refuses to consider inclusion of any affordable housing (which should be 40% forthis site as it is the Inner Urban Area). It follows that this planning proposal isclearly not addressing the fundamental housing issue which the Bristol CoreStrategy seeks to resolve.

Does it address the “significant need for housing for older people in Bristol”? NO

● Again, these properties are simply not affordable for the majority of older peoplein Bristol.

● At the time of writing, within a few hundred metres of the development there arecurrently 3 retirement flats for sale at £395k to £475k at Carfax Court. There are 4properties for sale at The Vincent, £460,000 to £1.25 million, some of which havenot sold since that development was opened in July 2020.  There are alsosupported living flats available at Abbeyfields on Redland Road. There are 21extra care properties for sale at St Monica's Trust, some just a short stroll acrossthe Downs. 

● The supply of upper-end retirement living already appears to exceed demand –there is no need to add to this, and this scheme simply will not address the needfor affordable housing for the elderly.

● It is worth noting this development is not considered part of BCC’s officialExtraCare Housing (ECH) programme and BCC will not be getting referral rights toany of the flats. This proposal is, in fact, surplus to BCC’s projection of extra careprovision.

Does it free up family sized homes in the city? NO

● Very few Bristolians will be able to afford to live in this luxury development. Theapplicants obviously share this concern; in their proposed planning agreementthey suggest that property sales should be restricted to Bristol City residents foronly 3 months from release. This is a ludicrously short period of time andsuggests that the applicants are not interested in helping to address the pressinghousing needs Bristol now faces.

● The developers’ viability study calculates sales on the basis of 24 units being soldoff plan then unit sales at a rate of 2 per month. Therefore on the developers ownevidence (assuming for the purposes of this calculation that the report isaccurate) they appear to be anticipating selling only 30 units to Bristolians! Butbased on the above figures, we believe it is likely to be much lower than this.

● So:o There is no guarantee that any significant number of units will be sold to

Bristolianso For the few which are, they will not release properties that are affordable for

most families in Bristol, and will do little to address the housing situation in thecity

o In fact, it is likely that most purchasers will be down-sizing to move to Bristolfrom the more affluent areas of the UK.

Does it open a previously inaccessible, inhospitable, and now derelict site and providepublic access to a listed building? NO

● The previous occupant of the site was, until 2020, a once thriving residentialschool for children with severe learning difficulties, who are some of our mostvulnerable and in-need citizens. The St Christopher’s School was highly integratedinto the local community and it was never seen as inhospitable – the contrary isthe case. The site was regularly opened for garden parties, festivals andconcerts to which all Westbury Park residents were welcomed.

● The site is currently occupied by around 100 residents - providing affordablerental for low income people and an income to the applicant. It is ourunderstanding that those residents, who are becoming part of the community,really enjoy living on such a beautiful site - appreciate its nature & wildlife andoften use the grounds for outdoor gatherings and parties. The site is also used asa COVID vaccination centre, the grounds and hall have been used by a scoutgroup and the applicant themselves has made much of opening up the grounds tothe public and community groups2 in its current state. All these meanwhile useswould cease should any development be permitted.

● One can therefore conclude that the site is currently adequately hospitable,accessible and in a suitable enough state to charge rent for and allow publicaccess to.

● We draw your attention to the applicant’s assertion they would be;“Undertaking key maintenance and preservation works to a listed building(Grace House) that is in disrepair, with water ingress and deterioratingbuilding fabric, and with no viable use, will fall into disrepair;”

If this important heritage asset, or the villas at the front, are now in disrepair or,indeed the site is derelict, it is only due to recent neglect which it is thepurchaser’s responsibility to address. As owners of this Grade II listed building,they have a legal duty to ensure that the asset does not fall into disrepair. Thethreatened non-maintenance of a listed building should not be used as abargaining tool to gain planning consent. This remarkable building should belooked after and cared for regardless of whether additional development isgranted.

● Furthermore, this listed asset does not need to be further damaged by theproposed over-development - it faces greater long term, irreversible andpermanent threat of damage from the current proposals to overcrowd andoverbear its setting. It should be noted that both Historic England and Bristol CityCouncil’s Conservation Officers have stated that the proposed development wouldcause irreversible harm to the setting of this Grade II listed building.

● The applicant claims to be “providing public access to a listed building (GraceHouse) that has not been accessible to the community in its history”. This isfactually incorrect and reveals that the applicant has done no proper research intothe history of the building or the site - a quick glance at Google would havesufficed to establish the truth.

o In reality, Grace House was used, not only by Bristol’s SEND communitythroughout its entire history and until its closure in 2020 - including the

2 https://www.bristolpost.co.uk/news/former-st-christophers-school-site-7045317

children, their families, their friends, teaching, care and volunteer staff, butalso by the local community for annual festivals, concerts, exhibitions,shows, exercise classes (there was once even a library and many peoplewho grew up in Westbury Park remember learning to ride a bike in thegrounds around Grace House!).

o The wider community across Bristol regularly had access too, for exampleas a centre for conferences on the specialised SEND education that StChristopher’s provided, among other events. A city-wide volunteer schemeran with workers from Lloyds and Axa offices on a day release volunteerprogramme, visiting the site regularly to help out in a number of ways.Other schools across Bristol also held reciprocal visit programmes andused the swimming pool adjacent to Grace House. The school receivedroyal patronage and visits by civic dignitaries like the Lord Mayor of Bristoland the current Duke of Edinburgh.

o Until very recent, and understandable, safeguarding guidelines made publicaccess more regulated, the site was actively used by multiplecommunities. The above quoted statement from the rebuttal reveals a highlevel of ignorance regarding the legacy of St Christopher’s School.

● No commitment has been provided relating to any future public access to thelisted building. The applicant has defined no specifics about any facilities whichmay be made available, or the proposed nature of that access - it is all vaguesuggestions, with no guarantees or defined conditions that any significant ormeaningful access will exist. In practice, it is difficult to believe that the(estimated 200) residents of this luxury development would be happy to competewith members of the general public for use of facilities paid for by their servicecharge. Nor that public access would be or remain financially viable. For example,a retirement complex within a mile of St Christopher’s, The Vincent, has arestaurant that is ostensibly open to the public. The most recent owner of therestaurant has had to close (May 2023) because he can't make the business work.It's the third iteration of the restaurant in as many years.

Does it preserve Grace House and refurbish and conserve the existing villas? Notuniquely

● Any sensitive development of these villas should do this, but it does not requirethe effective destruction of the backland in order to do so.

Does it allow public access through the site for people to use and enjoy? NO – notguaranteed, and likely to be impractical

● We are not aware of any conditions, or clear level of commitment, to providingpublic access to the site. Plans have previously indicated that pedestrian accessto the site will be “Controlled residents access only (fob access 24hrs)”. Weunderstood that this was for two reasons:

o There will be a large number of elderly residents, some of whom are likelyto be vulnerable dementia patients, which is likely to restrict public access.

o To reduce safety concerns from residents of The Glen about increasedpublic footfall.

● It is not clear if – or why – the applicant would have changed their mind on thispoint, but either way there is currently no firm definition of, or commitment to,public access.

