Dear David,

We have now undertaken an initial analysis of the tree removal plans which are summarised below:

Clearly we need to see the plans for the changes to the highway and the river restoration before we can comment meaningfully on this application. Please advise who we should approach to see these.

Is it intended for council officers to comment on both the Arboricultural and ecological impacts?

Regards

Mark CD AshdownChair - Bristol Tree Forum

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exhausted, there is no realistic prospect that any of the trees lost will ever be replaced

offsite. As a result, these proposals fail because they do not comply with planning policies,

in particular with DM17: Development Involving Existing Green Infrastructure.

7. We calculate that the applicant’s proposals will result in a reduction of 42.28% biodiversity

net gain habitat units. The application should be rejected because it fails to achieve even

the zero net gain currently required by the LPA, let alone the 10% which will be required

when the Environment Act 2021 takes effect.

Background

The proposed development site1 at the junction of Malago Road and Hereford Street comprises

five elements, each with very different characteristics. The proposed site is some 1.02 hectares

and has, we estimate, tree cover comprising 48% of its area. The site was not part of the Site

Allocation identified in the 2014 Local Plan. It comprises:

Figure 1 The four separate elements of Plot 5, Bedminster Green

1 https://bristoltrees.space/Planning/application/QZW8O0DN0DG00

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1. The Hereford Street Public Car Park and the headquarters (called The Greenhouse) of

the Social Farms & Gardens,2 a UK-wide charity supporting communities to farm, garden

and grow together. The building has been there since the early 1990s. The trees on the

site are noted on the part of the Council’s asset register3 though the site is no longer

shown as a Council (BCC) asset4. The site is 0.35 hectares and has tree canopy cover

(TCC) of 59%

2. The Dalby Avenue Open Space covers 0.36 hectares and has a TCC of 73%. It belongs

to BCC and is designated a Park & Green Space5 and an Important Open Space6. Not

all of the site falls within the development area. There is a strip to the north along Malago

Road that falls outside it, as does an area (0.09 hectares with a TCC of 98%) to the south-

east through which the Malago River flows underground. There is a separate proposal to

restore the Malago River so that it flows above ground. Highways works are also proposed

along the northern strip. Both of these proposals will result in the removal of trees.

3. The Northern Commercial Zone lies to the north of Dalby Avenue Open Space. It

comprises two commercial buildings and related car parking. The site is 0.25 hectares

and has a TCC of 20%, mostly along its boundaries

4. The Southern Commercial Zone comprises a car repair garage with an undeveloped

triangle at its western-most tip. It lies to the south of Whitehouse Lane. It is 0.11

hectares and has a TCC of 29%, all of which is located on the undeveloped triangle.

Site Area (ha) TCC (ha) % TCC

All Plot 5 1.02 0.49 48%

Hereford St Public Car Park 0.35 0.21 59%

Dalby Ave Open Space 0.36 0.26 73%

Northern Commercial Zone 0.25 0.07 26%

Southern Commercial Zone 0.11 0.03 29%

Totals 1.07 0.57 53%

Table 1 The Plot 5 elements showing areas and percentage tree canopy cover

The planning context

The National Planning Policy Framework (the Framework), the Mitigation Hierarchy and Bristol’s

core planning policies, BCS9 – Green Infrastructure, DM15: Green Infrastructure Provision and

DM17 Development Involving Existing Green Infrastructure - the local policies upon which the

goals of the Framework may be achieved – are set out below. This is the case whether or not

2 https://www.farmgarden.org.uk/ 3 https://opendata.bristol.gov.uk/explore/dataset/trees/table/?q=hereford 4 https://maps.bristol.gov.uk/arcgis/rest/services/ext/INSPIRE/FeatureServer//2 5 https://maps.bristol.gov.uk/arcgis/rest/services/ext/datagov/FeatureServer//15 6 https://maps.bristol.gov.uk/arcgis/rest/services/ext/datagov/FeatureServer//208

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the relevant sections of the Environment Act 2021 have been enabled by the time this

application is decided.

1. The National Planning Policy Framework

This Framework seeks to ensure that new development is sustainable. It stresses the importance

of green Infrastructure as one of three overarching, interdependent objectives – economic,

social and environmental. This means that sustainable environmental development is no less

important than the economic and social development objectives.

The whole emphasis of the environmental objective has changed to become much more

imperative with the publication of the latest version of the Framework last July. It now reads:

an environmental objective – to protect and enhance our natural, built and historic

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

natural resources prudently, minimising waste and pollution, and mitigating and

adapting to climate change, including moving to a low carbon economy.

Furthermore, with the introduction of a new paragraph 131, trees are made an integral part of

this:

Trees make an important contribution to the character and quality of urban

environments and can also help mitigate and adapt to climate change. Planning policies

and decisions should ensure that new streets are tree-lined, that opportunities are taken

to incorporate trees elsewhere in developments (such as parks and community orchards),

that appropriate measures are in place to secure the long-term maintenance of newly-

planted trees, and that existing trees are retained wherever possible. Applicants and

local planning authorities should work with highways officers and tree officers to ensure

that the right trees are planted in the right places, and solutions are found that are

compatible with highways standards and the needs of different users.

Paragraph 174 states:

Planning policies and decisions should contribute to and enhance the natural and local

environment by:

a) protecting and enhancing valued landscapes, sites of biodiversity or geological value

and soils (in a manner commensurate with their statutory status or identified quality in

the development plan); …

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;

e) preventing new and existing development from contributing to, being put at

unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air,

water or noise pollution or land instability. Development should, wherever possible, help

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to improve local environmental conditions such as air and water quality, taking into

account relevant information such as river basin management plans …

Paragraph 180 states:

When determining planning applications, local planning authorities should apply the

following principles:

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;

a) development on land within or outside a Site of Special Scientific Interest, and which

is likely to have an adverse effect on it (either individually or in combination with other

developments), should not normally be permitted. The only exception is where the

benefits of the development in the location proposed clearly outweigh both its likely

impact on the features of the site that make it of special scientific interest, and any

broader impacts on the national network of Sites of Special Scientific Interest;

b) development resulting in the loss or deterioration of irreplaceable habitats (such as

ancient woodland and ancient or veteran trees) should be refused, unless there are

wholly exceptional reasons5863 and a suitable compensation strategy exists; and

c) development whose primary objective is to conserve or enhance biodiversity should

be supported; while opportunities to improve biodiversity in and around developments

should be integrated as part of their design, especially where this can secure measurable

net gains for biodiversity or enhance public access to nature where this is appropriate.

The status of habitat and biodiversity has also been given greater emphasis. Paragraph 181c)

now makes it clear that:

development whose primary objective is to conserve or enhance biodiversity should be

supported; while opportunities to improve biodiversity in and around developments

should be integrated as part of their design, especially where this can secure measurable

net gains for biodiversity or enhance public access to nature where this is appropriate.

2. Biodiversity Net Gain

With the publication of Biodiversity Metric 3.0, (BM3.0), a new way of measuring and accounting

for biodiversity losses and gains resulting from development or land management change has

been adopted. Net Gain is defined as an:

… approach to development that aims to leave the natural environment in a measurably

better state than beforehand. This means protecting existing habitats and ensuring that

lost or degraded environmental features are compensated for by restoring or creating

environmental features that are of greater value to wildlife and people. It does not

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change the fact that losses should be avoided where possible, a key part of adhering to

a core environmental planning principle called the mitigation hierarchy.

3. The Mitigation Hierarchy

Ideally, development should always be planned around existing trees whatever their size or

quality. This is because an established tree that is retained offers far more benefits and

ecoservices than newly planted trees (no matter how many are planted), whose potential will

take decades to be realised, if indeed it ever is.

The mitigation hierarchy provides a cascading decision process: only if the preceding choice is

unavailable is the next one considered.

1. Avoid - Where possible, habitat damage should be avoided.

2. Minimise - Where possible, habitat damage and loss should be minimised.

3. Remediate - Where possible, any damage or lost habitat should be restored.

4. Compensate - As a last resort, damaged or lost habitat should be compensated for.

4. Local planning policies

Local planning authorities have a duty to consider both the protection and planting of trees (an

important part of Green Infrastructure) when considering planning applications. The potential

impact of development on all trees is therefore a material consideration. The following key

planning policies relate to this application:7

a. BCS9: Green infrastructure

BCS9 states that ‘Individual green assets should be retained wherever possible and integrated

into new development.’

Where habitat damage cannot be avoided (which we would dispute), BTRS and the Biodiversity

Metric are two tools which the planning authority can use to ensure that:

• the integrity and connectivity of the strategic green infrastructure network will be

maintained, protected and enhanced

• opportunities to extend the coverage and connectivity of the existing strategic green

infrastructure network are taken

• individual green assets are retained wherever possible and integrated into new

development

• appropriate mitigation of the lost green infrastructure assets is required

• development should incorporate new and/or enhanced green infrastructure of an

appropriate type, standard and size

7 https://www.bristol.gov.uk/documents/20182/34540/Core+Strategy+WEB+PDF+(low+res+with+links)_0.pdf

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• where on-site provision of green infrastructure is not possible, contributions will be sought

to make appropriate provision for green infrastructure off site.

b. DM15: Green infrastructure provision

The provision of additional and/or improved management of existing trees will be expected as

part of the landscape treatment of new development. The design, size, species and placement

of trees provided as part of the landscape treatment will be expected to take practicable

opportunities to:

• connect the development site to the Strategic Green Infrastructure Network, and/or

Bristol Wildlife Network

• assist in reducing or mitigating run-off and flood risk on the development site

• assist in providing shade and shelter to address urban cooling

• create a strong framework of street trees to enclose or mitigate the visual impact of a

development.

We have set out Bristol’s planning policies as they relate to trees in more detail here - Planning

obligations in relation to trees in Bristol.

c. DM17: Development involving existing green infrastructure

Trees DM17 also recognises the important status of trees.

All new development should integrate important existing trees. Development which would

result in the loss of Ancient Woodland, Aged trees or Veteran trees will not be permitted.

Where tree loss or damage is essential to allow for appropriate development, replacement

trees of an appropriate species should be provided…

Due to their characteristics and value, Aged and Veteran trees are considered to be of

relatively greater importance than other trees and even trees of a similar species. Aged

trees, by definition, have developed characteristics associated with great age and often

have particular landscape and townscape value. Veteran trees are considered to have

particularly important nature conservation value. Both will often have significant visual

amenity, and potentially historic and cultural importance. As such their loss or harm will

not be permitted, and the design and layout of development will be expected to integrate

them into development.

Trees are considered valuable multifunctional green infrastructure assets. The policy

seeks to protect the most valuable trees and in line with the Core Strategy approach to

green infrastructure assets, mitigate for the loss of other important trees by securing

replacement trees on-site or in the public realm. The tree compensation standard set out

in this policy provides a suitable mechanism to determine the appropriate level of

mitigation where loss of trees is proposed as part of development.

The council’s Planning Obligations Supplementary Planning Document sets out the

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circumstances when off-site tree provision will be necessary. Where trees are to be

provided off-site, planning obligations will be sought to provide the appropriate number

of replacement trees, utilising the approach set out in the Supplementary Planning

Document…

Where trees are present on a development site a British Standard 5837 Tree Survey ‘Trees

in relation to Construction survey’ and related survey information should be submitted

along with an application for planning permission.

Important open spaces

Development on part, or all, of an Important Open Space as designated on the Policies

Map will not be permitted unless the development is ancillary to the open space use.

Important open spaces with a role and value for recreation, leisure, community use,

townscape, landscape or visual amenity quality are designated and shown on the Policies

Map and protected from development.

Under DM17, development of features such as these are not permitted:

• unless the development is ancillary to the open space use

• if it would result in the loss of open space which is locally important for recreation, leisure

and community use, townscape and visual amenity.

Tree survey analysis

The applicant has produced an Arboricultural Assessment and Method Statement (AIA) dated

September 2021 which is based on surveys undertaken in accordance with BS 5837:2012 on 15

June 2018 and updated on 16 March 2021. It is unclear if all the trees were resurveyed in March

2021 and had their dimensions updated.

The AIA identifies 106 trees comprising 10 individual trees (though the numbering starts at T11)

and 12 tree groups (though the numbering starts at G2 and omits G9).

We note the following anomalies:

1. There are seven species noted in group G7, but only five trees are listed.

2. There are six species noted in group G8, but only two trees are listed.

We have added six trees to the trees surveyed and used the data given for these groups.

The trees survey is divided into three separate groups comprising those trees impacted by the

developer’s, Dandara Ltd, proposals, trees impacted by unspecified works which the Highways

Authority plans to undertake, and unspecified works related to the restoration of the nearby

River Malago. On the basis of the data provided in the AIA we have identified the tree groups

as follows:

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Instigator

Canopy

Area

(ha)

Trees To

Remove

BTRS8

Replacements

Dandara Ltd 0.2297 38 74

Malago Restoration 0.1517 22 67

Highways Works 0.0653 8 34

Trees Retained 0.4606 38

Totals 0.9073 106 175

% Removed 49% 64%

Table 2 Tree works proposals

We are unable to comment on the merits of any proposed highways and Malago Rover

restoration works because these have not been made available, but we assume that, at least,

the Highways works arise as a result of these proposals and so are a relevant consideration

when deciding this application. We have asked for details of the proposed works, but these

have not yet been made available.

We note that many of the trees designated for removal to facilitate the Malago River restoration

are growing within the applicant’s development area (trees G8.2, G11.3, G11.4, G12.4, G12.7-

G12.9 & G12.11-G12.13).

The Environment Agency has also expressed concerns about the planned Malago restoration in

their letter of 12 November 2021.9 They state: “We have reviewed modelling and a draft FRA

in support of the proposed restoration of the River Malago, a designated ‘Main River’. We

understand that this be submitted as a separate planning application by Bristol City Council in

due course. We have raised a number of points about this modelling and recommended they be

addressed before formal planning permission is applied for, some of which are relevant to this

site.”

They also express concerns about flood risk: “In this instance the developer’s flood risk

assessment fails to demonstrate that the development is ‘safe’ for its lifetime and that flood

risk will not be increased in the surrounding area as a result.”

Given the interrelationship between these three proposed schemes, they ought to be

considered and resolved before this application is allowed to proceed.

8 Bristol Tree Replacement Standard - https://www.bristol.gov.uk/documents/20182/34520/SPD%20Final%20Doc%20Dec2012.pdf/daf75908-50fd-4138-afed-770310a6a431 - p20. 9 21_05219_F-ENVIRONMENT_AGENCY-3084547.pdf

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Dalby Avenue Open Space

We note that 43 of the 106 trees identified for removal are growing on the Dalby Avenue Open

Space. Some of these will be removed to facilitate the Highways works and some to facilitate

the Malago River restoration.

DM17: Development Involving Existing Green Infrastructure, states that ‘development on

part, or all, of an Important Open Space as designated on the Policies Map will not be

permitted [our emphasis] unless the development is ancillary to the open space use’ and that

development ‘which would result in the loss of open space which is locally important for

recreation, leisure and community use, townscape and visual amenity will not be permitted

[our emphasis]. Most of Dalby Avenue Open Space is designated an Important Open Space,

so for this reason alone this application cannot be permitted because the proposals are

not ‘ancillary to the open space use’. They arise because of the applicant’s proposals.

DM17: Development Involving Existing Green Infrastructure also states that ‘development

which would result in the loss of Ancient Woodland, Aged trees or Veteran trees will not be

permitted [our emphasis]. Many of the trees growing on Dalby Avenue Open Space are mature

and of high quality (most are listed as category ‘A’ under BS5837:2012). They should be

considered to be Aged trees or Veteran trees.

The potential application of BTRS

DM17: Development Involving Existing Green Infrastructure states that ‘Where tree loss or

damage is essential to allow for appropriate development, replacement trees of an appropriate

species should be provided’. The mechanism for achieving this is called the Bristol Tree

Replacement Standard (BTRS).

The AIA does not discuss how many replacement trees will be required under BTRS should this

proposal be allowed, but our analysis (see Table 2 above) shows that 175 trees overall will be

needed (74 due to the proposed development, 67 relating to the proposed Malago River

restoration and 34 caused by the proposed Highways works).

The applicant’s Ecological Assessment10 shows 39 trees to be planted on site (see Figure 2), so

space will need to be found offsite for the balance of 69 replacements overall.

10 21_05219_F-ECOLOGICAL_APPRAISAL-3045128.pdf

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Figure 2 Biodiversity Net Gain plan showing proposed new trees

In our view, the obligation imposed by DM17 to provide ‘replacement trees of an appropriate

species’ falls wholly on the applicant. This obligation cannot be considered discharged unless

the applicant has identified suitable new planting sites. Merely entering into a S106 agreement

to pay for the trees to be planted does not discharge the applicant’s obligations under DM17.

Whilst we estimate that there are only five tree planting sites currently available within a mile

of Dalby Avenue Open Space,11 they are all sites where a tree once grew. This means that

planting in these sites would not replace what will be lost as a result of this proposal; there

will be no net increase in tree cover overall, even if all the other outstanding S106 agreements

also ‘competing’ for these sites are ignored. The developer’s proposal to mitigate the loss of

these trees by planting new trees offsite is therefore unviable and unrealistic because there

are insufficient alternative new sites nearby. This application should be refused because it fails

to comply with planning policies BCS9 & DM17.

11 https://bristoltrees.space/trees/home.xq?_path=search/tree&state=Available%20for%20Sponsorship&range=1609&latitude=51.440613&longitude=-2.595514

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The Biodiversity Net Gain analysis

We have asked for a copy of the Biodiversity Metric Calculation (BNG 3.0) referenced in the

applicant’s Ecological Assessment but have yet to receive it. However, we have attempted to

reconstruct the calculation using the tables annexed to the assessment at Appendix E.

The assessment also annexes a baseline habitat map (Figure 3 below), but the key does not

match the habitats listed in the annexed tables. It is also notable that new trees appear to be

shown where existing, retained trees already grow (Table 2 cf. Table 3).

Figure 3 Ecological Assessment habitat map

Despite this, we have adopted all the habitats and parameters used, save for the following:

A-1 Site Habitat Baseline calculation

1. We have classified all the trees growing within the development area of Dalby Avenue

Open Space as a Woodland and forest - Other woodland; broadleaved in Moderate

condition. We have classified its strategic significance as Within area formally identified

in local strategy. This is because it is classified as both a Parks and Green Space and as

an Important Open Space. Using the measured canopy data reported in the AIA, we have

calculated that the habitat has an area of 0.584336 hectares of which 0.13272 hectares

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will be retained. This gives this habitat a baseline Habitat Unit (HU) value of 5.38.

2. We are already written about the failings of the BNG 3.0 methodology used in calculating

the area of Urban Habitats - Bristol Tree Forum response to the Small Sites Metric

consultation.12 Notwithstanding this and using Model One in the above paper we have

classified all the remaining trees growing on the development site as an Urban – Urban

Tree habitat covering an area of 0.2203 hectares, of which 0.0552 hectares will be

retained. The habitat is in Moderate condition with a strategic significance of

Area/compensation not in local strategy/no local strategy. This gives this habitat a

baseline HU value of 1.76.

3. We take issue with the classification of the hedge growing around the south-western

boundary of the Hereford St public car park as Introduced shrub rather than as a mixed

native species hedge habitat as the AIA describes it. We estimate that it is 60 metres

long and would fall to be replaced by another, similar hedgerow habitat. The fact that

it will be removed, as a result of proposed Highways works is irrelevant. It falls within

the development land and should be considered as a separate habitat in the baseline

calculations. We have assumed that the hedge is a Native Hedgerow habitat in good

condition and is worth 0.36 Hedgerow Units. The size of the Introduced shrub habitat

should be adjusted accordingly, though we have been unable to do this because the

Ecological Assessment fails to identify which Introduced shrub habitat covers this area

and the units of measurement are different (area cf. linear).

4. No BNG 3.0 analysis has been presented in relation to the proposed Highways and Malago

River restoration. Given our observations above, these calculations should be published

as part of this application or prepared if they have not already been undertaken.

A-2 Site Habitat Creation calculation

1. The evidence is that the applicant plans to plant 39 trees on site (Figure 2 above). We

have assumed that these will all be Medium-sized as per the BNG 3.0 guidance.

Size DBH

(cm)

RPA

Radius

(m)

Area

(ha)

Trees

per Ha

Small 10 1.2 0.0005 2,000

Medium 30 3.6 0.0041 244

Large 50 6 0.0113 89

Table 3 BNG 3.0 Guidance - Table 7.2

On this basis, the Urban – Urban Tree habitat created will have an area of 0.057 hectares

with a strategic significance of Area/compensation not in local strategy/no local

strategy and an area of 0.1017 hectares with a strategic significance as Within area

12 https://bristoltreeforum.org/2021/07/25/valuing-our-urban-trees/

14

formally identified in local strategy. None of the other parameters used by the applicant

have been changed.

