-management

This and the fact that the hedgerow is well over 30 years old means Lovell do not have the legalright to issue any works that would damage the protected hedgerow. Their developmentcompletely relies on 2 access roads which cut the hedgerow into sections destroying itsconnectivity. This is such an important issue because hedgerows are essential to our ecosystemand they have to maintain their connectivity to be usefully as a wildlife corridor. I'm not anecologist so I asked one of the country's leading hedgerow experts Megan Gimber her opinion onwhether the access roads would cause permanent damage to the biodiversity of the hedgerowand she kindly responded:

'Absolutely. Hedges provide 3 wildlife functions: habitat, food/shelter, connectivity. Fragmentingthe network like this can impact on at least 2 of these. Connectivity is vital for bats, flying insects,mammals such as dormice etc. Fragmentation is limiting factor to distribution of some species andeven a threat of extinction to others.Connecting habitats up should be a real priority, & given hedges combine elements of woodland,scrub and pasture, they can accommodate, as well as facilitate the movement of species fromeach.'Source here: https://twitter.com/favcolour_green/status/1447645253952065543?s=21

3. Outdated Biodiversity Net GainThe applicant has used Biodiversity 2.0 which is now outdated. Natural England published thefollowing about the upgrade to 3.0:

'Biodiversity Metric 2.0 has been updated and replaced by Biodiversity Metric 3.0 which waspublished on the 7th July 2021.Biodiversity Metric 3.0 introduces a number of improvements andcorrects some issues associated with metric 2.0. The new Biodiversity Metric 3.0 will be the metricthat underpins the Environment Bill's provisions for mandatory biodiversity net gain in England,subject to any necessary adjustments for application to major infrastructure projects.'

4. The development fails to meet Bristol planning policy requirements of 10% biodiversity net gain

Bristol local planning policy as stated in the recent ecological emergency report states:

'Biodiversity Net Gain of 10 per cent net gain will become mandatory for housing anddevelopment, meaning habitats for wildlife must be left in a measurably better state than beforethe development. Developers must submit a 'biodiversity gain plan' alongside usual planningapplication documents. The local authority will assess whether the 10 per cent net gainrequirement is met.'

The ecology reports included in this application clearly state that this development has drasticallyfailed to meet the biodiversity net gain requirements.

5. No suitable site to offset their biodiversity loss.

Continuing from the previous paragraph on biodiversity net gain Bristol planning policy states:

'If net gain is not achievable on-site, off- site habitat creation/enhancements will have to beagreed.'

Lovell have claimed on their application that they are considering Crox Bottom for offsetting butthis has not been agreed by the council or Crox Bottom. In fact the Crox Bottom friends grouphave written their own objection to this application and have stated that Lovell has never contactedthem about the biodiversity mitigation. They commented the following:

'I read with interest that Lovell have proposed offsetting some of the impact of the development byimproving areas of Crox Bottom in mitigation. This is impossible. Crox Bottom is classed as asteep sided wooded valley. It is not the same habitat whatsoever and cannot provide analternative to Novers Hill. There is also no space within Crox Bottom to establish any other type ofhabitat, without removing some of what is already there, which would be completely irresponsibleand unacceptable. I might also add that not one person from Lovell has contacted the Friendsgroup with regards to this proposal. One would have considered that to be a basic courtesy, giventhe current tensions around the planning application.'

6. No winter or sufficient breeding bird surveys were done

No winter bird surveys were done and their breeding bird survey was only done over one daywhich is not a sufficient survey. For a breeding bird survey to be valid the British Trust forOrnithology requires 'three site visits between April and June - a recce and two morning visits,along with data entry.'

The applicant's report stated that a breeding bird survey was required:

'The range of habitat onsite provides ample foraging and nesting opportunities. The hedgerows,woodland and scrub are key areas although there is also some potential to support ground-nestingbirds. For this reason, a breeding bird survey will be required.'

Then they admit to only recording one day of results:

'A breeding bird survey was undertaken on the 30th June 2020.'

They then make a claim that there were low numbers bird recorded but fail to point out that theydid not meet the time and date requirements for a sufficient breeding bird survey:

'The bird survey recorded surprisingly low numbers of breeding birds with activity focused on theeastern hedgerow within the established trees. And within the patches of scrub. Species recordedincluded nesting magpies, chiff chaff, great tits, kestrel, swifts and large flock of approximately 30gold finches. As there are habitats of value for breeding birds on site, these species are discussedfurther in section 7 of this report.'

However in section 7 these bird species are never mentioned again as you can see:

'The breeding bird survey showed relatively low bird activity on site and relatively few species,however, it is clear the scrub and woodland habitats are important for foraging and breeding birds.The retention and enhancement of the grassland/scrub/woodland mosaic will be important inallowing birds to continue to forage and nest on site. It is not considered that any furthercompensation for breeding birds is required, however, section 8 makes recommendations formitigation for birds during construction and outlines opportunities for enhancements for breedingbirds.'

Section 7 is basically just repeating the same unsubstantiated claims and the species mentionedare never discussed further despite the report claiming they would be. Let's try section 8 then...

'Any areas of scrub or trees that require removal to enable the development will be undertakenoutside of the bird besting season (i.e. avoiding the months March - August inclusive). If thiscannot be avoided a breeding bird check will be undertaken by an ecologist prior to vegetationremoval;- A minimum of 50 bird boxes will be provided on site to be integral to new buildings.Specifications and locations will be finalised in the LEMP or a separate bat and bird.'

What is bird besting season? Did the applicant not have a proofreader? Separate bat and birdwhat? This is a very poorly written report riddled with errors.The decision to add 50 birds boxes has no evidence to back it up and they never specify whatspecies they are mitigating for.

7. No sufficient Invertebrates and reptile surveys were done

The applicant has claimed in their limitations section of the ecology report that they could notconduct a proper reptile or invertebrates survey because horses are their mats. Is this theecologists version of the dog ate my homework?

This was their reasoning:

'The presence of horse grazing on the site resulted in damage to the grassland which may haveresulted in some botanical species being under recorded. The horses also disturbed and damaged

some of the reptile mats which was a limitation on this survey. The impacts of the horses fromdisturbance and grazing also limited the ability to undertake invertebrate surveys.'

I consulted several ecologists about this and the consensus was that horses are capable ofdamage to reptile mats but an experienced ecology team would 100% know that and should havefenced off the horses so they couldn't tamper with the mats. These surveys should have beenredone before an application was submitted.

8. Two of the Bats detectors used in the applicants surveys stopped working for 'unknownreasons'

In section 3.5.2 of the applicant's ecology report they mention:

'Two static detectors (4 and 5) failed to record during the survey period for unknown reasons. Itwas assessed that the amount of usable data obtained during the active season was sufficient tomake a robust assessment of the site for bats, despite the failed recordings.'

As a member of the BS3 bat group I've been on many bat surveys and can say with confidencethat 2 detectors failing to work should constitute a redo of the bat survey in order to get anaccurate reading. The fact that this wasn't done is very concerning.

9. They violated CIEEM principles by incorrectly claimed finding 11 bat species was common foran urban green space

The Chartered Institute of Ecology and Environmental Management(CIEEM) states that all claims made in ecology reports need to be supported with substantialevidence provided in the report for easy reference. The applicant's ecologists make the assertionthat finding 11 bat species including the rare greater horseshoe bat is common in Knowle West,Bristol implying that it is not a significant deterrent for development. However no reference orevidence is ever mentioned in the report to substantiate these bold claims. The report states:

'The presence of eleven species of bat recorded on static detectors is not unusual for this part ofBristol, and the low numbers of lesser and greater horseshoe bats is also not unexpected.'

Not only are there are no sources listed on the report to support this claim there is consensusamong ecologists that finding horseshoe bats in an urban green space is quite remarkable and isa deterrent for any development on this site.

10. No Environmental Impact Assessment was doneNature England wrote in their letter in the pre-planning documents that their recommendation thatan EIA was not needed was decided because the site was not an SSI or AONB and that they hadmo knowledge of the site other than that. It clearly states that they should be contacted again after

an ecological survey is done if any protected species were found so they could reevaluate theirdecision. As we know 11 bat species were found in the survey including 2 rare species. All batsare protected species and require a mitigation license. There is no evidence on the planning portalto suggest Natural England were ever contacted about the bats. Bristol City Council has thereforeissued their decision to waive the EIA prematurely. This is very poor and could potentially be usedto cite bias towards development in a judicial review.

11. The Golden motion to protect Bristol's green spacesOn September 7th a motion was brought forward to full council from the conservatives with afriendly amendment from the Green Party. This cross party motion protected Bristol's greenspaces and greenbelt land from development and specifically mentioned the land that theapplicant is attempting to build over. The amendment states:

'Council calls for1. To call for a halt to the proposed redevelopment of or incursion into any remaining productivewildlife rich agricultural land.Furthermore,6. To assign or instruct officers to consider adopting the Western Slopes and Brislington Meadowsas Local Green Space as provided for within NPPF guidance, providing similar planning protectionas for the Green Belt.'This motion, which specifically mentions saving the western slopes (aka Novers Hill) fromdevelopment, was unanimously passed. By submitting this application Lovell have sent a clearmessage that they do not respect the will of the Bristol people and it's elected officials. Approvingthis application would send the message to residents that voting doesn't matter since privatecompanies are above democracy. It would be a poor choice and could potentially result in directaction.

12. Sound levels for this development are too high

The applicant's sound report can be found here which shows mitigation for excessive sound levelsare required.

13. The sound survey was done in during peak lockdown and before the recycling centre was built

Despite claiming otherwise during the public consultation on zoom, the applicant has conductedtheir sound survey in June 2020 which was the height of lockdown. Traffic levels would have beenlower than any other time in history due to lockdown measures being implemented to preventspread of the COVID-19 virus. This means the sound readings on the report do not reflect theactual levels of noise from the traffic on Hartcliffe Way and the noise from the nearby industrialestates.The applicant also wasn't aware of the new recycling centre being built so this has not been takeninto consideration in the design of the homes or the sound mitigation.

14. Alternative ventilation has to be used for the affordable flats because they are being used as asound barrier for the market rate housing.

Because the sound levels were too high Lovell was required to provide mitigation for this excess innoise. I consulted a top acoustical engineer, George Spano, and his professional opinion is thatthe bare minimum solution would be to build a sound wall to manage the surplus noise. Instead ofdoing this Lovell have used the flat buildings which are mostly comprised of the social rent units,as a sound barrier for the rest of the development. I don't need to explain further why this isdistressing and poor practice.

15. There are several instances of Incorrect information in the applicant's planning documents.

In the original consultation website Lovell claimed the extra people their development would addwould bring an increase of money to nearby pubs and shops and create 10 new jobs. As anyonewho lives in Knowle West knows there are no pubs in the area and very few shops are withinwalking distance of Novers Hill. Its disconcerting that Lovell would make a claim like this withoutchecking the area first and definitely erodes confidence in there proposals. Where did they get the130 jobs number from? How can you create a ob at a pub that doesnt exist? They have sincetaken this down because it was embarrassing for them but luckily it still survives on the internet:source: https://twitter.com/DanicaPriest/status/1414696355075956738?s=20

In the community engagement document they try to remedy this by saying there is a Spar 10minutes walk away from the development site. Its true that if you look on google maps this is thecase but that is actually outdated and there hasn't been a Spar there for years. It's a Londis now.They have managed to cover their mistake with another mistake.

In the pre-planning documents Pegasus try to claim their development will have a minimum impacton the highways but this conclusion was proven unsubstantiated by the planning officer.Source: https://twitter.com/DanicaPriest/status/1453321532135153665?s=20

These are just a few examples of incorrect information presented in the applicant's planningdocuments.

16. Important documents were kept from the public until after the consultation was over.

The ecology report was not published until after only public consultation so residents and exertswere given no opportunity to ask questions about any of the essential information on this report.The applicant has also refused to answer any questions regarding the ecology report and declinedour request to hold a follow up meeting to discuss it. They claimed the report was not finished sothat was the reason they could not show it to us before the final consultation however when it wasfinally released it was dated June 2020 for the survey dates so they had over a year to publish the

report. This lack of transparency is concerning.

17. The site has viability issues that may lead to the applicant backing out of their affordablehousing obligation.Lovell have mentioned many times that their original plan was for 188 homes but they were forcedby the council to scale back to 157 due to height requirements. They use this as the reason whythey can't reduce the number of housing claiming they are already stretched to their limitfinancially. This is worrying because Lovell, like most developers have a history of using viabilityas an excuse to get out of their affordable housing requirements. Sadly this is perfectly legal andthe council has no control over it. Here is an example where Lovell has done this in the past whenthe affordable requirement was far less than 30%:https://www.shropshirestar.com/news/property/2017/10/30/work-on-telford-development-currently-unviable-says-developer/

18. There is a well documented Subsidence risk

Novers Hill is in a zone which has reported a high risk of subsidence. There have been doumentedissues with cracking and sinking in housing along the Western Slopes/Novers hill and the NorthernSlopes.

19. Previous planning decisions spanning at least 30 years have all refused development on thissite including appeals.Mr Patch has sought planning permission for this exact site many times before. It's disturbing thatPegasus mention on their report that the details of the application from the early 90s are unknownto them since Lovell was the developer who attempted to obtain planning permission and lost boththe application and the appeal. This poor communication and shoddy research does not inspireconfidence in Lovell and Pegasus's competence. It's very worrying that they failed to discoversuch an obvious detail.The Lovell application in the 90s and the Persimmon application 10 years later both were refusedfor reasons that are all still relevant today. The fact that this land is allocated in the local plan doesnot override those material planning considerations which were legitimate reasons for refusal. Thefact that every application has also lost its appeal proves that it isn't just politics, the independentplanning inspectors all agreed that the council had valid grounds for refusal. Previous planningdecisions are a material planning consideration as they establish a precedent of refusal whichwould take a serious change to overcome. Lovell has failed to provide this change incircumstances so the precedent for refusal will be upheld.

20. WECA has designated this land as 'core grassland' and high biodiversity space which shouldbe protected from developmentWest England Nature recovery network labels this site as the best or 'core' areas of wildflower-richmeadows .

Their map states:

'The brown areas show the 'core' areas of grassland. These are areas greater than 0.5ha whichare the most species and flower rich areas in the region. The orange areas show the land thatsupports the core areas and enable species to move from one core area to another, helping makecoherent and resilient networks.

Why is this ecosystem important?Grassland is particularly important for maintaining pollinator species which are crucial for manyfood crops.'

Novers Hill is both brown and orange on the WENP map.

The WENP map also lists Novers Hill as a Multiple Ecosystem Service:

'Many areas of land in the West of England is providing more than one ecosystem service. Thismap has combined the services mapped to create a multiple ecosystem service map.

What does the map show?Different ecosystem services have been overlaid to show where the land is delivering multipleecosystem service provision. It shows the areas that contribute to good water quality, areas thatare providing natural flood defences and areas that are part of an ecological network. The darkerthe colour indicates where more services are being provided.

Why are these ecosystems important?Areas that are providing multiple services are helping improve the regions overall resilience. Thedarker areas are the most ecologically important areas that should be protected to ensure theycan continue providing multiple services.'

So the map is clearly saying this land needs to be protected because of it's importance to nature.

Source: https://www.wenp.org.uk/nature-recovery-network/https://wenp.org.uk/maps/

21. Surface water and drainage is a serious concernDrainage is listed under the constraints section of this application for a good reason. Slopes are animportant part of flood management since the water is absorbed through the soil which also filtersout the pollution. If Lovell succeed in their pursuits to concrete over this slopped land it will cause

irreparable damage to the aquifer which will lead to water quality problems, poor drainage andincreased flood risk. These slopes need to remain green if we don't want our water brown.