● We believe there are inherent complications and impracticalities in allowingsignificant or meaningful public access into private care/retirement communities.With this proposal in particular , there is a distinct lack of clarity about how thiswould work in reality. How, with a site full of potentially vulnerable elderly withcare needs, multiple proposed access points and 24 hour vehicular usage, wouldthis public access work?

● Critically, the Bristol Crime Reduction Unit (objection dated 3/1/23) raised safetyconcerns about the site access, specifically stating:

“This development does have 6 access points which for a development of thissize is extremely permeable. I continue to be concerned that if not adequatelyaccess controlled, with robust boundary treatments, disproportionate levels ofanti-social behaviour and criminality similar to those we are now seeing on thedevelopment at the site of the old Bristol General Hospital, which also hasexcessively high permeability from a safety and security perspective, will beexperienced by residents.”

● Research work carried out by SCAN among other extra care facilities in Bristol,highlights a number of issues that are not dealt with or explained in the currentapplication; these would suggest the ‘openness’ and ‘access’ that the applicantclaims to be promising in theory would be entirely impractical in reality. We found:

o The majority of ECHs (Extra Care Homes) in Bristol we spoke to are NOTopen to general public access during the day without a key fob, doorbellentry or manned reception due to safety and security reasons for theresidents. Doors are generally alarmed in the evening and at night.Residents are free to come and go as they wish, unlike a care home, butpublic access is tightly controlled.

o Visitors are welcome but they are usually granted access by the residents.Some ECHs allow family members to have personal key fobs.

o The general public would not generally be allowed into the private areaslike the gardens or those that are maintained and funded by residents fees.

o Extra care complexes that have a salon or rooms that are bookable bynon-residents usually have a system of pre-arranged visits/advancebooking and/or entry is controlled via one entrance only/key fob.

o If there is a community element that is open to the general public e.g. acafe , it seems usual practice to have only ONE entrance to that facility forthe public meaning they cannot access the other parts of the complexfreely. Most of the ECHs we spoke to have completely different accesspoints for the public and private realm - with very clear delineationbetween the two. For example, the communal gardens or residents-only

areas are only reachable through locked/key fob access doors off thepublic/cafe area. One care manager told our researchers that it would be“quite difficult” to manage public access in the absence of 24 hourcontrolled entry because of the vulnerability of some of the residents.

● The current proposals for this site do not address this fundamental conflictbetween the public and private realms within the design, and there is noexplanation as to how this would work in practice. It follows that the commitmentto genuine public access is entirely unconvincing. This is particularly the case forthe proposed ‘communal hub’ in Grace House and the spa that the applicantmaintains would be openly accessible and embedded in the wider community. Theplans submitted show these buildings would have to be accessed by individualsbeing able to freely cross the site from either Etloe Road or Westbury Park - andthere is no delineation between resident (private) and non-resident (public) areas.These multiple shared entrances between the public and the residents alsoincrease the risk of ‘tailgating’. This demonstrable lack of detail and forethoughtindicates either that the applicant has failed to appreciate the practicable, workingaspects of public access to an extra care facility on this particular site (and thatthe promise of openness is merely included to make their application seem moreappealing), or that they will be forced to limit or erase public access to the sitewhen they realise that public access is not, in fact, possible because of theconstraints we outline above.

Does it provide community benefit from the new “Urban Village Hall”? NO

● The applicant raises the possibility of North Lodge, described as a so-calledUrban Village Hall, delivering a community benefit (for clarity the plans for NorthLodge provide for a number of small workshop style rooms rather than a ‘hall’ assuch). We understand that these rooms may be available for a limited number ofhours a week. In reality, shared use between the residents and other potentialusers, particularly use by more vulnerable groups, like the nearby primary school,creates formidable access, staffing and safeguarding challenges. In his objectionto the planning application the Head Teacher of the local primary school indicatedhis dissatisfaction with the proposals for North Lodge and expressed his seriousconcerns about safeguarding issues. Again, there is a distinct lack of detail andno firm guarantee that North Lodge, as it is locally known, would ever be genuinelyor significantly open to the public. There is also concern that this offer could bewithdrawn at any point by the landowner, should problems arise.

● The roads directly bordering the site contain 3 school/Church halls, which alreadyprovide easily accessible and well-used community meeting rooms. The newmeeting rooms proposed by the applicant would take business away from theexisting church and schools, which are charities and rely on rental income.Moreover, this proposal would increase visitor traffic and parking demand in TheGlen (the proposed access point), which is a narrow cul-de-sac, and this wouldhave an adverse impact on road safety. These points suggest that the proposed‘Urban Village Hall’ would damage the local community, and would not offer anybenefits whatsoever.

● In summary, this suggestion from the applicant, despite being wrapped up as a‘gift’, simply exemplifies their complete failure to understand or address the actualneeds and priorities of our local community. No weight should be attached to thisempty, unwanted promise.

Does it deliver benefits to the physical and mental well being of future residents? NO

● As above, the local market for luxury retirement developments is saturated. Thisis clearly not the right location for another luxury retirement complex.

Does it deliver economic benefits including increased local spending and jobcreation? NO

● The increased local spending will not be significantly more than a development ofa much more acceptable density, and probably less than a development thatincluded provision for young people and families. On the other hand, it doesdeliver an unwanted increase in demands on local health services, which arealready stretched, and increased parking pressures on an area which is alreadyseen as unsafe due to the existing excess demand.

Does it “result in savings to the NHS”? NO

● The adverse impact of introducing over 200 frail elderly on the health and socialcare system of Bristol needs to be considered. Bristol hospitals have been someof the worst in the country for A&E waiting times and have large numbers ofelderly patients awaiting discharge. At least one GP surgery local to the site hasclosed (Helios practice Spring 2022) and others are struggling to meet demandgenerated by increasingly complex patient needs.

● When the evidence quoted by the applicants 3 about the potential benefits of theproposed scheme on health and social care utilisation is scrutinised in detail, itdoes not substantiate the claims made by the developer with regard to areduction in health service utilisation. Indeed, rather than being 'beneficial' as thedevelopers suggest, the addition of several hundred frail elderly people into anarea with overstretched GP, community and secondary care services will beentirely detrimental. It will result in increased pressure on services and reducedquality of care and quality of life for other local residents who need this supportfrom the NHS and social care.

● In summary, Professor Sarah Purdy, Pro Vice-Chancellor for Student Experience, aProfessor of Primary Care and a practising GP, found that the "research"4 quoted

4 https://www.extracare.org.uk/media/1169231/full-report-final.pdf

3 Housing Need Reporthttps://pa.bristol.gov.uk/online-applications/files/79231D5B6812A2BECEA6B6F5B0BEE9BC/pdf/22_01221_F-HOUSING_NEED_REPORT-3162631.pdf

does not substantiate the claims made in the planning submission. This isbecause the early promising data from 2015 was not confirmed by the full study.In effect, the final report suggested there was no reduction in healthcare costs orhospital stays for Extra Care residents as opposed to the control group and nodecrease in planned nurse or GP visits but actually as a significant increase inplanned nurse visits. 5 Professor Purdy shows how the applicants have quotedselectively from the cited research, and have completely ignored the actual finalfindings.

Does it provide environmental benefits? NO

● Certainly not once the considerable environmental damage through loss of treesand green space is taken into consideration (See Section 7 below).

