This is a very attractive proposal, considering the nearby archtitecture is unimaginativeand "cookie-cutter" style.

Replacing an uninspiring and dated short building with something that matches the density of thesurrounding buildings is needed, and I do not understand the Civic Society comments about thecurrent building being a landmark.

The steps taking the step the upper floors back to allow a view of the Leadshot Tower iswelcomed.

If Bristol desires more attractive architectural styles, it needs to build up. However, this is a veryattractive building for such a low profile - rare as shorter buildings want to maximise floor space.

Fully support this proposal and urge the council to approve this soon, as it's a shame it has sat inthe planning stages pending a decision for so long.

This is a great proposal, and fits in very well with the surrounding 12 storey officebuildings and 12 storey residential building. It's a shame it has been in the planning system forover 2 years with little movement, and I would urge the Council to expedite this as quickly aspossible so the developers can progress.

I have studied the revised plans and can't see enough of a change to revise my opinion.Therefore I continue to object to this application.Public Realm. The massing is too large, the building is too high and it ruins the public view of aheritage asset (shot tower) from Castle Park and from the public walkway on the east side of thefloating harbour (from the bridge over the moat to St Philips Bridge).Housing need. If this were affordable housing I might consider the trade-offs differently but moreoffices? Really?Personal impact. My flat is in Ferrymans Court. The sunlight diagrams show that my flat will be inthe shade for much of the morning. Whilst I will miss the light the costly impact will be the loss ofheating. The sun, even through cloud, coming in through the large windows has a marked heatingeffect during much of the winter. This development will cost me on increased heating bills and thusadd to CO2. Add the impact to other flats and I think an assessment against the CO2 reductionwould fail one of your planning policies - BCS13 is it?

Objection to the Principle of Redevelopment.

Bristol Civic Society objects to the principle of this proposal which would require the demolition ofa relatively modern building. We believe that consideration should be given to upgrading andextending the accommodation whilst retaining the bulk of the existing building. We ask the Councilto consider whether this would be a more sustainable solution in line with its climate changemitigation objectives.The Society lodged an objection to this application in January 2022. Although there have beensome changes to the design of the building, we do not regard these as substantial. We also notethat Historic England are still not satisfied with the changes.Issues Raised by the Proposal.Whilst objecting to the principle of the proposal, the Society has considered the application andregisters the following concerns:

Height and Massing.

The Society considers that the proposal is an over development of a relatively constrained site.We consider a more modest proposal should be brought forward if the Council is minded to permitthe redevelopment of this site.

Visual Impact.

The enormity of the visual impact and its harm to surrounding area are clearly shown by the

verified visual montages particularly views 1, 2, 7, 8, 15 and 16.We agree with and support the views of Historic England regarding the adverse impact of theproposal on the Grade II* Pip and Jay Church and Generator Building. Historic England state thata reduction in height would significantly reduce the impact and harm of the proposed developmenton these buildings.Its impact on views of the Shot Tower is mitigated to some extent by stepping back of upper floors.Nonetheless, the visual impact of the Shot Tower would be diminished.In addition, the proposal would overbear and overshadow the existing modest buildings on theopposite side of Passage Street.

Public Realm.

The Society is disappointed that public access to the edge of the Floating Harbour is not included.If the development is permitted, public access to the waterside should be provided.

Accessibility.

The site is well served by public transport and so the Society would support the approach oflimiting the space for car parking, and providing cycle parking in excess of policy requitements. Weare not clear what provision would be made for mobility impaired staff and visitors and trust theCouncil will assess this to its satisfaction.

I am resident at #33 Cask Store, Finzels Reach.Counterslip , Passage Street and the bridge connecting the two are in a shocking state of repairresulting from 5 years of non-stop development and the heavy construction vehicle traffic arisingfrom it. Walking and driving on these two roads is an ongoing nightmare. Recent work on thebridge appears to be shoddy in the extreme.

In view of the many historic buildings in the area , the safeguarding of the bridge and the awfulroad conditions for residents in the area, I ask the Council to ensure that all additional HEAVYTRAFFIC arising from the demolition and redevelopment of No.1 Passage Street will beRESTRICTED TO PASSAGE STREET and not use either the bridge or Counterslip

Commenter Type: Neighbour

Stance: Customer made comments neither objecting to or supporting the Planning Application

Comment Reasons:

Comment:I

Counterslip , Passage Street and the bridge connecting the two are in a shocking state of repair

resulting from 5 years of non-stop development and the heavy construction vehicle traffic arising

from it. Walking and driving on these two roads is an ongoing nightmare. Recent work on the

bridge appears to be shoddy in the extreme.

In view of the many historic buildings in the area , the safeguarding of the bridge and the awful

road conditions for residents in the area, I ask the Council to ensure that all additional HEAVY

TRAFFIC arising from the demolition and redevelopment of No.1 Passage Street will be

RESTRICTED TO PASSAGE STREET and not use either the bridge or Counterslip

My concern is the tendency for BCC to permit large scale road and pavement closuresto permit these developments.

I feel strongly that the building site must be contained within it's own property boundaries and mustnot encroach onto the public highway as is the case in Passage Street now, Mitchell Court forthree years, and Three Queens lane also now. This is donating our communities public land todevelopers for no benefit to cyclists or pedestrians, for many months and BCC must stopconsenting to this. If these developers can't work inside the property they own then thedevelopment is not viable.

Justin Thomas

Dear Sirs,

Counterslip , Passage Street and the bridge connecting the two are in a shocking stateof repair resulting from 5 years of non-stop development and the heavy constructionvehicle traffic arising from it. Walking and driving on these two roads is an ongoingnightmare. Recent work on the bridge appears to be shoddy in the extreme.

In view of the many historic buildings in the area , the safeguarding of the bridge andthe awful road conditions for residents in the area, can you assure me that all additionalheavy traffic arising from the demolition and redevelopment of No.1 Passage Street willbe restricted to Passage Street and not use either the bridge or Counterslip?Yours failthfully,

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:My concern is the tendency for BCC to permit large scale road and pavement closures

to permit these developments.

I feel strongly that the building site must be contained within it's own property boundaries and must

not encroach onto the public highway as is the case in Passage Street now, Mitchell Court for

three years, and Three Queens lane also now. This is donating our communities public land to

developers for no benefit to cyclists or pedestrians, for many months and BCC must stop

consenting to this. If these developers can't work inside the property they own then the

development is not viable.

In the Economic Assessment document - 21_06933_F-OPS_ECONOMIC_ASSESSMENT_INFOGRAPHIC_-_UPDATE-3367401.pdf - the "Operationaland expenditure benefits" suggest over 2000 jobs will be created. However, most of these jobswon't be new but the hoped for relocation of existing jobs. Other than a small number of "support"staff, new buildings don't create jobs, they mainly provide an alternative space for existing jobs.Consequently, in reality I expect the true "Additional GVA per annum" will be significantly less thanthe £102.4m quoted.

Dear Mark/ Development Management

We have noted that additional drawings/ evidence has been submitted on 23rdDecember including an updated Heritage Assessment and verified views. We note thatthese still show a significant impact on the setting of the Shot Tower as a ListedBuilding. The Heritage Addendum still notes that there will be harm to the Shot Tower.

We do not consider that the benefits outweigh the harm to the Listed Building. Howeverwe request additional time to be formally reconsulted and consider the impact on theShot Tower. Please confirm this and the dates for preparing a response.

Best regards

Further Objections to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 2

the assessment has been undertaken exclusively in the Spring/Summer (presenting the best-case scenario), failing to account for greater visibility of the shot tower in the Autumn/Winter months as a result of leaf fall from trees. This means that it is not possible to properly gauge harm.

• A lack of public benefits that would outweigh the harm to the Listed Shot Tower While the LPA may ultimately consider that this harm is less than substantial, there are insufficient benefits to mitigate such harm. The Application should be refused for failing to meet the relevant test under paragraph 203 of the National Planning Policy Framework.

Having reviewed the proposed amendments to the proposals, which amount to the omission of a small portion of built form at the 4th, 5th, and 6th levels of the building, together with the additional information and amended reports seeking to justify the proposals, we maintain all of the objections stated above.