22. Bristol Local Plan review lists this land as a 'prominent green hillside' and therefore legallycan't be altered to the extent this application is proposing

Policy DM17 Development Involving Existing Green Infrastructure states:

'Whilst the Site Allocations Policy was introduced after the publication of the NPPF (2012), the SiteAllocations Policy DM17 added further definition to Policy BCS9 and details the approach for itsapplication in Development Management. With regards to Open Space, Policy DM17 identifiedImportant Open Space which mandates that 'development on part, or all, of an Important OpenSpace as designated on the Policies Map will not be permitted.'

The objection report from Bristol Tree Forum goes into this further so I recommend reading it.

source: https://www.bristol.gov.uk/documents/20182/34536/Local+Plan+Review+-+New+protection+for+open+space+-+Web.pdf/6b443275-293f-e56e-7009-764c4122fc59

23. This site is meters away from the Air quality management zone and this development wouldincrease the already toxic levels of Air pollution.

5 people die a week from the air pollution levels in Bristol resulting in £170,000,000 in costs to theNHS a year. This study was done in 2019, after the western slopes were allocated for housing inthe local plan in 2014. The western slopes are merely 180 meters from the current air qualitymanagement boundary.

The mayor was even quoted on the issue saying:"We have a moral, ecological and legal duty to clean up the air we breathe. This researchemphasises how vital it is that we act quickly to improve health and save lives in Bristol."

Did you know the greatest contributor to the toxic level of emissions is personal cars? I've done arough estimation and if just 150 of the 157 planned homes owned a car that would add 690 metrictons of CO2 to the area a year. This is all in addition to removing one of the last spaces we have inSouth Bristol that actually filters this deadly pollution.

Bristol is the 5th least green city in the uk so it's no wonder why its air quality is one of the worst inthe country. Other cities have more people but less pollution because they have more trees perperson. This is why we can't afford a single green space to be lost. No housing shortage no matterhow severe is worth people dying over. Nothing can justify touching an inch of this life savinggreen space. The western slopes/Novers Hill needs to be protected at all costs.

sources:

https://www.theguardian.com/environment/2019/nov/18/air-pollution-kills-bristol-health

https://www.walesonline.co.uk/news/uk-news/aerial-mapping-reveals-uk-most-20425145?fbclid=IwAR2biZ2QVWntcexlAaBhgMJL7uNHnEjpw97iUJaS-rngvAbXQ5wyC8Jgu4M

https://www.theguardian.com/world/2020/sep/26/escape-country-covid-exodus-britain-cities-pandemic-urban-green-space

https://airqualitynews.wpengine.com/2019/12/03/green-spaces-can-prevent-premature-death/

24. The allocation in the local plan for BSA1114 is for 50 houses and this application exceeds thatby 50%

Lovell are attempting to fit more housing into the allocated that is allowed for the site. The reportby Pegasus states:'While the target yield of 50 dwellings is more than met within the proposal, this must beconsidered in the context of the extensive escalation in housing need.' then they follow it up withthis highly manipulative sentence: 'The delivery of housing represents a key consideration thatshould be afforded great weight'

So essentially Pegasus and Lovell are just deciding they can change the rules here and they thinkyou should let them get away with that because of 'housing need'. We can't let them do that. Sincewhen did increase in housing need mean the local plan allocations get to be changed without theformal legal process to do so?

I'm not surprised they are attempting to slide this past you since 'housing need conquers all' isLovell's entire argument for this application.Deregulate a village green?- housing need demands it.Violate a unanimous decision in full council to protect this site? - housing need means its okCut corners and make affordable housing a sound barrier? You get the point...If someone kicked an elderly women out of her 5-bed home because of housing need that wouldobviously be unacceptable and against the law. That means there is a line where housing needdoes not justify actions and we need to remember that. This application clearly crosses that linefor all the reasons listed here and in the other hundreds of well written objections on thisapplication.

For too long developers have used the housing crisis to expand their profits at the expense ofpeople and the climate. You just have to look at the cladding scandal and our biodiversity crisis to

see proof of that. It's time we stopped treating developers like charities and held them to the sameethical and legal standards we hold other companies. No one is above the rules so we shouldn'tbe giving special treatment to Lovell and Mr Patch. Planning law should apply to them in the sameway it does for everyone else.

This application exceeds the allocated amount of housing on BSA1114. That's against the rules.This application requires TVG status to be deregulated but Lovell and Mr Patch haven't evenstarted the application process yet. That's grounds for refusal. The applicant's ecologists used anoutdated biodiversity metric to measure net gain, they failed to meet Bristol's 10% biodiversityincrease requirement and their offsetting attempts are objectively inadequate. Three violations inone sentence. This is an open and shut case. Refuse this application and keep Novers Hill green.It's the right thing to do.

I'm happy to speak more on this if 10+ pages wasn't enough.

Dear Sir/MadamI am expressing my distress for losing our beautiful rare green spaces.It is massive concern to ourneighborhood especially our young children.

The covid-19 pandemic has highlighted how important green spaces are for our mental health andwellbeings. By taking them away means there will be more people with depression and mentalhealth issues. Additionally, the animals and nature that are being pushed out of thier habitats.

Please stop this proposal now and listen to the neighborhood and local community.We are strongly object this proposal which and it needs to stop.1.The development will creates noise pollution and as majority of the neighbours have schoolchildren they will not be able to concentrate to their study.2. It will have high environmental impact.3. Loss of our green spaces means , more mental health problems.4. More traffics.5.More crime

Thank you

I object to the loss of green space and natural habitat. We need to protect these vitalspaces and build on brownfield sites.

Once land has been built on it is gone. Bats,Badgers, Reptiles and birds need their habitatprotecting, we need wildlife and in light of the climate change we have a responsibility to futuregenerations to safeguard wildlife corridors/spaces as much as we can.

I am also concerned about flooding.

The local plan is dated and needs reviewing urgently.

The site allocations plan where the land was identified as being suitable did not take into accountthe situation we are in now. Biodiversity/climate change are improtant factors that must be takeninto account.

There are little facilities in the area and Hartcliffe Way is hardly a high street and the area will beaffected by the new waste facilities as will any new residents if the houses are built. With the manyhouses being built on Airport Road and likely development of the old cinema & swimming pool atFilwood Broadway I do not believe there are adequate facilities or infrastructure to cope with anyfurther development in this area, there are few work opportunities.

The common (Village?) Green and hedgerows adjacent to the proposed site need protecting and

should not be disturbed.

We object most strongly to the destruction of wildlife and pollution caused by traffic soclose to local schools. With COP26 talking of the deforestation of land destroying Novers Hillslopes goes totally against Government guide lines. Broadmead is becoming a ghost town now isthe opportunity to revitalize & breathe new life into this area instead of desecrating Our beautifulNovers Hill Slopes.

It seems that every green space in South Bristol is being built upon. I feel that this is nota good idea in the current situation that we live e.g. climate change.

No

I strongly object to the building of houses on a vital wildlife corridor within the city ofBristol. I live on Novers hill and the plan has no access from the Hartcliffe way so the increasedtraffic would not be manageable. The proposed new homes would add a 1000+ car driving up anddown the narrow hill of Novers Hill. The road just isn't build for this project. I thought we weresaving green spaces and not building on them?? Matt Brooks

Given that Bristol has declared a climate and ecological emergency, building on thisbiodiversity rich land in close proximity to the city centre should no longer be considered possible -especially when BCC has now pledged to protect its existing green spaces. South Bristol is part ofBCC! Housing should instead be concentrated on existing brownfield sites. This is a harder taskfor BCC, as it may require compulsory purchase orders for disused sites - innovation is what isneeded, not the exploitation of the green spacesadjacent to some of our most vulnerableneibourhoods.Should any homes be build here their construction and lifetime energy use/needs shoukd also fitwith the zero carbon requirements of the BCC Climate Strategy and aim for carbon zero. Inaddition, for the 47 homes that may be affordable within this proposal, it is important to recognisethat to encourage community cohesion for future generations, affordable homes should be"pepperpotted" throughout the development and not be segregated in anyway from privatelyowned homes. A home should be a home, irrespective of who owns the deeds.

Western Slopes Planning application Dear Sir or Madam,

Sorry I have been unable to find the planning application number for the Western Slopes. So can you please confirm that you have received this email & it is being put against this planning application? Many thanks.

Please see my concerns regarding this planning application and why I am against them:

The site is on the nature-rich Western Slopes which stretch from Novers Hill down to Hartcliffe Way - an area of meadow and woodland.

It is a wild life corridor, home to birds, animals, insects & plant life. It is a site of nature conservation interest to be protected as it is a vital wildlife corridor

It is an ancient habitat which has never been cultivated so there are rare wild flowers which can be seen

If you drive along Harcliffe Way you can see how green it is, you can see horses in the field & birds flying overhead.

If the plans are passed the vast eco system will be destroyed. It is so very essential for this site to be kept for future generations.

Western Slopes is an asset to Bristol, it is one of the steepest points in Bristol, hence not suitable to be built on.

Re, the ozone layer etc. We should be protecting green field sites & only be building on brown field sites.

There are many pieces of land where buildings have been knocked down & left for years, builders should be made to build on these sites first.

I hope you will look into these matters for me and refuse the planning application. Yours sincerely.Mrs. C.J. Pratley,

My husband John and I wish to stand with the Bristolians who love our city. We realisethat this wildlife corridor contributes to the air we all breathe and is providing an accessible areafor outdoor recreation for our children's children. Look at the Downs! Ashton Court! It's timely tosafeguard these slopes now.

This development would only bring more traffic and pollution to an already busy andpolluted area.

This development would only bring more traffic and pollution to an already busy andpolluted area.

This application is for a site that has previously been marked as an area for natureconservation due to the wildlife it possess. Also, there has been no increase in infrustructure forthe increase in the number of motor vehicles that it would bring into the area. Not to mentionschools, gp surgeries or even amenities that aren't being increased to cope with this development.

To add to my previous comments...

The drains already struggle to cope. Whenever it rains, the drains overflow from all the draincovers on Novers Hill. Additional load on the local drains will only make this worse.

Also, Emergency services are already stretched very thin. In recent years I have called forambulances for non-life-threatening incidents (head injury and broken hip) and had to wait up to 5hours for the ambulance to arrive. More houses means more stress on emergency services andcould mean the difference between life and death for someone.

I am objecting to this application as I believe it is not compliant with the agreed2011/2014 Local Plan, and sets a precedence for similar sites across Bristol.In the local plan the site allocation (BSA114) states that the potential housing is estimated to be 50homes.This is the area of development immediately uphill of the existing Bristol Waste depot. Iunderstand that this is the "northern allocation" in the application.The applicant wishes to provide 75 homes (Planning Statement Para 4.2) on 69% of the spacewithin that site allocation (Planning Statement Para 7.14).This is an increase of 25 homes above the local plan figure, or an increase of 50% - on a smallerarea.

I am concerned that if agreed the application creates an intensity of buildings and people notenvisaged when the Local Plan was developed; but also sets a precedence for similar sites acrossBristol to be developed using figures that are significantly in excess of the Local Plan.Please note this is a personal objection and does not reflect the views of any organisation I aminvolved in.

The One City Ecological Strategy states we need to protect green spaces in Bristol.Developments like this should be built on brown land, not green areas like the Western Slopes.

The damage done to the ecology of Bristol by developments such as the proposed would beimpossible to mitigate for, and would cause irreversible damage to the ecology of the local area,both in terms of flora and fauna (meadow grass, badgers, bats etc)

Further, the benefit of this green space for the health and mental wellbeing of the local populationis immeasurable. Added to this is the increased burden on the already strained trafficinfrastructure once the development is populated.

This application must be rejected.

This application is an appalling proposal. The loss of such diverse woodland that cannotbe replaced. Bristol City Council is trying to champion climate action this is not reflected in theapplication. Not to mention the detrimental affect on mental health to local residents this will bringby taking away a green lung from South bristol. The absolute horror story of the affordable housingbeing a noise buffer between the recycling and roads and the more expensive properties isabhorrent. The drainage in this area is currently under emense pressure and struggles to copewith the more frequent wet weather.

In view of the drastic climate situation, this application should be rejected as our greenspaces act as the lungs of the city . A motion was passed by Bcc to stop all future developmentson green spaces using brownfield sites instead. The Mayor has said there is an ecological disasterand the loss of meadow, shrubs, trees and the valued wildlife will only hurry this. The area alsoprovides mental and physical wellbeing for the residents of one of the most deprived areas of thecity

This proposal is shockingly inadequate and spews out false claims in the hope that noone checks the validity of any of them.The concerns of building on this vital wildlife corridor, which has been voiced by all environmentalgroups around bristol - espeically the avon wildlife trust and the bristol tree forum. The claims thatthey will be 'building wildlife corridors' into this vast housing estate is a myth, it has been proventime and time again by many studies that within 3 years all wildlife disappears completely. Theyalso claim to be planting new trees down in crox bottom, which is already at 85% tree cover anddoes not need any more trees - a mythical statement.

Although most of my concerns for this development are for environmental reasons, there is a hugeincrease in occupancy in an area without providing additional public transportation, wastemanagement or road services to factor in the additional 600 residents expected in the area. Or thepotential increase in crime or traffic in the area as a result.

This sort of development has a HUGE impact on the local area and the proposals try to pretendlike they have covered all bases but they actually havent. I understand we have a housing crisisbut we also have a huge environmental crisis and the one is not more important than the other,mayor.

This comment is made on behalf of Sustrans to clarify our view on this development,following the inclusion of our informal comments in the Statement of Community Involvement.

Sustrans was contacted via email requesting a meeting regarding the development. Due to themany projects we are currently working on this invitation was declined, but a standard emailresponse was sent by Sustrans offering general encouragement for the inclusion of new walkingand cycling infrastructure and a list of useful resources. The line from our response - "That is greatnews that you are considering adding a dedicated walking and cycling path along the length of theproposed Novers Hill development" - has been used several times in the planning document.

While we stand by our encouragement for the inclusion of cycling infrastructure, we would like toclarify that this does not in itself constitute support for this development. We have not scrutinisedthe plans for the development or the walking/cycling infrastructure so we are not in a position tooffer an opinion on the suitability of these.

I'm concerned that this development will have a detrimental impact on wildlife in thearea which has already been negatively impacted by the recycling centre development. As thecouncil passed a motion to protect green spaces in the city approving this development would becontrary to this.The provision of 30% affordable housing is also completely insufficient given the green spacebeing removed. This area is already losing a lot of it's green spaces with other housingdevelopments in the area and the new recycling centre. The increase in traffic caused by thesenew developments will also increase pollution levels. I can't imagine that many of the newresidents will use the bus service as the routes are generally into central Bristol which is of no usewhen getting children to school locally before travelling.Please do not approve this planning application - once the greenbelt is built on it is lost forever.

I'm concerned that this development will have a detrimental impact on wildlife in thearea which has already been negatively impacted by the recycling centre development. As thecouncil passed a motion to protect green spaces in the city approving this development would becontrary to this.The provision of 30% affordable housing is also completely insufficient given the green spacebeing removed. This area is already losing a lot of it's green spaces with other housingdevelopments in the area and the new recycling centre. The increase in traffic caused by thesenew developments will also increase pollution levels. I can't imagine that many of the newresidents will use the bus service as the routes are generally into central Bristol which is of no usewhen getting children to school locally before travelling.Please do not approve this planning application - once the greenbelt is built on it is lost forever.