2) HERITAGE & HERITAGE BALANCE

Does it “preserve or enhance the designated heritage assets”? NO

We believe this scheme will cause permanent damage to the heritage assets within aconservation area. The proposed buildings would be built in very close proximity toGrace House and adjacent homes in Bayswater Avenue, The Glen and Royal AlbertRoad, compromising them for years to come. It is an irreversible and irretrievableposition and for that reason we consider the harm to be PERMANENT and thereforeat the top end of the scale.

We respectfully ask you to consider that this proposal constitutes ‘substantial’ (ratherthan ‘less than substantial’) harm to the designated conservation area and theheritage buildings, and amend the report accordingly to strengthen this reason forrefusal.

Do the alleged public benefits and heritage harm justify the size of the proposals?NO

The applicant's rebuttal states that: “The comments of the conservation officer,reported at paragraph 90 of the CR, that state that alternative forms of developmentmay achieve similar public benefits are misleading and factually incorrect”.

This is in itself a factually incorrect statement. Although a potential, viable alternativescheme that delivers equal or more public benefit may not necessarily be consideredwithin the planning process, it may well be the expert opinion of the ConservationOfficer, with extensive knowledge of heritage sites, that they are correct in theirassumption that an alternative form of development would achieve similar, or even

5 Please see attached addendum for full analysis by Professor Purdy.

more, public benefit. It is not introducing another test, it is merely stating the expertopinion of the Conservation Officer.

In addition, to challenge the statement that “a smaller scheme could achieve similarpublic benefits” is without foundation..

A smaller, less harmful, scheme may achieve even more public benefit preciselybecause of its reduced size along with multiple other reasons:

● If it is a smaller scheme with fewer housing units it would cause less crowdingand permanent damage to Grace House or the backland setting.

● If some of those units are affordable housing units rather than luxury housingunits, more weight would need to be given to the increased and preferablepublic benefit this provides.

● A smaller scheme that doesn't need communal facilities to justify a high costmonthly maintenance fee, and no need for a ‘care hub’, could make differentuse of Grace House, for example, returning it to SEND use, and therebyproviding enormous public benefit that does not exist in the current proposals.

Furthermore, the applicant maintains that an Independent Retirement Communityneeds to be of a certain scale to achieve the economies of scale necessary to deliverthe care, support, and welfare facilities that are required by a facility of this type. ButSCAN produced a viability assessment (using the applicant’s own base figures)showing that there could be a profitable development with substantially lowerdensity.6

3) DENSITY AND OVERDEVELOPMENTThe Committee Report Rebuttal demonstrates, not for the first time, that theapplicant either: 1) Does not yet know how to calculate residential density figures fordevelopments in the UK, or 2) Prefers to try to mislead Bristol City Council planningofficers by making the absurd claim that the entire site is developable land. Theyclaim that the density of their proposal is 60 dwellings per hectare (dph), a trulyludicrous suggestion. The density proposed is, as the letter submitted by theWestbury Park Community Association (WPCA) to Alex Hawtin earlier this monthdemonstrates, an astonishing 160 dph.

Any independent professional assessment of the actual density proposed by theapplicant would be bound to conclude that this planning application proposes a trulymassive overdevelopment of the site.

For the developers to arrive at their density figure they have assumed that the entirearea of the site is available for development. This is ‘fantasy land’ planning. Itassumes that it is fine to demolish Grace House, the Grade II listed building that liesat the heart of the site, as well as the fine Victorian lodges fronting Westbury Park.As any first-year city planning student will know, to calculate the residential density of

6 SCAN COMMENT ON FINANCIAL VIABILITY ASSESSMENT - OBJECTIONhttps://pa.bristol.gov.uk/online-applications/files/6A74DAB152B90107F10C1F6498F60811/pdf/22_01221_F-SCAN_COMMENT_ON_FINANCIAL_VIABILITY_ASSESSMENT_-_OBJECTION-3258954.pdf

a proposed development, it is vital to establish with care and precision the actualextent of ‘the developable land’. This is particularly important in Conservation Areas.

As the WPCA letter makes clear in detail the developable land is, by the applicant’sown admission, one that is approximately 50% of the back land site, say 0.57 hectare.This results in a proposed density of 160 dph. This is way over the level of densitythat BCC would be willing to accept anywhere in the ‘Inner Urban Area’, and certainlynot within a Conservation Area.

As well as proposing entirely false figures relating to the residential density of theirproposals, the applicant has ignored the advice provided by Secretary of StateMichael Gove in the letter he issued to all planning authorities in December 2022when he stated that: ‘… all development that is not well designed should be refused,especially where it fails to reflect local design policies…’

4) HIGHWAYSThe applicant claims that the officers have not indicated the number of parkingspaces that they consider appropriate.

However, the TDM has referred to the Design Principles for Extra Care Housing (3rdedition) June 2020 which sets out that “Parking standards will need to be negotiatedwith the planning/highways authority as there are often no defined standards for‘housing with care’” and stated that they agree with this.

SCAN has previously presented an analysis of a reasonable (not worst case) numberof required spaces, based on independent government/academic research, andexpert advice previously used by PINS. Our analysis is available on the PlanningPortal, but to summarise, we identified the following requirements7:

Residents’ spaces 732 car-club + 1 mini-bus 3Staff (including carers) 30Residents’ visitors 15Visitors to Urban Village Hall and other publicfacilities 5TOTAL Required Spaces 126

The safety impact of any overspill parking on the local area, given the existing highdemand, is hopefully now universally acknowledged. For this reason it is crucial thatthe applicant bases their parking provision on an objective assessment of the likelydemand for parking, for this development, at this location, rather than continuallyreferring to the parking provision at other sites which are not comparable in terms ofdemographics, occupancy, or location. Very obviously - the number of spaces

7 Detail provided in SCAN statement on portal dated 3/1/23; with staff numbers updated (due to furtherinformation provided in the applicant’s Technical Note 2) in SCAN document on portal dated 22/2/23

provided at other sites (which may rely on their surrounding roads to eitheraccommodate or prohibit overspill) does nothing to determine the amount of parkingspaces needed to prevent any overspill at this particular development.

The applicant has access to the same publicly available research sources that wehave used, and it is difficult to understand why they have not used this data to comeup with needs-based estimates, which could form the basis of a sensibleconversation with BCC as to the number of parking spaces needed to reduce the riskof overspill to an acceptable level.

We also note that in the Committee Report, the conclusion regarding the C2 or C3classification was summarised as “Whilst it is recognised that there are aspects ofthe development which could reasonably be argued to constitute a C3 classification,overall it is considered to be a finely balanced judgement which reflects thecomplexity of this issue at a national level and the inconsistency of decision makersto date.”

It is therefore reasonable to consider the amount of parking that would be providedunder a C3 classification. This is defined as:

One bed house/flat: one space per dwellingTwo bed house/flat: 1.25 spaces per dwelling

Based on 104 x 2-bedroom and 12 x 1-bedroom units, C3 parking standards wouldallow for 142 spaces.

In fact, 142 spaces would be a good estimate of what may be needed to fullymitigate any risk of overspill, given the combined nature of the accommodation –where mobile (and wealthy) residents are likely to retain their cars, less mobileresidents may rely on being driven by their partners, and where there is also a needfor on-site staff. Our own reduced estimate of 126 spaces was calculated as agenuine attempt to provide a balanced, rather than worst-case, estimate, and we areall too aware that it will not fully remove the risk of overspill.