The proposed scheme amendments represent a token gesture and do not go to the heart of the issues with the proposal, many of which have been raised by the Council and other stakeholders over the past 9 months.

Consensus on Scheme Failures

Since the February 2022 objection on behalf of the Workforce Development Trust, other organisations and consultees (both internal and external to the Local Planning Authority) have commented on the proposals, raising concerns that overlap with those raised above. For ease of reference and emphasis, these are summarised as follows:

Organisation Status/Role Date Details

20th Century Society

The Society is acknowledged in national planning guidance as the key organisation concerned with the modern period and is a constituent member of the Joint Committee of the National Amenity Societies.

Feb 2022 • Raises concerns about the heritage impact that the current scheme will have.

• Objects to the proposed total demolition of the 1970s office block, considered to be of architectural merit, making a positive contribution to the local historic environment, particularly to the setting of the nearby Grade II shot tower. The building could be adapted for reuse and its demolition is not justified.

• Raise serious concerns about the design of the proposed replacement building. Acknowledges the set back from the west elevation of the Shot Tower, but considers the proposal to be over-development of a sensitive, historic site.

• Refers to views down the Floating Harbour from Castle Park and St Philip’s Bridge, but also views along Tower Hill from Castle Street which are of greater interest than claimed.

• States that the tower is a unique, eye-catching structure that derives much of its heritage significance from its height which communicates its original function.

• Object to the application and recommend that the LPA refuses planning permission.

BCC City Design Group

BCC Internal Consultee

April 2022 • Key views of the shot tower will be lost particularly from Castle Park, Queen Street and Broadmead.

• The historic significance of the shot towers stem from its form and function, its height and landmark quality. The special interest is diminished through proposed scale and massing.

• Views of the tower will be completely lost from some locations.

Further Objections to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 3

• The proposals require clear and convincing justification for scale and massing and level of harm.

• Could the design do more to reference and celebrate landmark status of shot tower?

• The level of harm is likely to be less than substantial though further VuCity assessment is needed to fully assess the level of harm.

• Once clear and convincing justification is provided there needs to be a public benefit balance, but not currently clear what benefits are being offered to outweigh the harm.

• Design options should be provided to demonstrate how harm can be minimised through adaptive reuse with some extension of the existing.

BCC Conservation Advisory Panel

CAP was established to provide independent advice and guidance on planning, listed building or public realm proposals that potentially have a significant impact on Bristol's heritage assets.

May 2022 • “The Panel strongly objects” • “The Panel accepts that the existing red brick building is of its

time and the blank brick wall does not address the street well, but bearing in mind local policy DM26 and RIBA guidance the building should be reused and retrofitted to minimise carbon content.

• The proposed building of 12 storeys would cause significant harm to a large number of listed and locally listed buildings. In particular, damage would be caused to the setting of the Grade II Shot Tower by the proposed building, which would be very close and actually taller.

• The Shot Tower has an important Landmark quality and the damage to its setting would perpetuate the damage to Bristol's industrial heritage caused by the loss of the original shot tower.”

BCC Conservation Section

Internal Consultee May 2022 • Confirms that the Shot Tower is the principal asset that would be impacted by development.

• Considers that harm is posed where the extreme scale and massing impacts on the setting of the listed buildings (and particularly significant where key views of the Shot Tower contribute to the surroundings as a prominent and legible landmark).

• Notes that all views of the shot tower from Tower Hill, Queen Street, and the eastern end of Castle Park, from St Philip and St Jacob’s church tower, and some distant locations would be entirely lost with historic character across the north and east heavily impacted.

• With particular emphasis on the Shot Tower, judges that the degree of harm is at a high level, but not of a “substantial” degree as defined by the NPPF. Notes that this still requires the LPA to place “great weight” on conservation, giving listed buildings this emphasised prominence in assessing planning applications that impact them.

• Considers there is no clear demonstration that the site is suitable for a tall building, of how the current quantum of development has been arrived at, and what alternatives have been tested.

• Advises that the proposed form is pulled-back from the Shot Tower to allow the column form to be fully revealed from Castle Park, together with reduction in scale to reveal at the very least, the upper portion from Queen Street, Tower Road and the Churchyard.

• Considers that the impact of development would not be offset by public benefits.

Further Objections to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 4

• Strongly recommends that the application is withdrawn by the applicant, or refused in line with national legislation, and national and local planning policies, designed to protect the historic environment.

Despite the applicant’s claims within the Covering Letter (26 August 2022) that it has carefully considered the comments received during the determination period, it has failed to meaningfully address any of the above issues.

Proposed Revisions

The proposed revisions amount to the omission of an element of built form at the 4th, 5th, and 6th levels of the building.

Based on the revised scaled floorplan drawings, we have estimated these omitted areas as 130sqm, 150sqm, and 25sqm respectively, resulting in a total reduction of internal floor area of approximately 305sqm.

For context, the application forms state that the building would deliver a total of 15,658sqm floorspace, which includes over 10,000sqm of office accommodation and 450sqm of flexible commercial floorspace.

The area of floorspace to be omitted from the proposals therefore represents just under 2% of the total floor area of the original proposal.

Given that each floor area appears to have a relatively uniform floor-to-ceiling height, a similar exercise can be used to estimate the proposed reduction in massing (or volume). Even allowing for the 1,262sqm basement floor, the reduction in mass is estimated to be just over 2%.

The below images indicate the elements of the originally submitted proposal to be removed.

Further Objections to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 5

Image 1: North Elevation Comparison

Image 2: West Elevation Comparison

The quantitative comparison gives an indication of the extremely small concession by the applicant, while the above visual comparison indicates that in practice, there will be a very small difference in the ability to perceive the shot tower effective from only a very limited range of viewpoints (principally an extended glimpse from Castle Park). The Shot Tower will still be rendered invisible by the mass of the proposed building from the majority of viewpoints as previously raised.

Additional Information Supplied by Applicant

Changes to Verified Views

We have previously criticised the applicant’s approach of focusing design decisions relative to a narrow range of three ‘key’ views without substantive justification. The applicant appears reluctant to entertain the potential for harm to the townscape and listed buildings relative to other viewpoints including those within Conservation Areas.

Page 79 of the D&AS Addendum highlights this by presenting ‘before and after’ visuals for only two views. The Appendix to this Objection Letter (see Images A-D) provides a similar comparison, which clearly highlights the existing foreground roof profile against the proposed building and the massing to be omitted under the latest revision. It reveals the relatively small elements of mass to be omitted. However, at the same time this highlights that the proposed changes would only slightly improve visibility of the Shot Tower from these two very specific viewpoints, and that even then the form of the Tower would still be cramped as a result of the overall massing of the proposal.

Further Objections to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 6

The Appendix to this letter also presents a viewpoint from within Castle Park (Images E-F), further to the north-east, which will retain exactly the same degree of impact on views towards the tower as the original iteration of the scheme. Again, it is worth reiterating that these images in particular benefit from being captured at a time of full tree cover, which softens the impact of the proposal on views across the city.

Had these images been captured in the Autumn/Winter, then the changes to the townscape as a result of the proposed development would only be more pronounced. This remains a fundamental flaw in the assessment and makes it difficult to assess the full nature of the impacts brought about by the proposal.

Loss of Views

Page 24 of the D&AS Addendum provides details of the Council’s comments on the proposal from April 2022. The Addendum’s responses are unconvincing.

The LPA’s comments note that key views of the Listed Shot Tower will be lost from Castle Park, Queen Street and Broadmead. The Addendum simply states that “parts of the lower levels facing the harbour edge have been set back to reveal more of the tower, and in particular the lower stem.” The Applicant continues to ignore the significance of any other views from Castle Park other that those that they deem most important for reasons yet to be justified.