I object to building on this land, my bungalow backs on to the slopes and aside from allobvious reasons for objecting, saving green spaces, protecting habitats and wildlife an increase intraffic therefore more noise and more pollution. However a big concern is subsidence, in thishousing estate from houses 3 to 15 all which back on to the slopes , all of them have issues withsubsidence. I have spoken to a few of my neighbours and they have the same concerns and inprevious planning attempts when they weren't allow to build the fact that subsidence is an issuewas bought up time and time again. apparently the land is unsafe for building on it is bad enoughwhen some recent road works were carried out and the houses rumble and vibrate even when it isjust heavy traffic. I think building here is the worse ideal and in this area people do not haveenough green spaces or places to get out in to nature

As a local resident of Bedminster, I would like to formally state my opposition to theproposed plans for the Novers Hill development.

My understanding is that the development will result in the destruction of a significant Site ofNature Conservation, removing yet more of South Bristol's local green space and destroying thehabitat and hunting grounds of a huge number of species which are reliant on the area. Iunderstand the ancient hedgerow will be impacted and that a number of trees will have to befelled. This seems almost counter-intuitive at a time when the capacity of trees for carbon captureis so widely applauded. The biodiversity of any new planting space within the proposeddevelopment could not even begin to come close to that of such a mature and well-establishedgreen space.

In addition to my environmental objections, I am also concerned about the impact this newdevelopment will have on the local roads and the increased amount of vehicular traffic it will bring.This area is already heavily polluted with exhaust fumes and a nightmare for cyclists to navigatesafely, and I cannot imagine that making Novers Hill a one-way route will in any way improve thesituation.

This is shameful. Building car dependent sprawl on vital green spaces with the vastmajority of housing completely unaffordable and zero council housing. Tweeting aboutsustainability and how much you care about the environment means absolutely nothing when youare building over the green spaces Bristol people and nature need. You're not 'providing openpublic space' you're destroying it permanently for the benefit of developers. Oh, and addinghundreds more cars to Bristol illegal levels of air pollution in the process. Green city- what a joke

The loss of the green space and trees will add to the air pollution problem alreadypresent in this area. The increased traffic especially when running idly in queues will add to thepollution which will affect the health of everyone including those at the local primary school. This isin addition to the traffic already to beexpected from the siting of the new Recycling Centre.We can all enjoy the presence of a green wide open space together with the wildlife and localhorses. This will not be matched with the public space promised by the property developers.The noise of the traffic moving along Hartcliffe Way is already a constant hum similar to beingclose to a major highway, this will be exacerbated with the loss of the quiet outdoor that we alldeserve to be blessed with.Bristol South is becoming more and more densely populated and built up with no evidence ofimprovement and expansion of local amenities. We do not have competitively priced, regular andreliable public transport links to all areas of Bristol (except to the centre of Bristol) meaning peoplewould rather travel by cars causing more congestion and pollution. There is a lack of wide, safecycling lanes (and in fact some have been removed) and traffic calming systems in this area ofSouth Bristol. Therefore this new population are probably going to be car users.

I fully object to building on this site it flies in the face of everything COP26 stands for aswell as contradicting the Labour Mayor and Bristol City Council's manifesto

BIODIVERSITY - rare Horseshoe Bats, Badgers and ancient hedgerows will have their habitatdestroyed

NOISE AND POLLUTION - there is new recycling centre being built nearby, so nearby thedevelopers have suggested finding alternative ventilation for the properties. Increase in number ofcars in an already highly polluted area, increased traffic in the area again more noise andpollution. All without sufficient public transport infrastructure (now, not some nonsense about afuture underground system)

BUILDING ON GREEN FIELD SITE - there are many brownfield sites undeveloped in Bristol, let'sstart on these. Novers Hill is classed as "Prominent Green Hillside" and mapped as a "valuableurban landscape" in Bristol. Novers Hill in its' entirety is a Site of Nature Conservation Interest. In2.19.15 of Site Allocations and Development Management policies, it states that: "Sites of NatureConservation Interest (SNCIs) collectively represent the city's critical stock of natural capacity. Insome areas of Bristol, SNCIs offer people their only valuable contact with wildlife. Therefore,development proposals which would harm the nature conservation value of an SNCI will not bepermitted."Building here goes against everything Labour stand for.

As the founding member of the Crox Bottom Friends Group, I am writing to lodge myobjection to the planning application from Lovells to build 157 homes on the Novers Hill end of theWestern Slopes.

This planning permission should not be granted for the following reasons:

1) The council voted to protect green spaces from development on the 7th September, and toreview the Local plan. Therefore, no planning permissions should be granted, or even considered,until this review has taken place.

2) The site is designated as an SNCI. Avon Wildlife Trust and the Bristol Tree Forum are againstany development of any part of the Western Slopes, including Novers Hill. To allow thedevelopment of such an area would make a mockery of the council's Biodiversity Action Plan andthe declaration of Bristol's ecological emergency.

3) Novers Hill forms part of an important wildlife corridor linking Manor Woods Nature Reserve andCrox Bottom to the Northern Slopes. To build any number of houses on this site would destroy thiscorridor, no matter how many small green spaces were left between the houses. The area isestablished meadow, and development would mean this habitat was destroyed, losing all of thebiodiversity that resides there, including rare species of bats.

4) I read with interest that Lovell have proposed offsetting some of the impact of the developmentby improving areas of Crox Bottom in mitigation. This is impossible. Crox Bottom is classed as a

steep sided wooded valley. It is not the same habitat whatsoever and cannot provide analternative to Novers Hill. There is also no space within Crox Bottom to establish any other type ofhabitat, without removing some of what is already there, which would be completely irresponsibleand unacceptable. I might also add that not one person from Lovell has contacted the Friendsgroup with regards to this proposal. One would have considered that to be a basic courtesy, giventhe current tensions around the planning application.

Thank you for reading these objections. I hope that the application is not approved, for the sake ofthe future of biodiversity in South Bristol. We have recently seen large-scale and rapiddevelopment of any available space in South Bristol (around Hengrove Leisure centre, along thesouth Bristol Ring Road, at Imperial retail park, and soon to be at Hengrove Leisure Park). Thesewere all patches of green and trees: vital corridors for our wildlife from the surroundingcountryside, that are being closed off one by one. Please don't close Novers Hill as well.

Kind regards,

Caroline Lawrence

Crox Bottom Friends Group

The increase in pollution from traffic and the proposed change to one way Novers Hill isharmful to local people.The nearby area around Parson Street School has one of the highest levels of pollution in the cityand more cars will use these roads because of the changes caused by this development.

This does not create enough social housing for local people - only 47 homes will be sociallyrented/shared ownership. This is NOT council housing.The other 110 homes will be at "open market rate" - which is still unaffordable to most.We are losing yet another precious green space that so many benefit from.

The increase in pollution from traffic and the proposed change to one way Novers Hill isharmful to local people.The nearby area around Parson Street School has one of the highest levels of pollution in the cityand more cars will use these roads because of the changes caused by this development.

This does not create enough social housing for local people - only 47 homes will be sociallyrented/shared ownership. This is NOT council housing.The other 110 homes will be at "open market rate" - which is still unaffordable to most.We are losing yet another precious green space that so many benefit from.

Green belt land was put there for a reason. The quality of life is more important than justa question of squeezing as many new homes as possible out of an area that is especially loved bythe local population. We regularly walk on this land and therefore recognise it as a wildlife refuge.Bristol is supposed to be a green city and quite rightly so. Please think again.

South Bristol is having an inordinate amount of massive developments. This proposaltakes away yet another green belt , open field site, close to Hartcliffe in particular but also othersouth Bristol wards.

I object to any planning permission of any kind to be given on Novers Hill in belowgrounds:Preventing Global warming is not possible if planning permission continuously given on greenlands in Bristol and specially in south Bristol. It also conflicts with BCC's November 2018announcement on climate emergency and by the mayor's recent update on addressing both thedirect and indirect sources of the emissions that are responsible for climate change.South Bristol is suffering from poor air quality due to heavy traffic and lack of green spaces. Thishas been the result of excessive building projects on green lands in and around the area. Thegreen spaces are disappearing one by one with no hesitation on how much negative affect theyhave and will bring to local's health which includes children, ill people and elderly. Trees are beingcut and replaced with buildings for the past few years under the name of affordable housing yetthere is no control on rent prices which is much easier solution. Why not build on many brownfields for the purpose of increasing affordable housing if this is the main concern of the council.Novers Hill is a great asset to the area in every aspect. The nature is a home to variety of wildlifesuch as bats, badgers and birds which are very important and it is our responsibility to protectthem. It also has a unique combination of trees, flowers and plants which cannot be replaced onceits destroyed. The area has become a refuge to locals since the lockdown and continues to be theonly green area that those who suffer from mental health issues can use to relax and recuperate.This is essentially important for low income locals who can't afford traveling or paying forexpensive alternatives. Low income families with 2-3 children live in the area that need council'ssupport in terms of offering a safe and healthy area to live in. These children are our city's futuregeneration and their physical and mental health should be the main concern. Making them live inpolluted area for the purpose of generating income and profit for companies like Lovell is an

unforgivable crime. Increasing the population of the area that is already suffering from everyaspect is not a sustainable and responsible decision. People need houses and equally need greenareas around them to produces clean air and visually stimulates their mind. This is called quality oflife which everyone regardless of their income deserve it.Building houses on Novers Hill will bring so much air, noise and land and mental pollution that thelosses are way more than just offering few affordable houses. Low income locals won't afford anyof the expensive houses priced over £300,000 as part of this project.I would like to remind you that people who live in south Bristol are as important as any other areasin Bristol and you need to listen to their views, requests and do as they ask. Novers Hill if not moreis as unique and important and valuable as Clifton Downs for it's local and the whole city.I would like to remind you that recently, the full council passed Golden motion to protect all greenareas in Bristol which was remarkable and one big step towards the right direction to protect greenand wildlife which needs to be respected and followed.The full Novers Hill site must become officially a ''Nature Reserve'' to be protected from anycurrent or future attacks. I trust you listen to people's view and reject this planning permissionrequest for everyone's sake.

Destroying Novers Hill for the purpose of building houses is a wrong decision. This sitemust become officially a ''Nature Reserve'' to be protected from being destroyed. We need freshair and greens around us and no matter what part of Bristol we live in, air pollution in one areameans trouble for all Bristol. We are one city and my neighbours pain is my pain and we all shoulddo what we can to prevent the disasters from happening. Global warming is serious and wee needto save our green areas.

I am writing to object to planning application 21/05164/F. Principally, my objection is onthe grounds that this greenfield site should be retained in favour of development on brownfieldsites (of which Bristol has 248 according to the Brownfield Land Register). I note the application'sdeclaration that through off-setting there will be a bio-diversity net gain, however the potential ofthe green space for future biodiversity gain will be lost for good.

Having reviewed the planning documents, I believe there are a number of pros to thedevelopment, namely: good transport links; inclusion of footpaths and access through the area;inclusion of air source heat pumps; and majority of plots including gardens.

There are also a number of cons that I believe need to be addressed: The children's playground isvery small and appears to be the bare minimum to meet the planning requirement; Novers Hill isalready dangerous for pedestrians, this development offers nothing to improve that situation; thereis no provision of electric car chargers, car share, or visitor parking in the development plans;there appears to be no provision for bicycle storage.

I take issue with the conclusions of the Biodiversity report. In particular the conclusion that "shouldBristol City Council not agree to the use of the site as an offset, an alternative is to use a 3rd partyprovider to provide a net gain. Ethos Environmental Planning are working with a landowner nearNailsea on a biodiversity offset project." There is a risk that the proposed biodiversity offset will notbenefit either the local residents, or the occupiers of the proposed development. Surely more canbe done within the Novers Hill site to reduce the biodiversity loss; has the inclusion of a communitygarden and allotment been considered? Could there not be regeneration of the Pigeonhouse

Stream?

In addition, it is impossible to judge the proposal's compliance with the criteria "Integrateappropriate landscaping to ensure that green infrastructure links to the surrounding area aremaintained, including links to the Northern Slopes and Crox Bottom" and, "Maintain or strengthenthe integrity and connectivity of the Wildlife Network", as in the developer's own report they statethat the "The remainder of the allocation BSA1108 is to be delivered under a separate planningpermission, with an application yet to be submitted."

In conclusion, I fundamentally object to the proposed development of a greenfield site when somany brownfield sites remain undeveloped in Bristol. I also have a number of objections with thespecifics of this application and have proposed some improvements.

I object to this application for a number of reasons.

- Firstly, air quality is a real issue in Bristol, and to propose a development that would destroy anenvironment that captures carbon, whilst adding to carbon production (households, vehicles etc) isillogical. I live near the site and there is a 40mph road surrounding it which reduces air quality, plusindustrial sites nearby with more polluting heavy goods vehicles (which will only increase once therecycling centre is opened). This space (and others) acts as a buffer for residents and should beprotected and encouraged. When I was reading the Lovell literature and attended on onlinemeeting with them in July, it seemed air quality surveys had not been carried out.- Secondly, the plans for mitigating damage in the plans are insufficient and cannot get anywherenear the established hedgerows and tree growth. The area is a site of interest in terms of wildlife,valuable habitat and as such approving this would contradict the city's ecological strategy.- Another reason is there was a council vote in September on a motion to protect green spaces inthe city and prioritise brownfield, and I think the local plan should be updated reflecting this beforebuilding developments are approved.- The plans do not address the housing crisis in any meaningful way, which I acknowledge is anissue - with under 50 being allocated as 'affordable' (shared ownership/socially rented).- In addition, as far as I can see the plans for the development do not take advantage ofsustainable building methods like passive housing, or plan to have solar panels as standard.- Green space has been recognised as vital for ecological reasons and also health ones. For thepeople of South Bristol like me, we are proud of, and value the spaces we have near to us whichhave been vital sources of exercise and nature interaction, especially for those unable to travelfurther afield for cost or mobility issues.

- South Bristol's green spaces could be promoted in the same way other parts of Bristol have suchas Frome Valley Walkway and the Downs, bringing visitors who will help local businesses andhelp south Bristol shed some of the stigma is has had associated with it. A housing developmentcatering for car users next to the Hartcliffe Road will lead to people leaving the area to spend(which I suspect is happening at the Filwood Park development given the design, which could leadinto Filwood Broadway and help regenerate that area, doesn't, bafflingly) .

In conclusion, there are too many unknowns (air qual estimates) and known detrimental effects(habitat loss, carbon capture depletion) to do anything other than object to this proposal.

I object to the destruction of the beautiful hillside that is a very important and hugehabitat for may species of wildlife. It is a very important green corridor in south Bristol.

The development will not improve this large hillside that dominates the view from BedminsterDown. I can see horses grazing and many birds of prey flying overhead. I know that badgers,foxes and a huge amount of birds live on the slopes.

I think the increase in traffic will have a devastating impact on the local community, including at thepollution hotspot of Parson Street School. Hartcliffe Way is already congested at peak times, andthis is before the new recycling centre has even opened.

There are already many green spaces being lost to housing in this area. We should be building onbrownfield sites and saving our precious green spaces.

The development offers nothing to the local community and only includes a small number ofaffordable houses. They will be out of reach to most local people.

We already have overstretched services, such as doctors, dentists and schools, that won't havethe capacity to cope with these extra people. There are also no local shops within easy walkingdistance and no pubs or cafes.

I want to object to planning new housing on the land on the west side of Novers Hill inBristol, with planning application number 21/05164/F.It will significantly impact the whole neighborhood, overloading already heavy traffic as there is noplan to improve existing infrastructure, apart from making part of it a one-way street.So what then will happen with Novers Road and other streets?It is not a solution to this problem.There will be significant numbers of cars on the road creating heavy traffic and looking for parkingspace, and this will overload already busy streets, making it even more dangerous to walk anddrive.Not mentioning traffic noise affecting residents of Novers Hill, which rises on any occasion whenlocal streets are blocked. Novers Hill never complained before about too much attention of thelocal council regarding surface condition, cleaning frequency, or safety of users.Additionally, this is an area of green space and wildlife which is going to be lost forever. Any greenspace, especially one where we have established wildlife, should be protected, as Bristol councilstated many times, so if that is what we should keep and protect, why are Western Slops ofNovers Hill are exemption?There is no infrastructure to support those extra 157 houses, no roads, no school spaces forpupils, and you can't have health appointments because local GP Surgeries are too busy. There isvery weak public transport. It all will go with the cost of current residents' wellbeing and health nadmake more problems in future.