2. We have assumed a delay in the creation of all new habitats of three years whilst

development takes place.

A-3 Site Habitat Enhancement calculation

3. The applicant has categorised the Distinctiveness parameters as Moderate, but as this

parameter cannot be set, we assume this is a mistake and have instead set the Condition

parameters to Moderate.

We note the Environment Agency’s comments on Biodiversity and river restoration –

“Insufficient information to assess any impacts on the water environment and geomorphology…

This objection is supported by paragraphs 174 and 180 of the National Planning Policy

Framework (NPPF) which recognise that the planning system should conserve and enhance the

environment by minimising impacts on and providing net gains for biodiversity.” Clearly, this

information needs to be provided as part of this application.

Notwithstanding this, on the basis of the proposal presented, we calculate that the applicant’s

proposals fail to achieve even neutral net gain, with a reduction of 42.28% Habitat Units. If

the Hedgerow habitat is taken into account there will be a loss of 100% of the Hedgerow Units.

We cannot comment on the impact which the proposed Malago River restoration might have on

biodiversity net gain overall though, as habitat, hedgerow and river units may not be combined,

it will make no difference of our conclusions. Figure 4 below shows the headline results.

Figure 4 BNG 3.0 Biodiversity Net Gain headline results

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Here is a breakdown of the loss of distinctiveness that will result from these proposals.

Figure 5 % Area lost by distinctiveness category

On this basis the application should be rejected because it fails to achieve even the neutral net

gain currently required by the LPA, let alone the 10% which will be required when the

Environment Act 2021 takes effect.

A copy of our BNG 3.0 calculation can be made available on request.

Bristol Tree Forum

17 January 2022

Its appalling that in the times of climate crisis we have companies like this who not onlydestroy important local habitant but also does it even before application was even considered.Sounds like a crime against local community to me. Bristol tree forum counted that 54 trees willhave to be replanted and who knows how many years waited to compensate the damage. Shameon you!

I am writing in support of the Tree Forum's comments. That this many trees are beingfelled in this day and age is beyond comprehension especially noting the Council's recent publiccomments on supporting street trees.

In addition the height and mass are out of proportion to the neighbourhood as seems to beincreasingly the norm with planning applications in south Bristol.

Yet again the application is being made (amd presumably will be considered) without reference tothe rest of the area and without any form of co-ordination so that a planned streetscape andbuilding design can be achieved.

This is geared to provide the maximum units for maximum developer profit as is to be expected. Itshould be the Council's role to ensure instead that we are left with just as many units in a moreacceptable, planned streetscape with mid and lowrise buildings consistent with the area.

Bristol Tree Forum - 21 March 2023 2

tree habitat areas.

5. This BNG 3.1 model has been produced as part of the Malago River restoration proposals.

As a result, the premises and parameters upon which these closely interlinked habitats

have been assessed are no longer aligned. Given this close interconnection between the

sites, it is important that these proposals are each assessed using the same metric.

We also note the following:

1. The applicant’s calculation – which we have had to undertake based on what little

evidence the applicant has produced – fails to comply with the BNG 3.0 Trading Rule

requirements. Medium Distinctiveness habitats have not been replaced in accordance with

Rule 3 of the BNG 3.0 User Guide, which requires that: ‘Trading down’ must be avoided.

Losses of habitat are to be compensated for on a “like for like” or “like for better” basis.

New or restored habitats should aim to achieve a higher distinctiveness and/or condition

than those lost’.

2. The applicant has failed to set out the methodology used to calculate baseline Urban tree

habitat areas.

3. The area of the development footprint and the habitat creation exceeds the area of the

habitat lost by 0.03 hectares, which is contrary to the requirements of BNG 3.0/3.1.

Tree removal by Bristol Highways Department

Highways has been undertaking works on Malago Road. This has resulted in the removal of 15

trees identified in the applicant’s AIA – T19, G2.2 – G2.11, G6.9, G6.11, G6.13 & G6.14. The

technical reasons for the removal of these trees are unclear, but we assume this was necessary

to facilitate these highways works. Many of these trees appear to have been growing within the

applicant’s proposed redline development area. Some were not identified for removal in the

application.

We are advised that Highways plans to comply with DM17. We calculate that 54 BTRS4 trees will

be required to replace what has been lost, but it remains unclear if all the trees removed by

Highways will indeed be replaced.

Taken together, these trees had a BNG 3.1 Urban tree habitat area of 0.1298 hectares, which

we have valued at 1.1426 BNG 3.1 Habitat Units – each being of Medium distinctiveness, in

Moderate condition and growing in an area of Medium strategic significance.

If they are to be replaced under BNG 3.1, then 279 Standard-sized trees will need to be planted,

each of which would need to grow into a BNG 3.1 Small-category tree with an Urban tree habitat

area of 0.0041 hectares after 30 years. This assumes that all the trees planted survive for 30

years. If a 10% net gain were required, then 307 such trees would have to be planted.

As highways projects are treated as Permitted Development, we understand that there is no

obligation for Highways to comply either with national or local planning policies in this regard.

4 Bristol Tree Replacement Standard.

Bristol Tree Forum - 21 March 2023 3

As a result, the Biodiversity losses we have identified will not be compensated for and Bristol

will suffer yet a further decline in both tree cover and biodiversity.

Compliance with the BNG 3.1 Trading Rules

We ask that the LPA exercise its discretion5 and require the applicant to update its

arboricultural and ecological evidence and to recast its BNG calculation using BNG 3.1.

We have recast our Biodiversity Metric calculation using BNG 3.1, which we submit with these

further comments. In particular, this uses the methodology set out at paragraph 7.9 of the BNG

3.1 User Guide for the baseline Urban tree habitat area, which advises:

The area calculation for Urban trees is worked out using the Root Protection Area

(RPA) (British Standards Institution, 2012)44 formula area = π × r2 where r is twelve

times the tree's Diameter at Breast Height (DBH) for a single stemmed tree. For multi-

stemmed trees the DBH of the largest stem in the cluster should be used to determine

radius (r).

• Where detailed measurements are available to the assessor, through an

Arboricultural Impact Assessment (AIA) or similar, these measurements should be

used to determine the area measurement for use with the biodiversity metric.

• The area of all trees within the project boundary should be accounted for,

regardless whether a tree would require root protective measures or not.

Therefore, DBH values within AIA reports should be used to calculate area

Our BNG 3.1 baseline Urban tree habitat area calculation is set out at Appendix 1.

Given the above, we have also recalculated the number of BTRS trees required under DM17 to

be 74 trees needed to compensate for the 38 trees which will be lost. The applicant plans to

plant 19 trees within Dalby Avenue Open Space plus another 20 elsewhere on the development

site, making a total of 39 new trees planned.

Whilst this is enough to satisfy the requirements of DM17, we calculate that there will still be

a net loss of Urban tree habitat of 0.87 units, which will need to be replaced in order to comply

with the BNG 3.1 Trading Rules.

To ensure that these are complied with, we calculate that a further 71 Standard-sized trees

need to be planted offsite in order to achieve BNG 3.1 Urban tree Small-category habitat size

after 30 years (assuming that none have died in the meantime).

In addition, 0.01 hectares each of Broad habitat Heathland and shrub (we have used Mixed

shrub habitat, which has Medium Distinctiveness, in our calculation) and Lakes - Ponds (Non-

Priority Habitat) habitat will also need to be created to comply with the BNG 3.1 Trading Rules.

5 http://publications.naturalengland.org.uk/publication/6049804846366720 - ‘Users of the previous Biodiversity Metric 3.0 should continue to use that metric (unless requested to do otherwise by their client or consenting body) ...’

Bristol Tree Forum - 21 March 2023 4

Save for this, we have adopted all the other areas and parameters used by the applicant in its

BNG 3.0 calculation.

On this basis, in order to comply with the BNG 3.1 Trading Rules, we calculate that the proposed

development needs to turn a 10.28% net habitat gain into a 31.14% net habitat gain.

Figure 1: Headline BNG 3.1 Calculation

Bristol Tree Forum - 21 March 2023 5

Appendix 1

Methodology used to calculate the baseline habitat area of the Urban tree habitat

on the development site.

Tree

Count

Trees

Removed

Baseline

RPA

(ha)

RPA

removed

(ha)

RPA

Retained

(ha)

62 38 0.4161 0.1519 0.2641

Tree

ID

Tree

Count

Trees

Removed

DBH

(cm)

RPA

(m^2)

Baseline

RPA

(ha)

RPA

removed

(ha)

RPA

Retained

(ha)

T11 1 1 40 72.38 0.0072 0.0072 0.0000

T12 1 1 38 65.33 0.0065 0.0065 0.0000

T13 1 1 20 18.10 0.0018 0.0018 0.0000

T14 1 1 21 19.95 0.0020 0.0020 0.0000

T15 1 1 13 7.65 0.0008 0.0008 0.0000

T16 1 1 21 19.95 0.0020 0.0020 0.0000

T17 1 1 36 58.63 0.0059 0.0059 0.0000

T19

T20

T21

G2

G.2.1 1 1 32 46.32 0.0046 0.0046 0.0000

G2.2

G2.3

G2.4

G2.5

G2.6

G2.7

G2.8

G2.9

G2.10

Bristol Tree Forum - 21 March 2023 6

Tree

ID

Tree

Count

Trees

Removed

DBH

(cm)

RPA

(m^2)

Baseline

RPA

(ha)

RPA

removed

(ha)

RPA

Retained

(ha)

G2.11

G3

G3.1 1 1 12 6.51 0.0007 0.0007 0.0000

G3.2 1 1 18 14.66 0.0015 0.0015 0.0000

G3.3 1 1 10 4.52 0.0005 0.0005 0.0000

G3.4 1 1 10 4.52 0.0005 0.0005 0.0000

G3.5 1 1 10 4.52 0.0005 0.0005 0.0000

G3.6 1 1 45 91.61 0.0092 0.0092 0.0000

G3.7 1 1 18 14.66 0.0015 0.0015 0.0000

G3.8 1 1 13 7.65 0.0008 0.0008 0.0000

G3.9 1 1 22 21.90 0.0022 0.0022 0.0000

G3.10 1 1 29 38.05 0.0038 0.0038 0.0000

G3.11 1 1 24 26.06 0.0026 0.0026 0.0000

G3.12 1 1 13 7.65 0.0008 0.0008 0.0000

G3.13 1 1 16 11.58 0.0012 0.0012 0.0000

G3.14 1 1 40 72.38 0.0072 0.0072 0.0000

G3.15 1 1 28 35.47 0.0035 0.0035 0.0000

G3.16 1 1 30 40.72 0.0041 0.0041 0.0000

G3.17 1 1 11 5.47 0.0005 0.0005 0.0000

G3.18 1 1 17 13.07 0.0013 0.0013 0.0000

G3.19 1 1 11 5.47 0.0005 0.0005 0.0000

G3.20 1 1 20 18.10 0.0018 0.0018 0.0000

G3.21 1 1 14 8.87 0.0009 0.0009 0.0000

G3.22 1 1 25 28.27 0.0028 0.0028 0.0000

G3.23 1 1 65 191.13 0.0191 0.0191 0.0000

G4

G4.1 1 1 26 30.58 0.0031 0.0031 0.0000

G4.2 1 1 20 18.10 0.0018 0.0018 0.0000

G5

G5.1 1 0 28 35.47 0.0035 0.0000 0.0035

G5.2 1 1 26 30.58 0.0031 0.0031 0.0000

G6

G6.1 1 0 42 79.80 0.0080 0.0000 0.0080

G6.2 1 0 46 95.73 0.0096 0.0000 0.0096

G6.3 1 0 39 68.81 0.0069 0.0000 0.0069

G6.4 1 0 41 76.05 0.0076 0.0000 0.0076

G6.5 1 0 39 68.81 0.0069 0.0000 0.0069

G6.6 1 0 34 52.30 0.0052 0.0000 0.0052

Bristol Tree Forum - 21 March 2023 7

Tree

ID

Tree

Count

Trees

Removed

DBH

(cm)

RPA

(m^2)

Baseline

RPA

(ha)

RPA

removed

(ha)

RPA

Retained

(ha)

G6.7 1 0 47 99.93 0.0100 0.0000 0.0100

G6.8 1 0 42 79.80 0.0080 0.0000 0.0080

G6.9

G6.10 1 0 38 65.33 0.0065 0.0000 0.0065

G6.11

G6.12 1 0 37 61.93 0.0062 0.0000 0.0062

G6.13

G6.14

G6.15 1 0 26 30.58 0.0031 0.0000 0.0031

G7

G7.1 1 1 16 11.58 0.0012 0.0012 0.0000

G7.2 1 0 28 35.47 0.0035 0.0000 0.0035

G7.3 1 1 71 228.05 0.0228 0.0228 0.0000

G7.4 1 0 13 7.65 0.0008 0.0000 0.0008

G7.5 1 1 65 191.13 0.0191 0.0191 0.0000

G8

G8.1 1 1 25 28.27 0.0028 0.0028 0.0000

G8.2

G10

G10.1

G10.2

G11

G11.1

G11.2

G11.3

G11.4

G11.5 1 0 35 55.42 0.0055 0.0000 0.0055

G11.6 1 0 58 152.18 0.0152 0.0000 0.0152

G11.7 1 0 49 108.62 0.0109 0.0000 0.0109

G11.8 1 0 52 122.33 0.0122 0.0000 0.0122

G11.9 1 0 63 179.55 0.0180 0.0000 0.0180

G11.10 1 0 75 254.47 0.0254 0.0000 0.0254

G12

G12.1

Bristol Tree Forum - 21 March 2023 8

Tree

ID

Tree

Count

Trees

Removed

DBH

(cm)

RPA

(m^2)

Baseline

RPA

(ha)

RPA

removed

(ha)

RPA

Retained

(ha)

G12.2

G12.3

G12.4

G12.5

G12.6

G12.7

G12.8

G12.9

G12.10

G12.11

G12.12

G12.13

G13

G13.1 1 0 81 296.81 0.0297 0.0000 0.0297

G13.2 1 0 92 382.90 0.0383 0.0000 0.0383

G14

G14.1 1 0 53 127.08 0.0127 0.0000 0.0127

G14.2 1 0 48 104.23 0.0104 0.0000 0.0104

Dear David,

I must also add that I find it quite unbelievable that the developer should have takenpreemptive action to remove these trees while their application is pending. Was thisstep agreed with you?

I appreciate that, in law, there is nothing to prevent them doing this because the site hasno statutory or policy protections. However, by their actions, the developer haseffectively removed one of a number of possible development options which mightotherwise have been available to planners or considered by the committee deciding thismatter that they might otherwise have had.

Needless to say, this puts me in mind to the similar preemptive action taken by thedevelopers of the old Bart Spices site on Mead Street last year. You will recall the furorethis generated at the time.

In light of this, we ask that you now place an emergency TPO on all those trees stillgrowing on the whole development site which have not yet been removed so that thissort of behaviour cannot be repeated.

Regards

Chair - Bristol Tree Forum

The density of this development would create an overcrowded site and no new serviceshave been provided for so many people (NHS services are already at capacity). Furthermore theloss of this green site would result in the loss of trees and the wellbeing benefits of this greenspace for local people. The density of the development would lead to new residents also missingout on the health and welll being benefits of living in this nature area. Lastly this is an importantspace for nature and the building over of most of the green space is not in keeping with thecouncils declaration of an ecological emergency and promises to protect green spaces asimportant for public health.

The resulting development will be negative factors on:Loss of light or overshadowingVisual amenityTraffic generationLoss of treesLayout and density of buildingDesign, appearance and materialsLandscapingNature conservation

It's the only little bit of green space left in the area. Keep it and turn in in to a wildlife haven and aplace to help local residents with fresh air, mental and physical health.

I object to this development on the grounds of loss of amenity, loss of trees, lack ofparking provision and increased traffic generation

Amenity: Bedminster green is a small oasis of green, with crocus cover in the spring and severallarge and imposing trees. It has immense value as a means of respite from the busy roads andshops that surround it. It is a link to Bedminster's history, providing a sense of place and identitywhich will be lost if this development goes ahead.As the City Council says itself in its Ecological Emergency Action Plan: "The Bristol GreenInfrastructure Strategy together with other strategies and plans, new and revised policies includingthe Liveable Neighbourhoods policy, will enable planning and management of green infrastructurethat is crucial to sustainable healthy living"

Loss of trees: The planning application mentions "we will retain 'some' trees". There are severalhuge and beautiful elms, sycamores and other trees providing habitat for wildlife, and shade andbeauty for passers-by. Again, the City Council itself says:"Trees and Woodland deliver significant benefit to nature, people and place. They are a keyelement of the ecological network and green infrastructure."

Lack of parking provision: The site is not large enough for housing as well as associated parking,so local streets, already overcrowded with quite a bit of illegal pavement parking. This will onlyincrease.

Increased traffic generation. Bedminster streets are some of the busiest in Bristol - levels ofpollution are high and building on a green space to provide housing without consideration of theincrease in traffic that will be generated and the associated air pollution is completely contrary toall the Council's ambitious plans for combatting climate change.

This development will significantly reduce the number of tress and amount of greenspace at the site. Considering the other developments going on in the area it is essential that thegreen space and all existing tress are retained. The mayor has acknowledged that there is aclimate emergency and has pledged that Bristol will commit to action. If this development isapproved in its current form, it will do significant environmental harm. It should not be approved.

This application would lead to an unacceptable loss of green space, including longestablished trees - this is a rare green lung in the area & the small provision for new greeningwould both be a large net loss, but also would unreasonably remove the established ecosystem &verteran trees. Saying that, the opening up of the Malago is a positive idea - but is something thatcould be achieved without the vast building project.

The density of the scheme, especially given the existing usage, is wholly unsuitable.

The removal of The Green House, an inspiring & unique building, would be a great loss. We wouldhave a low-carbon (& already established) green building replaced by dense & carbon-intensivenew builds - unsuitable!

I would also pose that the materials used in such a construction project should be termed ashazardouse - while relatively benign in isolation, the whole process of use, the highly carbon &energy intensive nature of the production, highlights how destructive such a project is in local,national & international terms.

While some redevelopment & changes might be valid, the whole scheme is over the top. Whenany parts are accepted, and people are generally not against *some* redevelopment, then it is keythat the ecological aspects of building regulations are not just met but greatly exceeded - it can notbe acceptable to wave through buildings that are not zero-carbon in use (let alone construction &all the embedded carbon in the materials). The Council can & must set strict conditions so that a

project like this truly has minimal impact.

Application Reference: 21/05219/F

Address: Plot 5 Bedminster Green Hereford Street Clarke Street, Whitehouse Lane Bristol BS34NA

Proposal: Demolition and redevelopment to provide 3 new buildings (7-10 storeys) comprising 339residential apartments (Use Class C3) (including affordable housing), ancillary residential areas,commercial space (Use Class E), landscaping, public realm and parking.

Case Officer: David Grattan

As well as adding my name to other objections raised, whilst my comment isn't strictly a planningobjection and therefore cannot strictly speaking be useful, I want to raise a concern that thedeveloper insisting that the size of the development is the only financially viable way to achievethe 30% affordable housing is nonsens, and is merely a means by which they are attempting toask for a compromise on the min 30% policy figure. Just saying...sucks!!

The height of this block will block sunlight from the green for large parts of the year.

Having all these blocks looming over the green will make it less friendly for users of the green as itwill effectively become a courtyard for the blocks.

Lower rise blocks required all round to allow sunlight into the green

I am objecting to this further development due to its massive size alongside all the otherproposed developments. How is the local infrastructure going to cope?

Has Bristol City Councils Urban Design Team provided their view on this proposal, as this will bevery interesting to see?

Also are there any physical models that show the cumulative impact on the local area of all theseseparate developments? Again this would be very helpful to see.