For the above reasons we believe that it is clear that the development will result inoverspill which cannot safely be accommodated by the surrounding roads, thereforeas the applicant has failed to demonstrate safe highways conditions, the scheme isunacceptable and the application should be refused on these grounds.

5) SUSTAINABILITY &6) OVERHEATING

Does it deliver sustainable buildings compliant with Bristol City Policy? NO

● The Committee Report already demonstrates that the buildings lack resilience toclimate change and failure to comply with basic council policy for sustainableconstruction. We support the reasons for refusal on lack of sustainability andhighlight two further areas that officers may wish to additionally record to supportthis refusal.

i) Living conditions for future residents (para 202 of the CR)

“It is considered that the proposed development, by nature of the proximity of Villa A toKenwith Lodge, and the interrelationship between Villa C and Villa D would result in anunacceptable living environment for future occupiers.”This paragraph shows an obvious conflict with local planning policy and SPD1 and isa clear additional reason for refusal.

ii) CO2 emissions (para 222)

“The applicant has not demonstrated that the proposed development would reduce carbondioxide emissions from residual energy use in the buildings by at least 20%, and insteadprovided figures against Target Emission Rate (TER) as set out in Building Regulations.

It is clear that the developers have failed to comply with the council’s basicsustainability policies which are critical to Bristol’s climate emergency with regard tocarbon dioxide emissions as well as the overheating issue. It is not acceptable tomake such crucial assessments ‘post planning’ as suggested by the applicant (para223) and demonstrates a lack of commitment and willingness on behalf of theapplicant to comply with basic climate change proof requirements for new buildconstruction.

7) TREESDoes it deliver a biodiversity net gain with regard to our urban trees? NO

● We note a ruthless approach has been taken to remove mature trees and squeezein as much development as possible. This is simply unacceptable in aconservation area when we have a climate emergency and does not constitutethe elements of good design.

● There are 121 trees, many of them mature and spectacular, growing on theproposed development site. 40 of these will be removed to facilitate theapplicant’s plans. Under DM17 and BTRS, 104 replacement trees will need to beplanted.

● The applicant has used BNG 3.0, a flawed and outdated version of NaturalEngland’s Biodiversity Metric, which does not work when calculating the habitatvalue of the trees on the site. The flaws were corrected with the publication ofBNG 3.1 & BNG 4.0, which offer the only viable approach to a proper valuation ofUrban tree habitat. Therefore the applicant’s Urban tree habitat calculation cannotbe relied on because they use this unworkable table. This is why we say that theapplicant’s proposals will result in a net loss of biodiversity of at least 8.60%(assuming a zero net gain is applied).

● The developers "promise" that they will plant 104 trees within a 1-mile radius ofthe development site. Further, they claim that all of these will be planted in openground. There are currently 15 tree planting sites available in hard standing withinone mile, and zero sites for planting in open ground. Therefore, it is not possiblefor this development to comply with DM17. This application should be refused onthe basis that it does not comply with DM17,and therefore BCS9, and that paying

a fee to the council is not an alternative to proper mitigation of the loss of treeson the site.

● If it is the case that the policy document (in this case DM17) is contradicted bythe implementation document (in this case the Planning Obligations SPD),regulations state that it is the policy which must apply. In the majority of planningapplications, developers apply this “ruse” to avoid their obligations to replace losttrees. If we do not want to lose what remains of our natural environment, it shouldbe made clear to developers that this is not acceptable, preferably atpre-application, but if necessary at committee, by refusing planning permission.

8) OTHER COMMENTS

1. In the final section of their rebuttal document, the applicant makes thefollowing points:

a. “At paragraph 30, the CR notes that some comments have been made about thequality of public consultation and that it was misleading, but makes no furthercomment on this. The CR should acknowledge that as a matter of fact, and asset out in the Statement of Community Engagement, a great deal of publicconsultation has been undertaken, and that perceptions on the consultationcarried out is not relevant to the consideration of this planning application.”

Is the applicant really saying that the honesty and effectiveness of the communityconsultation is completely irrelevant provided that they can “tick a box” to say thatthey have done it? This could certainly explain a lot about their approach to it! It issuch a shame that they have taken this cynical approach, wasting all our time,instead of actually listening, and really trying to understand our priorities andconcerns and to address these as much as possible.

b. “Paragraph 149 of the CR says that services and facilities would not be availableto the general public. This is incorrect, and the planning application makes itclear that the firm intention is to embed the community into the wider localcommunity and encourage integration and the wider use of the ‘clubhouse’within the Listed Grace House for example.”

As covered above, no clear definition has ever been provided about what would bemade available to the general public, under what terms or restrictions, with nosuggestion to make this a binding commitment covered by a formal condition. Assuch, we understand why the CR cannot rely on this vague “intention”.

2. The applicant has been quick to allege mistakes within the CommitteeReport - whether justified or not - but fails to acknowledge their own litany of errors,

omissions, misleading images and information, lack of proper consultation andbasic technical miscalculations in their own application and the effect this has had.

In addition, the submission of a vast number of lengthy documents, subsequentalterations, in multiple addenda, often to clarify information that was missing in thefirst place or to offer insultingly minor and insignificant revisions - all of which add upto a complicated and ever changing picture - inevitably result in confusion, puttingunnecessary workload pressures on hard working planning officers.

Below are just some of the errors that we would like to highlight and to quote theapplicant back at themselves - this is a “long list that could run on for pages”. Whilstindividually many of these discrepancies may appear minor in nature, accumulativelythey show a disregard by the applicant to present the community with accuratefactual information surrounding their scheme. Some examples of errors/omissionsare taken from comments made in the statutory reports about the elements lackingin the application. Others are taken directly from the application itself.

1) FLOOD RISK MANAGER8 REPORT - “not enough information provided” “notincluded a detailed….Strategy” etc

2) SITE WIDE Service Strategy REPORT Discrepancy between the ‘plant’ planson the Site Wide Services Strategy 9 and the third iteration of the spa building10- unclear and conflicting drawings

3) SUSTAINABLE CITY TEAM REPORT11 - no information provided onoverheating, issues of blinds not addressed, energy statement referenceincorrect policy, baseline for existing buildings needs to be updated

4) CRIME REDUCTION UNIT REPORT12 - “the submission fails to provideinformation on the construction and security of staff cycle storage”, theapplication has a “lack of documentation around management, CCTV andlighting plans”.

12 Crime Reduction Unithttps://pa.bristol.gov.uk/online-applications/files/590A5F862763B3205958E70504BD5F0F/pdf/22_01221_F-CRIME_REDUCTION_UNIT-3371802.pdf

11 Sustainable City Tram Reporthttps://pa.bristol.gov.uk/online-applications/files/8E42048CBA5421B16EAD7E5704A08ECE/pdf/22_01221_F-SUSTAINABLE_CITY_TEAM-3405821.pdf

10 Spa and Service Area planshttps://pa.bristol.gov.uk/online-applications/files/75C6710D5066579C288A7F9B395B7FF3/pdf/22_01221_F-SPA_AND_SERVICE_AREA-3442522.pdf

9 SITE wide M and E Strategyhttps://pa.bristol.gov.uk/online-applications/files/37F1B58B2CAC222EC303282B6109192A/pdf/22_01221_F-SITE_WIDE_M_E_STRATEGY-3442528.pdf

8 Flood Risk Manager reporthttps://pa.bristol.gov.uk/online-applications/files/1FD3DDDBADA82FF8F04F21D358F263F1/pdf/22_01221_F-FLOOD_RISK_MANAGER-3372412.pdf

5) TDM REPORT13 - Parking Survey needs to be redone to make it more accurate,contradictions in statements about the staff/resident minibus, more accurateparking survey needed.