Yours sincerely

Dorota Mela

I do not want 150+ new homes built on green belt land thus destroying sorely needednatural habitat when there are other options for so called "affordable housing".Novers Lane and the surrounding roads are ill equipped to deal with the levels of traffic that thiswould bring.

The proposed development of 157 houses on the Western Slopes should be rejectedfor a number of reasons:

1. The removal of trees would increase the amount of air pollution in the local area. Parson StreetPrimary School, near to the proposed site has one of the highest levels of air pollution recorded ata Bristol school. There will also be an increase in traffic from the proposed development adding tothe existing congestion along the Hartcliffe Way and by Parson Street School. When you alsoconsider the increased traffic from those using the new recycling centre (currently being built), itwill be too much for the area which currently has cars sitting with engines idling in numerouslocations on a daily basis. Novers Hill will become even more of a rat run to avoid this, a one waysystem will not prevent that. This situation is unacceptable and will put local children's lives at risk,especially those with breathing conditions such as asthma.

2. There is a complete lack of any new amenities to serve the proposed development. Where willthe new residents work and attend school? Will there be new doctors' & dentists' surgeries andshops to help boost the local area? It currently looks like this will just add pressure to the existinginfrastructure and services. Lovell have stated in their research that "with regard to schoolscapacity, there is some evidence of primary schools in the area being at or above capacity". Iknow from personal experience that local GP and dental practices are at capacity and operatingwaiting lists. Similar developments in Hengrove and around Imperial Park are already increasingdemand on local amenities while simultaneously reducing the availability of green space. A lack ofamenities for the 157 proposed houses will force the new residents to use their cars and spendmoney elsewhere each time they need something.

3. The quality of the proposed housing is not acceptable. Lovell have admitted that the affordablehousing section (if delivered) is to be used as a noise barrier for the other houses. Affordable doesnot mean cheap so why should it be poorer quality? Even when discounted from market rate, theproperties will be too expensive for a lot of local people to afford. Why should the new residentshave to choose between the noise and smells of a recycling centre or keeping the windows closedon a hot day. AC is not a cost effective or environmentally friendly solution in 'affordable' housingaimed at poorer families. The design of the proposed cycle path in Lovell's plan is also very unsafe- it weaves in and out and straight onto the entrance to the industrial estate. How are thedevelopers going to ensure cyclists are kept safe given the increased amount of traffic in theimmediate area?

4. This location is designated as a 'prominent green hillside'. This means that development shouldnot be permitted unless the development is ancillary to the open space use, however this proposalwill not enhance the existing open space and goes against Core Strategy policy BCS9. This is alsocontrary to the recent motion passed on 7th Sept 2021 by the full council, to protect our greenspaces and prioritise brownfield sites. No building should take place on green space until the localplan is updated to reflect this democratic vote.

5. As a Site of Nature Conservation Interest, the unspoiled nature of the Western Slopes allows ahuge variety of plants, insects and other animals to be supported. It also feeds into the ecosystemof other local areas such as Pigeonhouse Stream, the Malago, Manor Woods and the NorthernSlopes. Destroying these habitats will cause huge ecological damage which is the completeopposite of BCC's Climate and Ecological Emergency Programme. This application is NOT one of"sustainable development". It will result in a significant net loss of ecological diversity that cannotbe mitigated on other green spaces. Mitigation on Crox bottom is not suitable because we arelosing a type of meadow that cannot be recreated. There is no space for this meadow at CroxBottom. There is also no room for additional trees - it is an already thriving ecosystem.

6. Animals from rare and protected species will be threatened if this application is allowed. RareHorseshoe bats and a well established, large colony of badgers will lose their habitat along withmany birds of prey that hunt in this area. The badger sets are due to be destroyed by the work toremove the Japanese Knotweed but the plan to move them to a man-made set has no guaranteesof success, especially with all the noise and disruption caused by the building work and then theproximity to the new development. The same applies to the bats. A recent survey has found 11species of bats including 2 very rare species in this location, yet this development would removemost of their habitat. The bat corridor is NOT sufficient and the noise and light from the buildingwork/new houses will disturb and disrupt their natural behaviour.

In light of all these objections please reject the application. The developer should use a moreappropriate brownfield site to build on and the valuable meadows on the Western Slopespreserved.

With little green space left in bristol it's vital we do our upmost to protect what we haveleft.We are trying to combat pollution and climate change internationally but yet here we aresqueezing hundreds of unnecessary housing in a built up area.The traffic this is going to cause will be incredible.It's so sad to see!Save our greenery, me, my future children and their children's children need fresh oxygen notpollution.

The Northern Slopes Initiative is a group of local volunteers who wish to the see theNorthern Slopes become a nature reserve for the health and well-being of people and wildlife.The Northern Slopes are 4 areas of green space (including Local Nature Reserves) to the east ofthe development site. Its most easterly site is covered by the Town and Village Green.The proposals for the TVG requires the loss of 92 square metres of land included in that area, atthe junction of Lynton Road and Novers Hill.We object on the basis that:- The area identified for the reprovision of this area does not fall within the Northern Slopes andtherefore is not likely to benefit users of the Slopes, both people and wildlife.- The proposals provide a function for users which is not the same as that provided on the Slopes -in that a LAP is provided within the reprovision.- We do not understand why the details of an application for the TVG change have not beenprovided at this stage so that people can fully understand the implications of what is beingproposed.- We note it is intended that area is repurposed to improve vehicle access to the area. Wequestion whether full consideration has been given to the road safety implications of thisdevelopment and potential harmful interactions between vehicles, cycle and scooter users andpedestrians.

We also object to the loss of green space through the development through an area whichprovides a critical link with the Northern Slopes and Crox Bottom/Manor Woods Valley andbeyond. This affects the way that wildlife reaches the Northern Slopes and return to sites furtherwest. To add more housing to the corridor increases the risk that wildlife further to the east on the

Northern Slopes will not travel to and from them, reducing the variety and richness of wildlife onthe Slopes. We believe that the whole of the Western Slopes (including the area owned by theCouncil) should be turned into a nature reserve and formal park to support the health and well-being of people and wildlife.

The Northern Slopes Initiative has noted that poor ground stability and drainage have causedsignificant delays and additional cost to construction projects on the slopes. Given the geologicalsimilarity of the Northern and Western Slopes it is likely that this will factor in any newdevelopment on the Western Slopes which in itself is an additional argument against using thearea for housing development.

I object to the application to build housing on the Western Slopes. It is a wildlife corridorand one of the 'Green Lungs' of South Bristol. It is necessary as an area for local wildlife to thriveand should be preserved. It is often noted by visitors how part of the cities character is that it hasthese green rural spaces amongst the housing. These places must be kept - they make the cityspecial. I enjoy the view over to the Western Slopes from where I live.

I dont want it to happen as it would make more traffic on the roads and it is a part of thegreen lands in the area that I live in which I walk around Daily

As a resident and home owner on Novers Hill , this development, if given the go aheadis going to cause absolute traffic chaos on what is already a very busy and dangerous hill. Theamount of pollution this will cause us will have a detrimental effect on our health as residents .Also the loss of what is a beautiful green space where we walk and take time to relax and take inthe wildlife around us . We often sit and watch nature at its best . To lose this is going to have aneffect on our wellbeing .

I fully object to the proposed development.

Building on this site would result in a tragic loss of green space and wildlife, impacting localpeoples mental health as well as the wildlife and biodiversity in the area. The land has beendeemed a vital wildlife corridor and no amount of mitigation could truly compensate for thedisruption and harm this would cause to the wildlife that inhabit the space.

There are plenty of brownfield sites that should be used before such historic, green spaces shouldbe used for housing. Approving this site will go against a recent motion passed by BCC to protectour green spaces and prioritise brownfield sites.

I am fortunate enough to enjoy a view of the green hills of this site, and take great joy in drawingmy curtains back in the morning and watching the horses on the fields, or admiring the sun peakover the horizon. I will lose privacy into my home from this development, and many choose to livein this suburb for the green spaces and building on this land would be a real travesty. My housedeeds date back to the 1900s and detail the rich history of these historic hedgerows and the landwhich surrounds us.

For a city which apparently is 'green', we do a pretty good job of trashing the few remaining greenspaces around us. This space is referred to as the lungs of South Bristol and even though the airaround here is still illegally high, how much worse will it be with 300 extra cars on the road whichwill come as a result of this development being approved?

That brings me to my next point, which is how the amenities in the area just are not set up to copewith any more houses. Having recently moved here I know how difficult it has been to getregistered with a local surgery- what is the plan for these new houses?

The prospective residents of these houses are also going to have to live with the noise pollution ofthe nearby trading estate and recycling centre, many having to leave their windows closed in thedaytime just to bring levels down to within the upper end of what's reasonable. With many nowworking from home, that doesn't strike me as a very realistic solution for the summer months?

If the council even consider passing this application then at least stipulate that the provision ofaffordable housing is increased, something with this city very much needs whilst there are luxuryhomes and apartments being built centrally.

This is an objection to the proposed Lovell development of 157 homes on Novers HillWesternSlopes.I live directly opposite the proposed development. We have lived here since 2014 at number 85Novers Hill.We chose this place for its privacy and light and knowing our neighbours. We believe it to be ahealthy place to bring up our young family.Here are the following reasons why this Lovell housing development will negatively impact us andthe area.Increase traffic making the roads more dangerous and pollution at a higher level. In an area wherethere is not the capacity on the roads or pavements to support the current population of the area.Where the pavements are not maintained by the council and brambles prevent them from beingused, and the road has continual temporary road surfaces, accidents are waiting to happen.With added work traffic already in the area with the developments that are happening here. HGVS,bikes, scooters, cars, mobility scooters and pedestrians (including many young families) all usethisroad together. There is no protection between road and pedestrian.If it is trying to avoid pot holes, not taking the bend tight enough, people driving too fast, bikehittinga pot hole, these are just some of the things I have witnessed as a pedestrian, driver and observerofthe road.Irreparable Damage to the established local ecosystem. Currently we have bats, magpies,

sparrowhawks, buzzards, kestrels, goldfinches, chaffinches, sparrows, badgers, hedgehogs, foxes,woodpigeons, slow worms, weasels, are just some of the creatures we have seen here.It will block our light by 90%. The impact of the housing development completed in 2016 which hasblocked light and is directly opposite part of this terrace of houses where we live, has given us ataster of what is to follow.Negative impact to physical and mental health. It is ironic that Knowle West was built because ofneeding to move people out of the built up, central city slums and now in 2021! It is becoming anever increasing built up area, that the delicate environment has not the capacity to cope with.

I'll open by pointing out that South Bristol is currently groaning under the weight ofhousing development with seemingly every bit of spare green space being grabbed and concretedover. If we are to have any regard at all in this city for 'the Earth beneath' then surely commonsense should prevail here. Clearing a space and felling trees to provide more space for aburgeoning population to dispose of more of their waste will produce more light, noise and trafficpollution in an already congested area - to then even consider building on a wildlife corridor thatnot only provides local people with the opportunity to feel like they are out in the countryside ontheir very own doorstep, it also provides visual respite and a way to watch the seasons comingand going - my house looks out on this site from across the way and not a day goes by when Idon't cast my eyes over to the green space and drink it in. This 'green finger' is an important bufferzone for wildlife in a city where such things are touted as being important but in reality are pushedaside in the name of progress. Wildlife thrives here as surveys have confirmed, local people valuethis site for relaxation and the chance to explore - if this land goes it will be gone forever - it is astable and established wildlife site on virgin land - it provides a breathing space - a green lung ifyou like - it is also a natural part of the geography around here - a steep sloping grassy areawhere the landscape can absorb rainfall and allow it to soak away. There is so much at stake here- housing needs must be met we are led to believe but avarice is a destructive thing and it cansteamroller through decisions that do not have future generations in mind - green belt and sitessuch as this should not be built on otherwise we just end up with urban sprawl - Bedminster,Withywood, Hartcliffe, Hengrove and Ashton Vale will all soon be joined up and there will be littleor nothing in between - in effect another town is being built in South Bristol but with all the bittyplanning applications it was difficult to keep tabs on - this site deserves better than that - as do thepeople and wildlife of South Bristol. A mature tree or a meadow cannot be replaced in any one

lifetime.

I am writing to object on behalf of my household. We currently live on Novers Hill buthave been residents of South Bristol for over 10 years. Novers Hill/Western Slopes has alwaysbeen held by us as an important wildlife corridor and visual reminder of how valued these greenspaces are to the urban landscape. Bristol is meant to be a city leader against climate changehaving declared an 'ecological emergency' so we need actions not just empty words and promisesin protecting our valuable green spaces.

Ecology:Secretary of States 2003 appeal decision against Persimmon Homes' development of Novers Hillstill holds true in all its key arguments. The inspector of this report noted that the site had city wideimportance and the 'adverse and permanent effects of the built development would be sufficientlylimited to be offset.'

The offsetting strategy outlined by Lovells is weak. They have proposed to this being offset at CroxBottom - this site is owned by the council and from their report it does not look like that thedeveloper has agreed with this approach. As this land isn't in the control of the applicant how canthey ensure that the management maintenance and monitoring of the net gain is secured in theirproposed time frame of 30 years?

As Crox Bottom is publicly accessible this makes it harder to deliver the management and 'netgain' they are attempting to offer. Alternative site suggested at Nailsea is a long way away andimportantly provides no equivalent benefit to local residents.

From the Pegasus report provided by Lovells it states 'remainder of the allocation BSA1108 is tobe delivered under a separate planning permission, with an application yet to be submitted. Thisportion of the allocation would address any connectivity to Crox Bottom located further south.' Thissuggests that this planning application is premature as it can't be demonstrated that thisconnectivity can actually be delivered. Lovells have also used out of date biodiversity metric 2.0where they should have used 3.0.

Novers Hill is an important section in a belt or chain of open grasslands, hedgerows and scrub -development would break and reduce the degree of ecological linkage with amongst othersNovers Common and Northern Slopes. This linkage cannot be easily mitigated by modals andassumptions of how wildlife will react to the destruction of their habitats. Novers Hill is such a richmix of habitats and areas that it can support such a diverse range of species such as badgers,foxes and smaller mammals such field mice,voles, moles and rare horseshoe bats. In the pastweek, I've spotted on four occasions birds of prey including kestrals and buzzards flying over theslopes.

Novers Hill was previously given the status of a Site of SNCI (Site of Nature Conservation Interest)- with citywide importance. This is why the writer of the Secretary of States report concluded that'It is its openness and its prominent 'natural' or undeveloped qualities that are in his view its mostimportant visual attributes. 'He goes on to comment that he does not consider this a degradedlandscape' but one which is obvioulsy thriving.

It also appears the Council haven't followed EIA regulations correctly as they have published theirEIA screening opinion in accordance with regulation 5 of the EIA regulations 2017. Pegasus say ithas been done but it isn't available on the planning portal.

It would appear statutory consultees such as the Environment Agency, Historic England andNatural England have not been consulted, which for a development of this size is of graveconcern.

Traffic, Transport & Amenities:I walk up and down Novers Hill every day for work. There are ways to make the road safer whichshould have been done many years ago. Making the road one way is not the only solution. Amuch simpler one would be to add traffic calming give way triangles along the length of the road,to slow traffic and provide safer pedestrianised areas.