On the key views from Broadmead, the Addendum asserts that “the harbourside corridor is considered to be a leisurable route / views for all whereas views from Queen Street and Broadmead are views that are part of a transient route – there are no viewpoint for passer-bys to pause / reflect as they will constantly be ‘on the move”. This clearly is incorrect, as shown within the Appendix to our earlier objection (also attached – see Photos 7-9). There are long views to the tower along Merchant Street in Broadmead, this is highlighted as an important viewing corridor within the City Centre Context Study. The Street includes a designed public square at its centre with a large number of benches for the public to enjoy. Public seating opportunities also continue to be available further south along merchant street, while there is a further opportunity to sit and perceive the tower from the Café Nero outdoor seating. The applicant has failed to give due consideration to this important corridor. The scale of impact on views to the Shot Tower from this corridor remains unresolved.

The Savills Cover Letter (August 2022) states that “It is important to note however that in terms of identified views, the proposals do not harm views which contribute specifically to heritage values.” Given, the comments of the BCC Design City Group, Conservation Advisory Panel, and the 20th Century Society, it is difficult to see how the Applicant can sustain this position.

In attempting to justify the loss of views of the Shot Tower, the Addendum also introduces a recent scheme, which is the result of a design competition on the site of the temporary energy centre. According to the press release referenced in the Addendum, the scheme is yet to be submitted for pre-application advice. No weight can be afforded to such a proposal in the determination of the current planning application at Passage Street.

Overall Justification for Scale and Massing

Further Objections to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 7

The LPA’s comments reiterate that the proposals require clear and convincing justification for scale and massing and level of harm, and request that design options are be provided to demonstrate how harm can be minimised through adaptive reuse with some extension of the existing building.

The D&AS Addendum notes that the proposal is designed to be a ‘Best in Class’ development and provides a series of details and diagrams relating to solar PV generation, wind direction, ventilation and pollution, together with the aforementioned focus on three ‘key’ views from across the harbour. However, no consideration of alternative massing and scale arrangements is included.

Page 34 of the Addendum provides 6 stages of the design process in diagrammatic form. However, this only serves to illustrate how similar the resulting proposal at stage 6 is to the initial maximum ‘site volume as mass’ envelope at its starting point (See image 3 below).

Image 3: Extracts from Design and Access Statement Addendum (page 34)

It is not clear whether alternative arrangements have been tested. Is there an argument for a taller and slimmer element at the eastern end of the site, and a separate element more closely aligned with the prevailing scale at the waterfront? Or perhaps a generally smaller scale building that more closely matches the scale and massing of the existing building, with some taller elements?

Public Benefits Assessment

These questions lead on to consideration of the public benefits that the proposal could potentially deliver and how these relate to the specific form of the application proposal.

Depending on the nature of the harm to heritage assets, these benefits will either need to outweigh the harm or loss, or the harm should at least be weighed against public benefits (NPPF Paragraphs 200-203).

The Public Benefits Statement (Savills August 2022) and accompanying ‘infographic’ includes aspects such as:

• Access 'Level access for all', close proximity to bus and train services, limited parking provision; • Landscape/Public Realm Green infrastructure, Biodiversity net gain; • Social/Community Active frontages, café and gym accessible to the public; and

Further Objections to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 8

• Energy Connection to District Heating Network, improvements to built fabric.

These elements either already exist due to the site context, would be requirements of any proposal, or would be entirely deliverable on a range of alternative proposals likely to have less impact on the surrounding heritage assets. As a result, they should be given limited weight in any balancing exercise.

Potential benefits, such as specific job creation figures, defined economic boosts to the construction industry, and LPA Revenue streams (CIL Contributions and Business Rates) are to some degree dependant on the scale of floorspace to be created and therefore specific to the scheme in front of the LPA. However, despite these impressive figures, it is reasonable to consider whether an alternative proposal (a more modest scheme, or a conversion/extension scheme) could deliver a similar quantum of benefits while generating a less harm, and therefore a preferable outcome overall.

On this basis, the package of potential public benefits promoted by the Applicant is not considered sufficiently robust to properly weigh against the harm to heritage assets.

Conclusion

We concluded our previous objection by urging the Applicant to revisit the proposal and to provide a scheme that better integrates into the immediate context, one that softens its impact on surrounding heritage assets, in particular the Grade II Listed Shot Tower.

Based on the revised proposals and supplementary information, which attempts to further justify the proposal, it is clear that the Applicant has not given appropriate weight to the comments of the LPA, or other stakeholders. As a result, we urge the LPA to recommend refusal of the proposal.

If you wish to discuss any issues raised herein, please do not hesitate to contact either Stuart Rackham (07841 674794/ stuart@rackhamplanning.co.uk) or David Williams (07475 076767/ david@rackhamplanning.co.uk).

Yours sincerely

David Williams

Rackham Planning Limited

cc. Workforce Development Trust

Further Objections to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 9

Appendix 1: Updated View Comparison

Image A: View 6.27 Existing / Consented Position

Image B: View 6.28 Proposed / Revised Position

Further Objections to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 10

Image C: View 67.31 Existing / Consented Position

Image D: View 7.32 Proposed / Revised Position

Further Objections to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 11

Image E: View 4.18 Proposed / Revised Position

Image f: View 4.20 Proposed / Revised Position

We want more residential properties, not more offices. What will you do when anotherpandemic will drive all the companies out? Leave an empty building? Stop the office craze, wehave enough of them already (they are even empty).

All the buildings being erected south of the docks fail to make visual, historical referenceto the City of Bristol and the city is looking like any other inner city development. The exteriorscould easily reflect the local history but with modern interiors and amenities. Please don't completethe destruction of the character of central Bris.

The Panel strongly objects

The Panel accepts that the existing red brick building is of its time and the blank brick wall doesnot address the street well, but bearing in mind local policy DM26 and RIBA guidancethe building should be reused and retrofitted to minimise carbon content.

The proposed building of 12 storeys would cause significant harm to a large number of listed andlocally listed buildings. In particular, damage would be caused to the setting of theGrade II Shot Tower by the proposed building, which would be very close and actually taller. TheShot Tower has an important Landmark quality and the damage to its setting would perpetuate thedamage to Bristol's industrial heritage caused by the loss of the original shot tower.

This tall building would cast a considerable shadow across the whole street, including theforecourt of the Bridge Inn.

Dear Mark,

We are looking at this application and are pleased to note that the three TPO trees will be retained. However, we are concerned that the plans to crown lift the two weeping willows, T2 & T3 are unclear:

Will this only entail the removal of new growth or will more substantial, lower limbs be removed? Also, where will the three metre height be measured from? As you can see from this image, the branches extend well below the level of the street.

Has an arboricultural planning officer commented on these plans? If so, may we please have a copy of their comments?

Mark

Regards

Mark CD AshdownChair - Bristol Tree Forum

Objection to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 2

The Sheldon Bush and Patent Company Shot Tower

The building immediately south of the application site is known as ‘the Sheldon Bush and Patent Company Shot Tower’ or simply the ‘Shot Tower’. It is described by the Statutory Listing as a 'unique 20th Century shot tower and one of only three shot towers of any period now surviving in England'.

The Council’s City Centre Character Study describes the building (page 144) as follows:

“The Lead Shot Tower (Grade II), Cheese Lane was constructed in 1969. Built of reinforced concrete with vertically set slit windows in the tower. At the top is a twelve-sided room with a central band of vertically set windows.”

Section and elevation drawings from 1966 are enclosed for reference.

The building is understood to have been completed by the engineering firm E.N. Underwood and Partners, and replaced the world’s first ever shot tower, which dated from the late 1700s. It is generally regarded as an important example of brutalist architecture in the City. Brutalism was a sub-sector of the 20th Century global modernist movement, often associated with the mantra that ‘form follows function’ and for experimenting with new building techniques and materials. In this case, the form of the tower was driven by the need to have a substantial drop distance in the manufacturing process of lead shot. Lead was heated in a cast iron cauldron at the top before being dropped into a tank of cooling water as the base.

Appendix C of the Urban Living SPD (2018) lists the Shot Tower as a landmark building within the City Centre. The 2013 City Centre Context Study also highlights the landmark status of the Shot Tower. When considering its immediate context, page 140 states that it is an important landmark, especially viewed from the south and east. When considering its value from further afield, page 152 focussing on Broadmead, states that “the best views are channelled via the straight main thoroughfares of Union Street…and Merchant Street (view south to the shot tower).”