6) Height of H01 Cottages in site section drawing 2006 rev A - Duringconsultation with the developer these were described to us as single storeywith accommodation in the roof. The rooftops now line up with the top of a1930s house so are more like a townhouse with two full storeys and a roofabove, and will be significantly higher than the current single storey building.

7) Site section drawing 2006 – The top of roofline of the H01 cottages has beenobscured by tree branches to disguise their height. In fact, there is no tree thatcan obscure the front of these cottages, so the view is misleading andincorrect.

8) 2006 site section – this section is still showing the two very large trees tree 52and tree 65 which elsewhere in the proposal says are to be removed for sewerworks. The inclusion of these trees makes the scene deceptively green, andthis error was pointed out in the first consultation, however, has not beenremedied.

9) Landscape addendum – Shows the ground as level between the rear boundaryof the proposed ‘Cottages’ and the rear of 15/16/17 The Glen. This isincorrect, with there being a change in ground level, with the proposedcottages being higher.

CONCLUSION

In our view, the applicant’s rebuttal is inaccurate, unbalanced and unfair - it is entirelywithout merit and nothing more than a desperate eleventh hour attack on hardworking city council officers who have spent the best part of two years providing theapplicant with wise and helpful advice on how to develop this site in a sensitive andappropriate way; advice that the applicant has chosen to ignore.

The applicant has consistently failed to provide sufficient, accurate, up to date anddetailed information when requested, and appears to be hell bent on maximisinghousing units and profit for shareholders over heritage, environment, sustainabilityand the delivery of social wellbeing to the community of Bristol. It is startling to seethat the applicant has the audacity to claim this application will deliver ‘publicbenefit’ when the reverse is the case. In reality this application rides roughshod overa whole range of Bristol City Council policies, our community and our city.

13 TDM reporthttps://pa.bristol.gov.uk/online-applications/files/6CFA0FE46BE471B665157F4CAE415167/pdf/22_01221_F-TRANSPORT_DEVELOPMENT_MANAGEMENT-3464247.pdf

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Heritage and the Heritage Balance

The applicant has brought into question the decision-making process and asks why the generic benefits which

all developments generate are not included in the weighing up of the heritage pros and cons. The impact on

heritage was deemed to be ‘less than substantial harm’ meaning the applicant is correct in their statement that

the wider public benefits of the scheme need to be considered when making decisions on heritage balance.

We believe that whilst every benefit to the surrounding community is not individually listed within this section of

the report, this does not imply that they are not considered elsewhere in the CR. The applicant’s rebuttal appears

to have missed several of the benefits of this scheme being discussed along with their respective drawbacks –

for example, the creation of purpose-built housing for the elderly, a sector which currently has very high demand,

and the knock-on effect of freeing up family homes for the next generation of buyers (Paragraph 151 and 160).

However, the applicant has also included within their extensive list of wider societal and environmental benefits

some elements of policy compliance which should not give weight to the wider benefit argument. For example,

working within EU timber regulations or preventing the use of asbestos products in construction – both of which

are mandated by UK legislation. These benefits are not a direct result of a well-designed scheme they are secured

by existing legislation and therefore should be discounted from the heritage harm / public benefit discussion.

The purported public benefits of the proposal are made clear throughout the CR, for example providing the

opportunity for the transition of elderly people into the area - which was concluded to be an overall benefit when

weighed up to its drawbacks of securing the future use of Grace House as a listed building. There are numerous

examples of a fair evaluation throughout the CR and to imply that none of these topics were considered when

deciding on the heritage balance lacks evidence.

NPPF paragraph 200 is most pertinent, stipulating that; ‘any loss of, or harm to the significance of a designated

heritage asset should require clear and convincing justification.’ This policy provision necessitates the evaluation

of all appropriate wider benefits, which must be taken into account before deciding whether a case for any harm

or loss of significance of a heritage asset has been successfully made.

In this instance, the issues taken into account by the officer include the lack of a 5-year land supply in Bristol, the

delivery of much needed homes and the associated benefits of development, all of which are listed throughout

the CR. However, such benefits are tempered by the heritage harm the proposal causes to the listed building, its

setting, and the wider conservation area it sits in. In this case the conservation officer has deemed that there is

not ‘clear and convincing justification’ for the proposed harm to heritage assets.

In paragraph 197(c) NPPF it is stated that in determining applications of proposals effecting Heritage Assets, three

points should be considered.

(a) the desirability of sustaining and enhancing the significance of heritage assets and putting

them to viable uses consistent with their conservation.

(b) the positive contribution that conservation of heritage assets can make to sustainable

communities including their economic vitality; and

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(c) the desirability of new development making a positive contribution to local character and

distinctiveness.

The applicant takes issue of a ‘critical flaw’ with flat Block B being referred to as 6-story unit. According to the

applicant this renders the CR’s decision unbalanced due to incorrect information being identified by the officer.

However using the criteria above, a 5-story block would have a similar negative effect on the surroundings of a

listed building within a conservation area and the local character and distinctiveness of the wider area. This would

entail a potential failure to positively address two of the three criteria.

Density and Overdevelopment

The applicant’s rebuttal stated.

“Sections in both the Design and Access Statement and Planning Statement explain why the

proposal is not “high density”, so it is concerning that this has been missed or ignored.”

In contrast, the word density is not mentioned once within the Design and Access Addendum with the most

relevant section regarding this being the Reduction in Scale and Massing, which only addresses the changes in

the latest submission showing a reduction of 1 story from a block of flats along with 2 houses becoming

bungalows as changes to respond to the first set of consultee comments.

Whilst this is a step in the right direction, it is still a long way from the preservation of the setting of Grace House.

However, it is not just a matter of density but also the grain, orientation, and overall architectural design of the

scheme as a whole, which has a direct baring when considering whether the proposal constitutes

overdevelopment. It is a combination of these factors which makes the blocks of flats stand out greatly when

compared with the mostly 2/3 story Georgian terrace vernacular of the local area. This scale and mass is in direct

conflict with DM27, which enforces that developments should be appropriate to the immediate context, site

constraints and character of adjoining streets.

Ultimately, the proposal in these terms is contrary to multiple Development Management Policies in respect of

design matters, notably; BCS21, BCS22, DM27, DM31.

Highways

The rebuttal asserts that the applicant has received no tangible information on the level of under provision of

parking they have provided. However, within the CR the officer highlights that the development would likely cause

overspill parking and the surrounding streets already suffer from parking stress, due to sitting on the boundary

of the city centres residents parking scheme, adding further strain from commuters. Due to these concerns,

Transport Development Management (TDM) consider it necessary to reference the below in their consultee

response.