In 2011 Bristol City Council installed traffic counters. These measured traffic Monday-Friday 7am-7pm. 2214 journeys down the hill, and 1619 up the hill were made daily on average. Regardless ofwhether the hill would be made one way, adding 157 houses in this development as well as theadditional traffic from other proposed developments in South Bristol (such as Hengrove airfield(1400 houses), BokLok (173 currently being built) as well as sites in Inns Court, Broadbury Road,Health Park and the Youth Zone) the cumulative effect of all these developments would mean not

only the traffic on the Hill increasing but also local roads in the area and Hartcliffe way wouldbecome even more congested than they already are. Quite simply the local infrastructure cannotcope.

There are highway safety issues related to all the increased traffic across the whole of Filwoodward as well as those neighbouring the development. Especially with Parson Street primary schooland Greenfield ACT primary school. The measured pollution levels are already dangerously highat both schools. Significantly, Lovells have also made no junction improvement to the bottom ofNovers Hill and Lynton Road. Should the actual validity of this application be brought intoquestion? Any major road planning changes need permissions before a planning application issubmitted and these have not yet been sought by Lovells.

In the Secretary of States report he 'did not find the site to be particularly well located in relation torailway stations and bus stops.' Its accessibility in modes other than the car was the only realoption for many. Apart from the addition of the M1 bus stops, which are not particularly close toeither end of the site therefore these traffic comments still remain valid.

There are obvious noise and light pollution aspects to also consider as well as the air pollutantsfrom all the increased car use.

Bristol City Council even before the pandemic, struggled to make timely bin collections so addinga further 157 houses will only exacerbate this. The same can be argued for the increaseddemands on local medical services and school class sizes. Again the cumulative impact ofdevelopments across the whole of South Bristol will make these issues completely unmanageable.

Proposed Site Housing Issues:

Town and village green - TVG - from studying the map, I do not believe this to be a true equivalentand I certainly do not believe the equivalent by function can be achieved in the areas earmarkedby Lovells. The enjoyment of the TVG space will not be equal for locals well as all residents ofBristol so Lovell's open space strategy is questionable. It says part of the site is land locked andan existing access can't be used. This means Lovells are breaching planning policy of theprotected TVG green space through the middle. It also appears they are double counting byproviding the public open space POS within the safe guarded corridor. Again this brings into thequestion the validity of this application as TVG status change should have been approved prior tothe application submission.

There is an important function performed by the site as recognised in the Secretary of State reportin separating residential development to the East of Novers Hill from the industrial and commercialdevelopment to north and west of the site.' This open space is a 'visual amenity even provides anoutlook, or variety in the urban scene. There is a definite visible impact of the designated open

space. From more distant viewpoints, such as the Clifton Suspension Bridge. There is also thevisible impact of lost hillside. This is felt along and around the Malago greenway. Visible openspace affords a relief to the adjacent built up area.

In analysing EBB768B404BF0FA73286FCCF11464FD1/pdf/21_05164_F-SITE_SECTIONS-3044944.pdf on the planning portal section 2 shows the building height of Flat Type A block 6 ashigher than the tree line, this is even with the provision of the block being 'sunk'. With the height ofblock 6 being so high this has a clear implications for loss of light and overshadowing for residentson Novers Hill. The sun sets behind Headley park and this is in the direct lines of the development.This loss of light and over shadowing will impact all the residential properties from numbers 53-77on Novers Hill. As well as a lesser extent, Haven House up to number 99 on Novers Hill. Photos ofthe loss of this light will be provided in photos emailed separately.

There are also clear privacy issues with balconies being installed down the sides of block 6 due tothe height breaching the tree line.

The topography of the site is steep in many areas so unless the build quality is very high, there arereasons to believe significant sections of the site could succumb to subsistence.

Point 7.9 on the housing allocation states that 'while the target yield of 50 dwellings is more thanmet within the proposal, this must be considered in the context of the extensive escalation ofhousing need' This shows that the numbers of housing on the smaller allocation far exceed policyso this isn't policy compliant.

On the same report 7.14 states 'application proposals only address 69% of allocation BSA1114,with the remaining south-western field within Council control. This area could therefore comeforward for employment development in future should the council elect to do so.' This brings intoquestion why haven't Lovells worked with the council to prepare a comprehensive masterplan forthe entire allocation which seeks to deliver a policy compliant scheme of 50 dwellings andbusiness uses that also seeks to deliver a 10% biodiversity net gain. While the applicant statesthat they have future proofed /safeguarded the remainder of the allocation, it is of a size andshape that would make it difficult to develop and therefore is unlikely to be developed in the future.Lovells should have demonstrated how the entire allocation could have been brought forward in away that delivers comprehensive and good design in accordance with the National Planning PolicyFramework.

Alternative Vision:

Ultimately, I do not feel this land should ever have been included in the outdated 2012 LocalRegeneration Plan. Regenerate brownfield sites, regeneration of a green field site is an oxymoron.This delicate eco-system can only be destroyed by a housing development.

This part of the city is relatively poorly provided with public parks in the local Filwood ward, and thelimited amount and distribution of the ward's publicly accessible space. So why not make thisunique site into what it is already in all but name - The Novers Nature Reserve.

Just like we all look back on disastrous post war town planning decisions, the next generation willnever forgive us if this decision goes against our precious green space to further harm andaccelerate the climate crisis.

I'll open by pointing out that South Bristol is currently groaning under the weight ofhousing development with seemingly every bit of spare green space being grabbed and concretedover. If we are to have any regard at all in this city for 'the Earth beneath' then surely commonsense should prevail here. Clearing a space and felling trees to provide more space for aburgeoning population to dispose of more of their waste will produce more light, noise and trafficpollution in an already congested area - to then even consider building on an adjacent wildlifecorridor that not only provides local people with the opportunity to feel like they are out in thecountryside on their very own doorstep, it also provides visual respite and a way to watch theseasons coming and going - my house looks out on this site from across the way and not a daygoes by when I don't cast my eyes over to the green space and drink it in. This 'green finger' is animportant buffer zone for wildlife in a city where such things are touted as being important but inreality are pushed aside in the name of progress. Wildlife thrives here as surveys have confirmed,local people value this site for relaxation and the chance to explore - if this land goes it will begone forever - it is a stable and established wildlife site on virgin land - it provides a breathingspace - a green lung if you like - it is also a natural part of the geography around here - a steepsloping grassy area where the landscape can absorb rainfall and allow it to soak away. There is somuch at stake here - housing needs must be met we are led to believe but avarice is a destructivething and it can steamroller through decisions that do not have future generations in mind - greenbelt and sites such as this should not be built on otherwise we just end up with urban sprawl -Bedminster, Withywood, Hartcliffe, Hengrove and Ashton Vale will all soon be joined up and therewill be little or nothing in between - in effect another town is being built in South Bristol but with allthe bitty planning applications it was difficult to keep tabs on - this site deserves better than that -as do the people and wildlife of South Bristol. A mature tree or a meadow cannot be replaced in

any one lifetime.

Inappropriate development on valued important open space and wildlife habitats.Destruction of this green lung would occur and loss of bio diversity at a time when Bristol shouldbe leading the way in preserving and valuing such natural spaces for future as well as currentBristolians, and which it purports to do.

I'm just astounded how this can be considered when Bristol has a declared climateemergency. I understand the need for affordable housing, but most of these plans only include avery small amount of this, and generally the affordable part isn't that affordable. Social housing issurely whats needed considering the rising cost of rents. I understand that there are plenty ofbrownfield sites identified by the University of the West of England.

More importantly, I live on the Parson Street gyratory system and the amount of pollution cominginto our homes and over our cars is truly alarming. If you build all the houses the you areconsidering, then it can only get worse. Already Parson Street school has illegal levels of pollution.

The green slopes offer a green lung to the south of Bristol and it will be a sad day if these are lost.

Disgusting to even think about using this land. What will happen to the horses, thewildlife that lives there. You BCC are building all over South Bristol, go build in Clifton if you haveto build anywhere.Also, what doctors are going to be used for the residents moving in, what schools? The local HC'sare too busy as it is and the education establishments.You are ruining Bristol with your cycle lanes, narrowing of pavements, cutting off roads, Bristol CityCentre, the shops in Broadmead will be closed within 10 years. Your ideas are selfish just to winbrownie points from the Government, to be the 1st, the top Council and no thought to theresidents.I schooled at Merrywood Girls, Knowle West was local to me and Novers Hill was part of that.You will get your own way though, you will bully your way through and sod the public, I can't waitto leave Bristol even though I was born and bred here 58 years ago, I'm starting to despise itbecause of BCC.

We should not be building on green spaces within the city, especially those which havenever been built on before and provide sanctuary for local wildlife, like the badgers we had thisspring!

Green spaces are also important for air quality, outdoor space to walk and play in, and have beenreally important for mental health, especially over the pandemic.

South Bristol's green hillsides are beautiful, and building over the green space will change the waythat the area looks forever. The Western Slopes are a slice of countryside in the city and I don'twant to imagine them being built over.

This area is close to one of the busiest and most polluted junctions in Bristol (Hartcliffe Way withBedminster Road). Additional homes will bring additional cars onto the road, and will contribute topollution in the area.

Finally, as a local resident I'm also concerned that houses are being built with no thought to localamenities, adding pressure to existing local services like GP surgeries and schools.

I wish to object to this Planning application as it goes against Bristol taking the lead indeclaring the 'climate emergency.'

Greenfield sites such as this one on Novers Hill provide important wildlife corridors supporting avast array of species from Badgers to Birds of Prey. Human impact of housing developments cannever be mitigated against leaving these green spaces well alone. Brownfield sites should bebrought forward and prioritised and greenfield sites should be an absolute last last resort.

Novers Hill has a diverse mix of shrub, grassland and trees, there are no guanrantees theinstallation of bat corridors and new badger setts will work, and if not, these habitats will bepermanently disturbed and potentially lost.

Traffic around the Novers Hill site on neighbouring roads and especially Hartcliffe Way is alreadyat breaking point, standing traffic is resulting in very dangerous levels of pollution at Parson Streetschool. Another 157 homes alongside all the other developments in South Bristol will onlyexacerbate these problems which are already acute.

I'm concerned about flooding due to increased run off into Pigeonhouse stream and along theMalago, and the steep gradients make me further worried about subsistence issues across the

site.

Ultimately an alternative use could be a nature reserve and city farm which would be a great assetfor residents of Knowle West who have limited access to green spaces and opportunities to benefitfrom the incredible green space that is Novers Hill.

I would like to register my OBJECTION to the Planning Application by Lovell Homes.The application has put in for 157 homes on part of the site.This would create terrible chaos because of the increased vehicles, also the lack of facilities ..school, Medical, shops and Public Houses for the total good and welfare of the Residents.This site was refused Planning once before for Lovells and in 2002 by the BCC and the Secretaryof State who wondered who would want to build on an asset such as this in Bristol.Nothing has changed in fact just two years ago a BCC Researcher identified that this and it'sadjoining site, all within the area known as the Western Slopes has a high value from anEcological aspect.BCC are leading the way to a Clean Air City and also very Ecological conscious but to grantpermission would be flying against their own beliefs and aspirations.It is also noted that on the 7th September 2021 a Full Committee passed a Resolution not to buildon any GREENFIELD SITES in Bristol.It must also be noted that all the Residents in the immediate area, plus those from Dundry,Headley Park, Bedminster Down, Kingsdown, Clifton and the multitude of public who pass throughthe area of the site which is part of the Western Slopes would be deprived of the current statusand would only have vision of houses. This would adversely effect their physical health andprobably more importantly, their Mental health.

I use these slopes for exercise and recreation, they should belong to the people andwildlife not be sold to developers to sell onto private landlords. Our green spaces make Knowlesuch a nice place to live and without them our mental health and physical health and fitness wouldsuffer.

Full Council vote to protect green spaces:Full Council voted in favour of keeping all green belt and green spaces in the city. No councillorsvoted against the motion. I don't think any further planning permissions should be granted forgreen space until that democratic wish has been put into the new Local Plan. The Local Planreview should be a priority and delivered way ahead of its current schedule. Because of theinterest generated by the Full Council vote there is a genuine opportunity to get a high level ofengagement and participation from local communities in shaping the new Local Plan.

Local Plan and Knowle West Regeneration Framework:The existing Local Plan is beyond its shelf life. And stuck in review. Site allocations were madebefore our knowledge of the climate and ecological emergencies had increased. Allocations thatwe may have felt comfortable with, now feel very out of date. The Local Plan itself is not widelyunderstood or known about by local people. The number of local people who responded to theLocal Plan or it's review is tiny, this will be very different now as communities begin to finallyunderstand how large chunks of their local green spaces get assigned for building. The Local Planalso took a shortcut on sites in the Filwood Ward by relying on the Knowle West RegenerationFramework. This approach has meant that communities surrounding Novers Hill who were not inthe Filwood Ward have never been invited to participate in shaping any ideas about the slopes.Novers Hill tips up to face neighbouring communities of Headley Park and Bedminster Down, yetthey have not been part of the discussion of its future.

Unsustainable development:Progressing Bristol's Development (the document that aims to fill the gap left by the out of date

Local Plan) talks about support for sustainable development but this proposal is not sustainable. Itwill result in a net loss to conservation, we can't carry on building like this. The design is veryintrusive and destructive of the hillside, at its highest the retaining wall between houses in4.8metre high, with a 1.8metre fence above it. That height is excessively high and will result ingardens with very little sunlight in them as the sun rises behind Novers Hill and sets at the front ofthe properties. A retaining wall the height of a double decker bus does not suggest asustainable low impact build. Little of the land left for nature will be left undisturbed. A large slopewill hold up the road, with crash barriers on the edge, much of the soil will be disturbed in thisconstruction, and there will be two areas of significant soil disturbance to remove knotweed and afurther third point of disturbance to dig out an artificial badger sett, and they will be a temporaryconstruction road between the two estates. There will also be a large number of trees lost in thebuild. Grassland will be lost. Subsidence issues are well known on the Western and NorthernSlopes, Torpoint slipped down the hillside, houses on Novers Lane have garden walls and shedsslipping down the hillside. Considerable parts of the hillside are old landfills that continue to slipand slide.

Previous applications refused:Previous applications for house building on this site have been refused. The reasons to protect thewildlife corridor of the ancient hedgerow are still valid, even more so now that the city has declaredan ecological emergency.

Environmental Impact Assessment:There doesn't seem to have been done, or not made available, why is that?

Ecological importance:Novers Hill is a Site of Nature Conservation Interest (SNCI), the whole of the hillside. Avon WildlifeTrust has spoken of the importance of this meadowhabitat.https://www.avonwildlifetrust.org.uk/news/support-bristols-green-spaces - It is a completeecosystem that supports many species. The development will result in a net loss to habitat andecology. The mitigation proposed on the site is flawed, for example counting new trees in backgardens as these will have no protection and if they survive will take 20 or 30 years to reach anylevel of maturity. But there is nothing to stop the homeowners or tenants from cutting down treesthat interrupt their views of the suspension bridge. Mitigation is not possible on the slopes, CroxBottom has been suggested but that site is not suitable to take meadowland as it is woodland andwater habitat.

The whole of Novers Hill is recognised by the West of England Nature Partnership as being part ofa nature recovery network, specifically as grassland network. In the proposed development theamount of land suggested to be left for wildlife is far too small, it won't sustain the vast numbers ofspecies on this hillside where I regularly see Kestrels, Buzzards, Sparrowhawks (and lessregularly) owls. The combination of meadow and tree cover is needed to provide all the speciesthat support these top level predators. 11 species of bat are recorded as using these slopes. The

moth diversity must be enormous as this is such a large unlit area. Bird life is very active, and youcan hear a vast variety of birdsong even above the traffic noise of the Hartcliffe Way and thesound of the industry alongside.