Since taking on ownership of the Vertigo building, the Workforce Development Trust continues to invest in the building. Restoration works to the Shot Tower have recently been undertaken (scaffolding around the Tower is visible within the Applicant’s visual impact assessment). The building will form part of the Bristol Light Festival, hosting installations in early March 2022. The event is organised by the Bristol City Centre Business Improvement District (BID), in partnership with the Temple Quarter BID, and is part-funded by the Arts Council England. The use of the building in events such as this underlines its landmark status and cultural significance within the City.

Design and Townscape Character

Policy Considerations

Rackham Planning’s review of the proposal has been undertaken with the relevant planning policy and guidance in mind. On issues related to the design of the proposal and how this impacts on townscape character, the following elements of policy and guidance are most relevant.

Core Strategy Policy BCS21 states that new development should deliver high quality urban design, before providing a series of expectations for development proposals. These include:

Objection to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 3

• “contribute positively to an area’s character and identity, creating or reinforcing local distinctiveness;”

• “Promote legibility through the provision of recognisable and understandable places, routes, intersections, and points of reference;” and

• “Deliver a coherently structured, integrated and efficient built form that clearly defines public and private space”.

The Site Allocations and Development Management Policies continue some of the above themes. The general design principles set out on page 52 of the document highlights the following:

• “Respecting, building upon or restoring the local pattern and grain of development, including the historical development of the area” (principle ii);

• “Retaining, enhancing and creating important views into, out of and through the site” (principle iv);

• “Making appropriate use of landmarks and focal features, and preserving or enhancing the setting of existing landmarks and focal features” (principle v); and

• “Responding appropriately to the height, scale, massing, shape, form, and proportion of existing buildings, building lines, set-backs from the street, skylines and roofscapes” (principle vi);

Policy DM27 on Height, Scale and Massing requires that developments should be designed appropriately to the immediate context and character, with consideration of the importance of the proposed development and its location within the townscape.

Part 3 of the Urban Living SPD (2018) provides guidance for tall buildings (defined as 30m or higher). This includes consideration of appropriate location for tall buildings. It states that the onus is on the applicant to demonstrate that the site is appropriate for a tall building through context and urban design analysis. Fig 12 states that tall buildings should not be located where it “harms valued views from key vantage points,’ or ‘has a detrimental impact om the city’s historic environment”.

Section 3 of The City Centre Framework (June 2020) considers the form and scale of new development. While the site is located within an area with opportunity to adopt the BCAP ‘Reinvented City’ urban design approach, which for larger blocks envisages “taller elements set back from the street defining 4-6 storey base building”. It also highlights the importance of contextual considerations such as views and surrounding built forms.

Assessment

Firstly, it is notable that while the Planning Statement does reference elements of the above within its review of planning policy, the planning assessment portion of the document does not undertake any consideration of the design of the proposal against theses policy requirements.

Following a review of the surrounding context, we consider that while the scheme proposes some high-quality detailed design elements, including areas of human scale proportion and façade material choices, the overall design concept suffers from excessive bulk, which results in a dominant horizontal emphasis across the large site and a contrived stepped frontage to the water. This is at odds with the surrounding pattern of development.

Objection to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 4

Page 34 of the Applicant’s Design and Access Statement asserts that the proposed building takes massing cues from the surrounding buildings, but there are no other examples of such stepped form in the vicinity. The majority of the buildings in this area typically emphasise waterfront elevations.

Historic England’s consultation response (27 Jan 2022) states that the stepped form would “counter the historic character of the Floating Harbour corridor, where there is a prevalence (even in new buildings) for vertical elevations rising from the harbour walls.” The letter also notes that this is a departure from “the more utilitarian and solid-over-void- attributes of the industrial aesthetic”.

While the building does step-up from a lower height to its full 12 storey height, this is not a gradual transition. Unlike the existing building, the proposal covers almost the full site area, leaving little room for the proposal or surrounding buildings to breathe. This sense is compounded by the majority of the proposed building being at least 8 storeys (approximately 32m from ground level) in height.

On this basis, the proposal would not contribute positively to the immediate context and does little to reinforce local distinctiveness. It therefore fails to adhere to Core Strategy Policy CS21.

In addition, this scale, bulk, and high degree of site coverage means that the building cuts off key views within its wider City Centre context. As noted earlier, both the Urban Living SPG and the City Centre Context Study highlight the landmark status of the Shot Tower. When considering its landmark value from longer views, page 152, confirms the importance of the view of the Tower along Merchant Street, the main north/south street within Broadmead. The Shot Tower is visible from the northern end of Merchant Street, at the junction with the Horsefair; at the central square of Broadmead; and closer to Castle Park at the entrance to the Galleries (see enclosed Photographs 7-9). It appears that this important view corridor has not been considered within the Applicant’s design rationale.

The Urban Living SPD states that tall buildings should not be located where they can harm valued views from key vantage points. The proposed building is likely to eliminate this key City Centre viewing corridor that connects the shopping centre to the floating harbour area across Castle Park, diminishing legibility across the Centre. The proposal would fail to retain an important landmark view, or to preserve the setting of the landmark Shot Tower, as required by the SADM’s Design Principles.

In short, the proposal fails to adhere to Bristol City Council’s Policy and Guidance relating to urban design and tall buildings. The building appears as disproportionately large and overly bulky across a large site, at odds with the immediate surrounding context, and harmful to legibility across the City Centre. We therefore consider that the scheme should be refused for its failure to comply with Policies BS21, DM27 and supporting guidance.

Heritage Impact

Policy Considerations

The latest version of the NPPF (2021) considers proposals affecting nationally significant heritage assets. NPPF part 194 states that LPAs should “require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting”. Part 195 covers the LPA’s role in assessing significance and impacts. Part 199 is clear that when considering impacts on

Objection to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 5

significance of an asset “great weight should be given to the asset’s conservation” with greater weight given the more important the asset.

Part 200 requires that any harm to or loss of significance of an asset should require “clear and convincing justification.” Parts 200 to 203 provide two tests depending on whether there is “substantial harm to or loss of” the asset, or “less than substantial harm” to the asset.

In the former case, the Framework directs that consent should be refused unless harm is necessary to achieve substantial public benefits that outweigh the harm or loss. In the latter case, harm should be weighed against public benefits.

The Core Strategy’s broad strategic policy on heritage assets, BCS22, requires that proposals “safeguard or enhance heritage assets and the character and setting of areas of acknowledged importance”. This includes: Scheduled Ancient Monuments; Historic Buildings both nationally and locally listed; and Conservation Areas. The Development Management Policies also provides Policy DM31, which states that where a proposal affects the significance of a heritage asset or its wider setting, the applicant will be expected to “demonstrate how the local character of the area will be respected.”

Assessment

The building is described by the Statutory Listing as a 'unique 20th Century shot tower and one of only three shot towers of any period now surviving in England'.

The Applicant’s appraisal of the significance of the asset is unclear. The submitted Heritage Statement does acknowledge the rareness of the form of the Shot Tower building under paragraph 6.37, noting high importance in its structural form and evidential value due to the historic manufacturing process. However, other types of heritage value that would add further significance are not considered.

The Heritage Assessment accompanying the now complete Assembly/Temple Way scheme to the east (Ref 16/06195/F) concludes that the building has “considerable historic illustrative and evidential value, which is manifest principally in its distinctive form.” Also noting that “although it retains a degree of landmark status, this has been weakened by development within its wider vicinity, which has reduced the impact of its height.”

We also consider that the Shot Tower possesses Aesthetic value. Historic England’s guidance defines this as “the ways in which people draw sensory and intellectual stimulation from a place.” As noted earlier, the building contrasts with earlier surrounding development in form and materials and is an important Listed example of a 20th Century functional modernist building, designed around an industrial process.

It also forms an important landmark across the city, visible from a range of locations within the City Centre, a status reinforced within the Council’s Central Area Context Study. This status and the building’s construction just over 50 years ago, indicates that the Tower also possesses Communal value derived from “the meanings of a place for the people who relate to it, or for whom it figures in their collective experience or memory.”

Objection to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 6

As a result, we consider that the Applicant has underestimated the significance of the Shot Tower, by failing to consider all potential aspects of heritage value attached it. On this basis the Applicant has failed to comply with NPPF paragraph 194.