“Design Principles for Extra Care Housing (3rd edition) June 2020 sets out that “Parking

standards will need to be negotiated with the planning/highways authority as there are often

no defined standards for ‘housing with care’”. TDM maintain this view.” This is in addition to the

highways consultee comments, which make clear how the local council wish to resolve this

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issue, through open dialogue as opposed to being provided with multiple sympathetic parking

need metrics.

TDM note within their consultee response that the calculations made whilst presuming this development fell into

use class C2 are not felt to be appropriate. They justify this position by outlining that there are key differences

between the transport needs of a typical C2 development such as a care / nursing home and the ‘retirement

community’ being proposed by the applicant.

The main difference in the opinion of TDM is that a much larger percentage of ‘retirement community’ residents

are likely to be engaging in more active lifestyles than someone in a care home, thus, they will typically retain a

greater reliance on the private vehicle in day-to-day life than would be expected of a typical C2 use. As such,

this is likely to give rise to an increased level of on-site parking to ensure that the proposal does not give rise to

discernible harm to the existing highway network.

In addition to the above, if the applicant was still in need of a quantitative example of the amount of parking which

could be acceptable, the example offered in the CR implied that the proposed parking provision of 0.56 parking

spaces per dwelling is some way short when assessed comparatively to another similar scheme within the area

which offered approximately 1 parking space per dwelling.

Whilst the officer has not offered an determinative number of spaces that the applicant is required to provide for,

a ballpark and eminently reasonable comparative, which is considerably higher than the applicant’s provision, has

been clarified through ongoing dialogue. Ultimately, it is the responsibility of the applicant to demonstrate that

their proposal is acceptable in planning terms, and it is clear in this case that this threshold has not been met in

respect of highway considerations.

Sustainability

The applicant asserts that there is no requirement for their application to provide an Overheating Assessment as

this is not expressly referenced within policy BCS13. This position does not withstand scrutiny. Policy BCS13,

expressly states that developments should contribute to both mitigating and adapting to climate change:

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

meeting targets to reduce carbon dioxide emissions.

Development should adapt to climate change through measures including:

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

change.

A demonstration, through the provision of a Thermal Comfort Assessment, that a new development will not

overheat when assessed against the standard TM59 climate scenarios (2020, 2050, 2080) quite clearly falls

within this remit.

In addition. Part 3 of the Bristol Urban Living SPD offers assistance to officers when making decisions on

developments of approximately 30 meters or higher. Villas B, C and D are all of the appropriate height to trigger

assessment via this adopted Development Plan document. Q3.7 (b) of the SPD states:

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Minimising excess solar gain that could lead to overheating risk through use of external shading

and careful consideration of façade design. Thermal Comfort Assessments (following CIBSE

guidance or similar) should be prepared to demonstrate that the building will not overheat in

current or future climate change scenarios, accounting for the urban heat island effect where

relevant.

In tandem, BCS13 and the Urban Living SPD patently make clear that considerations of thermal comfort within

new development is a material consideration in the determination of a planning application. The applicant’s

complete failure to provide such evidence to provide officers comfort that the development will be able to adapt

and mitigate to climate change provides officers with a clear policy conflict which in itself is sufficient to

recommend refusal – as they have done so.

Whilst the applicant’s agent makes reference to the ‘sustainability credentials’ and commitment of the applicant,

ultimately, these statements provide no determinative, or evidence based detail to confirm that their proposal is

compliant with BCS13.

Trees

The loss of trees T52 and T65 is contrary to both policies DM17 and BCS9. Both trees, as per the applicant’s

schedule submitted with their application fall into Category A and both are also under the protection of a TPO.

BCS9 states the following:

Individual green assets should be retained wherever possible and integrated into new

development. Loss of green infrastructure will only be acceptable where it is allowed for as

part of an adopted Development Plan Document or is necessary, on balance, to achieve the

policy aims of the Core Strategy. Appropriate mitigation of the lost green infrastructure assets

will be required

Policy DM17 states:

All new development should integrate important existing trees.

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

of an appropriate species should be provided, in accordance with the tree compensation

standard below:

Due to the development resulting in the loss of two trees of ‘greater importance’ the scheme submitted by the

applicant cannot, by definition have integrated these green infrastructure assets into the development, as

required by both BCS9 and DM17. The acceptability of replacement trees in lieu of the existing can only be

considered acceptable in principle if they are of the view that the development is ‘appropriate’ in the first instance.

Having come to the respective conclusions in respect of design, heritage and adapting to climate change, it is

logical to conclude that officers do not consider that the scheme proposed is ‘appropriate’ and therefore,

replacement tree planting to the schedule set out within DM17 do not remedy the loss of the existing Grade A

trees on-site.

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Yours faithfully,

Rapleys LLP

19.06.2023

Loss of far to many mature trees.

Loss of far to many mature trees.

Application 22/01221/F – Response from SCAN to “Technical Note 4”

We would certainly welcome the Council considering whether a CPZ could be implemented, but for

the above reasons it does not appear a likely or realistic solution. We made the applicant aware of

this situation more than a year ago, so unfortunately their offer to support it appears to be another

empty gesture.

More fundamentally, we are sure that the decision on this application must be based on the current

known road environment; the applicant should not suggest that some hypothetical and highly

unlikely future road changes by Bristol City Council could reduce their responsibility to provide

sufficient on-site parking to avoid overspill.

Section 4 – Fire Access

The applicant continues to ignore the comments about access from The Glen which have been raised

many times. As well as encouraging the use of The Glen and Belvedere Road for overflow parking, we

have also commented on the other impacts of the new access, most recently in SCAN’s response to

Technical Note 3, in which we stated:

“The applicant has still not stated how many on-street parking spaces would need to be removed from

The Glen (or indeed other roads) to implement their plans, worsening the existing parking stresses in

this area. Simply showing an updated road-sweep diagram with the new yellow line and one parked

car (page 12) does not do this (although it does show that a fire engine would hit the parked car, as

well as leaving insufficient room for parked cars on the other side).”

This issue remains outstanding; we cannot understand why the applicant does not produce a clear

statement about the number of on-street parking spaces which would need to be removed to

implement their current plans.

Furthermore, their new diagrams on Page 4 show the proposed route within the car park to allow

the fire engine to turn and it is noted that this would need 2 previously allocated parking spaces to

be removed and the space kept clear. However, it is obvious from the diagrams that if anyone did

park in either of the vacant spaces – or in fact, parked even slightly badly in any of the other spaces –

the fire engine would not be able to access or turn. Maintaining sufficient clear space to enable the

fire engine to turn appears unenforceable.

Finally, while the applicant states in paragraph 4.1 that their fire consultant has confirmed that

access is required from The Glen, this is also said to be based on the existing layout. We continue to

maintain that if there was an internal route through the site enabling a fire engine to reach the rear

section from the front entrance, access would not be required from The Glen.

Note on the On-Site Parking Allocation

As an aside, it is very difficult to tell from any of the applicant’s plans exactly where each of the

purported 65 parking spaces is located – we have certainly not been able to count all 65. May we

suggest that BCC asks for a plan which clearly shows the location of each space, so that these can be

confirmed.

ST. CHRISTOPHER'S SQUARE: APPLICATION NUMBER 22/01221/FOBJECTION TO THE URBAN LIVING SPD RESPONSES

Preface

This objection relates to the note submitted by the applicant in response to questions asked by theCity Council's City Design team. What follows below first sets out a single, overall picture of issuesof character and design in relation to the planning application. Points from that are then picked upin comments on the responses by the applicant to the questions asked by City Design that relateto the Urban Living SPD.