Tiny biodiversity enhancement areas:In the proposal there are tiny bits of land classed as "biodiversity enhancement areas", these arereally just scraps of land not big enough for housing. Although better than just paving them overthey are too small to make a significant contribution to biodiversity. Private gardens can be paved,astro turfed or concreted at the whim of the resident. This all points to a site that is not workinghard enough for biodiversity and unable to mitigate the loss on site. Lovell also used a betaversion of the Biodiversity net gain calculator despite a more recent version having been madeavailable. So even if the data they have come up with is inaccurate and especially cannot be reliedupon for the more 'wild' type of plantlife, which is exactly the habitat we need to maintain andincrease species in Bristol. Biodiversity offset is suggested at Crox Bottom but has not beenagreed, and the site seems unsuitable to recreate the lost meadowland. The importance of thespecific habitat on the Western Slopes is further demonstrated in this application by the othersuggested location for net gain being far outside Bristol in Nailsea. This does not benefit localresidents or the wider people of Bristol. Does the narrowness of the remaining nature strip reallyallow the wildlife corridor across the slopes to remain viable.

Business use missing from the proposal:The allocation BAS1114 is for a business and housing mix. Housing up to 50 homes. Thisproposal is using more housing than suggested in the allocation (74 homes) and the reasoning isnot well argued, as it leaves it to be resolved on the other allocation BSA1108 which doesn't havebusiness use in it. This opportunity to create local jobs could be lost. The proposal is across twoallocations, both should be considered together in full. This planning application should be linkedto any future application for the allocation BSA1108 and both be considered together due to thecombined business, housing, ecological, transport and pollution issues across the whole hillside.There has been no consultation on the allocation BSA1114 as only for homes, it has always beenconsulted on as a mix of employment and residential.

Pollution increase:There appear to be no or very little recent traffic surveys done, no data for the new recyclingcentre. No convincing consideration of the cumulative impact of all the new housing being builtnearby and the new increase for the recycling centre. These are all unverified predictions. Trafficpollution at Parson Street School is already dangerously high, and this site is not well served bypublic transport.

Noise pollution:Noise surveys carried out after the first lockdown when journeys and industry were not at usuallevels. Lovell describes the industrial buildings on the "...edge of the site to the north and eastabout a light industrial area with a garage, builders merchant and other light industrial uses..." This

doesn't seem accurate as there is already a large waste transfer site in the large blue buildings,https://www.recyclingbristol.com/waste-transfer-centre/ - The noise emitted from the new recyclingcentre currently being built is not known. The noise from the ETM waste transfer station just belowthe proposed estate can be loud. I can hear it over in Bedminster Down if the wind is blowing inmy direction. It is not unbearable at a distance but it surely will be incredibly loud to live right nextto this existing business. Surely we're not expecting the residents, especially of the social housingnoise buffer, to live inside with their windows shut and to stay inside. Will they not be sitting ingardens or strolling next to the drainage pit we are told is a nature feature, or by the 'orchard', afew trees at the car turning circle at the end of the estate. Will this existing business be forced tomove and take their jobs with them?

Local inaccuracies and lack of local knowledge:Lovell says "...a range of nearby facilities and amenities required on a day to day basis areavailable along Hartcliffe Way, with typical high street stores available...." There are no high streetshops on Hartcliffe Way (there are vehicle hire, hand car wash, waste transfer station), there areno pubs nearby. Headley Park is not near enough and not easily reached by foot from that topedge of Novers Hill (with no access through the industrial estate or across Pigeonhouse Stream).Bus stops on Hartcliffe Way are beyond the recommended walking distance and other stops on Novers Lane and heading south, not north into town.

Strain on local services:Further increase in housing will put strain on existing local services such as schools, GPs anddentists. The Health Impact Assessment seems to do little more than list local services. It is notjust the 157 homes from this proposal that need to be considered as there are so many projectsunderway or lined up. The new school is already delayed.

Loss of Town and Village Green protected land:More of the TVG is taken than is given back as a useful habitat. What is given is a playpark, thisisn't the same habitat. And this is on the strip of land that is not in either of the site allocations andcannot be built on anyway. To change the status of the TVG the council will need to apply to thesecretary of state, and I think would need to consult separately to this planning application withlocal people, as this TVG is clearly aiming to protect the land and hedgerow. This loss of habitatcannot be mitigated. Previous planning applications have been refused in order to protect thisancient hedgerow as a wildlife corridor.

Prominent hillside:The viewpoints and photos used in the application are misleading. For example the view fromManor Park is actually very low down on the Bedminster Down hillside. A more accurate view ofthe dominance of this hillside as a large green space with grazing horses can be seen fromBrooklyn Road, Ilchester Crescent, Ilchester Road, Valley Road, Eastlyn Road and so on. Walkingoff Bishopsworth Road onto Ilchester Road, as you reach the peak of the hill and start to movedownwards the huge green expanse of the Western Slopes tips up in front of you, breaking up the

buildings of the housing on the farthest side of the road of Novers Hill from the industrial units, forexample the large blue ETM building on the industrial estate that joins Hartcliffe Way. And loss ofthis green space of grass and trees will upset the existing balance and create anoverabundance of buildings with little or no greenery to break them up. This has been anundisturbed green hillside for years and has recovered from previous use as a landfill site. It hasnaturally recovered itself from previous use.

Road changes and cycle path:Changes to the road and cycle path need to be a separate consultation. Are these safe? The cyclepath if coming from the south begins on the right side of the road, half way along Novers Laneyou'll need to cross over the road to the left hand side. Then cross the first of the roads in and outof the upper estate (the only access), to join the cyclepath behind the hedgerow. Behind thehedgerow there will be low level lighting in an effort not to disturb the many bats that live or passthrough the site, will this be safe for cycling or walking when it's dark? At the other end of thehedgerow you need to cross the other road into the other estate (again the only access road inand out) and rejoin Novers Hill, At this point the hill is very steep and you'll need to go past theonly entrance and exit to industrial units, including a windows factory. Lovell have made acomparison with the lack of accidents involving bikes on the Hartcliffe Way cycle path. But thesetwo locations are not comparable, Hartcliffe Way has levelled off by this point and is wide, with notree cover or hedgerows obscuring entrances. Novers Hill is a steep, narrow hill and entrances tothe factory cannot be seen until you are level with them.

Will making the road one way mean more large lorries and local residents' cars need to pass bythe school children in the Greenfield Academy. Currently lorries can come and go using the lowerend of the hill at Parson Street. Length of journeys will be increased as lorries and cars will needto pass by more houses. Also there don't seem to be enough parking spaces, 3 and 4 bed housesonly have 2 spaces and 3 bed flats only one space. It is really unlikely that future residents are yetready to reduce car use, especially as the alternative public transport here is not good. Will thiscreate parking issues for the existing streets? This is local resident parking, not commuters, so it'sdifficult to see any parking scheme helping to solve the problem.

Flood protection:Drainage currently occurs naturally across the vast hillside, it can retain water for long periods oftime, releasing it slowly in the local waterways. A drainage pit that releases directly intoPigeonhouse Stream does not allow any time for pollutants to evaporate and sounds like apotential health and safety risk if the pond is not typically experienced as containing deep water.This will literally be a dark secluded backwater at the bottom edge of the estate and also seemsdesigned to encourage anti-social behaviour.

Future care for the natural areas:Lovell proposes to set up a Residents Management Company to run the common areas on theestates, so there will be ongoing costs to live here, presumably also for the affordable/social

properties. How do we know that future residents will not want to change the use or access of thecommon areas of the estates. I'm thinking of a scenario such as some anti-social behaviour in theplay park that causes residents to make these areas residents access only. These aren't reallyareas given to the wider community, they could become gated.

Pedestrian access across the slopes:In the proposal there is a secluded footpath that goes down towards the Hartcliffe Way end of theestate, around the back of a bin store, next to the drainage pit. It doesn't lead anywhere and feelsa very dangerous design, even if it were to be opened up to the industrial estate below. Accessdown the slopes to the Hartcliffe Way is needed if this site is to be properly linked to publictransport, but safety of that secluded route needs to be considered. It's the same landowner andshould be resolved in the one application. Also routes across the hillside are poor and onlyprovided by roads. This is not improving the landscape by creating green spaces that are pleasantand desirable to use.

Accessibility:Disability living allowance claimants in Filwood are almost twice the city average, yet the numberof accessible properties is low and links to public transport are not good. Overall there is very littlegiven back to the community in this proposal which harmfully encroaches onto views looking at thehillside and away from it. Paths across it are steep and winding, the extreme topography makes itdifferent to see a future resident being able to get easy access in and out without a car. Thenumber of adverse impacts surely outweigh any claims to provide homes, which seems to be theonly positive that it does fulfil.

Pre application consultation:The pre application consultation was poorly handled. There was a restricted access meeting(Zoom only) with Knowle West Future. Followed by an open meeting, also Zoom only despite achange in Coronavirus restrictions. This is in an area with below average access and use of digitalservices. Only one date was given, no documents shared ahead of the meeting and documentspresented were too small and detailed to follow easily during the meeting. No options werepresented and no changes appear to have been made to the proposal at all. Minutes of thediscussion were not made available. There were no further meetings or chances to ask furtherquestions or get answers to issues raised. The process felt very rushed.

Volume and complexity of planning application documents:There are a huge amount of complex and very large documents attached to this planningapplication. It feels almost deliberately designed to make it impenetrable to the average resident.There appears to be very little effort to plain English the proposals in a way that will be easilyunderstandable to the widest range of people. In all the many documents there are no mock ups ofhow the hillside will look with the proposed hillside.

Novers Nature Reserve:

We have an opportunity to provide something really good for local residents, something they canbe proud to have in their neighbourhood. The slopes should be protected as the nature reserve ithas become. Creating a Novers Hill Nature Reserve and truly opening up access for all will be areally valuable regeneration facility for local people, improving mental wellbeing and physicalhealth, maintaining and increasing biodiversity in the city. The slopes are already a completeecosystem, the type of environment we are now trying to shoehorn back into other parts of thecity. It's much harder to recreate once it's lost.

I am wholly against the building of these homes on land that is green space. Regardlessof percentages across the city this is our little piece of greenbelt, used by myself to walk and watchthe birds of prey and at night the bats. To lose this would greatly disadvantage our part of the cityfor people and animals. Another concern is the access points being on Novers Hill. This is anarrow lane with houses directly fronting one side and hedgerow the other. It's gradient is steepand it has no pavements either side. Last week the main part of Novers Lane was closed for work.The traffic was unbearable for noise and pollution but equally safety! The sheer volume and speedof traffic was dangerous. On two occasions I had to avoid other motorists and was very worried forpedestrians on the hill. This is not fit for access for this proposed development. Based on theparked cars outside the small recent estate at the top of the hill the plans fir 157 homes are notsatisfactory to give enough on road parking for residents of these new homes let alone deliveriesand visitors. This is a badly thought out and designed development that doesnt fit. I would suggestthe developer finds some of the numerous brownfield sites and builds there.

I've been a resident of Novers Hill since 1968. The wildlife on the hill has been aconstant source of fascination for all the family and should be protected for many generations tocome. Any housing will destroy this delicate ecosystem.

Traffic is too heavy on the Hill as it is, 157 extra houses here, plus all the others across SouthBristol will mean traffic chaos. Being a more elderly resident I do not agree with the one waysystem as this makes a very long round trip, should I just need to pop out for a short trip asunfortunately I'm ever more reliant on my car in later life.

Pollution and littering is very bad on Novers Hill and this will get worse. I'm concerned council andhealthcare services won't cope with the additional houses here and across South Bristol. Withprimary schools at Novers Lane and Parson Street all the extra cars and pollution is a worry for allthe kids that travel to these schools.

I believe for large parts of the site local residents will experience loss of light, privacy and overshadowing due to the front of the Novers Hill houses all getting the afternoon/evening sun.

Please protect this vital green space for all the people of Bristol.

NB: Due to my age one of my neighbours has kindly submitted this online application on my behalfbut I have agreed to this in advance.

I am strongly apposed to this land being used for housing at this stage due to ecologicalconcerns. We need to protect green spaces and prioritise building on brownfield sites. The habitatloss and net loss of ecological diversity cannot be mitigated. I am particularly concerned about therisk to the Horseshoe bats, although the hedgerow is 'protected' it is being altered in two places,there will also be a significant increase of light pollution and traffic pollution to this and otheranimals that are established in the area.

I am greatly concerned about the increase in pollution form traffic due to the new houses but alsodue to making Novers road one way - meaning hundreds of people will have to drive furthercausing more pollution and congestion.

I understand the need for more housing but using this valuable ecological area will havehorrendous consequences at a time when Bristol Council says it wants to fight the ecologicalemergency.

You will also impact the mental wellbeing of those around the area. Public transport links in thisarea are already poor, meaning locals rely on the green spaces around them for mental wellbeingand quality of life. This proposal sets a president for further development of the Western Slopes,an area of prominent green hillside.

My property will also be directly impacted by this development. I will loose my views of themeadowland and a huge chunk of my views of the wider city due to the houses and blocks of flats.This will directly impact the value of my property. BUT worse than that, it strips local recourse from

the area when in reality the properties will not actually be affordable to the average demographicof the area.

Having lost some of our local greenbelt land to development (which is on floodplain) it'san utter disgrace that councils especially Tewkesbury borough council do not support local peopleor do not have any power it what happens to our precious land. I strongly object to the plan ofbuilding on Novers Hill on the Western Slopes in Bristol, this land should be protected fromdevelopment to protect wildlife and ecosystem that obviously exists there. It is always withoutdoubt a better options to develop on Brown field sites other than destroying an beautiful areawhich local people are passionate about saving from the greedy developers who don't care. Thishas to stop. This area should be recognised as a nature reserve and protected.

I moved to the area because of The Western Slopes. Novers Hill is a local meadow landbeloved by the community. I often bump into people who are visiting the area to see the horsesand enjoy nature. The pocket of nature in an otherwise quite depressing landscape hugelyimproves the wellbeing and mental health of local people. This land should be protected. Thedeveloper claims the plans will "opening up" the site but the plans show fenced off areas and amassive loss of ecological diversity.

In addition, the plans have been publicised as if they are a social housing project or communitylead initiative. When in reality the consultation with residents was a joke and at times offensive.The plans do not create enough social housing for local people. The 'affordable housing' is sociallyrented/shared owner ship and the area's suggested for the shared ownership properties are (againoffensively) dumped next to the nearby industry/new recycling centre.

The people of Knowle West already feel let down by Bristol City Council and forgotten. ThisDevelopment needs to be seriously reconsidered for the sake of Knowle West and for the sake ofthe environment.

What makes a city a good place to live is not just having the kind of cheap shoddyhousing that has been built on the Northern Slopes, it is having a good quality of life, and amassive part of this comes from green spaces.

South Bristol is already lacking in good quality green spaces that north Bristol has. There isnothing in south Bristol to rival Stokes Park, Snuff mills, Oldbury court, Rodway Common andMangotsfield golf course. The Western Slopes is one of the few large green spaces and you wantto take this away. Green spaces aren't just for nature - they boost our mental health too and in sodoing provide a massive boost for our city.

A recent article in the New Scientist says "But even as the pandemic has highlighted them [thelinks between green space and mental wellbeing], it has also exposed that, in an increasinglyurbanised world, our access to nature is dwindling - and often the most socio-economicallydeprived people face the biggest barriers. Amid talk about building back better, there is an obviouswin-win-win here. Understand how to green the world's urban spaces the right way and it canboost human well-being, help redress social inequality and be a boon for the biodiversity we alldepend on."

https://www.newscientist.com/article/mg24933270-800-green-spaces-arent-just-for-nature-they-boost-our-mental-health-too/amp/

And here you are, a labour council wanting to destroy green spaces in our most deprived cityareas. Far from "greening the world's urab spaces", you're actually destroying them. It's sickening.