When assessing the proposal’s impact on heritage assets, the Heritage Statement appears overly reliant on an assertion that the Shot Tower was designed to 'display' itself to the water and that views across land are somehow less important (page 86).

This seems to ignore the fundamental functionalist nature of the building - It was designed by a structural engineering firm to perform a function, which in turn drives its unique form. The tower is almost symmetrical (see attached architectural drawings) with no elevation being designed to be more visually appealing than any other.

The applicant’s methodology for assessment via verified views is also unclear. The Design and Access Statement states that “3 key views have been identified by the design team” but there is limited justification for these choices. Page 16 of the Design and Access Statement provides a diagram summarising these key views as:

• A view from the war memorial in Castle Park – it is not clear why this view is more important than other views within this part of Castle Park, the whole of which is part of the Queens’ Square and City Conservation Area;

• A view from the southern end of Temple Bridge (Temple Way) – a road carrying fast moving vehicle traffic with a not particularly inviting or well-used footpath; and

• A view from the south western end of St Philip’s Bridge (Passage Street) – it is acknowledged that this is a useful public viewpoint from the southern side of the water.

This approach of focusing on these viewpoints is carried through the Heritage Statement’s assessment of impact. It either diminishes the importance of or ignores other views from the north and north-east including the following:

• The view from the bandstand and other viewpoints to the east of the War Memorial (See enclosed Photographs 5 and 6 alongside the Applicant’s V04/fig.19/20) - Part 7.2.9 of the Conservation Area Appraisal for Castle Park notes the importance of the “pedestrian/bicycle route running from Bristol Bridge on the north bank of the Avon along to Old Market.” This is a very well used pedestrian and cycle link, which allows for multiple views towards the Shot Tower. Page 46 of the Design and Access Statement highlights the ability to view the Shot Tower against the sky as an important element of its value, however, the massing of the proposal would leave a very narrow corridor in which to do so. The vast majority of viewpoints within the park, including those from the main west/east path would either be fully obscured by the proposal, or would provide such a cramped foreground that the Shot Tower would blend into the townscape.

• The glimpsed view of the Shot Tower south down Queen Street at the main eastern entrance to Castle Park and the Conservation Area (See enclosed photograph 4 alongside the Applicant’s V15/fig.67/68) – The Heritage Statement does not consider this view of “designed relevance to the Tower”, however it is a busy pedestrian and cycle junction at the edge of the Conservation Area. It would not be possible to see the Shot Tower from this location post-development.

Objection to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 7

• The view towards the Shot Tower from the western edge of the Old Market Conservation Area through the setting of the Grade II* Listed Church (See enclosed photograph 1 alongside the Applicant’s V03/fig.16) - The Heritage Statement reports that from this location, the view towards the Shot Tower is currently obscured by trees. While this may be true during late Spring and Summer, this is not the case in the Autumn and Winter. Failure to consider the seasonal variations in these viewpoints in a fundamental flaw in the assessment.

• Multiple views and vistas from the edge of the Kingsdown Conservation Area to the north – The Heritage Statement ignores vistas from the edge of the Kingsdown Conservation Area. The Conservation Area Appraisal document highlights this series of 6 vistas along the north-west/south-east oriented streets, which slope down steeply towards the City Centre. The Shot Tower is clearly visible within the majority of these vistas, however the scale and mass of the proposed development would alter this. Page 4 of the Appraisal document highlights the main issues affecting the conservation area and includes the “threat to key views and vistas from new developments/high level advertisements outside the Conservation Area.’

Views of the Shot Tower would be completely obscured from the majority of the above highlighted viewpoints, however, the application submission fails to justify why these are any less important than those deemed to be the key viewpoints, other than by assertion that the Shot Tower was designed to face the waterfront.

It is also important to reflect on the cumulative impact of several very large built forms being approved and developed within the vicinity, including the Former Central Ambulance Centre (17/04267/F) immediately to the north and former Temple Way House (16/06195/F) immediately to the east of the application site and the adjacent shot tower. In commenting on the latter scheme in February 2017, Historic England questioned the erosion of the setting of the Listed Shot Tower Building.

“Although the impact of the proposals on the setting of the Grade II Shot Tower is not the primary reason for the referral of this application to Historic England, there are concerns that the scale of the current proposals will diminish its prominence in the townscape. Clearly these urban design issues require careful consideration, such as the scale and length of the building to Temple Way; is the elevational treatment sufficient to break this up adequately, and is it seen as an appropriate response to local distinctiveness and character?”

While, public viewpoints towards the Shot Tower from the south-east are not as prominent as those from the north-east, north, and west, this still represents a gradual erosion of the building’s broader setting, which would be continued by the current application proposal at One Passage Street.

The Applicant’s Heritage Statement provides a conclusion on the proposal’s likely heritage impact on the Listed Shot Tower Building under paragraph 8.14. It finds a small degree of enhancement as a result of improved public access which, would better reveal the Shot Tower.

We strongly dispute this conclusion. While the small areas of setback along the waterfront retain some visibility of the Shot Tower from viewpoints within a limited central section of Castle Park, the overall scale and bulk of the building would eliminate the majority of existing views of the Listed Building from the north and north-east. In particular, it would eliminate a view that links the Shot Tower to the Old Market Conservation Area via the Churchyard of the Grade II* Listed Church.

Objection to the redevelopment proposal at One Passage Street, Bristol Rackham Planning Ltd, 2A High Street, Thornbury, BS35 2AQ 8

As well as underestimating the significance of the Listed Shot Tower, it is considered that the Applicant has underestimated the harm to that significance. There is no “clear and convincing” justification for this harm as required by the NPPF.

While the LPA may ultimately consider that this harm is less than substantial, we consider that there are insufficient public benefits that would outweigh the harm to the Listed Shot Tower. In its current form, the Application should be refused for failing to meet the relevant test under paragraph 203 of the NPPF.

On the above basis, we would urge Applicant to revisit the proposal in order to provide a scheme that better integrates into the immediate context and that softens its impact on surrounding heritage assets, in particular the Grade II Listed Shot Tower.

If you wish to discuss any issues raised herein, please do not hesitate to contact either Stuart Rackham (07841 674794/ stuart@rackhamplanning.co.uk) or David Williams (07475 076767/ david@rackhamplanning.co.uk).

Yours sincerely

David Williams

Rackham Planning Limited

Enc. Photographic Survey; Original Architectural drawings

cc. Workforce Development Trust

City Centre Photography (January 2022)

Map 01 Shows the locations of 16 photographs taken shown over the following pages. In particular, these focus on views from the Old Market Conservation Area to the north-east, Broadmead to the north, and the Castle Park foot/cycle path to the north.

Map 02 The above shows the core verified views used by the Applicant in the Heritage Assessment. The 3 bolder icons (V07, V08, and V09) illustrate the 3 views considered most important, according to the Applicant’s Design and Access Statement.

In reviewing the Application and supporting documents, Rackham Planning, undertook a brief appraisal of the approach taken to views in relation to the Shot Tower’s value as a Listed Building and Landmark Building. The following diagrams provide context.

City Centre Photography (January 2022)Views from Old Market

Photo 01 Shows the Shot Tower from the edge of the Old Market Conservation Area. In Autumn and Winter, the Tower is clearly visible through the trees. This is a similar viewpoint to the Applicant’s Verified View V03 / Fig.16

The Applicant’s heritage assessment fails to identify the visibility of the Shot Tower from the western edge of the Old Market Conservation Area. This series of views show the Tower as visible across the roundabout with the Grade II* Listed Church’s setting in the foreground. The proposal would sever the visual link between the Conservation Area and both Listed Buildings.

Photo 02 Showing the Shot Tower from the crossing at the edge of the Old Market Conservation Area

City Centre Photography (January 2022)Views from Old Market

Photo 03 Showing the Shot Tower from the crossing at the Old Market Roundabout

Photo 04 The Shot Tower viewed from the Castle Street / Tower Hill Junction, close to the south-eastern entrance of Castle Park.This is a similar viewpoint to the Applicant’s Verified View V15 / Fig.67/68

Continued

City Centre Photography (January 2022)Castle Park Bandstand and Park Entrance

Photo 05 - View from the Castle Park Bandstand, along Queen Street to the south. This is a similar viewing corridor to the Applicant’s Verified View V04 / Fig.19/20.