Although I have helped with contributions to other objections on behalf of the Westbury ParkCommunity Association (WPCA) and am a resident of the area, this is a personal objectionbecause it focuses solely on aspects of character and design which are my specific area ofprofessional expertise. Over many years I have contributed nationally to many aspects ofarchitectural design, especially about designing in character. I have played a role in particular inthe development of community-based Character Assessment and Design Statements, all builtaround the now nationally accepted theme of 'Local Distinctiveness' which I played a major role inintroducing into the planning system. In relation to character assessment, I led the group of localpeople who produced the 'Westbury Park Character Assessment and Design Statement'. This isnow a material consideration for Bristol City Council.

1 POLICY CONTEXT

1.1 National Planning Policy Framework

1.1.1 The current version of the NPPF (2021) states, inter alia, that:

"Planning policies and decisions should ensure that developments ..... are sympathetic to localcharacter and history, including the surrounding built environment and landscape setting ..." (para130)." Development that is not well designed should be refused, especially where it fails to reflectlocal design policies and government guidance on design, taking into account any local designguidance" (para. 134).

1.1.2 As this objection will make clear, the proposals are, in almost all ways, not "sympathetic tolocal character and history, including the surrounding built environment and landscape setting".For this reason alone the application should be refused.

1.1.3 Though linked more to community engagement (on which the WPCA has submitted aseparate objection) the NPPF makes clear the importance of engagement in ensuring good qualitydesign, as follows:

"Good design is a key aspect of sustainable development, creates better places in which to liveand work and helps make development acceptable to communities. Being clear about designexpectations, and how these will be tested, is essential for achieving this. So too is effectiveengagement between applicants, communities, local planning authorities and other intereststhroughout the process" (para. 126). "Design policies should be developed with local communitiesso they reflect local aspirations, and are grounded in an understanding and evaluation of eacharea's defining characteristics. Neighbourhood planning groups can play an important role inidentifying the special qualities of each area and explaining how this should be reflected indevelopment" (para.127). "Applicants should work closely with those affected by their proposals toevolve designs that take account of the views of the community. Applications that can demonstrateearly, proactive and effective engagement with the community should be looked on morefavourably than those that cannot" (para.132).

1.1.4 Engagement with communities is seen as critically important in the NPPF as above in orderto deliver high quality and especially locally distinctive design. How this has been addressed inrelation to the above application was the subject of an earlier objection by the WPCA in which itwas made clear exactly why what was done was appallingly inadequate, for example by totallyfailing to "take account of the views of the community".

1.2 National Design Guide and National Model Design Code

1.2.1 These two documents are referred to in, and supplement, the NPPF as above. They build in

particular on the work of the Building Better, Building Beautiful Commission (to which I contributed)and its final report. Both documents place great emphasis on starting work on any design bystudying, describing and analysing the local character of any site - in part by talking to local people- and using this to prompt design approaches.

1.3 Bristol City Council Urban Living SPD

1.3.1 This is the key document about character and design for Bristol and therefore for the St.Christopher's site. It includes a number of criteria about character and design which largelyshaped the questions to which the applicant has now responded (though this is not explained inany way in the submitted document). The questions and the applicant's responses are addressedlater.

2 CHARACTER CONTEXT

2.1 In relation to the St. Christopher's site, the Westbury Park Character Assessment and DesignStatement places it in 'Character Area1: Westbury Park Frontage' (p.25). The word 'frontage' iscrucial because all the properties in Character Area 1 front onto the road and onto The Downs andtherefore contribute to the high quality character of the Downs edge that led in part to the creationof The Downs Conservation Area. Properties to the north of the site form a strip of nothing morethan front garden/house/back garden development and that was also the case, according to a planof 1835, for the Lodges along the front of the St. Christopher's site. It was only later that the landto the rear of the original back gardens became slowly incorporated into the frontage land tocreate the full site which is the subject of the current application.

2.2 As in all the remainder of Westbury Park, the development that took place before the FirstWorld War is of two storey houses, if sometimes with rooms in the attic. That includes CharacterAreas 2 and 4 - those that bound the site on three sides. The core assumption would therefore bethat development on what is clearly the backland behind the Lodges along Westbury Park shouldalso be of mainly two storeys. This point is reinforced in the applicant's Design and AccessStatement which draws on the detailed architectural vocabulary of not just Areas 1 but also Areas2 and 4.

2.3 It may seem to be a smaller point, but the Westbury Park Character Assessment and DesignStatement also highlights the importance of street trees to the environmental quality of Area 4 inparticular and that quality is very much reinforced by visually 'borrowing', at an important junction,the copse of trees in the north east corner of the St. Christopher's site. This is a significant copseof often tall trees, mainly conifers, important because it is more than just a line of street trees.

2.4 The applicant's Design and Access Statement ignores the crucial point about what areessentially two different characters to the St. Christopher's site - the frontage Lodges (and theirfront gardens and original back gardens) and the backland area. This key difference has

implications for the form as well as the density of the proposed development.

3 THE FORM OF DEVELOPMENT

3.1 Following on the argument about the site having two very different character areas, importantpoints can be made about the general design model that development should therefore take onthe backland in particular. The obvious suggestion is that it should be of 2 storey 'streets' as inAreas 2 and 4. This could be 2 storeys plus rooms in the attic as a third storey - which I will call2+1 - and there might even be parts of the site where 3+1 might be appropriate, in principle atleast. The proposals do in fact include nine 2 storey properties to the east and south of the site.

3.2 It would have been good to continue this 2/3 storey design model across the backland area,which would have helped with the relationship to Grace House, but this would not have beenappropriate for two reasons. First, not all buildings could be 2 storey and anything of 2+1 or 3+1scale would have had to be in single storey apartments necessitating lifts for every 'house'. Thatwould no doubt be unviable. Secondly, the result would have been far fewer apartments,presumably also prejudicing viability.

3.3 One other model was suggested in the pre-aplication work by the previous site owners - asingle, monolithic, care home style building. That would have been totally inappropriate in such asensitive setting in a Conservation Area.

3.4 The basic model that the applicants chose to adopt was therefore one of 'villas' to relate ingeneral, as they argued, to the villas (called Lodges) along the Westbury Park Frontage. TheNPPF makes clear that, while local character needs to be respected, there will always becircumstances where blindly following this would be inappropriate. This site is one of thosesituations, so it might seem that a villas model would be appropriate.

3.5 Unfortunately, the applicants chose a completely inappropriate, version of a villas model.When the operators of the earlier St. Christopher's School wished to add new buildings to whathad at one time been a large open garden at the rear of the Lodges, they used the entirelyappropriate model of 'buildings in a landscape' rather than clustering them all together in the formused along Westbury Park. That 'buildings in a landscape' approach on this occasion would alsohave ensured compliance with two of the City Council's key criteria - making backlanddevelopment "subservient" to Character Areas 2 and 4 and putting forward a design that is"landscape-led", as well as helping to establish an appropriate relationship with Grace House

3.6 Though 'buildings in a landscape'(in this case villas) is not easy to define, there are two criteriacommonly used to assess it:

1. Spaces between habitable rooms in the villas should be a considerable distance apart, certainlymore than the usual criteria used by local authorities of 20, sometimes 25, metres. The applicants

might argue that in some cases the Westbury Park Lodges are closer than 20 metres, but thosebuildings are in a formal, linear, urban design relationship and there are no habitable roomwindows (or balconies) on the flanks to the Lodges.2. Distances between buildings should be such that rooms in any of the buildings would not be inshadow at any time of the year from other buildings during the normally applied 9am to 6pm times.