This application has received 96 objections, no support & 1 neutral.The Community consultation that they undertook (online during Covid) said 60% welcomedregeneration & 71% supported mix of affordable & for sale new housing units...so how has thisapplication managed to receive virtually universal condemnation.? This is not Nimby-ism!I hope when the Committee looks at it they will reflect the public view. Otherwise where is localdemocracy?My views: the basic problem is excessive density. That arises from the flawed BDF, an exercisecarried out by alliance of Developers, that considered the Plot sites 1-5 with little consideration ofthe larger context & problems of East St. (BCC accepted this flawed plan. Why? Note it does nothave Local Plan status.) The result is the excessive density of accommodation on these plotswhile around the larger East St. area there is a low-rise, low density, run down mixture of shops &flats. Many of these are empty or in poor state. The BDF was assuming a trickle down effect,which is highly questionable.Dandara has claimed that the requirement to put in 30% affordable housing has led to the densityproblems...otherwise the scheme would not be viable. This is a variation on the proposals on othersites that claim the unviability of the affordable requirement. In this case BCC owns the site.This high density has produced unfortunate design results: overshadowing, overbearing blocks,that are reflected in many ways. They claim a net gain to biodiversity. Really? By opening up theMalago stream & removing some Green area, disturbing tree root communities, etc. We may berelying a bit much on the little trickle of this stream: hardly a river?The Green being surrounded on E., S., & W. sides is going to make it a miserable space, & lessused than it is even now. To put up 7 to 10 storey blocks around these sides is not desirable.

In one of the houses on Stafford St., the daylight analysis shows an 80% loss due to the block infront of it. In the sectional plans & sun/daylighting analyses we have little indication how Block 3with its 7 storeys would overshadow the Green. Many of the "model" views seem to try say "lookwe're a bit lower than all that across in Plots 2 & 4!" The whole complex looks horrendous!The Townscape & Visual Impact views- even though the viewpoints have been carefully chosen-show a great heights of brickwork, an over-uniformity of treatments. Block 1 particularly, againwiping out numerous trees, surrounds a courtyard that will get little light. The design raises it toimprove this: as if that would make the height of the surrounding blocks lower when viewed fromoutside!.We need affordable housing & housing in general, but it should be spread more around thegeneral East St area, upgrading existing buildings, providing model schemes how to add perhapsa couple of storeys...while the Plots around the Green should, before it is too late, be lowered &redesigned. The block almost on the railway should be scrapped (block 3).BCC owns this site. The Planning Committee should be stringent in demanding a differentproposal to this. They should listen to the 96 (so far) Objections & demand a completely newproposal. Even the Developers should reject it, on the grounds of their won criteria/ thesenumbers. Please don't ruin Bedminster!

Bedminster Green is a beautiful little park with mature trees and plants which cannot bereplaced. Each Spring there is a spectacular display of crocuses and it breaks my heart that suchthings are helpless against the ruthless greed of developers

The proposed development of plot 5 is a gross over development of these sites whichwill be a lasting harm to this part of Bristol and to those who live and work nearby.The current public open space and rights of way across this space are shown within the red lineboundary with no assurance that these public spaces and rights of way will retain that status if thisdevelopment should go ahead.The proposal ignores the context and urban grain of this part of Bedminster.The Daylight and Sunlight report makes much of a diagram showing the majority of the retainedgreen open space gathers a minimum of two hours of direct sun at some point during the day on21 March. It does not report that even on the longest day of the year, at any time throughout mostof the day shadowing will enclose over half of the site. The ambition to create a wild flowermeadow with an even more diverse plant selection look thwarted.The Arboricultural Assessment by fpcm on their drawing 8501-T-08D shows Category A trees(trees of high quality) to be due for removal. These trees, G6.9(A) - G6.15(A) fall outside of the redline area and should not be referred to as being due for removal. Any plan for their removal shouldbe made public and include a justification.No meaningful employment use has been shown as a replacement for that which will be lost if thisdevelopment proceeds.

I am writing to raise my concerns regarding the proposed development Application No21/05219/F, in my capacity as a resident of Windmill Hill, and as a Green Councillor forBedminster as the impact of this development will effect what other planning applications comeforward across the city.

My concerns are detailed below:

Out of the five Bedminster Green developments, Plot 5 is going to have the most negative andunpleasant impact over all the four developments.By removing the Green House, and the surrounding green context Dandara are removing the lastattractive aspect of this area replacing the trees and greenery with towers that will block sunlight inthe winter, create shadows and dominate the surrounding victorian terraces.As a senior officer describes the design, we are creating the slums of the future.The petition organized by Councillor Lisa Stone, calls this space the Green Lung which is exactlywhat it is, but it also doesn't explain that its very attractive and a surpring amount of birds, batsand insects and yet it will be completely demolished apart from the bit of urban design around theMalago River.

DesignThe height will remove light from Bedminster Green from September to March; this lack of light willaffect the homes in similar way. The scheme divides into three blocks with consistent massing andmaterial treatment.

We are concerned the affordable housing block is within three meters of the railway line, and willsuffer from noise and pollution.Block 1 at its highest point reach 10 storeys, which will mask the topography of Windmill from therest of the city, and at the highest point exceeds the framework.The entrance to Windmill Hill will be obscured, and looking from the hill onto a wall of high-risedevelopment losing the iconic views across the city.

DensityThe density of the accommodation is over Bristol City Councils approved limit of 200 units Ha. Weestimate around 350 dwellings per hectare. A total of 339 apartments.

In a Bristol context, optimum densities in new development schemes have been demonstrated as:- 200 units/ha in a city centre setting (i.e. Wapping Wharf)- 120 units in an urban setting (i.e. Paintworks or Junction 3); or- 100 units/ha in an outer urban setting (i.e. Gainsborough Square, Lockleaze)'This goes against the Urban Living SPD.

Affordable housing We welcome the inclusion of 101 units of affordable housing, (social orintermediate rent) however this is only 7% of the overall development and as such is way belowthe Councils own guidance of 30 -20% for major developments.

Loss of bio diversity and site habitat.The majority of the trees on what used to be called Malago Green will be cut down, and replacedwith trees that can handle less light.

SummaryI am saddened and shocked that again, Bristol Council has not had the courage, to encourage ourvolume house builders to develop a master plan for this area, which focuses on the very bestideas of 21c urban design.As a Green Councillor for Bedminster, involved in developing the next Local Plan I understandhow these things work, and we need to be inspired by cities like Nottingham who are doing better.

This is considered to be over-development of the site. Taken together with the approvedand forthcoming surrounding plots this results in an excessive quantum of development. Thisscale of development will generate overshadowing for a significant amount of time. Furthermore itdoes not sit comfortably with the existing scale of development of both the existing immediateindustrial context and domestic scale of development within Windmill Hill and will block longdistance views towards the north west for users of Victoria Park. Consequently, it is consideredthat the proposal provides insufficient public benefits to outweigh the harm caused by the impactof such a poor scheme on relevant heritage assets. It does not accord with relevant up to dateLocal Plan heritage policies nor the requirements of the NPPF and cannot be supported.

We object to this application for the following reasons:

1. The proposals in the context of the framework will lead to overdevelopment, lacking appropriatestrategies for mix of unit sizes, tenure types, masterplanning, public realm and response tocontext.The massing and height indicated, together with the adjacent sites for future developments show aworrying and totally inappropriate scale for the area which would create a wall of buildingsovershadowing the public domain at street level and destroying the local and city wide views andvistas.The combination of these buildings plus the other surrounding applications could result in the mostdisastrous and destructive piece of urban planning seen in Bristol.

Refer toBristol Development Framework Core Strategy - Policy BCS18 & Policy BCS21BCS18 item 4.18.1 Housing Type & 4.18.5 - 4.18.8.Also Section 3 Spatial Vision and Objectives, 3.4 Objectives, items 2 & 4

2. Consultation has been poorly advertised, been sparse and comments from the community notconsidered. Key concerns, such as family housing, building height and massing, have not beenresponded to.

Refer to

Bristol Development Framework Core Strategy - Objectives 3.4 item 11. Community involvementand engagement, and page 125 Policy Delivery

3. The site is not an appropriate location for a building of the proposed height. The scale ofbuildings proposed is overbearing, insensitive and out of character with the local context. Amajority of the existing buildings in the neighbourhood are 1-3 storeys in height including thosewithin the Bedminster Conservation Area. The increase in scale of this new proposal displays acomplete disregard for context, neighbourhood, community, environment and views across thecity.

Refer toUrban Living SPD Q1.4, Q3.1Bristol Local Plan DM26: General Principles vi and DM27 Height, Scale and Massing

4. The proposed buildings are too high, overshadowing other existing buildings and public spacesfor significant periods of time. The sun- and daylight of neighbouring buildings will be significantlyreduced. The bulk and massing of the proposed buildings may overshadow and cut out daylightand sunlight to the existing and proposed residential properties. The distance between blocksseems ill considered, creating issues of privacy within the development and to neighbouringbuildings, to the detriment of existing and new residents.Day and sunlight to Bedminster Green and the Malago will be significantly reduced, leaving it asan uninviting and overshadowed space.

Refer toUrban Living SPD Q1.5, Q3.1, Q3.9Bristol Development Framework Core Strategy - item 4.2.13

5. We disagree with the visual impact assessment.Taking away views to and from Windmill Hill, and all of Bristol, views that currently provide respiteto residents, views that create the Genius Loci of Bristol, views that attract visitors and that are soimportant to the mental wellbeing of the population.Although many views are of concern, we note a number below that illustrate the inappropriatenessof scale and disregard for context.View 3,4 from Bedminster Station platform and Victoria Park playground show an ungainly solidwall, hemming in the park and Windmill Hill. The play park, intended as respite and joy for childrenand young people, will feel oppressing.View 5 and 6 show how out of place and inappropriate the height and massing of the proposeddevelopment is, masking the views to the surrounding creating a solid obstruction and obscuringany views to and from Windmill Hill. It would take away any visual connection between Bedminsterand Hotwells, Clifton, Ashton Court and the city centre.View 8: The views from St Johns churchyard illustrates how out of place and inappropriate theheight and massing of the proposed development is, masking the distant views to the surrounding

neighbourhood of Windmill Hill whilst overshadowing the context of East Street and theConservation Area. This is also a key view identified in the Bedminster Conservation AreaAppraisal.The distant Views 11, 12 show how the proposed development will blight the views and vistasacross the city, with yet another unimaginative ungainly block. It causes substantial harm to viewsfrom and to Brandon Hill to Windmill Hill, from and to Ashton Court. With its excessive height andmassing the proposal masks the historic assets, characterful colourful housing, topography andlandscape.In addition, important views to and from Victoria Park, Windmill Hill, recognised elevated vantagepoints, popular public spaces are missing in the TVIA and should be provided.The use of the outline of adjacent application on the visuals as a background is misleading, as theproposals submitted for the adjacent sites are totally inappropriate for the context and should notbe used as justification for another overbearing development.The TVIA admits "adverse" effects on townscape character area Windmill hill and Victoria park(page 21 of Townscape and Visual Impact Appraisal).The Design and Access Statement admits that the proposed development would "obscure long-distance views across the city centre including ... landmark features", and that this is "consideredan adverse change" (page 101).

Refer toUrban Living SPD Q1.3, 3.1. and 3.2SPD01 Tall Buildings - Appendix E Visual Impact Assessment - guidance on methodology &Appendix C View Protection Framework & also Appendix G (Policy B7A)

6. The application site sits in close proximity to the Bedminster Conservation Area.The proposed development would substantially harm the character of this area including keyviews, landmarks and identified heritage assets of this Conservation Area.

Refer toBedminster Conservation Area Character Appraisal Local character and distinctiveness 2.2Positive Context and 2.3 Negative ContextUrban Living SPD Q3.1The following views as identified in the Bedminster Conservation Area Appraisal are particularlyaffected:1.3 York Road: Key View and Landmarks: Views southwest from Whitehouse Street across toWindmill Hill and beyond as far as the Dundry Hills2.3 Bedminster Parade: Views channelled north/south along Bedminster Parade.3.3 East Street: View south to Windmill Hill terraces/Victoria Park from junction of EastStreet/Dalby Avenue;The Robinson Building to the southwest and the former Wills Factory to northeast5.3 Dean Lane: Vista across south Bristol punctuated by Bristol South Bath's chimney andRobinson Building, reaching to Windmill Hill and beyond to Bedminster Down

From Dean Lane/Catherine Mead St north towards the tower of St Paul's Church; and easttowards Wills Factory and Victoria Park beyondViews east from Lydstep Terrace towards Former Wills Factory and the ridge of Victoria ParkbeyondView to the Salvation Army building from the Booth Road/Cannon Street junction6.3 Coronation Road: Views to the south and south/east from the north end of St John's Road9.2 Landscape and Routes, and9.3 View east along New John Street and St John's footpath10.3 British Road: Views east from British Road across the city:Views to the south west from Diamond Street towards Windmill Hill/Victoria Park and BedminsterDownThe proposed development entirely contradicts the Bedminster Conservation Area Appraisal, page50: "9. St John's Churchyard Views north spoiled by 1960s tower block, Northfield House,Catherine Mead Street. Encourage the appropriate redevelopment that better responds to localcharacter and resist the development of over-scaled buildings that affect the context of heritageassets or significant landmarks through the planning process"

Refer toBedminster Conservation Area Character Appraisal

7. The Wind Assessment information for the proposed building massing within the applicationdocuments confirms that buildings of this scale may create undesired wind turbulences,'downwash' and wind funnelling at ground level, for residents, neighbours and pedestrians.

Refer toUrban Living SPD Q1.5, Q3.9Policy DM 27: Layout & Form: Blocks and Plots item v.Bristol Development Framework Core Strategy - item 4.21.13

8. The text in the Design and Access Statement refers purely to "non-resi use" along the majorityof Ground Floor spaces. This could be anything, including a garage or storage. These types ofspaces do little to engage with or enliven the streetscape. Opportunities for ground level activatesthat could interact with the public realm or creation of spaces for people to use, meet andsocialise, are missed.The street level, particularly Building 1 is is poorly thought out. A row of apartments for families(3B5P) are northeast facing, without any adequate outdoor space, facing a busy, polluted MalagoRoad.The proposed landscaped courtyard in Building 1 and 3 is very small and will be overshadowed formost of the year and most of the day. It feels uninviting, creating an oppressive environmentwhere public use will be poor, and planting is unlikely to thrive.The provision for car parking appears unrealistic with the number of residential units planned. This

will put increasing pressure on already overcrowded parking in the neighbouring streets.The elevations refer to "Bristol byzantine style". Whilst this style would feel foreign in the context ofBedminster in the first place, the elevations are detailed in a bland an unimaginative way

Refer toBristol Development Framework Core Strategy - items 4.21.8 - 4.21.13Bristol Local Plan - site allocations and Development Management PoliciesPolicy DM27: Layout & Form, Blocks and Plots item iiiPolicy DM28: Public RealmPolicy DM28: Shared Spaces - item ii & ivPolicy DM29: Design of New Buildings items 2.29.3 & 2.29.5

9. The proposed development does not appear to contribute to the community infrastructure,whilst the high density and large number of proposed flats would add pressure onto local facilitieswhere the capacity of local schools, GP surgeries, etc. is already under strain. The focus is onprivate resident's uses at ground floor rather than much needed community facilities.

Refer toBristol Development Framework Core Strategy - Community Facilities item 4.12.1 - 4.12.4

10. Poor consideration for the mix of housing tenures, types, sizes and a lack of provision forfamily homes. Provision of almost solely 1 & 2 bed flats in the scheme is not contributing to amixed and balanced community, especially in the light of the high number of 1 & 2 bed flatsalready proposed in the Bedminster Green area.

Refer toBristol Development Framework Core Strategy - Policy BCS18 & Policy BCS21BCS18 item 4.18.1 Housing Type & 4.18.5 - 4.18.8.Also Section 3 Spatial Vision and Objectives, 3.4 Objectives, items 2 & 4

11. A density figure has not been provided but is estimated at 339 dwellings on 0.96ha, workingout at about 350 dwellings per hectare. This is excessive and exceeds the Bristol DevelopmentFramework Core Strategy, Delivery Strategy and the Urban Living SPD

Refer toBristol Development Framework Core Strategy - Policy BCS20 Residential DensitiesUrban Living SPD 0.5

12. Not all apartments appear to have adequate external amenity, and there is little or inadequatespace for external realm or green space.

Refer to

Bristol Local Plan - site allocations and Development Management PoliciesPolicy DM27: Layout & Form, Blocks and Plots item iiiPolicy DM28: Public RealmPolicy DM28: Shared Spaces

13. The proposal may have detrimental impact on the biodiversity and wildlife, in particular aroundBedminster Green.Refer toBCS23 of the Bristol Development Framework Core Strategy (June 2011)Bristol Local Plan - site allocations and Development Management Policies ( July 2014)Policy DM33: Pollution Control, Air Quality and Water Quality

I object to this development due to;- over development of the site, not enough amenity space allowed within the site for bike storage,recreation, refuse storage, electric car charging- poor quality design- the development shows little variation in roof-line which is out of characterwith the surrounding area- poor quality design- the highly repetitious facade design does not reflect the existing high level ofvariation in facade texture and design in the surrounding area- poor quality design - monochromatic colour scheme out of character with the existing variety offacade colour seen in the surrounding area- poor quality design - materials proposed do not reflect the existing variety of surface materialscharacteristic of the surrounding area- obstruction of key views - the area surrounding the development (particularly the residential areato the south) is characterised by views and vistas of new landmark and historic buildings in the citycenter, the continuous nature of the proposed development creates a "wall" which blocks theseviews from key locations such as bedminster station, this has a negative impact on the amenityand character of the local area

Please do not pass this awful development! There are so many reasons why it shouldnot go ahead and so few why it should.1. Terrible living space; the triangle nature of the building puts one in mind of a prison block,windows overlooking the centre will be looking into a dark, probably rubbish filled, forgotten space.2. The loss of so many mature trees!!! Bedminster needs more mature trees, not fewer! Thesetrees are an important temperature regulator and carbon sink for the busy road passing by. Theloss of these trees will not be negated by any 'remedial' planting on the tiny bit of grass left behind.Bristol City Council has declared a climate emergency, why are there proposals to reduce treecover?3. Overcrowding; this area is already immensely busy with pressure on schools, doctors, dentists,parking and roads. Adding this number of flats with no parking spaces and no planning foradditional doctors or dentists is madness.4. There are plenty of actual brownfield sites nearby that don't have established trees on whichcould be built on, namely the empty retail sites along East Street.

The building is too tall to comply with local policy and the density of the proposal is toohigh. Block 3 is very close to the railway line and the detrimental effects of noise and air pollutionwill be felt by its residents. The material selection and repetitive nature of the design is oppressiveand not conducive to successful place-making. The visual impact of the blocks as a wall frommany viewpoints is damaging to the local area and the height of the building masks the localtopography. It will block beautiful views in both directions, and compromise the beauty of Bristol forso many people. The developer is going to make a massive profit for a poorly designed profitdriven solution. This proposalfails on so many levels and should be turned down.

The proposed development has buildings of significant effect combined with Catherine'splace will make Malago rd feel like an over shadowed valley

All off the buildings are too high and imposing wand would significantly reduce natural light in thegreen areas that are on the plan and are currently in existence

It would be a foreboding entrance to Windmill hill community

The infra structure in the area would not be able to cope with such a development

This is an extremely disappointing application which I am absolutely opposed. Whatmakes it worse is that the land is council owned, so the council had much more freedom to createsomething that the community wanted, but the have chosen to completely ignore it. We askedNicola Beech on numerous occasions what the plans were for Plot 5, yet this socialist chose toignore the wishes of local people, instead preferring to work with an Isle of Man-based developer.At no time was the community properly consulted, which I'm afraid is typical of this presentcabinet.This area will soon be densely populated, with numerous tower blocks planned. Therefore, itwould have made sense to keep Plot 5 as a green lung, providing much needed space to thesesurrounding tower blocks. Unfortunately, now it will form the last brick in a concrete and glass wallthat will stretch for several hundred metres right across the front of Windmill Hill, thereby cutting offthis attractive area from the City. It will create another Barton Hill, stupidly repeating the mistakesof the sixties. Bedminster Green, at present a much-loved space, will be reduced in size andsurrounded on all sides by tower blocks, so will be perpetually in the shade. The number of treeswill be drastically reduced, and consequently the biodiversity, for example, the green will no longerbe home to foxes, badgers and bats at the moment. The wooden building on the green forms partof the identity of the area, yet it will be removed in an act of what only can be described asvandalism. The blocks are far too high, square, and ugly, and will tower over the two-storeyhouses of Windmill Hill. Windmill Hill will disappear from view from the rest of the city.Another major problem is block 3 is too close to the railway, and this will cause an increasingproblem of noise and pollution for residents as the line gets busier over the coming years. This, ofcourse, is where this developer has chosen to place the affordable housing, lumping it together.

Altogether, if this application is allowed, it will further blight the area. It will be an eyesore fordecades, with people wondering what was the thinking behind building such a monstrosity. Itshould be turned down flat.

It's outrageous that planners seem to be able to build tower blocks with no regard forthe local community or the new residents' wellbeing.

How can it be right (especially in this time of climate crisis) to destroy green wildlife havens andcut down trees?