Photo 06 View down Queen Street, taken from the footpath close to the park entrance (in front of the bandstand). This is a similar viewing corridor to the Applicant’s Verified View V04 / Fig.19/20.

The Applicant’s heritage assessment and design rationale both place undue weight on a single northern viewpoint (from the Castle Park War Memorial). It does not justify why this viewpoint is more important than other view corridors within Castle Park, which would be completely severed by the proposal.

City Centre Photography (January 2022)View of Landmark Across Broadmead

Photo 07 Long view of the Shot Tower from the Horsefair, south along Merchant Street (Broadmead) as highlighted in the City Centre Context Study.

Photo 08 Long view of the Shot Tower from the central square of Broadmead south along Merchant Street.

The Applicant’s Heritage Assessment and design rationale both fail to consider the long view of the Shot Tower from Broadmead. This view is highlighted as important within the City Centre Context Study. This view corridor is likely to be lost as a result of the proposal, which would in turn result in a loss of heritage significance and decrease legibility across the City Centre.

City Centre Photography (January 2022)View of Landmark Across Broadmead

Photo 09 Long view of the Shot Tower south along Merchant Street, taken from outside the entrance to the galleries.

Photo 10 Continuing this route across the Newgate pedestrian crossing, using the northern staircase route into Castle Park.

Continued

City Centre Photography (January 2022)Castle Park Footpath and Cycle Path

Photo 11 Series of views towards the Shot Tower, walking east through Castle Park

Photo 12 Series of views towards the Shot Tower, walking east through Castle Park

Photo 13 Series of views towards the Shot Tower, walking east through Castle Park

The Applicant’s heritage assessment and design rationale both place undue weight on a single northern viewpoint from the Castle Park War Memorial. Considering a series of viewpoints along the path when travelling from west to east reveals that from the majority of viewpoints the tower already blends into the background of the newly built Assembly.

City Centre Photography (January 2022)Castle Park Footpath and Cycle Path

Photo 14 This viewpoint is close to the Applicant’s V06 / Fig.28 and V07 / Fig.32

Photo 15 This viewpoint is close to the Applicant’s V06 / Fig.28 and V07 / Fig.32

Photo 16 Series of views towards the Shot Tower, walking east through Castle Park

It is only from viewpoints east of the War Memorial that the full form of the Shot Tower can be perceived against the sky. Introducing such a tall and bulky building into the foreground will mean that there are no remaining viewpoints in Castle Park from which to view the full form of the Tower.

City Centre Photography (January 2022)Kingsdown Conservation Area

Photo 17 View south-east along Marlborough Hill, from close to the junction with Kingsdown Parade

Photo 18 View south-east along Marlborough Hill, from close to the junction with Cottage Place

Photo 19 View from the eastern end of Marlborough Hill Place

The Applicant’s heritage assessment ignores multiple views and vistas from the edge of the Kingsdown Conservation Area, that currently include the Shot Tower. Due to the scale, mass and layout of the application proposal, it appears likely that the Shot Tower would no longer be visible post-development.

City Centre Photography (January 2022)Kingsdown Conservation Area

Photo 20 View south-east along Montague Hill, from the junction with Somerset Street

Photo 21 View south-east along Spring Hill, close to the junction with Somerset Street

Photo 22 View south-east from Dove Street, with Francis House in the foreground

Continued

I object to this proposal because there is a climate emergency and it is inappropriate toknock down a perfectly good, recently constructed building. Only with a rigorous and verifiableassessment showing net zero carbon within a decade should developments of this sort beconsidered. The current building is a recent 4-storey construction in modern materials to a cleanand striking design. It fits in well with its neighbouring building along the Harbour, the glass-facedbuilding to the SE, and with other brick buildings in the immediate vicinity such as the GeneratorBuilding.

I also object because the proposed building is too high and is over development of this restrictedsite. It may be comparable in height to the neighbouring new Assembly buildings, and the Old FireStation development on Temple Back, but not other nearby buildings. It rises to 10 storeys at thepavement edge on Passage Street. Please refuse pp for this application.

The redevelopment plan is in the right direction.

Dear Mr. Dowling,

In respect to the aforementioned planning application and on behalf of Bevan Brittan LLP, KingsOrchard, 1 Queen Street, Bristol, BS2 0HQ.

As an adjoining occupier in principle we do not object to the development, however would like toensure that in the granting of licence Bristol City Council Planning Department ensures that thedemolition and construction plan include suitable and sufficient traffic management to mitigate tothe lowest impact to ourselves and other adjoining occupiers. The development is adjacent to theentrance to Queen Street and has the potential to disrupt the access and egress of traffic to oursite for our staff, tenant occupiers and related supply chain vehicles.

Kings Orchard and it's residents have already been subject to over two years of noise and trafficdisturbance due to developments adjacent including the residential development on the oldambulance station and more recently the energy centre (heat network) works on Queen Street.

Kind regards,

Rob HarrisHead of Property & FacilitiesBevan Brittan LLP.

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PLANNING POLICY CONTEXT AND REASONS FOR HOLDING OBJECTION Heritage and Conservation At the national level, the National Planning Policy Framework (NPPF) 2021 under chapter 16 ‘Conserving and Enhancing the Historic Environment’ and the heading ‘Considering potential impacts’ states that any harm to, or loss of, the significance of a designated heritage asset (from among other things, development within its setting), should require clear and convincing justification. It goes onto assert that substantial harm to or loss of assets of the highest significance (which include Grade II* Listed Buildings), should be wholly exceptional. The proposed development will harm both the settings of the immediately adjacent Sheldon Bush and Patent Shot Company Limited Grade II Listed Building, the Church of St Philip and St Jacob, Tower Hill Grade II* Listed Building and the Former Tramway Generating Station Grade II* Listed Building at Counterslip Street. The development as proposed will cause considerable harm to the settings of all three of these heritage assets, two of which has Grade II* status and therefore have the highest significance with regards historic interest. At the local level, Policy BCS22 of the Core Strategy outlines that development proposals will safeguard or enhance heritage assets and the character and setting of areas of acknowledge importance including both nationally and locally listed buildings. Additionally, Policy DM22 refers to development adjacent to Bristol’s waterways which make an important contribution to the character, distinctiveness and quality of life in the city. The proposals will cause considerable amount of harm to the settings of these designated heritage assets and there the application fails to comply with Policies BCS22 and DM22. Design At the local level, Policy BCS21 of the adopted Bristol City Council Core Strategy states that development will be expected to contribute positively to an area’s character and identity, creating or reinforcing local distinctiveness. The development management plan sets out that development would not be permitted where it would be harmful to the local character and distinctiveness or where it would fail to take the opportunities available to improve the character of the area and the way it functions. Local Plan Policy highlights that the design of development proposals will be expected to contribute towards local character and distinctiveness by:

i. ‘Responding appropriately to and incorporating existing land forms, green infrastructure assets and features; and

ii. Respecting, building upon or restoring the local pattern and grain of development, including the historical development of the area; and

iii. Responding appropriately to local patterns of movement and the scale, character and function of streets and public spaces; and

iv. Retaining, enhancing and creating important views into, out of and through the site; and v. Making appropriate use of landmarks and focal features, and preserving or enhancing the

setting of existing landmarks and focal features; and vi. Responding appropriately to the height, scale, massing, shape, form and proportion of

existing buildings, building lines and set-backs from the street, skylines and roofscapes; and

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vii. Reflecting locally characteristic architectural styles, rhythms, patterns, features and themes taking account of their scale and proportion; and

viii. Reflecting the predominant materials, colours, textures, landscape treatments and boundary treatments in the area.’