Your hypocrisy is sickening. You're meant to be standing up for people in deprived areas, and bybulldozing the Western Slopes you're showing how little you actually care about social inequality.These green spaces can't be brought back once you concrete them over to win some votes bycreating yet more cheap yet unaffordable housing.

I understand that new housing is important, but if it was so important, why would all the brownfieldsites in bedminster be earmarked for students instead of families and local residents?

Do not destroy our city. Please reconsider. If not your names will go down in history in the sameway as Colston's has. You will be shamed for hundreds of years as the people who built over ourprecious green spaces and inner city biodiversity even as world leaders met for crisis talks abouthow to save our planet.

I object to this. The land is an important green space, one of the few remaining areas ofsouth Bristol that has remained undeveloped. It retains rich diversity of animal and plant life thathas almost disappeared from the area. It is valuable to both nature and local residents and isecologically important to Bristol as a whole. It can not be replaced. This de elopement will also addpressure to an area already overwhelmed by development, putting further pressure on strainingroads and services, reducing the quality of life further for local residents and taking away a largeand important portion of what rural land is left. Concrete and brick on this kind of land in thislocation is not the answer to Bristol's housing problem. It needs protecting for wildlife and thehealth of the residents of south Bristol, not building on.

I am objecting to this application.There are a lot of practical reasons this site is not suitable for this development.The site is soft soils on sloping bed rock. I saw a lot of testing done, digging 10m deep pits , soilsamples, geophysics etc repeated.I think there is serious doubt that this is an easy or suitable site to build on from a technical point ofview.The development will destroy an important green area within a city, along with its wildlife.It will increase pressure on infrastructure and facilities in the local area.RoadsSchoolsHealthSewersIncreased local pollution -Parson st is regularly 200% of the government limit. School kidscampaigning to get people to turn off their engines.157 dwellings how many more school places?Will the new residents be able see a doctor/dentist or even register?Where will all the rain water and sewage go during extreme weather?The developers are suggesting doing work at Crox Bottom to offset damage caused by theirworks, to avoid breaching regulations.I don't believe this project has been well thought out.Yes we need houses, how many and where?

I am writing to object on behalf of my household. We currently live on Novers Hill buthave been residents of South Bristol for over 10 years. Novers Hill/Western Slopes has alwaysbeen held by us as an important wildlife corridor and visual reminder of how valued these greenspaces are to the urban landscape. Bristol is meant to be a city leader against climate changehaving declared an 'ecological emergency' so we need actions not just empty words and promisesin protecting our valuable green spaces.

Ecology:Secretary of States 2003 appeal decision against Persimmon Homes' development of Novers Hillstill holds true in all its key arguments. The inspector of this report noted that the site had city wideimportance and the 'adverse and permanent effects of the built development would be sufficientlylimited to be offset.'

The offsetting strategy outlined by Lovells is weak. They have proposed to this being offset at CroxBottom - this site is owned by the council and from their report it does not look like that thedeveloper has agreed with this approach. As this land isn't in the control of the applicant how canthey ensure that the management maintenance and monitoring of the net gain is secured in theirproposed time frame of 30 years?

As Crox Bottom is publicly accessible this makes it harder to deliver the management and 'netgain' they are attempting to offer. Alternative site suggested at Nailsea is a long way away andimportantly provides no equivalent benefit to local residents.

From the Pegasus report provided by Lovells it states 'remainder of the allocation BSA1108 is tobe delivered under a separate planning permission, with an application yet to be submitted. Thisportion of the allocation would address any connectivity to Crox Bottom located further south.' Thissuggests that this planning application is premature as it can't be demonstrated that thisconnectivity can actually be delivered. Lovells have also used out of date biodiversity metric 2.0where they should have used 3.0.

Novers Hill is an important section in a belt or chain of open grasslands, hedgerows and scrub -development would break and reduce the degree of ecological linkage with amongst othersNovers Common and Northern Slopes. This linkage cannot be easily mitigated by modals andassumptions of how wildlife will react to the destruction of their habitats. Novers Hill is such a richmix of habitats and areas that it can support such a diverse range of species such as badgers,foxes and smaller mammals such field mice,voles, moles and rare horseshoe bats. In the pastweek, I've spotted on four occasions birds of prey including kestrals and buzzards flying over theslopes.

Novers Hill was previously given the status of a Site of SNCI (Site of Nature Conservation Interest)- with citywide importance. This is why the writer of the Secretary of States report concluded that'It is its openness and its prominent 'natural' or undeveloped qualities that are in his view its mostimportant visual attributes. 'He goes on to comment that he does not consider this a degradedlandscape' but one which is obvioulsy thriving.

It also appears the Council haven't followed EIA regulations correctly as they have published theirEIA screening opinion in accordance with regulation 5 of the EIA regulations 2017. Pegasus say ithas been done but it isn't available on the planning portal.

It would appear statutory consultees such as the Environment Agency, Historic England andNatural England have not been consulted, which for a development of this size is of graveconcern.

Traffic, Transport & Amenities:I walk up and down Novers Hill every day for work. There are ways to make the road safer whichshould have been done many years ago. Making the road one way is not the only solution. Amuch simpler one would be to add traffic calming give way triangles along the length of the road,to slow traffic and provide safer pedestrianised areas.

In 2011 Bristol City Council installed traffic counters. These measured traffic Monday-Friday 7am-7pm. 2214 journeys down the hill, and 1619 up the hill were made daily on average. Regardless ofwhether the hill would be made one way, adding 157 houses in this development as well as theadditional traffic from other proposed developments in South Bristol (such as Hengrove airfield(1400 houses), BokLok (173 currently being built) as well as sites in Inns Court, Broadbury Road,Health Park and the Youth Zone) the cumulative effect of all these developments would mean not

only the traffic on the Hill increasing but also local roads in the area and Hartcliffe way wouldbecome even more congested than they already are. Quite simply the local infrastructure cannotcope.

There are highway safety issues related to all the increased traffic across the whole of Filwoodward as well as those neighbouring the development. Especially with Parson Street primary schooland Greenfield ACT primary school. The measured pollution levels are already dangerously highat both schools. Significantly, Lovells have also made no junction improvement to the bottom ofNovers Hill and Lynton Road. Should the actual validity of this application be brought intoquestion? Any major road planning changes need permissions before a planning application issubmitted and these have not yet been sought by Lovells.

In the Secretary of States report he 'did not find the site to be particularly well located in relation torailway stations and bus stops.' Its accessibility in modes other than the car was the only realoption for many. Apart from the addition of the M1 bus stops, which are not particularly close toeither end of the site therefore these traffic comments still remain valid.

There are obvious noise and light pollution aspects to also consider as well as the air pollutantsfrom all the increased car use.

Bristol City Council even before the pandemic, struggled to make timely bin collections so addinga further 157 houses will only exacerbate this. The same can be argued for the increaseddemands on local medical services and school class sizes. Again the cumulative impact ofdevelopments across the whole of South Bristol will make these issues completely unmanageable.

Proposed Site Housing Issues:

Town and village green - TVG - from studying the map, I do not believe this to be a true equivalentand I certainly do not believe the equivalent by function can be achieved in the areas earmarkedby Lovells. The enjoyment of the TVG space will not be equal for locals well as all residents ofBristol so Lovell's open space strategy is questionable. It says part of the site is land locked andan existing access can't be used. This means Lovells are breaching planning policy of theprotected TVG green space through the middle. It also appears they are double counting byproviding the public open space POS within the safe guarded corridor. Again this brings into thequestion the validity of this application as TVG status change should have been approved prior tothe application submission.

There is an important function performed by the site as recognised in the Secretary of State reportin separating residential development to the East of Novers Hill from the industrial and commercialdevelopment to north and west of the site.' This open space is a 'visual amenity even provides anoutlook, or variety in the urban scene. There is a definite visible impact of the designated open

space. From more distant viewpoints, such as the Clifton Suspension Bridge. There is also thevisible impact of lost hillside. This is felt along and around the Malago greenway. Visible openspace affords a relief to the adjacent built up area.

In analysing EBB768B404BF0FA73286FCCF11464FD1/pdf/21_05164_F-SITE_SECTIONS-3044944.pdf on the planning portal section 2 shows the building height of Flat Type A block 6 ashigher than the tree line, this is even with the provision of the block being 'sunk'. With the height ofblock 6 being so high this has a clear implications for loss of light and overshadowing for residentson Novers Hill. The sun sets behind Headley park and this is in the direct lines of the development.This loss of light and over shadowing will impact all the residential properties from numbers 53-77on Novers Hill. As well as a lesser extent, Haven House up to number 99 on Novers Hill. Photos ofthe loss of this light will be provided in photos emailed separately.

There are also clear privacy issues with balconies being installed down the sides of block 6 due tothe height breaching the tree line.

The topography of the site is steep in many areas so unless the build quality is very high, there arereasons to believe significant sections of the site could succumb to subsistence.

Point 7.9 on the housing allocation states that 'while the target yield of 50 dwellings is more thanmet within the proposal, this must be considered in the context of the extensive escalation ofhousing need' This shows that the numbers of housing on the smaller allocation far exceed policyso this isn't policy compliant.

On the same report 7.14 states 'application proposals only address 69% of allocation BSA1114,with the remaining south-western field within Council control. This area could therefore comeforward for employment development in future should the council elect to do so.' This brings intoquestion why haven't Lovells worked with the council to prepare a comprehensive masterplan forthe entire allocation which seeks to deliver a policy compliant scheme of 50 dwellings andbusiness uses that also seeks to deliver a 10% biodiversity net gain. While the applicant statesthat they have future proofed /safeguarded the remainder of the allocation, it is of a size andshape that would make it difficult to develop and therefore is unlikely to be developed in the future.Lovells should have demonstrated how the entire allocation could have been brought forward in away that delivers comprehensive and good design in accordance with the National Planning PolicyFramework.

Alternative Vision:

Ultimately, I do not feel this land should ever have been included in the outdated 2012 LocalRegeneration Plan. Regenerate brownfield sites, regeneration of a green field site is an oxymoron.This delicate eco-system can only be destroyed by a housing development.

This part of the city is relatively poorly provided with public parks in the local Filwood ward, and thelimited amount and distribution of the ward's publicly accessible space. So why not make thisunique site into what it is already in all but name - The Novers Nature Reserve.

Just like we all look back on disastrous post war town planning decisions, the next generation willnever forgive us if this decision goes against our precious green space to further harm andaccelerate the climate crisis.

My objections are as follows:-1.Traffic and Parking issues:-This site, if built on, would cause more traffic/ pollution, on the Heartcliffe Way, As well as, increased traffic, to and from the new Recycling Centre currently being constructed.

2. Amenity:- There is no 'infrastructure ' being built, to cater for the increased people, who will live there.e g. Shops/ G P surgeries/ schools/Dentists/ Chemists/Hairdressers, Barbers/Children's Play areas, as well as, reducing 'green areas', for 'well being' and exercise.

3.Wildlife:- It is a site of Nature Conservation, and acts as a 'corridor' for other wildlife/green areas. Wildlife lives there, which will be driven out.The ancient hedgerow, along Novers Hill, will be cut through, for access to this new, proposed, development. Hedgerows are a vital, shrinking, wildlife habitat, and I object to them being damaged in any way.

4.This 'Green Lung' , called Novers Hill, can be seen from Bristol City.The horses acted as management of the wildlife on this site.It is already reverting to scrub!They have been removed, so their influence has gone as well.This area has seen a great deal of our 'green spaces' being built on.This development will be the 'thin edge of the wedge' as far as I am concerned, and it should stop here,

Mr James Smith, local resident.

I object to this application because it is important to keep our green space for theenvironment and wildlife.I live on a already very busy road opposite a primary school I believe it would add more traffic tothe area therefore more air pollution

I believe we should have green space left in south bristol. This could be put to muchbetter use by putting a park in part of it for example.

There are plenty of brown field sites to build on in bristol and I don't see why south bristol takessuch a battering. We need more facilities before we build that many homes. Doctors areoversubscribed. No nhs dentists taking on patients. Schools oversubscribed. A and E over ran.You need more amenities before you pit in more homes!!

Novers Hill SNCI is completely unsuitable for Housing;planning has been refused on this same site twice previously (documents of which can berequested on the planning portal), which Lovell have failed to mention. It has been refused on thegrounds of irreparable damage to wildlife; the negative affect of development on the prominenthillside; the sustainability and access of the site and the overall benefits of development beingoutweighed by the reasons for it not being built. I believe these issues are even more relevanttoday.

Novers Hill is a Site of Nature Conservation Interest (SNCI) and a vital part of the Malago WildlifeCorridor. The Bristol Local Plan 2014 states that the site "is of city-wide importance to natureconservation". Bristol City Council's own Nature Conservation team has stated that if this site isused for housing "most of the habitat affected could not be recreated elsewhere within areasonable timescale, there is no potential for appropriate mitigation, and the integrity of theWildlife Network will be severely undermined".

Novers Hill is also identified by the West of England Nature Partnership as being part of a "naturerecovery network" encompassing "strategic grassland" and "woodland opportunities". BCC hasitself endorsed this wildlife network strategy as part of the Forest of Avon action plan. Novers Hillcontributes significantly to the 'Ecosystem services' that central government have incorporated intonational policy.

Avon Wildlife Trust has recently announced that Novers Hill should not be built on, and numerouswildlife experts (including Chris Packham!) have also echoed this same position.

Recently we have had a golden motion to protect our vital green space passed at full Council, withnot a single Councillor voting to oppose it. Novers Hill was specifically mentioned in this motion asone of the sites that must be protected.

It is well known that Bristol City Council has declared an ecological crisis, one of the first Council'sin the Country to do so, and now it must step up and prove that it can act appropriately. Both theMayor and BCC have recently confirmed that the city has planning permission for 12,000 newhomes already approved. What's more, the CPRE have stated that up to 30,000 homes could bebuilt in Bristol on brown field sites! Given everything described above it seems scandalous to methat this site is even being considered for housing at this time.

Reasons why this specific application should be refused;110 of these homes will be at open market rate, far more expensive than any local resident canafford. It is worth noting that the area of Fillwood is one of the most deprived in the UK. How willlocal people afford these homes, which will undoubtedly be more than £300,000k? And yet, thesesame people are seeing their much-loved green space of Novers Hill being taken from them.

I am also questioning how this allocation can be so different to what is allocated in the local plan.This site is BSA 1114, which has an allocation of 50 homes and mixed use with business. Thedeveloper is proposing solely housing and the number of dwellings on this specific allocation is farmore - 74. Also the allocation of part of BSA 1108 is part of a separate allocation for councilowned side. It is frustrating and seems like abuse and cherry-picking of the local plan.

The proposed Wildlife corridor is much too small. The development will not maintain the integrityand connectivity of the wildlife network. It has not strengthened it. Too many habitat units will belost, with a large net loss of biodiversity on the site. The majority of the meadow area is going tobe destroyed. The meadows count as a valuable part of the SNCI. Policy 2.19.15 of SiteAllocations and Development Management Policies states that "Sites of Nature Conservationcollectively represent the city's critical stock of natural capacity. In some areas of Bristol, SNCIsoffer people their only valuable contact with wildlife. Therefore, development proposals whichwould harm the nature conservation value of an SNCI will not be permitted". This point aloneshould be enough reason to stop this application - the meadow is part of the SNCI and will beharmed by development.The ecological mitigation measures suggested by the developer are inadequate.