The height, density and light pollution would have a devastating effect on wildlife, including thevery rare bats that fly through this area.

The development that has already received approval will already have a huge impact on traffic -it's already a problem, particularly during rush hour. An additional 300+ residences with only 27parking spaces is just ridiculous, and the implications in terms of congestion are off the scale.

Bedminster Green is hugely important to the local community, as is the wooden house with grasson top (also in terms of biodiversity) - replacing this with a 10 storey block is going to destroy thewhole area.

The saddest thing is that local residents feel the planning committee ignore residents feelings andhas no interest in preserving communities, only in ticking boxes. We are all exhausted anddemoralised by these frequent and horrendous proposals - this is not the place for high buildingsand the area doesn't have the capacity for this many new homes.

1. The proposed blocks are too high (anything more than 5 stories), and dense, and outof keeping with the low rise Victorian and Georgian architecture of the area. This developmentbelongs in the city centre nearer Bristol Temple Meads.

2. The immediate area surrounding Bedminster Green, has historic architectural distinctiveness,ancient topography, and a large residential community. More needs to be done to preserve this.

The Character Appraisal of Bedminster Green states:''The historic route (from West Street through East Street, onto Bedminster Parade and intoBristol) has pre-Saxon origin. The street layout and plot structure are medieval survivals, rare inboth the Bristol and national context. Many individual buildings and groups of buildings haveimportant local value. Despite its negative features, the merits of East Street significantly outweighthem.''[P.8 Bedminster Conservation Area Character Appraisalhttps://www.bristol.gov.uk/documents/20182/239165/BedminsterCAMarch2014update1_0.pdf/b0bfeed5-a280-40ff-93ee-138830f59ec4]as well as:''The 1960s saw the clearing of acres of Victorian townscape to the south and east of East Street.What replaced the bombed out buildings and vacant plots tended to be low-grade industrial sheds,or brutalist buildings and tower-blocks. St John's and St Luke's Church were both demolished.These post-War interventions posed a significant threat to the vibrancy of Bedminster.

Despite this, there remains much to be celebrated and protected in Bedminster. The fine Victorian

townscape and shopfronts, key landmarks and buildings of merit and remnants of the survivinghistoric route structure, underpinned by a community spirit that sets the area out as unique.''[P.20Bedminster Conservation Area Character Appraisalhttps://www.bristol.gov.uk/documents/20182/239165/BedminsterCAMarch2014update1_0.pdf/b0bfeed5-a280-40ff-93ee-138830f59ec4]

3. The loss of established trees and greenery around the Federation of City Farms building shouldnot be allowed during the urgent Biodiversity Crisis we are currently in. It will take many years tomake up for that loss and it contains protected species.

4. Red Brick Facade. P.36 of the Design and Access Statement states: ''The panel observed that'currently the facades are illustrated with a pale brick, whereas there are examples of strong, darkred brick within 5 minutes' walk of the scheme.' As the proposals were developed the design teamagreed with the panel and minimised the palette to a multi-tone red brick paired with a light redstone and light red metal. The choice of colours were to refer to the strong red brick found withinthe vicinity of the development. ''

This is wrong: So much red brick on the facade will stand out too much on the skyline, and add tothe building's oppressiveness. Instead lighter natural colours should be promoted to blend in, likeoff white, pale grey/green/ pale yellow a reflection of nature, e.g see Leonardo Hotel, Bristolcream/gold colour facade where 'Bristol-based architects AWW are designing the building, whichhas been "carefully considered" to respect the historic context of the surroundings':https://www.bristolpost.co.uk/news/business/huge-200-bedroom-hotel-shops-2732907

5. It is true that Bedminster contains former factory buildings such as Factory no.1, legacy of theSlave Trade, however today, Windmill Hill doesn't need several Tobacco Factory like buildings allclumped together, at the base of a charming cluster of terraced houses and the historic Romantopography of East Street.

6. It worries me that these factory buildings are the inspiration and design justification forBedminster Green development as explained in your Design and Access Statement. A BondWarehouse by the harbour for example, although listed, ought to be demolished and it isextremely oppressive to walk around.

7. The trade off for the justification of the Bedminster Green developments seem weak such asstated in the framework: "Town centres, such as East Street, are facing major challenges and it isvital that there is a substantial residential population on its doorstep to boost and support trade,investment and overall vitality.'' https://www.nashpartnership.com/2019/03/07/framework-to-revitalise-bedminster-green-supported-by-bristol-city-council-cabinet/

I argue that there is already adequate footfall on East Street, it is busy every time I have walkeddown there, and the local area of Windmill Hill / Southville is already a thriving community. It is the

poor quality of the shops (Betting Shops, Off Licences etc), and the closure of key services suchas Barclays Bank due to online habits, as well as the large Asda taking away the need for some ofthe shops, that has led to decline.

A shift in shopping habits, due to the way people are addressing the climate emergency, Covid-19realisations during lockdown of the importance of the street focussed on community interaction,and for originality to trump what a supermarket can offer, are already happening. A new ZeroGreen store has opened on East Street, alongside an independent traders emporium, and thelocally sourced produce from the Bristol Loaf have opened in the last few months. This hashappened without masses of new developments, and will continue to be the trend.

8. The close together nature of several large blocks of flats will create a wall cutting off WindmillHill from the rest of the city. The colourful houses along Windmill Hill are iconic of Bristol and canbe seen from the Clifton Suspension Bridge and Brandon Hill, and views should be preserved.

Building (1 is higher than the agreed height in the developers framework and is too highfor the location. It would cause a canyon effect on Malago Road with a seventeen storey buildingopposite. The shading of the Green would be oppressive. The internal shading of the centre of thebuilding would be depressing and damp. This building should not be the enclosed triangle that isproposed but should six storeys maximum and be open on one side.

Building (2 is too bulky and uninspired to be next to a recreational space. Its Hereford St elevationis too high and will create a canyon effect with St Catherine's Place. It should be set back furtherfrom the Green and the storeys above ground level should be set back to prevent it beingoppressive.

Building (3 is too high and too close to the railway. The original raison d'etre for this building wasto facilitate a new entrance to the station and provide workshop and office space. This has beencompletely forgotten and instead is being used and an excuse to cram in more cramped,unhealthy one and two bedroom flats. It would create a wall along the railway that would blockviews from Victoria Park and the streets at the bottom of Windmill Hill.

The approval of this proposal for plot 5 would be a missed opportunity to create a new heart forSouth Bristol and a disaster that would blight the area for generations. This land belongs to thepeople of Bristol and the council has a duty to protect the health and well-being of the citizens,now and in the future, and to look after their assets. The developer is going to make a massiveprofit for a poorly designed profit driven solution. The inclusion of the minimum percentage of

'affordable' housing on a plot owned by the city is outrageous. We need housing in a mixed tenure,mixed use, sustainable development that will facilitate a happy, healthy community. This proposalfails to do that and should be turned down.

I object most strongly to this development on the following grounds.

The building is too tall to comply with local policy

The height of the building masks the local topography

The density of the proposal is too high for an inner city area

The proposed methods of reducing energy use are unlikely to work

The scheme does not comply with policy regarding on site renewables

Block 3 is very close to the railway line and the detrimental effects of noise and air pollution will befelt by its residents

The material selection and repetitive nature of the design is oppressive and not conducive tosuccessful place-making

The loss of local biodiversity is unacceptable.

There are endangered species in the area that must be protected.

The visual impact of the blocks as a wall from many viewpoints is damaging to the local area.

In summary, so many elements of these plans are isolating, not sustainable for our community orour local ecosystem and hugely detrimental to this area of Bristol. Development yes, butsustainable and community focused surely?! We have a choice here how that happens. YOU havethat choice to either contribute to the health of this planet and those who live here, throughsustainable and conscious development of large scale projects like this, or to play your part indestroying it and all of us who live here. It's as simple as that. YOUR choice, so what do YOUchoose?

My objections relate to the density and scale of the developments, in the context of theother developments in this area, which together will overwhelm the existing housing. There isinadequate consideration of green spaces and the infrastructure does not support such a largepopulation increase. More balance and a cohesive approach to all these developments aroundBedminster Green is needed - clearly the area does need development but packing in as manyhigh rise blocks (10 storeys) as possible to generate profits for developers is short-sighted and willbe a mistake in my view that we will look back kn and regret.

Too tall, destroying green space

This whole plan is a monstrous carbuncle that will scar this area of Bedminster forgenerations to come. It will create a vast concrete wind-tunnel, affect wildlife and endangeredspecies such as bats on the green, have people living in crammed spaces right next to the railwayline and basically affect sightlines for present residents of the area.

There are no redeeming features whatsoever here, the designs are too tall and featureless, thereis complete lack of green space...it really is a throwback to East Europe of the 1960s and 70s.Appalling lack of vision when there is so much scope for exactly that here...

I wholeheartedly reject it.

Victoria Park on Windmill Hill was built to give working people some green space toprovide respite from their urban lives. Many people enjoy walking there to see the views over thecity and sitting on the slopes to watch the sunset over Ashton Court and Clifton.

Others enjoy walking across Bedminster Green with the tall trees and green space, and thedisplay of crocuses in the Spring is a much-loved local event.

This development will deny future generations of these simple pleasures.

It will block beautiful views in both directions, and compromise the beauty of Bristol for so manypeople.

I feel so ashamed that this is what we will leave the next generation, and so sad for the people,particularly children, who would have to live in such tall, cramped and unattractive buildings, soclose to the railway line and main road into Bristol.

Surely we can do better than this for the people of Bristol?

Building 1 is taller than the developers framework states. It would significantly reduce the lightfalling on the green.

Building 2 is too bulky and uninspired to be next to a recreational space. Its Hereford St elevationis too high and will create a canyon effect with St Catherine's Place. It should be set back furtherfrom the Green and the storeys above ground level should be set back to prevent it beingoppressive.

Building 3 is too high and too close to the railway. The original main reason for this building was tofacilitate a new entrance to the station and provide workshop and office space. This has beencompletely forgotten and instead is being used as an excuse to cram in more cramped, unhealthyone and two bedroom flats. It would create a wall along the railway that would block views fromVictoria Park and the streets at the bottom of Windmill Hill.

The approval of this proposal for plot 5 would be a missed opportunity to create a new heart forSouth Bristol and a disaster that would blight the area for generations. This land belongs to thepeople of Bristol and the council has a duty to protect the health and well-being of the citizens,now and in the future, and to look after their assets. The developer is going to make a massiveprofit for a poorly designed profit driven solution. The inclusion of the minimum percentage of'affordable' housing on a plot owned by the city is outrageous. We need housing in a mixed tenure,

mixed use, sustainable development that will facilitate a happy, healthy community. This proposalfails to do that and should be turned down.

The buildings are not only too high they are ugly and in combination with the otherdevelopments would create a visually unpleasant walled skyline of continuous brick blocking anyviews into Windmill Hill or out from Windmill Hill across to the city - the topography ruined.

The density of dwellings at 350 per hectare on such a small are of land is far too high. This willimpact on local services - Doctor's and dentists case loads are already over stretched andobtaining appointments would be even more difficult.

Parking in Windmill Hill is already an issue with residents and incomers cars parking for the dayand commuting from Bedminster Train Station - Windmill Hill will become an unregulated and overcrowded parking lot - stress levels of residents will only increase.

Bedminster Green provides a welcome space in an industrial and commercial area giving abreathing space and combating a traffic polluted area.Surrounding 'The Green' on all sides with towering edifices will create a dark and shaded arearestricting sunlight/day light and air flow and will affect all things growing there.

The Bedminster Green Framework recommended a density per hectare of 220- 320 which can beachieved by leaving plot 5 as an open space - it is after all public land and should be enjoyed bythe public. The space should be extended to become a 'Pocket Park' boosting the look and feel ofthe area creating an enhanced welcoming space with seating and more planting.

The council needs to think about everyone living in this area and the depressive effect of anovercrowd development on mental health and wellbeing of all residents.

It feels as if the council are treating us as a disposable neighbourhood to tick boxes for the wholeof Bristol's housing needs. Stop the rot before it starts and make Bedminster Green a mini NatureReserve - bats included.

These are the latest plans to come forward to vastly over-develop the BedminsterGreen area, changing its character in perpetuity with overcrowded building plots with lowestcommon denominator design and insufficient space between them. They are quite out of characterwith the existing housing locality and we wonder why it should fall to this part of Bedminster toprovide such a large contribution to Bristol's undoubted future housing needs. The preoccupationwith high-rise building brings to mind the discredited enthusiasms of the 1960s, which have notturned out well. It has been frequently demonstrated that lower building profiles on a more humanscale are quite capable of meeting housing needs without the many drawbacks of building higher.

The undistinguished design and rectangular outline of the blocks proposed would present an uglyand unrelieved wall of disruption to the valued views between Windmill Hill and the rest of the city.

Bedminster Green is a valuable green space to be enjoyed by local people and provides animportant local refuge for biodiversity. The proposals would remove some of the tree cover andreplace it with looming buildings on several sides, taking out much of the sunlight and airflowwhich are currently valuable for the mental health of local people and the perpetuation ofbiodiversity, including the protected species which are present.

The fact that only 27 car parking spaces would be provided for several hundred residences, whileprobably being in line with current planning thinking, would be disastrous for the local area as nodoubt many more incoming new residents will have cars and the predominant local places to parkthem will be on the already crowded nearby streets of family houses.

It seems inevitable that Building 1, proposed for the Hereford Street car park area, would involvethe loss of many more trees as well as the current grass-roofed wooden building. Illustrationsshow Building 1 as a triangle enclosed on its three sides. Surely this suggests that the areas in thecentre are likely to be gloomy and damp. It would be far better for the building to be open on oneside. It also reaches 10 stories which exceeds the requirements of the development framework.With a 17 storey building opposite on Malago Road there will be a canyon effect concentratingtraffic pollution.

Building 2 is of uninspired design, is likely to dominate the remains of the Green, and also tocreate a canyon effect with St Catherine's Place across the road.

Building 3 is given an unenviable position very close to to the railway. If the practicalities ofbuilding on this site can be achieved it is still likely to be a noisy home for the people living in it andwill disrupt views in and out of Victoria Park and Windmill Hill.

Overall the proposals for Plot 5 are very disappointing and it is to be hoped that even at this latestage there could be a rethink to provide a more human scale of development.

The development will do nothing to enhance the community.It is too high , too dense. A slum in the making.

The development will do nothing to enhance the community.It is too high , too dense. A slum in the making.

There is very little to approve of in terms of this proposal, apart from a small amount ofaffordable housing, though the height and proposed location (right next to the railway line whichwould have a devastating effect on the very rare bats that fly through.

The proposed tower blocks are ugly, far too dense, too high and will make a huge wall ofdevelopment in a very precious green space. The development that has already received approvalwill already have a huge impact on traffic - it's already a problem, particularly during rush hour. Anadditional 300+ residences with only 27 parking spaces is just ridiculous, and the implications interms of congestion are off the scale.

Bedminster Green is hugely important to the local community, as is the wooden house with grasson top (also in terms of biodiversity) - replacing this with a 10 storey block is going to destroy thewhole area.

The saddest thing is that local residents feel the planning committee ignore residents feelings andhas no interest in preserving communities, only in ticking boxes. We are all exhausted anddemoralised by these frequent and horrendous proposals - this is not the place for high buildingsand the area doesn't have the capacity for this many new homes.

This application looks very dense and I can't see any ways in which it will benefit thelocal area or natural environment/biodiversity. I also can't see how this would be a goodenvironment to live in, with high dose dense blocks and seemingly no amenity space.

There is no mention of any doctor surgeries, dentists or any other infrastructure weneed for so many people coming to live in an already under resourced area. The width and heightof the proposed work is monstrous for a built up area.

Very basic Architectural Design that is unsympathetic to the surroundings. Mixing loadsof students in with a small amount of social housing is barbaric and disrespectful to disadvantagedfamilies. There is still a corridor feel either side of the road which as a woman is concerning. It alsofeels like a huge slap in the face that the beautiful view as you walk down Windmill Hill will beobscured by some brown, drab cardboard box blocks. This wouldn't happen in Clifton.

I believe the development would be detrimental to the biodiversity of Bedminster Green,by cutting down well established trees, and overshadowing the land adjacent that is currently alittle wildlife haven in an otherwise built up area. Furthermore, I believe we should be conservingour green spaces, trees and plants as we are suffering a climate emergency. Malago Road is abusy road, the trees in the surrounding area need to be preserved to help clean the air of pollution.

The development does not have enough parking spaces to support the amount of residences it isproposing to create. The parking situation in Windmill Hill already causes a lot of stress andfrustration for the residents as well as pedestrians. The area being over populated by cars meanspeople are more likely to park on pavements, creating problems for wheelchair and mobilityscooter users. The proposed development would only add to this problem.

This proposed development is much too high. It will overshadow the Green to anunacceptable level, blocking light fromit, which will a) retard healthy growth of the existing trees and spring flowers, and b) turn the areainto an unpleasant wind-tunnel, which will reduce its potential use as an amenity. Green spacesare a vital part of a healthy urban environment, enabling people to have brief periods of peace.This isn't airy fairy nonsense, but a real need for residents in increasingly densely inhabited urbanenvironments. These places must be healthy and nurturing for the people who live in and aroundthem, and who pass through, not a resource to be as fully exploited as possible by developers,who will never need to live here. Please consider the welfare of all present and future residents inconsidering this application, which in its present form is much too high. Thank you.

I have moved to the Uk only recently to be with my husband. A proud Bristolian. As anoutsider what we Australians love about the UK is it history and green space.I totally understand that there is a housing shortage but there are also outstanding eco-sustainable projects being developed that work with the environment it is to encompass.Bristol, you are in an outstanding position to set an extraordinary benchmark for the rest of the ukEurope and the world. This housing project could be ground breaking rather then the complete eyesaw it currently is with huge eco deficits. The energy efficiency rating to start with.Please please become a leader and someone we can all be proud of. Have people visit the cityjust to see a structure that embraces all current and future challenges.There are many many firms out there wanting to do right by people and the environment. Pleaseuse them and be a leader of integrity rather then short sightedness.A Bankys building rather then a grotto. Green credentials rather then developer windfall. Protect your people and they will prosper. It's up to you now.

The need in this area is affordable social housing

A 10 storey building is totally out of character for the area and will significantly changethe community feel within the area. I feel the height should be limited to 5 or 6 storeys maximum. Iappreciate the need for more housing but feel that the number of 'affordable' housing may beactually be that affordable. Limiting the amount of car parking is commendable but realisticallycars will be parked in the already congested local roads.

This development horrifies me on many frontsThe loss of an important green corridor with mature trees in this time of climate change isoutrageousThe heights and such poor design of the buildings also concern meBasically this development would not be even considered in other wards egClifton I am proud to live in Bedminster and we deserve better!!!!!!!

I find it impossible to believe the proposal of such an eyesore.The lack of green spaceand parking will overload windmill hill with yet more traffic and air pollution,in a time when childrenwith asthma are suffering on their walks to school.We need lower blocks with adequate parkingand adequate green spaces not alleyways between buildings where rubbish and air pollution willaccumulate causing harm to the residences of the tower blocks and the surrounding area.Lack ofcaring for the inhabitants of this area and it seems a money grabbing ethos is the main reason forthis proposal.So much for let's think of the planet and working towards making things better foreveryone.Rammed roads,smog,and alleyways for people to scuttle around in.

I am not supportive of the proposed tower blocks in the area. This area has a lot ofyoung families, and we need to preserve outdoor spaces and protect the biodiversity in the areawhich these proposals do not. If there are to be residential dwellings built here, they need to below rise and well designed with amenities in mind that will provide for the nearby area. The area isvery special and we need to protect community resources such as the City Farm nearby which iswell used and makes the area a desirable place to be. The tall tower blocks will be a blight on thearea. We need a developer that prioritises place making, rather than maximising dwellings that willnot be fit for purpose, overpriced and end up empty whilst having a negative impact on the existingresidents. I don't believe the plans as they are right now are appropriate as they have notconsidered local need or the impact on the immediate area.

The flats are far too high, blocking views from Windmill Hill, and of the colourfulterraces/Victoria Park from other parts of Bristol. The height of all the towers makes sunlessgloomy corridors to walk through. The development is too dense, adding more people than theservices - doctors etc - could cope with. I am also worried that all the extra people will lead to extracars and will make the air quality even worse in the area, especially as the tall buildings wouldprevent the particles dissipating effectively.

I really don't like these ugly big towers. They should be kept to 3 or 4 stories and be more inkeeping with old houses in the surrounding area.