Policy DM27 states that the height, scale and massing of development should be appropriate to the immediate context, site constraints, the setting, public function of the proposed development and the location within the townscape. It is our view that the proposed development fails against Policies BCS21 and DM27. The proposal to remove the well enjoyed (large and matured) existing tree outside the entrance to Tower Wharf to make way for the entrance into the car parking will degrade the pedestrian environment here for all of the staff arriving at (and leaving from) Tower Wharf. This goes against Policy BSC9 ‘Green Infrastructure’ of the Core Strategy which seeks to improve and protect the townscape and landscape quality along with visual amenity. With regards to building height specifically, Bristol’s Tall Buildings Supplementary Planning Document (SPD)1 has now been superseded by the Bristol Urban Living SPD. The Bristol Urban Living SPD sets out requirements for the design process to demonstrate a positive approach to the visual quality of tall buildings whereby tall buildings are located close to other tall buildings, are at locations where the provision of a landmark building would clearly improve the legibility of the city, does not harm valued views from key vantage-points and does not have a significant negative impact on the amenity of nearby occupiers or the public realm. The proposals fail to satisfy the requirements of the Bristol Urban Living SPD. Construction Methodology Notwithstanding the fundamental objections to the proposals outlined within this objection letter, we have also considered the potential impacts of construction on the existing occupiers of Tower Wharf. Given the nature of the proposals, comprising of comprehensive demolition works followed by major new development, the construction works of the proposed development are expected to adversely impact on the day to day safety, operations and premises functionality for the occupiers of Tower Wharf. The dust and noise impacts associated with the demolition and construction phases have not been addressed in the application proposals. Details of the mitigation measures and site management measures will be required to ensure that the occupiers of Tower Wharf are not negatively affected. The impact of construction traffic should also be considered at the application stage, rather than this being managed through the attachment of a condition onto the consent should the application be approved.

RECOMMENDED NEXT STEPS Picton’s objection will remain in place until satisfactory supplementary information is provided that demonstrates how all of the above harmful impacts of development will be addressed and mitigated to an acceptable standard. Should the City Council be minded to approve the application, we request the following conditions be attached to a planning permission:

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1) Prior to the commencement of the development hereby permitted, a Demolition Logistics and Management Plan shall be submitted to, and approved in writing by the City Council. Details shall include control measures for dust, emission, noise, vibration, lighting, delivery locations, restriction of hours of work and all associated activities audible beyond the site boundary, advance notification to neighbours (including to Picton and the occupiers of Tower Wharf) as well as other interested parties [as appropriate] of proposed works and provide public display of contact details including accessible phone contact to persons responsible for the site works for the duration of the construction. Approved details shall be implemented throughout the project period. Reason: To appropriately mitigate the impact of the development during the demolition phase in terms of noise, vibration, dust, lighting or other emissions and the falling and collapsing of built materials from the building site. 2) Prior to the commencement of the development hereby permitted, a Construction Management Plan shall be submitted to, and approved in writing by the City Council. Details shall include control measures for dust, emission, noise, vibration, lighting, delivery locations, restriction of hours of work and all associated activities audible beyond the site boundary, advance notification to neighbours (including to Picton and the occupiers of Tower Wharf) as well as other interested parties [as appropriate] of proposed works and provide public display of contact details including accessible phone contact to persons responsible for the site works for the duration of the construction. Approved details shall be implemented throughout the project period. Reason: To appropriately mitigate the impact of the development during the construction phase in terms of noise, vibration, dust, lighting or other emissions from the building site. 3) Details of methods to identify any television interference caused by the proposed development, including during the duration of the construction process, and proposed measures to ensure that any television interference that is identified is remedied in a satisfactory manner shall be submitted to and approved in writing by the City Council prior to the commencement of development hereby permitted. The approved remediation measures shall be implemented immediately that any television interference is identified. Reason: To ensure that any television interference caused by the development is remediated, in accordance with Policy 10 of the NPPF.

CONCLUDING REMARKS As it stands, Picton as the owners of Tower Wharf which is directly adjacent to the application site object to the application proposals for the reasons set out above (namely that the current design will cause considerable/permanent harm to the settings of the three nearby statutorily Listed Buildings, all of which are presently visible from Tower Wharf; and as a result of the demolition and construction impacts of the development). Should suitable supplementary information be submitted in support of the application that satisfies Picton that there will be measures in place to prevent there harmful impacts upon Tower Wharf, the objection can be withdrawn. I trust that the contents and requests of this letter are clear and reasonable, but should you have any queries in relation to these matters or require any further clarifications then please do not hesitate to contact me.

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Yours sincerely

Thaddaeus Jackson-Browne MRTPI

Director

ESS

St Philip and St Jacob

Bridge

Ferrymans

Templebridge

Tower Wharf

2

Vertigo

1 to

6

10

Musicradio House

1

Apartments

18 to 26

Clinic

Ferryman's Court

15 to

22

with Emmanuel

Lodge

1

7 to

14

The Unity Church

23 to

30

Kings Orchard

Inn

Ordnance Survey, (c) Crown Copyright 2021. All rights reserved. Licence number 100022432

MARYBUSH

CHEESE LANE

NARROW PLAIN

LANE

QUEEN STREET

PASSAGE STREET

Floating Harbour

9.4m

10.1m

9.4m

10.4m

Landing Stage

LB

Landing Stage

St Philip's Bridge

Key:Application boundary

Document Title

Project Title

London 106 Weston Street, SE1 3QBBristol pivot + mark, 48-52 Baldwin Street, BS1 1QB Plymouth East Quay House, PL4 0HX

RIBA Chartered Practice

Client

020 7160 60000117 923 253501752 261 282

www.aww-uk.com

Document Status

Project Origin. Volume Level Type Role Number Revision

AWW Project Number Project Stage

NotesDo not scale from this document, unless for the purposes of planning applications where a scale bar is provided. Refer to figured dimensions only. All dimensions to be verified on site prior to construction. Report all discrepancies or ambiguities to the Document Originator immediately. This document is to be read in conjunction with relevant documents, drawings and standards.

P03

One Passage Street

Existing Site Location Plan

4404 AWW ZZ ZZ DR A 10001

4404

PLANNING

STAGE 2

KFIM

Rev Date Notes Drn Chk'dP01 17.11.21 Minor amendments. GCT MASP02 25.11.21 Minor amendment. GCT MASP03 06.12.21 ISSUED FOR PLANNING GCT MAS

North

0

SCALE 1:

504030201010

m1250

This official copy is incomplete without the preceding notes page.

Great to see brownfield sites being developed and the city improved.

I strongly object to this project on environmental grounds. It is a complete waste of theearth's natural resources to demolish a perfectly serviceable building, which is currently occupied,and replace it with another building with the same use - offices.This is not solving a housing issue or providing healthcare or any other critical services, the projectappears to be purely driven by commercialism.We need to start protecting the environment by considering the entire supply chain forvanity/purely commercial endeavors like this one.

Given the massing of the first 3 storeys of the proposal which is strikingly similar to thatof the existing building, the proposal to demolish the existing building seems at odds with so manyprinciples of sustainability and the wider goals of the city towards net zero.

Surely the developer and designers can see the benefit both from a marketing perspective,sustainability, financial and ethical perspective on retaining the existing building, deep-retrofittingback to structure with strengthening where required and extending up, similar to the proposedscheme at 1 Temple Way.

Notwithstanding the demolition I am in support of both the proposed design and use, and wouldlike to see more public realm improvements along the water on this side.

Chris Ratcliffe

1) The Lead shot tower is unique not only to Bristol but in the world - with Bristolindustrial heritage/ provenance2) The view of lead shot tower will be obliterated from many points of Bristol: Marlborough Hill /Merchant Street / Old Market conservation area3) The building proposed is unremarkable with no provenance4) The landscaping is only of positive impact to the sensory environment and the public realm if itis meticulously maintained. Currently there is a weeping Salix which appears to be within thecurtilage of one passage street. Its overhanging branches block much more than half thepavement forcing able bodied pedestrians into the cycle lane and the road. Those who are visuallyimpaired/ wheelchair users/ on crutches/ those with prams etc must struggle through the branchesor down and then back up the kerb.5) There are swathes of Broadmead screaming out for regeneration and self-nominated landmarkbuildings. Why must this corner be robbed of more sky, sunlight, warmth and make access to thewaterfront foreboding and unwelcoming?