Crox Bottom is not a suitable site for mitigation off-set because it is a very different habitat fromthat which will be lost on Novers Hill. Crox Bottom does not contain the type of ecologicallyvaluable grassland on Novers Hill, particularly calcareous grassland, lowland meadow and neutralgrassland. It is therefore not appropriate mitigation. The Friends of Crox Bottom have not beenapproached by Lovell and neither have BCC Parks department. As this has not been agreed yet,how can we be sure this will even take place? This should have been agreed prior to submission

of the application. The fact it has not been agreed suggests to me that the developer rushed thisapplication through and most likely knows the mitigation strategy is extremely weak and will not beaccepted. It is very obvious that Crox Bottom is not a suitable area for mitigation. It is anestablished habitat - densely wooded, with water pools. It has no grassland area that could beconverted to the kind of meadow lost on the Novers, over any reasonable timescale.

A site in Nailsea has also been suggested as an alternative site for mitigation. Nailsea is in NorthSomerset not Bristol. We would be losing a unique ecosystem in south Bristol, with the mitigationin another completely different geographic area. This suggests to me that the developer cannotfind an appropriate mitigation sites. In the Site Allocations and Development Management policy2013, it states that Novers Hill contains "the SNCI element of the site contains a number ofPrinciple Habitats and Species, which might be lost or harmed dependent on mitigation". It isevident that Lovell are struggling to mitigate adequately, meaning the SNCI will be irreparablyharmed, thus contravening policy.

A key finding in the ecology report was the presence of Greater & Lesser Horseshoe bats onNovers Hill. These are rare species that are in decline in the UK. The developer has claimed thatthey have left enough of a bat tree corridor to allow them to continue their commute through thesite. What they neglect to mention is that these bats require meadows to do their foraging, notwoodland. It is these valuable meadows that Lovell is planning to bulldoze.

Ethos ecological consultants carried out their botanical surveys during the period when heavyhorse grazing was still occurring on the site. Since the horses were removed in early June 2021,the wildflowers in the meadows have responded well. This was clearly evident from the roadside inAugust, and the ecology consultants should have carried out additional surveying to reflect thetrue botanical interest that was by then clearly obvious.

Similarly, Ethos did not carry out an invertebrate study because the grass was too short fromhorse grazing at the time of survey. The grass has since been allowed to grow, and I feel that anupdated survey for invertebrates should have been undertaken. They also stated that the horses"damaged the reptile mats" and made no attempt to re-do this survey, which to me, isunacceptable for an SNCI site such as this.

The large established badger colony is also a concern. The area proposed for their re-location ismuch smaller than the area they currently have accessible to them, and this may cause harm to acolony of this size.

The TVG proposed swap is not like-for-like in terms of function. The two areas have a completelydifferent ecological uses and function; we are losing ancient hedgerow in return for a small area ofplay. They are not the same.

In the Site Allocation and Development Management policies, DM17 2.17.3, the entirety of Novers

Hill is classed as "prominent green hillside". It states that "proposals which would harm importantfeatures such as green hillsides, promontories, ridges, valleys, gorges, areas of substantial treecover and distinctive manmade landscapes will not be permitted". Any development on Novers Hillwould harm the important feature of Novers Hill being a green hillside and therefore directly goagainst this policy. This point alone should be enough to stop this development. I wonder if this iswhy the developer has not provided us with any 3D artist impressions of what the development willlook like from a distance?

My other main concern with this application is the increase in road traffic and pollution it will bring,particularly with the proposed road change. The area around Parson Street Primary School isalready one of most polluted areas in Bristol. We continue to let these children down. This is notjust about the 200 or so new cars, but the fact that the one-way system will force many moreexisting vehicles onto Bedminster Road, Parson Street and the Hartcliffe Way, affecting not onlythe School but also traffic flow in & out of the new Waste/Recycling depot, which the BCCHighways department already had concerns about even before taking this application intoaccount. There are few shops and employment opportunities in this area. Most local people travelelsewhere for these things. This is not a sustainable location because of the heavy reliance on caruse.

The traffic assessment was carried out by Lovell during the lockdown! It's obviously not indicativeof the real situation on our roads. There is no evidence either that Lovell have considered thecumulative effect of all the many nearby developments that have been approved or have likelihoodof approval (too many to list). Good city planning would involve the investment in localinfrastructure and facilities before all this housing, to adequately support increased numbers ofpeople.

There is not sufficient public transport to support this application. The Lovell documents say thatthe development will be "well located for access into the centre of Bristol via regular bus routealong the Hartcliffe Way". The problem is that you can't actually get to Hartcliffe Way from theLovell development unless you wade across Pigeonhouse stream. Their proposed cut throughfrom the SUDS area through a non-existent lane down to the Hartcliffe Way, is exactly that -proposed. Again they are using theoretical "what ifs", to justify what is clearly an unsustainabledevelopment. Lovell doesn't own the land that the lane would go through and no application hasbeen made for it. Again, with bus stops, they mention Highbury Road. Only southbound busesstop here. Nobody travels southbound for any reason other than returning home. This bus stop isalso a huge walk from the development site and will not make any use of Lovell's other proposedpedestrian/cycle path as it is in the opposite direction.

From the beginning community engagement from Lovell has been very poor. The consultationphase was particularly shambolic, with Lovell attempting to carry it through in just three weeks.Many residents were locked out of the public consultation because Lovell decided to hide behindONE online zoom meeting. Covid restrictions had already ended by this time - it was an excuse for

them to avoid public scrutiny. Another huge issue with the allocation of this site is that it has neverbeen consulted on properly. Lovell continually peddle the notion that it is "an allocation in the localplan" and Knowle West Regeneration Framework. Neither of these plans consulted with residentsof Bishopsworth or Bedminster for what is clearly a cross-ward site. Residents of these areas arearguably closer to it than anyone in Knowle West, yet they were never included in consultations.This is a major flaw of the local plan allocation and therefore development of this site should behalted until further review.

The ecological report, crucial for a site such as this, was not made available before this meetingeven though the surveys had been carried out more than a year before! At that late-stage Lovellcould not tell concerned residents which way the proposed one-way system on Novers Hill wasgoing to go. When asked about how the increasing number of vehicles that might affect the trafficcoming in and out of the new Waste & Recycling depot on Hartcliffe Way, Lovell representativeshad shockingly, absolutely no knowledge of its' existence. Many important documents have onlybeen uploaded a few days away from the deadline for public comments. We have had to waitmore than a month for them to finally redact the location of the badger colony, which is alsocompletely unacceptable.

Finally, I want to mention the pub debacle. Lovell have stated that this development will be goodfor pubs in the surrounding area. But there are no pubs in that area, they have all closed. If Lovellhad taken the time to get to know the area they would already realise what an unsustainablelocation this is. When we pointed this out, they updated their documents to suggest the Maytreepub in Headley Park. The Maytree is 1.3 miles away on the other side of the Hartcliffe Way and anunbridged Pigeonhouse Stream!

Summary, and an alternative vision for Novers Hill;Both the site allocation for housing and this planning application are wholly inappropriate forNovers Hill. Building here will damage the environment, the wildlife network and the health of localpeople.What's more, given the recent golden motion passed to protect this site at full Council, buildinghere will also damage people's faith in local democracy.Instead, let's protect the entirety of Novers Hill and follow the call from the community to getNovers Hill protected once and for all as the Nature Reserve it should always have been. Peoplehere have had to fight this battle for over 40 years. The same issues of wildlife damage, access,effect on the landscape continually arise. Enough is enough. Its' protection will give so much hopeand positive wellbeing to thousands of local people. The support it provides to the hundreds ofspecies that have been recorded here (see BRERC) must be acknowledged once and for all.Leave this site alone.

There are so many empty or derelict buildings in Bristol that could be made intohousing. Please STOP building on green spaces. Bristol is supposed to be a green city but feelslike the exact opposite.

Save our slopes

I object to this development as I feel it is of great detriment the local area. Bristol is heldup as being a green city, and this development would go against that. Novers hill provides animportant wildlife corridor to crox bottom and manor woods valley, and this new developmentwould have a hugely negative impact on the wildlife in and around these areas. I feel that thisdevelopment is incredibly short sighted, due to the fact that there is no infrastructure to support it.There has been no thought for any additions of local amenities, shops, doctors, and the busservice is appalling. My wife has had to wait 40 minutes for a bus on more than one occasion thatnever turned up, which has forced her to walk through areas of Bristol late at night. The lack of busservice is surely going to force many (if not all) of the residents to be driving their own cars, whichwill clog up the roads in and around novers hill.

I'm concerned that this development will have a detrimental impact on wildlife in thearea which has already been negatively impacted by the recycling centre development. I believethe council passed a motion to protect green spaces in the city so approving this developmentseems contrary to this.

I love to walk in this beautiful place and it would be destroyed with the new housesbeing build

With already large developments of new housing in South Bristol and current housingareas requiring regeneration the further building on wildlife rich areas flies in the face of localconservation and Bristols commitment and policies re environmental protection and sustainability.The site further diminishes the green areas available to local wildlife and the slopes are anestablished bio diverse area of habitat. The destruction of these area do not only impact on theimmediate site under consideration but will separate wider surrounding areas of habitat for ourunder pressure local wildlife including protected species.With available grazing areas the slopes provide a crucial habitat that could continue to develop asa key area of nature and wilding for manyendangered species and are an important part of supporting local communities to have access tonature.Bristol City Council must not pretend that construction on these vulnerable sites can in any way beprotected or offset by developers plans .. once they are gone, they are gone.South Bristols local communities must have affordable housing but there is ample opportunity todevelop current under invested housing areas without sacrificing the last tensing areas of localnatural habitat.

This is a very valuable area of meadow grassland which supports animals, insects and protectedspecies, the loss of which will be devastating to the local area, residents and visitors.

Mental health and wellbeing are of paramount importance and local people will be directlyimpacted on both counts if this development goes ahead.

It is a much loved and well used green space and as such should have automatic protection fromany developmental proposals.

This development should happen, but not here. Secies rich grassland should not bedeveloped. COP 26 starts tomorrow

This ABSOLUTELY SHOULD NOT BE HAPPENING!We need to protect the eco system and the wildlife, the community needs this space!

I object to this development.

This is a 'prominent green hillside'

This location provides a unique location within South Bristol, to increase the tree canopy whichforms a essential part of a wildlife network. An important section of a chain of open grasslands,hedgerows, scrub and trees that extends from the South edge of the City via Manor Wood, CroxBottom and the Hengrove mounds, towards the city centre.This development will have a significant adverse effect on the feature.

Traffic, I live across from the Greenfields Academy and the parking of ever larger cars, theaddition of a Metro Bus route, and now the the possibility of 7.5 + tons vehicles are causingproblems for elderly and those with mobility problems. As the ever increasing size of the cars aretaking up more and more of the pavement. Forcing us to either cross the road onto the oppositeside of even sometimes Walk up the centre of the road. As the pavements are often unpassableduring school pick up times.

The proposal from the Friends of the Western slopes will provide much needed wellness andmental health benefits for the locals. And a Great addition for the rest of the city.

Thank you, Mike

The development on this green space would be a significant and permanent loss of awild life habitat at a time when Bristol City Council has declared an Ecological Emergency andalso when the government has announced that it will develop brown field sites over green spaces.How can this be allowed to happen taking into account the above?The green spaces in our city are valuable for wildlife and should be protected for futuregenerations to enjoy. They provide habitats for many protected species and wild life corridors &hedgerows for nature to thrive at a time when it is in decline, we should be doing all we can topreserve these environments and not destroying them.During lockdown we have benefited and appreciated our green spaces, the connection with naturehas helped our mental well being and encouraged an interest and love of the natural world aroundus, please do not allow this development to go ahead on this wild life rich green space.

I'm objecting due to the amount of traffic it will bring to the area, the anti socialbehaviour, the wildlife will be all put at risk.

I wish to object to this planning application on the basis of two main concerns:

- I am concerned about the loss of green space in this area of the city. Given the recent motion toprioritise building on brownfield sites and Bristol City Council's apparent commitment tosustainable development, granting permission to build on a space with significant ecological valueseems to completely contradict much of the local authority's communications.

- I am concerned that in return for this significant loss of green space, this development offers verylittle for the majority of local people. The provision of 30% 'affordable' housing is completelyinsufficient given the green space being removed in an area with such high levels of deprivation.

There is insufficient infrastructure in the area to support that number of new houses.The loss of green space and wildlife is inexcusable, given the amount of brown field sites availableto build on.

I am a born and raised Bristolian. I am very proud of that.

When growing up and going to school I used to get stuck in horrific amounts of traffic, the air wasdirty and it was a disgusting place to walk. The long Ashton bypass was supposed to fix that, andwhilst it made it better it is still bad. Adding 157 houses would not help this at all. Bristol roadscannot cope with that amount of traffic. We need to be providing clean air to our population, notmaking it sick. I was diagnosed diagnosed with Ashtma as a teenager and i believe the pollution inbristol was a contributing factor.

Living in a city has its positives and drawbacks. Every morning when I woke up and went outsidering my parents garden (Eastlyn road) I would be gifted gifted the site of Novers Hill and thewonderful horses than gallop on these slopes. To take this away would be a an unnecessarytravesty. My life would never be the same without watching those horses. Or without the gorgeousgreenery the slopes offer. We have already had houses built there, they are enough.

I please urge you to serious reconsider this planning application. Think of the wildlife that rely onour consciousness to survive. Think of those like me, who in difficult times such as the pandemicuse the view as a relief from the city. Please reject this application.

Thank you,

Grace Rees

The slopes house so much widelife, wildlife that already find it hard to live in a concrete jungle.Just honestly for once in our lives can we put wildlife first? Without wildlife there would be nopollination and with pollination, no food. Let's not think of ourselves.

I've lived here nearly all my life, I am now bringing up my 3 children here, they needspace, somewhere to go to get away from things, they need some freedom and walk along theslopes helps their mental health, everywhere else is built up, the amount of wildlife we would losewould be devastating, the birds, badgers foxes and many more is a asset to this area, do not buildon this green land, once it's gone it's gone forever

I strongly object to the development. Once precious green field land is lost it is goneforever. Wildlife habitat corridors should be protected and preserved. Brown field sites should beused not lovely areas such as this.If this land were in more well to do parts of the city it would noteven be considered it must be said.

I grew up near this site and enjoyed the green space and wildlife that enriches the areaso much. I am dismayed to hear that the land may be lost to development. Please do not grantplanning. In this day and age we must protect nature.

This lovely land is opposite my grand parents house, I can not believe that it may be lostto a housing development lining the pockets of developers to destroy a wonderfully diverse wildlife habitat. Nature needs protecting. I strongly object to the application.

Please do not grant planning for this housing development. The area greatly benefitsfrom the beauty and nature it provides. Nature corridors are precious and should be beingprotected. Use a brown field site instead, Bristol has too many of those. So much talk about airquality in Bristol surely preserving green field areas should be a priority in helping with this?

A recent report stated that the UK was one of the most nature depleted countries in theworld. We must, therefore, keep the green spaces we have left in the city for the benefit of all,nature included. There are plenty of derelict sites that can be built on.

I believe we need to take care of our natural environment and keeping are urban spacesfree for wildlife. We need to be using out brown field to support house building and not green.

This will be a loss of valuable open space to both local residents and also land that willdisturb the habitat of many animals and insects.

While I welcome the development of housing and affordable homes, I objectwholeheartedly to using green spaces that are essential to protecting what ecology remains in thiscity environment.

We need to preserve green spaces and biodiversity

Dear Council and Housing Developers

Please rethink your plan to build on the Novers Hill Southern slopes.

It is a species rich area and should be identified as an SSI.

Please do not proceed and allow homes to be built ..it is a place where other creatures havehomes.

Bristol council has made a number of excellent pledges to protect the environment, the localecology and to protect