Completely inappropriate high rise blocks for this area which will cause cessation ofcommunity, more traffic and unaffordability notwithstanding demolition of green spaces and treeswhilst swamping the city farm.

This proposal would be a disaster for the community and the environment. Valuablegreen spaces will be lost. The tall structures will make cramped and overshadowed environment.The fragile infrastructure will be broken by the influx of so many new residents. The inevitableadditional traffic will be a health hazard. By all means find ways of building something conducive tothe area. This isn't it. It must be stopped.

There are so many things wrong with this proposal that it beggars belief that it has beenput forward. Here are the main points of issue.Building (1 is higher than the agreed height in the developers framework and is too high for thelocation. It would cause a canyon effect on Malago Road with a seventeen storey buildingopposite. The shading of the Green would be oppressive. The internal shading of the centre of thebuilding would be depressing and damp. This building should not be the enclosed triangle that isproposed but should six storeys maximum and be open on one side.

Building (2 is too bulky and uninspired to be next to a recreational space. Its Hereford St elevationis too high and will create a canyon effect with St Catherine's Place. It should be set back furtherfrom the Green and the storeys above ground level should be set back to prevent it beingoppressive.

Building (3 is too high and too close to the railway. The original raison d'etre for this building wasto facilitate a new entrance to the station and provide workshop and office space. This has beencompletely forgotten and instead is being used and an excuse to cram in more cramped,unhealthy one and two bedroom flats. It would create a wall along the railway that would blockviews from Victoria Park and the streets at the bottom of Windmill Hill.

The approval of this proposal for plot 5 would be a missed opportunity to create a new heart forSouth Bristol and a disaster that would blight the area for generations. This land belongs to thepeople of Bristol and the council has a duty to protect the health and well-being of the citizens,

now and in the future, and to look after their assets. The developer is going to make a massiveprofit for a poorly designed profit driven solution. The inclusion of the minimum percentage of'affordable' housing on a plot owned by the city is outrageous. We need housing in a mixed tenure,mixed use, sustainable development that will facilitate a happy, healthy community. This proposalfails to do that and should be turned down.

The trees on the green must be protected, there are currently 30+ mature trees in thisarea and the green is home to some protected species. This area is the only green space onDalby Avenue. It provides a wonderful burst of colour with crocus, daffodil and tulip flowers in thespring. Surely in the current situation regarding global warming these areas must be protected.

I couldn't find any planning application notices on Bedminster Green and the surrounding area andthought this was a legal part of an application. I feel this has been done to reduce the public'sawareness of the application and to limit the negative feedback.

A portion of block 1 at the highest point is 10 stories and exceeds the framework

In visualisation studies the square nature of the blocks creates an unrelieved wall of development,exacerbated when taken into account with other approved developments for the green.

This development will further degrade the Dalby Avenue area and it will become an unfriendlyconcrete jungle with the potential to become a dangerous area for single women to get to WindmillHill or the proposed apartments/houses.

It is a disgusting proposition that these over-sized buildings will be built here.

Building (1 is higher than the agreed height in the developers framework. It is oppressive.

Building (2 is too bulky and uninspired to be next to a recreational space. Its Hereford St elevationis too high and will create a canyon effect with St Catherine's Place.

Building (3 is too high and too close to the railway. The original raison d'etre for this building wasto facilitate a new entrance to the station and provide workshop and office space. This has beencompletely forgotten and instead is being used and an excuse to cram in more cramped,unhealthy one and two bedroom flats. It would create a wall along the railway that would blockviews from Victoria Park and the streets at the bottom of Windmill Hill.

The approval of this proposal for plot 5 would be a missed opportunity to create a new heart forSouth Bristol and a disaster that would blight the area for generations. This land belongs to thepeople of Bristol and the council has a duty to protect the health and well-being of the citizens,now and in the future, and to look after their assets. The developer is going to make a massiveprofit for a poorly designed profit driven solution. The inclusion of the minimum percentage of'affordable' housing on a plot owned by the city is outrageous. We need housing in a mixed tenure,mixed use, sustainable development that will facilitate a happy, healthy community. This proposalfails to do that and should be turned down.

On top of all this, it is a disrespectful show of aggressive gentrification that will destroy the lives ofmany residents when the price of living goes up.

The proposed ugly buildings are much too high, and will see too many people crammedin to an area already in need of improved amenities. This proposal is about maximising profit forthe developers and never mind about local people, including the poor so and so's who are going tolive in the proposed high rises.

Once again an application that takes nothing of the local area into account. Blocks offviews to and from the city, funnels wind and pollution from busy roads, reduces much neededgreen space, removes mature trees with associated protected species. For once it would be niceto see a developer look beyond their site at the wider area. Affordable housing appears to berammed up against the railway line but the blocks aren't sufficiently separate to appear so frommany angles creating a "blockade", especially given their height which is excessive. Additionally Ifind it astonishing that given COP26 has just taken place that no renewables are planned and yetanother few hundred people will need to tap into the grid for their power.

I would like to object on the following grounds:1. Very large amount of dwellings proposed. This is a very high density for the area designated.2. very low amount of parking places in relation to number of dwellings, meaning that newinhabitants will have to park in Windmill Hill which already has a big parking problem.3. The loss of the trees on the green and the Hereford street car park. Trees are important to actas a lung for the area, and against the impact of climate change. It is also an important habitat forwild life.4. Block one is 10 storeys at the highest point which exceeds the agreed framework .5. In the visualisation studies the square nature of the block creates an unrelieved wall ofdevelopment, leading to Windmill Hill being walled in, and feeling unpleasant for those living there.

There seem to be several things wrong with the current plan.There seem to be very little parking provision for the amount of housing proposed (27 spaces for339 apartments). This will mean people will look for parking in the surrounding area such asWindmill Hill, which already suffers from severe parking issues. Also, the hight of the proposeddevelopment will conceal the topography of Windmill Hill from the rest of the city.This could also deflate the value of the existing houses on Windmill Hill that at the moment havestrong views over the city.The loss of green spce and trees at the bottom of the hill.

No thought given to the impact of the buildings, or the suitability for the currentenvironment. Totally incongruous and seemingly lazy architectural design. Will irrevocably alterthe look, feel and community of this area of Bristol. Effectively creates a wall between the hill andthe city, heightening the sense of the urban mass. The buildings are far higher than mosteverything around them.

This proposal has to be considered holistically as part of the whole Bedminster Green project andnot simply on its own. The cumulative impact (social and aesthetic) of all the planning permissionbeing granted in this area will be extreme, detrimental to so many, and permanent. This land can,and should, be developed more sensitively, and with more upfront effort given to design, suitabilityand community cohesion.

I don't like the look of this housing development at all. It looks like this building proposalnear Bedminster Green, railway and St. Catherines Place will make the area far too crowded andvery dark with little parking and oppressive tall buildings. If the accommodation is for students inthe holidays the flats will be empty and it will feel alienating and empty. The shopping area of EastStreet needs to be maintained and rubbish taken away instead. I can't see how hundreds ofunattractive modern flats will help or enhance this area of Victorian houses. Bedminster transportisn't great and there are no outside bike racks so more cars will be cluttered everywhere as peoplehave no choice but to drive. The pollution will be horrendous and it will be an unhealthy place tolive. The newish modern flats seem to work on the Harbourside as the light is good and there isthe expanse of water of the Harbour and big skies so it doesn't feel claustrophobic. Windmill Hilland Bedminster feel crowded already !

This proposal should not be considered in isolation but alongside the other proposedand consented developments in the Bedminster Green area.

If this development ( and those on neighbouring plots) are allowed to go ahead it will represent adistressing failure by the council to protect and/or enhance the built realm and to safeguard thehealth and wellbeing of its citizens, both future residents of the proposed development and currentresidents of the area. The only ones to profit and gain from this development will be thedevelopers, leaving the city and the citizens to pay the price in coming generations in terms ofpoor health, social deprivation and straight-forward uglification.

The blocks are consistently rectangular in outline which creates an unrelieved wall of blockydevelopment. This is unacceptable and undesirable in a low-rise residential area. When takenalongside the other upcoming and consented developments in the Bedminster Green area, itwould completely change the distinctive character of this area, one of the oldest in Bristol, which isa mix of low-rise housing, light industrial units, and open spaces.

The high-rise block at St Catherine's Place was original intended to be a landmark building ie astand-out high building in an area of low-rise, This seems to have been forgotten.

Although the scheme is divided into 3 blocks, their consistent massing blend them into one hugemass from some viewpoints which is unacceptable in terms of our city's topography. The heightand consistent tops of the blocks mean that Windmill Hill is hidden from the rest of the city.

The height of the blocks mean Bedminster Green will be shaded and surrounded by walls on 3sides, so destroying the current amenity and health benefits of this open space; keeping the Greenbut blocking off light, sun and air movement is an empty gesture.

Building 1 is 10 storeys at its highest point which exceeds the framework developed by thedevelopers themselves. It is too high for this location and would cause a dark and oppressivecanyon effect on Malago Road with a 17 storey building opposite.

The enclosed triangle design and height of the blocks will result in a gloomy and damp overlookedarea at its centre, not conducive to health and wellbeing and not aesthically pleasing.

Building 2 is blocky and uninspired; there is a huge need for inspired and inspiring design is thislocation alongside a recreational space to enhance this area. Its Hereford St elevation is too highand will create a canyon effect with St Catherine's Place.

Building 3, the one affordable housing block, is too high for this low-rise area, and is built veryclose to the railway line. This will be detrimental to people's wellbeing and livelihoods. Let's notrepeat the mistakes of previous decades - and centuries - when the wellbeing of the poorest insociety was disregarded.

The original reason for building in this location was to create a new entrance to the station andprovide workshop and office space; this aim needs to be reinstated.

The inclusion of the minimum percentage of 'affordable' housing is unacceptable. There is little'affordable' housing in the neighbouring schemes being proposed or already consented in theBedminster Green area. As this plot is actually owned by the city, there is an opportunity for BCCto set an example through the provision of plentiful social housing, if not actually compensate forthe lack elsewhere.

Some trees will be lost on Bedminster Green and in Hereford St car park; they are home toprotected species so should all be protected.

This proposal fails on every count: aesthetically, in social provision, in terms of the health andwellbeing of residents. It should be dismissed.

This is a hideous wall of building that when you will create a continuous wall of brick andconcrete. It is yet another building that is 10 stories high and will engulf the area. Not enough carparking has been provided, we are already seeing problems with parking on windmill hill from thedevelopments that have already gone up, without any sign of residents parking scheme this isn'tacceptable. We are losing vital green space that is home to bats, wildlife, trees and beautifulflowers. The affordable housing has been shoved next to the railway line like a inconvenient afterthought. This not a well thought out design for our community.

I object for the following reasons:- Affordable housing is too close too the railway line- not enough parking has been provided for residents- it takes away vital green space- it creates an awful continuous wall of buildings- the development is too high

I am very concerned about the number of dwellings and the imposing nature of thisdevelopment forming a wall of concrete which will have an impact on air quality that is alreadypoor in the area.

The development seems unimaginative and doesn't reflect the creative spirit of this part of town.

I also feel nicht enough thought has been given to amenities - schools, doctors etc.

With limited parking being built this will become a big issue for surrounding residents.

Other concerns as follows:

Heating to be by air source heatpump, combined heat and power plant also to be used. No on siterenewables will be used.

Loss of trees on the green and in Hereford St car park, the green is home to some protectedspecies, assumed to be bats

In visualisation studies the square nature of the blocks creates an un relieved wall of development,exacerbated when taken into account with other approved developments for the green

Concern that the tall floor to ceiling windows may cause overheating

Concern that the buildings have a high envelope area to heated space area I.e. poor form factorand this combined with difficult detailing around inset balconies and overhangs will make theimproved fabric performance difficult to achieve during building

Affordable housing block is built very close to the railway line worry that this will be disruptive anddetrimental to peoples livelihoods.

Concern that block 3 does not allow easy access to the railway embankment for maintenance.

The access points to the apartment blocks are not all in readily supervised areas, we have safetyconcerns

A portion of block 1 at the highest point is 10 stories and exceeds the framework

The height of the block and consistent tops of the blocks conceal the topography of windmill hillfrom the rest of the city.

My main objection is to another block of architecturally unimaginative high density flatscontinuing to change the historical nature of Bedminster. Specifically these blocks of flats willreduce light to the Green even if they are angled in certain ways. Some trees ( hopefully not thecherry trees) and greenery will be lost here and from Hereford Road Car Park area.

The affordable housing squeezed next to the railway line is likely to be noisy and affect the dailylives of those living there.

The height of the blocks of flats, even if just within the Framework, will dominate the small Greenand those using it, and seems out of scale, surrounded as it will be by tall blocks on all sides.

Social HousingThe Bedminster Green Framework promised that there would be 30% social or affordable housingon each plot. So far there is NO social or affordable at St Caths, a tiny amount on the approvedDandara building (on a piece of land belonging to BCC and in exchange for being allowed to builda multi storey car park) and none put forward on either of the huge student accomodationproposals. So this 30% offered here on Plot 5 is basically for the whole of Bedminster Green.Maths is not my strong point, but I think if the whole of Plot 5 were to be social or affordable, thatmay give us nearer to the 30% total that was agreed in the oft quoted Framework. I also feel thatputting all the affordable housing into the block squeezed between the railway embankment andthe road is shameful. These flats will definitely be worth less than others as the residents will beexpected to live metres from a busy intercity train line, the lower levels actually being below thelevel of the railway. This cannot be a healthy place for people to live.

Scale, massing and densityAll 3 buildings proposed for Plot 5 are completely out of scale with their surroundings. The tinygreen space that you are suggesting leaving us with in the middle of these 10 storey blocks will bean unpleasant place to spend time. There is a perfect balance between open space and the heightof the buildings around it. You need to walk through some of our other green spaces in Bristol,spend time sitting in them, look at the heights of the buildings around them, pace out the size ofthe green space, understand why these spaces work - try Queens Square, Millenium Square,Berkeley Square, Grosvenor Square. The list goes on and on. To have such a tiny green spaceremaining, and such tall buildings around it is a total lack of understanding of how the urban

environment affects people.The giant triangular building proposed - designed purely to get as much mass as possible on anexisting site - should not be built. The 2 buildings on the other 2 sides are far too tall, 5 or 6storeys is the maximum you should be proposing here.

Green Space, Biodiversity and WellbeingThe reason our Green works well for us, and for wildlife, is that it is made up of a mosaic ofdifferent habitats, in total creating a large enough space for wildlife and humans to thrive. Theactual green public open space is one part of this mosaic, the others are the roof of the woodenFederation of City Farms building, the wildlife garden around the wooden building, and thecarpark. The green roof has become a mecca for insects and therefore bats, the tree canopy andshrubs in the car park provide food and shelter for many birds, insects and mammals, the maturetrees on the green provide homes and feeding for many species and the wonderful wildlife gardenhas done what it was designed to do - become an important habitat for birds, insects, smallmammals, pondlife, and a feeding space for bats. For people, this larger green space allowssunlight to filter down onto the green, and gives views of and through trees and shrubs, and thesounds of wildlife. Although the actual public open space is planned to be kept (minus a strip ofshrubs and long grass on one side) the loss of the other 3 green areas will be incrediblydetrimental to our wellbeing, as shown through lots of current research into mental health. Greenspaces in cities are vital for our mental wellbeing, and in a city that has declared a BiodiversityEmergency we should be keeping such successful green spaces as this has become. We shouldbe keeping the wooden building and its green roof on this site (the most popular local buildingaccording to local community consultation), we should be opening the garden to the public, andperhaps opening the wooden building as a community space. The car park, with its mature treesand shrubs could become another community space, perhaps for boules/petanq, and so thisGreen Lung in the heart of Bedminster could offer a place of relaxation and restoration to the largenumber of new residents who are going to be living in the already planned tower blocks across theroad. On a very specific species point, there are rare bats using the railway line for travel betweenroosts and feeding grounds. These bats are very light averse, and a tower block on the site next tothe railway embankment (building 3) will create unacceptable levels of light pollution onto thedarkened railway corridor, which is so suitable for the bats at the moment.

ConsultationThis land is owned by Bristol City Council, therefore I would have expected them to consult widelywith local people before they made plans with a developer, Dandara, for them to exploit the landfor maximum monetary gain. If they had listened to local people, they would know that our ownextensive consultation (results all readily available in the WHaM Site Brief) showed that the FedFarm building is one of the most highly valued local buildings, that we care very strongly for wildlifeand care very much for our Green. That we want to develop a sustainable community, withbuildings that are healthy and liveable both for those living in them and for the whole community.That we don't want tower blocks or high rise, we want high density but low up to mid rise buildings.6 storeys is plenty and nothing more than that is necessary. Wapping Wharf is a good example of

a good development, or Paintworks, where there is a variety of heights and good design. All 3 ofthese buildings look to have been designed purely to maximise bulk and number of units,otherwise they would not follow the contours of the edge of each site so exactly.

Sustainability and Energy UseI can see nothing in the plans that satisfies our need for new buildings to be sustainably built andbased on the practice of minimal ongoing energy usage. The Bristol policy of 10% renewableenergy use does not seem to have been looked at here, and no mention of the sourcing ofongoing electricity use. I suggest that BCCs own Sustainable energy expert is asked to lookthrough these plans and give advice on whether they meet the needed criteria.

Size and Massing - This development is ginormous and reminiscent of sovietarchitecture. Creating the appearance of an unrelieved wall. At 10 storeys (in one place) itexceeds the heights specified in the council's own framework. Windmill Hill is a community drivenarea of bristol with a large demographic of you g families.

Although the Scheme is divided into 3 blocks this will blend together from many viewpoints. Thetopography of Windmill Hill will be concealed from the rest of the city. We will live behind abarricade made even worse by other proposed and approved developments close by.

Density - At around 350 dwellings per hectare, this is far too great for the area - it's infrastructure,roads and facilities. Already it took 6 months to for our family to get into our local GP's and thatwas 7 years ago!

Loss of trees and protected species - there is a climate emergency. This type of development fliescompletely in the face of that fact. Destroying trees and potential green corridors for wildlife.

Construction - The buildings have a high envelope area to heated space area i.e. poor form factorand this combined with difficult detailing around inset balconies and overhangs will make theimproved fabric performance difficult to achieve during building.

There are also no on-site renewables being used.

Health - The tall floor to ceiling windows may well cause overheating. The affordable portion of thebuilding is built very close to the railway line. This is far from ideal.

Safety - Block 3 does not allow easy access to the railway.

Ultimately this development screams greed from the council and greed from the developers andwill be a dirty great stain on Bristol's architecture if approved for years to come. It's shameful!

I wonder if that opening/exposing of the Malago on the green between WhitehouseLane and Dalby Avenue will - instead of being an attractive nature feature - simply end upbecoming a dumping ground for rubbish and fly tipping?

Objection for the following reasons:

Only 27 parking spaces for 339 apartments, meaning that residents will be using nearby streets topark - the additional traffic will result in increased pollution in an already overpolluted area, veryclose to a primary school.

No on-site renewable energy - a big oversight when we are all attempting to reduce the impact onthe environment.

Loss of trees - impacting on air quality, and on local wildlife.

Very high structures (up to 10 stories), blocking light for many existing residents, which will havean impact on their physical and emotional wellbeing.

The surrounding area is already very built up and does not need a further block of flats.Houses would be better and build more of scomkunity. Green space also needs to be preserved.

I am honestly horrified to see how many well established trees will be destroyed if theseproposals are allowed to go ahead. The Bedminster green area is so valuable for local wildlife andair filtering and as a carbon sink.

If housing needs to be built on this site everything possible should be done to safeguard theexisting natural resources. It should also be low intensity - 4 stories at the very most - to preservethe character of the area and avoid overwhelming local services.

Strongly object. Will ruin the green site & view towards town from Victoria Park

I object to this application on the basis that the amenities and area will deterioate fromsaid development. There will be inadequate parking inadequate schooling and doctor surgeries.The proposal does not align with the use of the area.

I wish to object to the scheme on the following grounds:

1. Over developmentThe density of the scheme seems far In excess of what the SPD on urban living suggests isappropriate for the setting of the site (an inner city area). The Bedminster Green frameworkdocument suggests a lower density would be appropriate, this seems to continue a commonpractice across all of the sites on Bedminster Green of too much development at the expense ofliveability.

2. Loss of green infrastructure, habitat and biodiversityThe SPD on urban living contains guidance on urban buildings designed to create peacemaking.Despite this site being one that has great context such as the green a wildlife garden and greenroof this context has been discarded the existing green space had portions of it cut away and littleto replace it. The application documents demonstrate that there is a net loss of biodiversity, and itdoes not seem sensible when you have a rich bio-diverse area to sacrifice this asset and top it upelsewhere when you are knowingly harming life (and endangered species in the case of the localbats) on this site: if this site is the one you can protect and control, you protect this site.Furthermore if biodiversity is lost here and replaced elsewhere outside of the local area, it isdoubtful that the community will ever see the benefit of that replacement so the development willharm the existing community rather than enhance it.