21/06933/F | Demolition of existing building to facilitate office-led redevelopment,including office floorspace (Class E) and flexible ground floor uses (Class E), along with amenityspace, cycle and car access and parking provision, servicing, landscaping, public realm, andassociated works. | 1 Passage Street Bristol BS2 0JF

The Civic Society has a fundamental objection to this proposal on the grounds that there is aclimate emergency and it is inappropriate to knock down a perfectly good, recently constructedbuilding. Surely there must be an option to consider upgrading / extending the existing building?Only with a rigorous and verifiable assessment showing net zero carbon within a decade shoulddevelopments of this sort be considered. The current building is a recent 4-storey construction inmodern materials to a clean and striking design. It fits in well with its neighbouring building alongthe Harbour, the glass-faced building to the SE, and with other brick buildings in the immediatevicinity such as the Generator Building.

Should redevelopment be considered the Society objects to the current scheme on the grounds ofexcessive height. The proposed development represents over development of this restricted sitewith a height which is inappropriate in this location. The 1 Passage Street proposed developmentmay be comparable in height to the neighbouring new Assembly buildings, and the Old FireStation development on Temple Back, but not other nearby buildings. It rises to 10 storeys at thepavement edge on Passage Street.

Objection: Whilst this development brings some benefits, it is simply too tall given thefact it lies to the south of the two major residential buildings of the area, namely Castle Park Viewand Ferrymans Court. Additionally it will block the views of the shot tower from the public realm inthat area.

Public realm benefits include improvements for cycling, walking and greenery (make sure the twowillows don't get hacked about, I would try to argue they are so treasured that they are grade Atrees).BUT...It is too tall for its location: The height of 12 storeys (although only half Castle Park View) has animpact on the occupants of the lower floors of these residences. This proposed development is tothe south of those blocks and will affect the light and heat coming in and the view of the heritageasset, namely the shot tower, something I have grown to like whilst living here. At informalconsultation I was told that it was to be 11 storeys, I said it was too tall It's now 12. I thinksomeone is trying to get their own back on me?

Heating bills and carbon: My flat and others draw heat from the sun coming in through the bigwindows, so much so, on some winter days I don't need the heating on at all (day or night). Thisnew development will reduce that heating effect and thus cost me more in heating bills. Should thedeveloper pay for that cost increase? It is also not carbon neutral.

Heritage Asset Views: From the public realm, the views of the shot tower are, well, shot, especiallyfrom the north (Castle Park north of the heat/energy centre), Queen Street, the Harbourside

walkway from Castle Park to St Philips Bridge and from St Philips Bridge East and Passage Roadespecially sitting on the tables outside the pub (the Bridge Inn).

In summary I object for the reason that it is too high reducing light and heat into the south facingflats of Castle Park View and Ferrymans Court as well as the loss of public views of a heritageasset especially looking from the north. It needs to be lower.

PS As a comment: the land use map (D&A1 p 22) shows 90% of the area as offices / mixed use. Iunderstand that demand for new high quality offices is strong, but Bristolians need homes. ThePlanning system continues to fail many Bristolians.

The Redcliffe & Temple Business Improvement District (BID) is a business led initiativewhereby a levy scheme is used to deliver projects to improve the Redcliffe & Temple area ofBristol. Our vision is for a Redcliffe and Temple area that is vibrant, thriving, sustainable,inspirational, and welcoming.In our Business Plan (January 2021) we committed to a range of projects as part of five keythemes to improve the BID area.We completed a detailed consultation from March 2019 to March 2021, a desire to improve thelook, feel and safety of the BID area was referenced as a key priority by a number of businesses.In our November 2019 survey the following statements were the top two priorities for respondents:'Work with Bristol City Council to improve public space in terms of pedestrian routes, signage,lighting and air quality.''Work with Bristol City Council to improve cycle routes, parking and secure storage facilities.'The BID would like to see the following points considered as part of future developments:Creating & maintaining quality spaces- Make positive contribution to green space in the city- Add to public realm space with opportunities to dwell, pause and socialise for people of all ages- Make cycling an easy choice for residents / occupiers via secure cycle storage and access- Clear and simple disabled access- Footprint to be adequately lit at night- Add colour, public art and visual appeal to the BID areaImproving sustainability and the environment- Make positive contribution to ecology and biodiversity of the city- Develop and champion initiatives to reduce waste, especially single use waste

Creating & promoting a vibrant place- Active ground floors and frontages to encourage vibrancy and interesting streetscape- If building internal cafés or catering units, it is preferable that these are open to the publicBuilding a safe and caring community- Add to the mix of residents living and working in the area, bringing a range of demographics- Engage with local community during consultation and build

We believe that the proposed re-development of One Passage Street as outlined in the planningdocuments will significantly enhance the look and feel of this area and will add to the high qualityoffice led space already being developed. There will be many benefits for those that live and workin the area with careful thought being given to the urban design principles and sustainabilityrequirements including the improvements to cycling and pedestrian routes, lighting and the publicrealm green spaces. Replacing the 1970's existing building with a new high quality A gradebuilding that is sympathetic in design to its historic surroundings is also an important factor.

I believe that this building should not be demolished. This is due to a number of factorswhich essentially boil down to the following...

A. Right next door (the block across the street) a building has been in the process of being builtover the last few years. This has caused numerous disruptions to the residents nearby, and wouldsimply be repeated if the neighboring building were torn down and then replaced. The newbuilding next door is also an office space, of which we have plenty of at this point. As it standscurrently, the Passage Street building serves as a hub for nearby neighbors, those passing by,and others who work in the area. The Tesco Express on Victoria Street is not only a lunch stop formany nearby workers, but also a weekly grocery stop for those who live nearby, myself included.

Tearing down the Passage Street building would simply benefit those who are already rich, andovershadow those who make up the bulk of the population. This area of Bristol does not needmore office space, it needs more cultural centers.

I hope this has been a comment worth review.- Alex

never mind ignore my last answer i thought you were talking about a different building,oops lmao

the demolition includes the Sheldon's Shot Tower, which is a listed building and,although modern, a local landmark and a constant reminder to Bristol's industrial heritage. As alisted building, it must be kept, preserved and displayed within the new development.

This is an ideal opportunity to replace building with open spaces and increase the parkland . There are enough vacant offices in Bristol. And I imagine the buildings will be a blight on thelandscape , just like the Heating Pump house monstrosity going on at the other end of the park.We are supposed to be a 'Green city' and yet you are continuing to fill the city with concrete andsteel . I strongly object to this proposal when open spaces are what people need .

After being surrounding by construction noise for the past five years, it's prettydepressing to learn that another large building is being planned. It's surprising to hear that there'ssuch a huge demand for office space, particularly when Aurora and other nearby blocks aren't full.

Clearly the development is inevitable, so as a neighbour overlooking the property, there are a fewthings I'd like considered:

- Construction is LOUD, and it has a huge effect on neighbours. To mitigate this as much aspossible, work hours should be restricted to 9am - 6pm on weekdays/Saturdays, with no work(even "emergency" work) on Sundays or bank holidays. This should include construction vehiclesarriving at the site. For some reason, The Assembly and Castle Park generator thing have beenable to get away with extended hours, due to the area apparently not being residential. Obviouslythat's rubbish, as I'm a resident, and I prefer being woken up by my alarm clock, not loud drilling at7am.

- As our bedroom faces the site, I'd also like to request that bright lighting is turned off at night.The street is bright enough as it is, without spotlights making it worse.

- We've lived through weeks and weeks of outrageously loud piling works due to issues at the OldFire Station site. If the same problems are faced on this site, work should stop immediately andsolutions found.

- I welcome the greenery on the building; it makes a nice change from the awful glass buildings

nearby - as well as the dreary cladding on Castle Park View. However, it seems that as you readthrough the plans, the amount of greenery gets smaller and smaller - reducing from multiple treesand bushes on each terrace in the initial artist impressions, to little more than a shrub edging. I'dlike for as much greenery as possible to be retained, to at least try and make the building looknice.

- The requirement for the ground floor spaces to be reserved for leisure/retail use should beprotected. It would be particularly great if a grocery store could be attracted to cater for the hugeincrease in residents and workers that are moving into the area.