3. On site renewable energy sources

The lack of renewables in the scheme is disappointing, and runs contrary to any ideal aboutmaking a scheme sustainable. The air source heat pumps discussed will require energy to run andare not in themselves renewable energy sources, neither is the CHP discussed merely an energyefficiency measure. Schemes coming through the planning process for sites within an air qualitymanagement area that do not comply with Bristol policy for on site energy generation should beturned down.

4. Unsuitable height for the contextThe scheme is too tall for the local area and appears as a sheer face of masonry despite attemptsto relieve it with insets and metal cladding. The flat tops and consistent materiality between theblocks makes them blend together and appear as a wall. The renderings show an abrupt wall ofmasonry towering over the context, blocking out the hill and staring down at the existing residentsof Windmill Hill.

5. Materiality and response to contextA portion of the development is 10 storeys making this a tall building under the terms of the SPDon urban living and this document says specifically that tall buildings should be sited away forareas of elevated ground. The 10 storey strip along Dalby Avenue does exactly this.

In summary the scheme will harm the local context and community by walling off Windmill Hill fromthe rest of the city, reducing the biodiversity in the area, and may compromise the liveability of thelocal area by virtue of its high density.

This development is over scaled for the area which is seeing major developmentsalready leading to a further loss of green space and biodiversity in south Bristol in the midst of aclimate and environmental emergency.The designs themselves once again show a lack of any vision or respect for the people who live inthe area, with the positioning of the affordable housing next to the railway line showing a lack ofrespect to the people who will love in this proposed development.There is demand for housing because Bristol is a great place to be, with community and greenspace, this development and others like it are dragging this city down.

This development will drastically impact green spaces in the area ruining bedminstergreen, precious biodiversity and ruining the skyline making windmill boxed in and urbanised. Thereis insufficient parking to accommodate the scale of new properties and will make parkingimpossible for the community. Bringing in student accommodation will destroy the family nature ofthis area... more drinking, drugs, noise and police presence I'm sure!

I object to this proposal for the following reasons:

-Building 1 is higher than the agreed height in the developers framework and will cause a canyoneffect in this location on Malago Road. The shading of the green would be oppressive and theinternal shading in the centre of the building would be damp and depressing (with little lightentering much of the internal well during the darkest months. The building should be open on oneside and no more than 6 storeys high.

- Building 2 is too bulky to be next to a recreational space. Hereford St elevation too high and willcreate canyon effect with St Catherine's Place. The building should be set back further from thegreen and the storeys above ground level set back to prevent it being oppressive.

- Building 3 is too high and too close to the railway - this building was originally planning to createa new entrance to the station, with workshop and office space. This commitment has beendropped in favour of cramped one and two bedroom flats. This building creates a wall along therailway that blocks views from Victoria Park and totally blocks the residential streets at the bottomof Windmill Hill.

This is poorly designed, Plot 1 uses land that is a public amenity, giving the only car parking to thestation at a point when Bristol has declared a climate emergency and pledged to become carbonneutral by 2030. There are already 12 schools in the vicinity that were found to have levels of airquality that breached WHO guidelines for NO2 and PM2.5. Allowing Building 1 to be built on land

that is in public ownership ('sold' or 'gifted' to the developers in a manner that hasn't been madepublic and transparent), whilst doing little to improve public transport or other public amenities inthe area (an area which is already under resourced into terms of infrastructure) is in directcounterpoint to this pledge and show no real commitment to improving air quality levels.

There is already massive development that has been give permission on all sides of this plot, withhundreds of students, several of Bristol's tallest buildings, thousands of new residents and littlethought to how they will integrate with the existing community. This proposal should be refused.

The proposed triangular layout of the building(s) to the north of Hereford Street and tothe south-west of Bedminster Green is an absolute disaster. It has the look of a terrible prisonblock.

How can you possibly condone the construction of a building that has such a narrow enclosedcentral area, that will be a shaded, dank and depressing area with little or no chance of enhancingthe life of anyone living there let alone anyone living outside of it.

Surely you can't condone this kind of construction. It is creating an unwelcome unfriendlydevelopment. You have to encourage interaction in communities, not these fortress like blocks.Open it up, more tree planting, more connected landscapes that are pleasant to be in.

The scale of the building will destroy a public view, destroy communities. Providehousing of the type that is not needed. We have a surplus of high rise apartments. There isnothing for families. Building work will cause disruption for a long time. A smaller scaledevelopment would have less opposition , would get built quickly. The proposed buildings aredestroying the area. It feels like the politicians hate the people of Bedminster and Windmill Hill. Iknow this is irrelevent to the criteria but whatever people say wont make any difference now. Youwill ignore any objections.

27 parking spaces for hundreds of new homes and no plan for a residents parkingscheme.Taken together, appartment blocks will create a solid wall of concrete and windows, blocking outlight and resulting in a canyoning effect for wind and noiseThe affordable housing block is far too close to the railwayWhat extra facilities will be provided in the area - nurseries, schools, dentists, doctors - already alloversubscribed.

STATEMENT OF OBJECTION AGAINST APP 21/05219/F

Once again I'm faced with the depressing task of writing to object to yet another ill thought out andcynical development application for high-rise blocks on Bedminster 'Green.' If it weren't so tragic,the name would be funny, as there will be virtually no daylight managing to hit anything greenliving in what is now a verdant space when it is surrounded on all four sides by high rise blocks -some with as many as 17 storeys, and half the 'Green' will have been torn up to provide floodescape (neatly badged as 'opening up the River Malago'), which will be caused by all the newbuilding altering the existing water flows.

The growth of housing should not be shoe-horned into one or two wards in Bristol but spreadevenly across it; rather than over-populating what are already the two densely populated wards inthe city which do not have the infrastructure to meet the needs of an exponential growth inpopulation.

My specific concerns with the proposed development of Plot 5 are:Block 3 - for social housing - it is nothing short of disgraceful that all of the social housing issquashed into a relatively small area practically on top of the railway line - Would you live thatclose to a railway line?

This form of ghettoisation has no place in a city which purports to care about equity and have asocial conscience. It is frankly disgusting that none of the other developments approved have the

minimum legal requirement of social and affordable housing. And that even although this plandoes have almost the minimum legal requirement this is situated all in one block and in the worstpossible space imaginable - this is not appropriate or acceptable in the C21st .

The social housing should be spread throughout the buildings. Shame on the developers forthinking that this is acceptable and even more shame on the Planning Committee if it approves theapplication.

Design - Looking at the artists drawings the blocks are incongruous with the surroundings - over-bearing and imposing. All are of similar material and design. Although separate buildings, whenviewing from Windmill Hill, in conjunction with the other developments approved, this massingpresents an unrelieved super-high and forbidding wall which cuts Windmill Hill off from Bedminsterwhich it has a natural geographical connection to.

This totally alters the typology of the city - it will not be possible to see the horizon to the North ofthe city from Windmill Hill and looking South the same is true - Windmill Hill will not be seen fromother parts of the city.

To be more congruous with the geography the buildings should be no more than 6 floors - 5 if thebottom floor is double the height. A number of the blocks in this plan exceed this - one is 10 floors- which exceeds the limit set in the Bedminster Green Framework.

Loss of light or privacy - there is a significant issue with the loss of light which will be experiencedby many of the flats within the blocks planned and the communal areas outside - these publicspaces will not be pleasant and the lack of light/light losses may well exceed the acceptable legallimits.

Overshadowing on homes - as the sun sets in the West from mid-afternoon onwards in Spring,Summer and Autumn the development will cast long shadows over the back of some of thehouses in Fraser Street and will cut significant light from all the houses in Fraser St which back onto the railway line. We don't get a great deal of sunlight on the railway side of the street as thegardens are North facing - it not acceptable to us that we should lose more.

Highway safety - adding 700-800 people - in addition to 800 students (Plot 3) and over 2,000 onadjoining developments at St Catherine's Place and Little Paradise, will dramatically increaseproblems with highway safety, especially as this development is sited adjacent to a main arterialroad to the South West of Bristol. That's even without considering highway safety during theconstruction of these tower blocks and the three even higher ones proposed for adjacent sites.

The entrances to all the blocks are less than ideal present a hazard - especially as given theirproximity to the junctions of roads (particularly Hereford St).

Safety and Maintenance of the Railway/embankment and Block 3 - if Block 3 is built access to theback of Block 3 to carry out maintenance will be severely restricted/impossible - as it will be tocarry out maintenance to the railway track and embankment behind the building - placing aresidential building so close to a railway line is nothing short of stupid.

Traffic and parking issues - As with the other developments which now have planning approvalthere is virtually no parking available in this plan (27 spaces, including disabled) and no way ofloading or unloading near the commercial outlets and none for Block 3 (affordable housing).Although car driving students are discouraged in the neighbouring Plot 3 development it is notrealistic to expect that a significant number of students, or their visiting relatives not to bring cars..All this next to the main arterial road from South Bristol into the city centre - it's a recipe for chaos,especially at the beginning and end of the academic year.

Making Whitehouse Lane one-way and closing Windmill Hill to cars as proposed in the transportplan to support this development, is a massive disbenefit to existing residents and I stronglyoppose this plan.

The suggestion of making Windmill Hill a CPZ would not solve the problem as these operatebetween 8 and 5pm Monday to Friday - when many car drivers on the Hill will be using theirvehicles to get to work - finding that there is nowhere to park on their return at the end of theworking day or at weekends. The situation is difficult enough at present as CPZs have beenintroduced in areas surrounding Windmill Hill, so commuters pushed out from these areas are nowusing Windmill Hill making parking difficult for residents already.

The traffic problems during construction will be horrendous as it will go on for years as there arethree adjacent sites all of high-rise development with applications already agreed.

Noise - It is not possible to add approximately 800 people (just on this one development) and forthe pre-existing noise level to remain the same. One of the unique characteristics of this area, andone we value most highly, is how quiet the area can be especially at the week-ends.

Noise during construction - in conjunction with three other applications approved the noise, dustand disruption is going to be horrendous for years.

Wind tunnel effect caused by density of high buildings and pollution - in conjunction with the otherhigh-rise buildings with planning approved there will be a significant wind tunnel effect andpollution will be trapped near ground level.

Amenity - The density of dwellings to space exceeds legal limits as it would be in the region of 350per hectare.

Primary care services are stretched to beyond capacity in this area even more so since the COVID

pandemic began - GP practices may still be registering patients - but that doesn't mean that theyare able to offer a decent service. It is almost impossible to get an appointment with a GP within areasonable time for a non-emergency health issue at present - especially if you are working.

With less than 30% of this development affordable housing, this development in conjunction withthe others approved, will be the death knell for the many retailers in East St who have remainedloyal to the local community in Bedminster by serving the less affluent of us in the area - where willwe go to shop once all the affordable retailers in East Street are pushed out?

Wildlife and conservation - currently we have a huge diversity of birds locally, sometimes we evenget a pair of Jays (very shy birds) in the trees between Fraser St and the railway. There are someprotected species living in Bedminster Green itself. We also have 8 different bat species, some ofthem rare, in and around Windmill Hill and Victoria Park area - you can see them at dusk in all thetrees and backs of houses on Fraser St. This recognised 'commuter route' for the bats, includingroosting sites, goes from the park and follows the railway all the way along past Cotswold Rd andbeyond. The massive scale of the developments will mean prolonged disruption, dust, constantheavy traffic and noise - this will have a significant and deleterious impact on the wild life -including the bats. There are legal consequences to destroying bat roosting and habitats.

Historic buildings - The Green House opposite the Plot 3 site is of historic interest being uniquebuilding in Bristol and of a rare construction in the UK - it's nothing short of a crime to destroy this.

Destruction of trees - many trees will be cut down if the application is approved but there is no planto replace them all in the application.

Please turn this application down - it is ill thought out, and creates a solid high-rise wall cutting usof from Bedminster, our local area.

WHaM comment for Plot 5 on Bedminster Green

Application no: 21/05219/F

The group objects in the strongest possible manner to this development.

The application form provides the following figures for the development of 339 apartments, 101 of which are affordable housing units (social or intermediate rent).

These apartments are divided into 3 blocks surrounding the patch of land known locally as Bedminster Green: Block 1 is to the west of the Green, Block 2 to the east, and Block 3 to the south across the road adjacent to the railway line. We understand that Block 3 is to be entirely affordable with the other affordable units located elsewhere.

Commercial space is located at the ground level on all 3 blocks

DrawingsIt has been very difficult to get a full appreciation for the scheme as the drawings do not have a scale bar (which this group understands is a requirement for validation of planning applications) and as a result it is not entirely clear on the full size of the development, neither does the scheme have an accommodation schedule which would also have assisted many people understanding the full extents of the scheme and what

that development entails.

DensityUndertaking a rough calculation from the figures supplied in the application form (the density calculation undertaken as part of the SPD on urban living could not be found) 339 dwellings on 0.96ha works out at about 350 dwellings per hectare, excluding that part of the green which is the subject of the council's Malago River restoration project, but making some allowance for the inclusion of portions of major roads.

Bedminster Green is within an Inner Urban Area as described in the planning document Urban Living and shown on the map on page 13 of the document. This document contains the aspiration that new developments seek 'optimal density' which is described as follows:"optimal density in new development is considered to be one that balances the efficient and effective use of land, with aspirations for a positive response to context, successful placemaking and liveability."The group has grave concerns that this aspiration is not being pursued. At over 300dph the scheme is much more dense than a typical inner urban area would be expected to be. Successful nearby developments, such as Wapping Wharf, and the first few phases of the Paintworks, are significantly lower (below 300dph) and it is appreciable through the quality in their well lit, generous public spaces. The Bedminster Green Framework envisages an average density over the whole Bedminster Green development of between 220 and 320 dph.Even this is already well above the 120 optimum first mentioned in the Local Plan or the 'Wapping Wharf' density of around 200dph later thought suitable for Bedminster Green. This development goes beyond this and makes no explanation for the increased density more suitable for a city centre area. These density guidelines have been set by the city council established to represent available resources in an area and what those types of areas can support. In going beyond these limits the development stretches what is currently available and compromises the liveability for new and existing residents without providing a solution.

Whilst it may be argued that the Green will add a significant public space to the development it must be remembered that this space is one that has grown and evolved over many years with much established plant life and extends beyond the tall trees that are the most obvious feature of the Green, but also include low level and intermediate green infrastructure thriving in the established conditions. To reach the density of this development some of the Green has been taken away (on the western edge) and bounded on 2 sides (east and west) with 9 storey buildings. The loss of this green infrastructure and the potential harmful impact this will cause on the remaining plant life is not considered 'optimal', particularly in a city that has a self declared biodiversity crisis, and particularly not on land that is owned by the council that declared this crisis.Bedminster Green is a well known, identified place loved by the local people who cross it regularly, The change to this space, which will become darker and more overshadowed by development, is not considered 'optimal' by this group.

Commercial developmentAs the area is already used by many local businesses the group was concerned about

the loss of employment, so it is good that some new spaces are proposed within the development. There is some concern that the over development of the site to 3 sides of this open space will lead to commercialization of the Green.

Biodiversity and its loss on Bedminster Green

The 'Green' in Bedminster Green is an already existing, much valued green, open space in this inner-city neighbourhood. Local people cross this space every day on foot and by bicycle to work, to the shops, to school, to college and for many other reasons. It is a part of many, many people's daily lives.

For people, and for wildlife, the Green provides an important place of safety and tranquility between 2 busy roads, a green lung and a lull in the frenetic concrete and tarmac city beyond. What makes this area so special is that it provides a mosaic of habitats for wildlife and a space for people to enjoy that reaches beyond the actual public open space. There are 4 main components to this green space.

o Firstly, the public open space of the actual green, which is made up of a range of species of mature trees, areas of wildflowers and bulbs, and long grass and shrubs along one edge.o Secondly, the Federation of City Farms building has a green roof, which is home to many species of insect and which, according to the Ecological Appraisal (Section 7.12), has a concentration of bat activity.o Thirdly, the Federation of City Farms garden has been planted and maintained for wildlife and offers a pond, trees, grass and shrubs particularly chosen to offer homes to a wide range of wildlife. The Ecological Appraisal (Section 7.12) tells us that bat activity is also concentrated around these gardens. o And fourthly, the public car park provides an almost complete leaf canopy over the carpark, for birds and insects. The trees and shrubs offer leaves, blossom and berries for people to enjoy, and homes and food for wildlife.

These 4 areas between them offer a wide range of habitats for wildlife, and a large enough area of green space for the sunlight to reach down to the ground and offer a good place for people, as well as for plants and animals to thrive.

This planning application attempts, at a stroke, to remove 3 of these 4 habitats. All that would remain would be the public open space, and that reduced at one edge. For wildlife this will have a huge negative impact with a loss of habitat and space. And this in a city where we have declared a Biodiversity Emergency. For people this loss will have a huge negative impact with a loss of greenery, sunlight and views of and through trees. And this in a time when we have research to show how important these things are to our mental health. The remaining 'Green' will be surrounded by buildings all over 9 storeys tall, and the loss of light and sunlight to the ground will impact hugely on the remaining biodiversity and on people. At the moment we can cycle and walk for a few minutes through a green area, with the sound of birds and wind in the leaves, blossom fluttering around us and the movement of small birds and mammals in the hedgerow. This proposal will leave us walking in the shadow of a huge building, and the wildlife will have had to move on.

Effect of light spill on the railway- a commuting route for rare batsRecent studies in the area have noted that rare and very light-averse bats are known to use the railway line as a commuting route between roosts and feeding sites. These species include, among others: Lesser Horseshoes, Bechstein's bats, and Brown Long-Eared bats. Some of these bats come from nationally important maternity roosts of the Lesser Horseshoe bat, which is a Priority Species under the UK Biodiversity Action Plan, please see references for those studies below.This is particularly relevant, as part of the planned development lies right beside the railway line. Artificial light can cause flight paths to be severed, which, even at some distance from the roost, can cause desertion of the roost. This light can include sources from external lights, windows, and glare. We are concerned that the Ecological Appraisal does not address this as an issue. It investigates potential bat roosts on the site, and it mentions minimising light onto trees (Section 7.17), but fails to address the effect of light spill on the railway, as a recognised bat commuting route. For reference, please see the following two documents: o Victoria Park, West Site. Bat Acoustic Surveys and Examination of Lesser Horseshoe Bat Activity, undertaken by Wild Service, November 2016o Ashton Park environmental assessment (Section 6: Bats), undertaken by Baker Shepherd Gillespie, 2009As noted above, these documents both show that Lesser Horseshoe bats, Bechstein's bats and Brown Long-Eared bats are known to use the railway line as a commuting route between roosts, along with other species including Serotine, Noctule, Leisler's, Common pipistrelle and Soprano pipistrelle, and possibly other Myotis species. Nationally important Lesser Horseshoe maternity roosts are mentioned to be in the vicinity of the railway line. In the city, a severing of a major commuting route would leave the bats with no other commuting route option. The survey carried out by Wild Service in 2016 states that the railway line provides a linear linkage for bats from the River Avon to Bedminster Down and beyond. It further recommends "the creation of a dark corridor along the railway line".It is currently illegal to cause disturbance that affects populations of bats, under the Wildlife and Countryside Act 1981 (as amended). Artificial lighting which causes disturbance and potential abandonment of a roost can constitute an offence (Information taken from Bat Conservation Trust guidance note "Bats and Artificial Lighting in the UK"). The Bat Conservation Trust guidance note states that "Artificial light can cause a flight path to be severed". Lesser Horseshoe bats, Bechstein's bats, and Brown Long-Eared bats, are known to be extremely light-adverse. The Bat Conservation Trust guidance note ("Bats and Artificial Lighting in the UK") informs us that any light at all will have an adverse effect on these species of bats, as apparently the average light level on hedgerows most regularly used by Lesser Horseshoe bats has been recorded at 0.45 lux, and it goes on to state that "a no-lighting approach should be taken on foraging or commuting habitat of rare and light-adverse species such as Bechstein's bats and horseshoe bats". The lack of an External Light Assessment for this development, means that the effect on bats using the railway line does not seem to have been assessed. Such a study should surely be undertaken and must include an assessment of light sources from:

o Outdoor lighting. o Windows: The document from the Bat Conservation Trust specifically says "sources of lighting which can disturb bats are not limited to roadside or external security lighting, but can also include light spill via windows.o Glare: the document from the Bat Conservation Trust states that " Additionally, glare may affect bats over a greater distance than the target area directly illuminated by the luminaire and must also be considered on your site". o The Vertical Plane of Light: This is apparently important, according to the Bat Conservation Trust guidance note, because it enables a visualisation of the effects of illumination at the various heights at which different bat species fly.As it stands, a development on land owned by a city council that has declared a biodiversity should not be permitted unless it can be shown that minimal harm is done to endangered species living and using the area.

Form and MassingThe buildings vary only slightly in height from around 7 storeys to 10 storeys and this has produced some blocky elevations which present an ugly, unwelcoming, and unimaginative façade. Rather than using this opportunity to enhance the Green and the entrance to Windmill Hill, a place popular and well identified with the locals, has become a space that will do the opposite. Rather than mark the entrance to a well defined character area of Windmill Hill the development gives no consideration to the local urban context by presenting the same type of treatment to all elevations.It does not assist the general person to navigate, and such measures which do not provide visual cues are unhelpful and frequently confusing. The result of this treatment is unimaginative, dull facades which will in no way contribute to a successful place-making effort.

Unrelieved square tops of buildings appear as a wall in many of the visualisations and will mask the visual cues of the area that enable the people at ground level to appreciate the topography of Bristol. The consistent, repetitive and disappointing choice to avoid identifying navigable features or any attempt to relieve the monotony of the façade has created 3 building which blend together as a wall and this can clearly be see in many of the visualisations. It is especially telling, in the views from Bedminster Station platform, Windmill Hill and along Malago Road, that it is difficult to see where one block ends and another starts. Truly this is a wall that will hide Windmill Hill from the rest of the city and provide a block of development that will face the homes and gardens of many on the hill, impinging on privacy for these residents.

A portion of this development, the 10 storey part of block 1, is outside the parameters of the Bedminster Green framework for height and should not be permitted for this reason.

The architect has brought up several examples of byzantine style for architecture as an inspiration. These examples are not local to Bedminster (once a separate settlement to Bristol and larger than it). In fact, the local historic material palette of Bedminster is Victorian red brick, with stone detailing and the use of pennant sandstone. This context has been ignored in favour of a brown brick and yellow/bronze metal cladding. The notable elements of the byzantine architecture example shown, such as the high contrast details around openings, are not referenced in their design, suggesting those

local cues are not picked up in this design.

NOTE: the visualisations included in the submission show this building in context with the other approved development. We urge these images to be used and referenced when making a decision on the application.

ConsultationThe nature of the consultation with the local residents has been disappointing for this part of the development at Bedminster Green. As this is council owned land the opportunity was there for the land owner to insist that early stage discussions were had to understand the concerns and the opportunities the site represents to benefit all of the needs of the current and future residents of the area. This was not done. The group understands that a lot of discussions were had with the city Design Group over the scheme to develop it, but the local residents have only seen late-stage representations of a very nearly finished scheme that has changed little between these consultation. At each time a very high proportion of comments have been directed at the height, massing, density and loss of biodiversity that this scheme represents, yet there has been no attempt to make changes within the scheme. It is disappointing that the development team has merely done a 'tick-box' exercise on the consultation rather than use this valuable design tool for its purpose which is to produce something site specific, suited to local area and that works with the local community. The failure of the development team to engage with local context is evident in the way that the scheme is blocky, square and contemptuous to the local typology and context of Windmill Hill, by ignoring it and blocking it out.

(The group recalls an earlier scheme by the same architect on a nearby site that originally 'celebrated' the coloured house facades of Bristol, this was in part rejected because the approach was contrived and could not emulate the organic development that these facades represent. This attitude has clearly changed as the same design team now wishes to block them out and create a monotonous, uninteresting, and homogenous façade as a response to context that is not local to Bedminster).

Sustainability and approach to energy useThe scheme intends to use air source heat pumps to provide space and water heating for the apartments and makes reference to using a combined heat and power plant, though it is not clear to what purpose, unless the heat is likely to be used just for the commercial space.Bristol planning policy notes that CHPs are not a renewable energy measure but an energy efficiency measure, it is not clear how this intends to be powered.The group thinks that the inclusion of air source heat pumps rather than gas boilers is positive, but draws its attention to the fact that these need to run on electricity. The building does not include any on site renewables and the proposal does not intend to insist on energy coming from a renewable source so the scheme makes no attempt to meet the Bristol policy of providing 20% renewables on site, and for this reason permission should be refused.The above methods of heating will both have a carbon impact on the development. The developer says that they intend to minimise this by using a better level of thermal insulation than required in building regulations (a level is not stated so this could be very

small and no target is stated) and reduce the level of air changes. The buildings themselves however seem to have a large ratio of heated area to perimeter, when designing for low energy buildings using Passivhaus, for example, this is called form factor. The high form factor of these buildings because of the high perimeter area suggests that a larger amount of insulation may be needed to lower the actual energy use of the building. Materials themselves have embodied carbon which represents the amount of energy required to make the materials themselves, this could therefore be larger for this scheme (although again the level of performance for the buildings has not been even suggested as a target).The forms of the buildings themselves contain many regular indents and overhangs which will make eliminating 'cold bridges difficult to achieve. (cold bridges are areas where the thermal envelope is reduced to very low thickness or eliminated entirely, allowing heat to be lost).

The group was also concerned about the floor to ceiling windows that feature on many of the south facing windows. These will have an impact in the summer by letting in heat through the glass as they are not being entirely shaded. No overheating study has been included in the application, but if mechanical cooling methods are required in the apartments this will further drive up the electricity use of the building and with no renewables on site, the carbon footprint of the development. We believe that a council development which includes affordable housing intended for those on low incomes, should not require large amounts of energy to live in. The recent rise in energy prices and the discussions at the recent COP26 suggests this is not a development that should be permitted unless it will protect the livelihood of those people it is accommodating.

In summary, the form, layout, and absence of renewables on the building mean that the developer has made little effort to make this a sustainable building. They make no effort to comply with local energy policy and any gains they intend to make through improved fabric performance may be cancelled out.

Block 3The proximity of Block 3 to the railway line was a great cause for concern to the team. This is a well used railway line, the principal route from Bristol Temple Meads to and from the west of the country. This means it is regularly used by passenger and goods trains during the day and night, many of which sit stationary outside Bedminster Station with their engines running as they wait for platforms to open at Temple Meads. This will have a detrimental impact on the residents of Block 3 as this will be especially close to their windows and, in some cases, front doors, noise and air quality (the train line is not electrified to the south west and any proposals to do so are not in the public realm). The open balcony access to the apartments in this block forms a narrow corridor and the gap between building and the embankment could trap any exhaust emissions from the trains within these spaces.

This should not be considered a good idea to place residents in such proximity to the station. It is sad that the developer seems to propose to put the lowest value (affordable) homes in this location. There was also concern that should this block be impossible to construct to appropriate levels of sound insulation and air quality it may not be built at all. Every effort should be made to ensure the full quota of affordable

housing required by local planning policy is implemented in all developments of Bedminster Green.

The southern facing apartments on the lowest levels of this block will be below the line of the railway and have severely impacted views and daylighting on the southern façade and should not be allowed for this reason.

SecurityThere is concern that the entrances to Block 1 at the western end is not supervised and may not be secure for people to be use late at night.

DaylightingThe courtyard of Block 1 will be in shadow especially at the lower levels, this courtyard is also very narrow even at the widest end (the lack of a scale bar on the drawings makes it difficult to be certain).The size of the courtyard and the overshadowing seem to render the double aspect nature of the apartments redundant. Most of these flats will only have a single aspect of any benefit to the scheme and so we do not think this block is well designed and the scheme refused for this reason. Block 2 suffers from similar problems albeit to a lesser extent.

To conclude:WHaM objects most strongly to this development on the following grounds.

o The building is too tall to comply with local policyo The height of the building masks the local topographyo The density of the proposal is too high for an inner city areao The proposed methods of reducing energy use are unlikely to worko The scheme does not comply with policy regarding on site renewableso Block 3 is very close to the railway line and the detrimental effects of noise and air pollution will be felt by its residentso The material selection and repetitive nature of the design is oppressive and not conducive to successful place-makingo The loss of local biodiversity is unacceptableo There are endangered species in the area that must be protected. o The visual impact of the blocks as a wall from many viewpoints is damaging to the local area

I object to this application on the following grounds.

Size and Massing - This development is massive. Creating the appearance of an unrelieved wall.At 10 storeys (in one place) it exceeds the heights specified in the council's own frameworkdocument.Although the Scheme is divided into 3 blocks this will blend together from many viewpoints. Thetopography of Windmill Hill will be concealed from the rest of the city. We will live behind abarricade made even worse by other proposed and approved developments close by.

Density - At around 350 dwellings per hectare, this is far too great for the area - it's infrastructure,roads and facilities.

Loss of trees and protected species - there is a climate emergency. This type of development fliescompletely in the face of that fact. Destroying trees and potential green corridors for wildlife.

Construction - The buildings have a high envelope area to heated space area i.e. poor form factorand this combined with difficult detailing around inset balconies and overhangs will make theimproved fabric performance difficult to achieve during buildingThere are also no on-site renewables being used.

Health - The tall floor to ceiling windows may well cause overheating. The affordable portion of thebuilding is built very close to the railway line. This is far from ideal.

Safety - Block 3 does not allow easy access to the railway embankment for maintenance.The access points to the apartment blocks are not all in readily supervised areas, we have safetyconcerns

One last point - WHY SO MONSTEROUS? WHY SO UGLY? WHY SO WRONG HEADED? Whenwe could have had something forward looking, creative and problem solving? Something toenhance this area and give people much needed homes?

Thank youEsmé Clutterbuck

I wish to object to the plans for Plot 5 as currently presented on the following grounds:

The density of dwellings (over 300 per hectare) is much higher than developments approved inother inner city areasThe height and design of the development presents a dominant, uniform and unattractive wallwhich obscures Windmill Hill Asan important landmark from the rest of the City. At its highest of 10storeys the tallest building exceeds the limits outline in the framework agreementIn the context of the current climate crisis, despite the proposals for combined heat and powerthere seems to be no inclusion of further renewable technologiesThe development and the removal of trees and the consequent impact on local biodiversity is anunacceptable incursion on the vital green space of Bedminster GreenWhile the proposals include an acceptable level of affordable housing, the fact that the majority isin Building 3 is cause for concern. Its proximity to the railway line is not an ideal environment andissues of access to the embankment and the nature of the land could also be problematic. If itwere ultimately gone the case that this was not deemed viable to build what guarantees wouldthere be that the proposed percentage of affordable housing would be delivered elsewhere in thedevelopment.Overall, I urge you to reject the current proposal in favour of any future proposals that would betterserve residents and the local community.

Paul Cox

Any rational plan for Bedminster Green would have included adequate provision of open spacebut, since the project has been mainly developer led, that has not been a priority. Even when thecouncil has been involved, as with Plot 4, their obsession with achieving numbers has meantsupporting the proposal for a sixteen storey block, densely packed with 295 small apartments. Andwhat did they get in return? Twenty-one social flats (7% of the total) and a three storey car park onLittle Paradise.

The provision of that car park is intended to release Hereford Street car park on Plot 5 fordevelopment. But why should development here mean housing? Why are planners simplycontinuing as if Covid never happened, as if there is no concern over our increasing carbonfootprint nor any recent promise on bio-diversity?

Hereford Street car park is not a post-industrial wasteland; it is a tree-lined open space alreadypartly occupied by a garden and a green roofed building. It would be suitable as an addition to theexisting Green to form a double urban 'lung' providing a small but welcome breathing space for thethousands of new residents expected nearby.

I should not have to remind the Planning Committee that Plot 5 is public land. It should be used forpublic benefit. Under this proposal, half of it (the car park) will be permanently gifted to Dandara,the developer, to build 158 homes for private sale. Does the council think this is a bargain simply

because 30% of the total build of 339 homes will be social housing, even though 30% is supposedto be the norm?

It will certainly come at a cost in density. Across Plots 4 and 5 (the two Dandara schemes) thedensity will far exceed the average of 220 to 320 dwellings per hectare envisaged in theBedminster Green Framework. Indeed, since Plot 4 has already been approved at 600 perhectare, the only way even the top end of the average could be achieved would be by buildingalmost nothing on Plot 5. Not a bad idea, perhaps.

The sad reality is that, because no-one in a position of power was prepared to take responsibilityfor creating an overall vision or even a sensible balanced plan, the whole Bedminster Greenproject will end up as the sum of each developer's ambition, to leave us with an uninterrupted,densely packed, uniform wall, 400 metres long and up to 50 metres high, permanently altering thetopography of the city.

I am old enough not to care and my grandchildren don't live in Bristol but is this the legacy wewant to pass on down the twenty-first century?

Effect of light spill on the railway- a commuting route for rare bats

Rare and very light-averse bats (Lesser Horseshoes, Bechstein's bats, and Brown Long-Earedbats, amongst others) are known to use the railway line as a commuting route between roosts andfeeding sites, including from a nationally important maternity roost of the Lesser Horseshoe bat,which is a Priority Species under the UK Biodiversity Action Plan.

Part of the planned development lies immediately beside the railway line.

Artificial light can cause flight paths to be severed, which, even at some distance from the roost,can cause desertion of the roost. This light can include sources from external lights, windows, andglare.

I am concerned that the Ecological Appraisal does not address this as an issue. It investigatespotential bat roosts on the site, and it mentions minimising light onto trees (Section 7.17), but failsto address the effect of light spill on the railway, as a recognised bat commuting route.

For reference, please see the following two documents:- Victoria Park, West Site. Bat Acoustic Surveys and Examination of Lesser Horseshoe BatActivity, undertaken by Wild Service, November 2016- Ashton Park environmental assessment (Section 6: Bats), undertaken by Baker ShepherdGillespie, 2009

These documents both show that Lesser Horseshoe bats, Bechstein's bats and Brown Long-Eared bats are known to use the railway line as a commuting route between roosts, along withother species including Serotine, Noctule, Leisler's, Common pipistrelle and Soprano pipistrelle,and possibly other Myotis species. Nationally-important Lesser Horseshoe maternity roosts arementioned to be in the vicinity of the railway line. In the city, a severing of a major commutingroute would leave the bats with no other commuting route option. The survey carried out by WildService in 2016 states that the railway line provides a linear linkage for bats from the River Avon toBedminster Down and beyond. It further recommends "the creation of a dark corridor along therailway line".

It is currently illegal to cause disturbance that affects populations of bats, under the Wildlife andCountryside Act 1981 (as amended). Artificial lighting which causes disturbance and potentialabandonment of a roost can constitute an offence (Information taken from Bat Conservation Trustguidance note "Bats and Artificial Lighting in the UK"). The Bat Conservation Trust guidance notestates that "Artificial light can cause a flight path to be severed".

Lesser Horseshoe bats, Bechstein's bats, and Brown Long-Eared bats, are known to be extremelylight-adverse. The Bat Conservation Trust guidance note ("Bats and Artificial Lighting in the UK")informs us that any light at all will have an adverse effect on these species of bats, as apparentlythe average light level on hedgerows most regularly used by Lesser Horseshoe bats has beenrecorded at 0.45 lux, and it goes on to state that "a no-lighting approach should be taken onforaging or commuting habitat of rare and light-adverse species such as Bechstein's bats andhorseshoe bats".

I am also concerned there is no External Light Assessment of this development, which would allowthe effect on bats on the railway line to be assessed. This should surely include an assessment oflight sources from:- Outdoor lighting.- Windows: The document from the Bat Conservation Trust specifically says "sources of lightingwhich can disturb bats are not limited to roadside or external security lighting, but can also includelight spill via windows.- Glare: the document from the Bat Conservation Trust states that " Additionally, glare may affectbats over a greater distance than the target area directly illuminated by the luminaire and mustalso be considered on your site".- The Vertical Plane of Light: This is apparently important, according to the Bat Conservation Trustguidance note, because it enables a visualisation of the effects of illumination at the variousheights at which different bat species fly.

The scheme is much too large in scale and massing for this site. The visualisations,even in a developer-friendly best-case scenario, appear as a relentless wall of development. In thecontext of the other relentless walls of development that have already been approved, this willappear very ugly indeed. It is poor design, to a poor brief, not suited at all to the setting. It will endup looking and feeling like a prison yard, but with less natural light and likely a howling windblowing through.

Loss of trees on the green will be lost, along with established habitat that cannot be replaced.

The affordable housing block is very close to the railway line. This will not be an attractive place tolive - disruptive to people's lives and potentially mental health. Sites close to the rail line should bereserved as sites to potentially move local light industries, and more suitable sites used forhousing. Documents related to rail noise note that trains stop by 10 or 11 pm. Anyone with anylocal knowledge knows that large, noisy freight trains move along the line throughout the night, asdo empty passenger trains getting in place for the morning. This block would be an awful place tolive.

I'm concerned about the safety aspect of some entrance points, which are not well trafficked norvisible.

A portion of block 1 at the highest point is 10 stories and exceeds the local framework.The height of the block and consistent tops of the blocks conceal the topography of windmill hill

from the rest of the city.

This is really one of the worst plots in the whole Bedminster green scheme in terms of cramming in'units' in a totally unsuitable spot.

Amongst my reasons for objecting to this planning application are the following:The density of dwellings is not appropriate to the area. The height of these proposed blocks isinappropriate alongside too many other planned high blocks nearby. The design results in a heavymass of building, not at all sympathetic to the other dwellings in the area which are mostly two andthree storeys.

Tall buildings need space around them, for the residents therein and for the general area. Somany of the flats will have only other flats to look at, no other view. And the social housing islimited to a constricted area close to the railway with limited safe access to outdoor space.

Whilst I recognise that car ownership and use need to be reduced the provision of such a smallnumber of parking spaces will not work currently.

The plans presented here remove too much of the green area, trees, bushes and other wildlifehabitats.

Two sections or areas within Plot 5 do need development but not all. The green area and theunique Green House are assets, not to be removed or diminished.

Housing is needed of course but this development is not the right choice of design or the right useof the land.

This is always going to be a contentious area for any building plans - the green is animportant local green space and the city farms federation building is something local people areproud of, most local people don't want ANY building on this plot at all, whereas some (sensible)building on other plots is generally accepted.The plans are monstrous, frankly. 7 - 10 stories is WAY too high. It will create a wall of buildings ina very small plot, utterly dwarfing the existing housing. Though to be fair in contrast with the otherhuge and inappropriate buildings already suggested for neighbouring plots, it's the same - butplease, consider what you are doing to this generally rather poor and disadvantaged area. It won'tgentrify it, it will obscure and cannibalise it, it will destroy the local area. It's too much, too dense,too high, too many homes all in one small space. It will make the area feel utterly depressing andoverwhelmed with just more building. This is a residential area, not central London or thecommercial centre of Manchester. Please don't accept this plan. It makes me want to cry andmove out of lovely Windmill Hill which has been my home for 30 years because the character isswamped by ugly towering buildings utterly out of character with the existing low level traditionalhousing . And parking? The lack of parking will also have a massive effect on local roads, we allknow, as do the developers, that people will of course have cars (because the travel infrastructurein Bristol is so poor) so parking will become a bear fight. Please, see sense. Building on this plotideally no! Leave us a green space. And NOT this high. Locals have suggested 2 - 5 stories max.Please listen to us.

Please save the green and skyline.

Frankly, given our current concerns about climate and specifically air quality in this partof Bristol, it seems wholly inappropriate rhat this level of proposed development is even beingremotely considered. What the area desperately needs is more trees and green and not moreconcrete. The increase in traffic that would follow the proposed development will contribute to thealready bad air quality.We need good quality affordable housing but the scheme as it stands does not come anywherenear what should be expected of modern housing developments. This is poorly thought out massmarket development which does not in anyway encompass what a modern city should aspire to.This proposal is poor from almost every way you look at it. Canyon like structures that will be avisual blight locally. Local services are already at a stretch and as such, these structures will placea terrific burden on the neighborhood.

I am concerned that the proposal exceeds the guidelines in the framework fordevelopment of the area, does not take into account the current nature of the space (open, withtrees and pathways), and does not sufficiently take into account the need for the new developmentto provide good quality, sustainable accommodation for new residents. I think it is very unfortunatethat the adjacent sites have remained empty and unused for much of the 26 years I have lived inVictoris Park; and equally unfortunate that the plans that have been submitted have failed to takeinto account the nature of the area, or to produce a develoment that will be fit for purpose forfuture generations. This is a space that needs to take into account the existing infrastructure andthe needs of all those who use the space, including walkers and cyclists. There is an opportunityto enhance the space while providing additional housing and amenities, but this is not being givenproper attention by the developers who have too narrow and partial a viewpoint.I would really like all the parties concerned to keep in mind the need for sustainable developmentthat will enhance rather than detract from the area and be something the council can be proud ofhaving helped to achieve. Short-term thinking that focuses on profit will not do this.

This development will completely change the Green forever.

The character of the area, the scale of the local architecture, the loss of trees and the home toprotected species will be forever lost.

Repeatedly over the years we have been asked to give ideas and suggestions to Bristol CityCouncil and to the developers of these plots.Repeatedly we have asked for reasonable human scaled housing offering good quality of life, withoutside garden spaces and real opportunities to grow communities.Repeatedly our concerns go unheard...what is democracy about if major decisions which will effectour lives and communities go unheard?

We need radical forward thinking developments for the future, to grow healthy physical andemotional human beings and communities, which incorporate less density housing with greenspaces and work opportunities.

- Parking.Whilst reducing motor vehicle use in the city is essential I am concerned that the provision of 27car parking spaces for the amount of flats proposed is completely UNREALISTIC, there will alwaysbe cars and hopefully electric ...where will they park??

- Visualisation studiesThe square nature of the 3 blocks with the same material treatment blends them together andpresents as a massive oppressive block of wall with no articulation to relieve the eye.The consistent height of the tops of the blocks will visually conceal/mask Windmill Hill from otherparts of the city looking towards it, with these dense tall blocksThese tall buildings will change the sky-line of Bristol and we will loose part of the significanthistorical and architectural heritage of our city.

- HeatingThere does not appear to be any renewable energy use in this development only air source heatpump with combined heat and power plant. What level of noise pollution will this make?

- Affordable Housing.The poor levels of Affordable housing in this development have been squeezed into the leastdesirable plot, so close to the railway line gives rise to considerable concern about the quality ofliving these dwellings will provide.

Please consider these important concerns

1. Too many stories: It is far too high, blocking views, dominating the skyline and creating aneyesore from Windmill Hill and Victoria Park (one of Central Bristol's most beautiful parks currentlywith views to rival Ashton Court). It also spoils the views of the charming colourful Edwardianterraces from outside the area looking south from, for example, Ashton Court, Cabot Tower orBristol suspension bridge. In addition, the effect of tower blocks in such close proximity in thissmall space would be to create a shady, gloomy canyon like atmosphere. Building height shouldbe in keeping with the local area and so no more than 3 or at most 4 stories.2. Too dense: The local area is already very densely populated and necessities such as access toGPs and the ability to park are already under a very great deal of pressure. There are alreadyserious problems with air quality which will be exacerbated. Parking is also already a real problemfor local residents.3. Unattractive design: The modern boxy design is out of keeping with the area. Most local housesare Edwardian/Victorian, and many of the larger buildings in the area are also attractive periodproperties.4. Poor quality: The accommodation is of the lowest quality with an emphasis on extractingmaximum profit for the developers at the expense of prospective residents, as well as those whocurrently live in the area.

Personally, I think the Council should publicly refute the damaging suggestion that it favours theidea of ugly cramped and monolithic tower blocks and declare a (very Bristolian) interest in highquality ecologically sound homes. They should make it clear to developers that 3, or at most 4,

stories of high-quality residential accommodation with good outdoor space would be betterfavoured by the planning department. Perhaps then the residents of Bristol can support the nextlot of plans and get the area developed.

The development in question is inappropriate for this location. It will put pressure onlocal infrastructure, increase traffic. And at ten storeys, It is too high which would destroy theviews. It is located too close to the railway line and would result in the loss of much needed greenspace.

Re Application 21/05219/FThis development will completely change the Green forever.

The character of the area, the scale of the local architecture, the loss of trees and the home toprotected species will be forever lost.

Repeatedly over the years we have been asked to give ideas and suggestions to Bristol CityCouncil and to the developers of these plots.Repeatedly we have asked for reasonable human scaled housing offering good quality of life, withoutside garden spaces and real opportunities to grow communities.Repeatedly our concerns go unheard...what is democracy about if major decisions which will effectour lives and communities go unheard?

We need radical forward thinking developments for the future, to grow healthy physical andemotional human beings and communities, which incorporate less density housing with greenspaces and work opportunities.

- Parking.Whilst reducing motor vehicle use in the city is essential I am concerned that the provision of 27car parking spaces for the amount of flats proposed is completely UNREALISTIC, there will alwaysbe cars and hopefully electric ...where will they park??

- Visualisation studiesThe square nature of the 3 blocks with the same material treatment blends them together andpresents as a massive oppressive block of wall with no articulation to relieve the eye.The consistent height of the tops of the blocks will visually conceal/mask Windmill Hill from otherparts of the city looking towards it, with these dense tall blocksThese tall buildings will change the sky-line of Bristol and we will loose part of the significanthistorical and architectural heritage of our city.

- HeatingThere does not appear to be any renewable energy use in this development only air source heatpump with combined heat and power plant. What level of noise pollution will this make?

- Affordable Housing.The poor levels of Affordable housing in this development have been squeezed into the leastdesirable plot, so close to the railway line gives rise to considerable concern about the quality ofliving these dwellings will provide.

Please consider these important concerns

This proposal will create the inevitable canyon along Dalby Avenue, which developerspromised a few years ago that this would not happen. The height will create shadowing overexisting buildings and roads especially in the winter months with people coming home fromschool/work in the dark.

The properties proposed would include children, however there does not seem to be enoughspace for children to play safely, and if families are on the seven+ floors how can parents checkthe safety on children seven floors below. We know from the recent lockdowns that keepingchildren inside in these type of building affects their mental and physical health. Why can we nothave town houses or other homes suitable for family life.

Do the developers really believe that only 27 households in 339 flats will have a vehicle?Numerous jobs these days require driving and usually the vehicles are taken home for early starts,or general home use. Where will these be parked? There is already a complete lack of parking inthe Bedminster area, and this is getting worse. This will be a huge detriment to existing residents,coming home from work and then be unable to park near their home, which they have used for anumber of years.

Many young people may start with a flat, but usually once a family comes along, they need ahouse, I know of quite a number of people who loved living in Bedminster, but started in flats - e.g.Airpoint - but as they started families have had to leave the area and their families to be able tofind a house. Many going to North Bristol or South Gloucestershire, which means even more car

journeys!

I strongly object to this ill considered and badly designed development, the sole aim ofwhich seems to be to extract maximum profit at the expense of the environment and local qualityof life. The current design is too high, obscuring iconic views across Bristol, and does not meshwell with the existing buildings in the area - the design is ugly beyond belief. This developmentwould destroy what little green space remains in the area, vital for improving Bristol's appalling airquality, and would also increase population density to breaking point - it is already impossible tosee local doctors and dentists, the local infrastructure cannot support this many extra people. Ofcourse people need somewhere to live, but this high density abomination of a development is notthe answer, please reconsider and stop this terrible plan.

With the other developments already about to take place perhaps it would be an idea to take abreath and see how that pans out before leaping in to yet more development and confusion. It willbe a vast amount of new people taking residence. Our doctors and dentists surgeries are alreadynot taking more people so how will that be resolved?Our precious green space is in fact quite small and could do with being extended into the car-parkrather than the car park being developed to such a high degree. The car park itself has quite a fewtrees which would go and also with the demolition of the Farm Federation building and garden wewill lose a large amount of greenery. The small courtyard within the buildings will not in replacethis.With the flats being so near the railway I'm surprised British Rail has allowed this. Could it be thatthey in fact won't happen? And where will the social housing go then?Windmill Hill, with it's unique Bristol feeling will be closed off of views to it or from it by a wall massof building.In my opinion, these plans are not yet fit for purpose.Sincerely,Kay Oliver

When I received this proposal in the mail, I did not hesitate to write to the council. I havelived for a few months with the noise of the demolition near my house and it is terrible. To add thatin this case, something is proposed as it will be a huge project that will modify the structure andappearance of the neighborhood, taking away a green area as well, being in the way of the freshand clear view that we have in that side, looking to our lovely Victoria Park.I honestly wouldnt like a project like this one take place.Kind regards

The height of this building is going to effect the views for the residents of Windmill Hill. Itis so lovely to go to sleep, draw the curtains and see the city skyline of old Bristol in the distance,to have this taken away by a modern block of flats is really depressing. We welcome developmentin the area if it brings new work and affordable housing but the height and the change oflandscape is of great concern to us.Please consider the thoughts of local residents.Thank you.

Yes some of these sites need to be used/reused butThese developements are inappropriate in scale andvery unsympathetic in style and design.The densisty of living will not improve the area and without carefully organised infrastructure will only downgradea very family/old and young demographics.

While I support the development of the area, I am against building such tall andcompact blocks of flats, which would have a negative effect on the community living here. On onehand side, I am concerned about the consequences on traffic and the lack of parking spaceswhich already affects the area. On the other hand side, the architectural design doesn't integratewell with the surrounding area and there will be a lack of sunlight not only for the neighbours, butalso for the residents of the flats that were proposed to be built.

Absolutely we object for this massive building to be built next to us. It will block the Sunlight and curropt the area. So please DO NOT go ahead! Thank you.

While I appreciate the need of building more homes I certainly do not believe that highrise buildings and tower blocks is a solution here. This development will not be a good addition tothe area and will result in higher traffic and air pollution, blocking the sunlight to the neighbouringareas, increased noise levels during evening/night hours. This planning proposal appears tobenefit the investors/developers at the expense of local residents.

I object to this development on the grounds of the impactful nature a building of this sizewill have on the area; in the blocking of sunlight and overbearing affect. Parking is also asignificant issue in the immediate surrounding area already which will only get worse with theimplementation of this development. Hereford Street and Whitehouse Lane are busy roads fordomestic and commercial vehicles alongside pedestrians and cyclists; overbearing buildings, alack of sunlight and the additional traffic these buildings will bring will no doubt be too much for thelocal infrastructure to take, therefore adding more problem to Bristol's already exacerbated trafficproblems and being an unwelcome eyesore for the local residents, businesses and theircustomers. No thank you.

an independent force for a better Bristol

October 2021.

PLOT 5 - RESPONSE TO CONSULTATION PROPOSALS OF MARCH 2021.

Bristol Civic Society supports the principle of a predominantly residential development of thisvacant site. However, we have a number of serious concerns about this proposal which are set outbelow and cannot support this application.

The proposal.Dandara's development comprises 339 apartments plus provision of mixed retail, eating andcommunity uses. There are three buildings from seven to 10 storeys immediately to the east, westand south of the Green. The non-residential uses are at ground floor level facing BedminsterGreen. Public realm improvements including redesigning Bedminster Green are included.

Height, massing and design.The Society notes that the proposed heights are consistent with the Bedminster Green Framework(BGF). However, as we said in our response to the BGF, the Green is too small to accommodatebuildings of this height on its perimeter along with the proposed cluster of taller buildings on thesite immediately to the north of Dalby Avenue. We, therefore, caution against strict adherence tothe guidelines in the BGF. We would also underline that the BGF is no more than a materialconsideration in terms of planning law. It does not carry the weight of the Development Plan interms of decision making. It has also not been subject to the rigours of a Supplementary PlanningDocument prepared in accordance with the relevant regulations. In the Society's view, theproposed buildings would have an overbearing presence on the small Green and cast shadowover a significant part of it in the afternoons for much of the year.

Building 1 would be 10 storeys facing Dalby Avenue. At the eastern end of the building this wouldface even taller buildings opposite producing a canyon effect on Dalby Avenue. A similar effect willoccur on Hereford Street if high buildings are permitted at this point on plot 1. At the western end,the proposed building would relate most uncomfortably to the two storey existing houses opposite.There has been no attempt to ameliorate this jarring juxtaposition which would have anoverbearing, if not overshadowing, impact on the existing houses.

Building 3 offers the opportunity to make a transition from the tall buildings proposed to the northto the traditional residential development south of the railway line. The BGF encourages atransition from the new to the existing among other things by stepping down in scale. However, aseven storey building would not achieve this. A three or four storey block of town houses wouldprovide a better transition both in terms of scale and residential type. We also consider that theupper storeys of a seven storey building would be more exposed to disturbance from the railwayline.

The proposed massing of the three buildings is oppressive. There is little variation in height and nobreaks in the facades to allow permeability or light into the developments. The Society wouldprefer to see less dependence on perimeter development in building 1 away from the elevation tothe Green. Building 2 substantially fills its site with very little offered to relieve the solid facades.The space between the southern and northern wings of the development appears very enclosedand shady. We have already suggested a different approach to building 3.

Although the elevations are relieved to some extent by projecting or inset balconies, the overallappearance of the buildings, in addition to the comments above on height and massing, isoppressive and lacks interest and variety. All the proposed roofs are flat and there is littlediscernible relationship or reference to existing buildings in the area. The Society would like to seethis site contribute more visually to stitching new development surrounding the Green into thewider neighbourhood.

In considering these issues, the Society is not convinced that the proposal meets the requirements

of national and local planning policies to achieve a high quality of design suited to thedevelopment context. Bristol City Council and the Planning Inspectorate are giving considerableweight to these policy requirements in assessing proposals in the Bedminster Green area.

Impact on Views.The impact of the proposed development on views is, to some extent, masked by other consenteddevelopments. There is no guarantee that these permissions will be implemented and, therefore, itis important to consider the proposed development as a free standing application. Additionally,there are significant and adverse impacts particularly looking from south to north. View 5 showsthat Building 1 would cut out a considerable part of the valuable view from Windmill hill towardsAshton Court and Leigh Woods over and above the impact of consented development. View 14shows blocks 1 and 3 dominating the immediate view north from outside Bedminster station.

As seen from the Alfred Road viewpoint, the proposed development cuts across the grain of thetopography and in visual terms flattens the slope. It foreshortens views from this part of Bristol andundermines the cascade of buildings mirroring the slope. In doing so, it significantly erodes one ofthe defining characteristics of Bristol's Victorian suburbs.

Living ConditionsThe Society considers single aspect apartments to offer a less than satisfactory living environmentfor their occupants. Significant numbers of the proposed dwellings would be single aspect. Manyothers are described as dual ventilation. These have one elevation in very close proximity toneighbouring apartments and offer very limited outlook. In some cases daylight on theseelevations will be compromised. We would support larger windows on southern elevationsprovided that they were compatible with sustainability objectives.

At least some of the proposed apartments are likely to be occupied by households with children.Each dwelling has a balcony but we are not convinced that there is sufficient external playspace atclose quarters for many of the dwellings apart from those facing the Green. We believe this couldonly be rectified with a different approach to the development rather than the perimeter designproposed for buildings 1 and 2. As it stands, the Society considers that the lack of outdoorplayspace in close proximity to many of the dwellings would result in poor living conditions forhouseholds with children. We are not convinced that the enclosed open space in building 1 at firstfloor level and its roof garden will be particularly suitable for children's play.

Building 3 would be seven storeys as proposed. The upper storeys would be exposed to noisefrom the railway which would adversely affect the quality of life in them. To mitigate the impacts ofnoise the dwellings should be able to be adequately ventilated with mechanical ventilation withheat recovery, in order that residents do not need to open their windows if, for example, they don'twish to or find it difficult to sleep. Enhanced fabric performance should also be applied to improveacoustics, such as acoustic glazing and acoustic wall insulation.

Size and tenure of proposed dwellings.30% of the units provided are proposed to be affordable. The Society welcomes this. We areconcerned, however, about the preponderance of one and two bedroom apartments whichcomprise about 87% of the total to be provided. The BGF's vision included seeking to provide arange of new homes and sustainable urban living offers through a mix of residential units andtenures to help meet Bristol's acute needs and contribute to a diverse, thriving and sustainableBedminster community. We consider that the range of units proposed does not contributesufficiently to this but rather would lead to a mono-culture of small flats as we warned in ourresponse to the BGF.

Non-residential land uses.Retail, eating and community uses are proposed for the ground floors of each building facing theGreen. If viable and consistent with a revived East Street shopping centre, the Society supportsthese uses although, as noted above, we consider that building 3 could be reformatted as townhouses to facilitate a smoother transition to the character of development south of the railway.

Sustainability.The Society supports the Council's Local Plan policy commitments to sustainability and reducingthe impacts of climate change. The Bedminster Green developments should be exemplars ofachieving sustainability. As it stands, the Society has a number of concerns about thesustainability of the proposed development. We urge the Council to ensure that the proposal'ssustainability objectives are policy compliant. Our concerns are set out below:

The form factor, i.e. the shape of the buildings, is very poor - there is a lot of heat loss area, so thebuildings are not energy efficient and will require a lot of heating.

Overheating is likely due to extent of full-height glazing.

Overheating modelling comments:- currently only 3rd floor and 1st floor are tested, which are not likely to be worst case - top floor,south-westerly apartments should be tested (as worst case)- 2020 weather file shows some overheating, which is mitigated by using constant mechanicalventilation. This increases energy demand, and it is not clear how the ventilation is provided.Mechanical ventilation with heat recovery (MVHR) should be employed if ventilation is required torun constantly.- 2050 weather file results show that air conditioning is required to the apartments tested, whichare not the worst case, therefore it appears that a significant number will require air conditioning.As this is not being considered as part of the initial development, it is likely that there will be 'bolt-on' air conditioning units mounted onto the outside of the building which would have a harmfulimpact on the appearance of the building.- heating pipework is not modelled in overheating model as 'understood to be located outside' -

unlikely that all heating pipework is to run on the outside of the building, and if it does, the heatlosses from this pipework will be significant and inefficient. If the pipework runs within the building(likely) the overheating will be worse than modelling results show.

Airtightness of the building is 3-5 m3/(hr.m2). At these levels of airtightness mechanical ventilationwith heat recovery should be employed as otherwise there is a significant risk of mould growth andmoisture build-up.

The Society suggests that the Council should assess whether CHP (combined heat and power) asis proposed is a suitable technology for this building type. Air source heat pump (ASHP)technology should be considered to determine if it is more energy efficient.

Traffic and transport.The BGF envisaged an entrance to Bedminster Station opening directly on to the Green. BristolCivic Society supported this. However, our own investigations support the view of the developersthat this would require prohibitively expensive work and would possibly be disruptive to the trainservice during implementation. Reluctantly, therefore, we accept that the station entrance mustremain to the south of the tracks for the present. We would urge the developers to discuss withNetwork rail whether a northern station entrance is possible in the longer term and, if so, to protectthe location where it could be provided. It is also important that Dandara work with the Council andNetwork Rail to improve the access to and appearance of the present entrance. In particular, theunfriendly and narrow approach through the bridge needs to become more pedestrian friendly.Sheltering facilities on the platforms would also benefit from upgrading.

Although there are few train services stopping at Bedminster currently, implementation of theMetrowest project including the Portishead line will significantly improve services including crosscity routes. It is important that the increase in population from the Bedminster Green project, aswell as the existing community, are encouraged to use the train. There is also potential to developa fairly convenient interchange between rail and bus services including the metrobus.

The Society is not clear how the buildings will be serviced by delivery and other vehicles. There isone layby shown on Hereford Street for Building 1 and Building 2 has access space indicatedparticularly for disabled drivers to park. It is important that parking on Dalby Avenue does notcontribute to traffic congestion on this busy road.

Public Realm.The Society supports the deculverting of the Malago River. It is important that the futuremanagement of it is agreed at the outset, however, in order maintain its aesthetic quality. We alsowant to see Bedminster Green improved as an open space. We are concerned, however, thatBedminster Green is designed to cope with the pressure of the impending population growth. It isa relatively small space and we have already commented on the overbearing and overshadowingissues that the proposed buildings would cause. Hard wearing surfaces and careful consideration

of the location of facilities and seating will be vital.

The width provided on the north of Buildings 1 and 2 is welcome and we would support theplanting of suitable trees to contribute to the creation of an Avenue on Malago Road and DalbyAvenue. Careful consideration of planting on Hereford Road, ideally in conjunction with proposalsfor the south side, will also be important.

I believe that this is an unnecessary development which only adds to the increasedtraffic and ruination of the area with yet more tower blocks etc. The plans to demolish The FarmFederation green building is a terrible shame as it is a unique structure and a great organisation,likewise the plans to 'open up' the River Malago, whilst laudable in theory is a farce as the riverwould be so narrow as to be little more than a shallow ditch. Please reconsider these plans, thewhole area is being ripped up and 'improved' and local residents like myself are very concerned atthe height of proposed buildings, the overcrowding of flats, the lack of parking and the impact thatwill have on our streets nearby, the loss of views and the destruction and removal of so many sitesas to totally change the area for ever. I recognise that many more homes are needed but do notfeel that vast student blocks and high-rise towers are the solution, regards, Philip S. Cass