3.7 There are therefore several results from the applicant's choice to use their version of a villasmodel - which is in fact a distorted version of the 'buildings in a landscape' model - that I, localpeople and the City Council would prefer and which would meet government standards of gooddesign. The key results of that choice are as follows:

1. In the absence of features of the land, landscape and surrounding buildings - especially GraceHouse - that might guide the location of the proposed villas, the oddly informal disposition of thevillas is completely meaningless except as a way to cram in the maximum number of apartments.2. The villas, at 5, 4 and 3 storeys, are too high in relation to the surrounding properties - certainlynot subservient - and especially too high and far too close to the Grade II Listed Grace House.3. The villas are also far too close to each other. In many cases the distances between habitablerooms and balconies (etc.) is as little as 10 metres. This is totally unacceptable. (In a recent courtcase it was determined that a distance of 34 metres between a balcony and a habitable room wasinadequate.)4. The proximity of the villas to each other also results in frequent shading of habitable rooms asillustrated by the applicant's earlier shadow diagram.5. The layout cannot in any way be described as "landscape-led" as the City Council require andas I and local people would support. The landscape design team have done a good job atsuggesting the landscape qualities of the different areas but those areas are no more, as used tobe said, than SLOAP - Space Left Over After Planning!

3.8 Spurious arguments have been put forward by the applicants to support their basic model forthe villas in the backland, almost certainly aimed at maximising apartment numbers. The result is alayout in terms of the number of villas, their heights and their proximity to other buildings that istotally inappropriate in character and design terms to this site.

3.9 Finally in this section, a comment is necessary on the proposed "Woodland Glade Cottage". Aglade is "an open space in a forest or wood". That just about qualifies here for the area to becleared after any demolition of the swimming pool. However, it is unbelievably ridiculous to thenpropose filling that new glade with a building that would be so entirely surrounded by trees, manyof them conifers, that nothing more than, at best, dappled sunlight would ever reach a singlewindow. And to then have the audacity to submit a shadow diagram that suggests that light wouldreach the property is disgraceful and unprofessional.3.10 Whatever proceeds from here on, the "Woodland Glade Cottage" must be removed from thescheme.

4 DESIGN DETAILS

4.1 I have little to say about the specific architectural designs proposed. The designs for theconversions of the Lodges appear appropriate as does the design of the 2 storey cottages.Various attempts have been made to suggest that features of the villas - for example the set-backfor the entrance areas - relate to features of the villas along Westbury Park to the north of the site.That is based on the seriously flawed assumption that people draw visual parallels based on flatelevations as on design drawings. They do not. As research has shown, people only rarely pick upparallels in form and then only on the basis of their experience when walking past not standingstill. Given that, as above, the villas form was chosen (if wrongly) to relate to the Lodges ratherthan to the more general local character, and that the villas are basically very contemporary indesign (which I do not query), arguing for parallels was a total and unnecessary waste of space inthe Design and Access Statement.

4.2 This attempt to argue the unnecessary has resulted in the recent submission of proposals toadd 'fins' to Villa B to supposedly relate better in design terms to the 'fins' on Grace House. This isridiculous and hints at desperation.

5 THE DENSITY OF DEVELOPMENT

5.1 I contributed to the earlier objection by the WPCA about overdevelopment of the site. In thatobjection, the point was made (paras. 4.1 to 4.9), that the site is in two distinct and, in characterterms, very different parts, as elaborated more fully above. It is stated in that earlier objection to bemisleading for the applicants to calculate a single density for the whole site - it should be based ondensities for the two different character areas. It is also argued that standard practice wouldcalculate the proposed density for the backland area of the site not for the site as a whole but inrelation to some agreed net developable area NDA) to which the density would then be applied.That NDA would therefore exclude the copse to the north east and Grace House and an area thatrelates its setting. A drawing to show this was in fact produced by the applicant's own architects,supported by the community at consultation events, included in the WPCA's initial objection butthen ignored.

5.2 It was further suggested in the earlier objection that, using the points above, the density on thebackland area could in fact be as much as 195dph, above the City Council's standards for thisarea and especially for a site in a Conservation Area.

5.3 Most importantly, in the completely understood context of our country's, indeed our own city's,need to maximise land for housing, serious note must be taken of a letter (December 2022) fromthe Secretary of State to local authorities which states that "developments that are not well-designed should be refused planning permission and housing targets should not be used as ajustification to grant them permission". This latter point is crucial in relation to all of the above.

5.3 The applicant's use of the maximising previously developed land and hence density argumentcannot be given any weight at all in this specific context.

6 APPLICANT RESPONSES TO THE URBAN LIVING QUESTIONS

I wish to avoid a full repeat of the questions and the applicant's responses to them so willcomment question by question (as numbered by City Design) with minimal reference to theapplicant's text (annotated with a C for my comments). Some questions are not relevant to thisobjection, as noted at the end.

6.1 Q1.1: Has the scheme adopted an approach to urban intensification which is broadlyconsistent with its setting?

6.2 C: The applicant's text argues that the City Council's ambition for 'urban intensification'suggests that an appropriate density for development on the site would be 120dph. They furthersuggest that, across the 5 acres of the site, their design "represents 58dph". As pointed out inSection 5 above, it is entirely inappropriate to calculate a single density for a site with twofundamentally different parts, especially when the very low density frontage part of the site hassuch a dramatic effect in lowering the overall density. In addition, the applicants make no mentionof the fact that much of the backland part of the site is completely undevelopable (withoutdemolishing Grace House and the copse to the north east), therefore suggesting the need for anet developable area approach. As above that makes the density on the backland close to195dph, totally inappropriate and unsupportable for this area and site.

6.3 Q1.2: Does the scheme contribute towards creating a vibrant and equitable neighbourhood?

6.4 C: This is more fully addressed in other objections by the WPCA and others but, in terms ofthe contribution to community vitality as a factor in good design, the inclusion of facilities and theopenness of the site is valued. However, those other objections have pointed out that WestburyPark is already extremely well supplied with facilities such as cafes (ours is already a nationalexamplar of a 15/20 minute neighbourhood in all senses) and the proposed "urban village hall" issimply not needed.

6.5 Q1.3: Does the scheme respond positively to either the existing context, or in areasundergoing significant change, an emerging context?

6.6 C: The inadequacy of the applicant's response to this question is clear from all that is coveredin the sections above. It is particularly galling that the applicants note that "the existing sitecomprises of a number of individual buildings set within the landscape", i.e. it is 'buildings in thelandscape', yet they still fail to be aware that their dramatic overdevelopment of five large villas inthis backland area fails completely to pick up on this form of character.

6.7 Q1.4: Does the scheme provide people-friendly streets and spaces?

6.8 C: First of all, a contradiction. The applicant's text in response to Q1.3 states that the site "isfully accessible throughout" but the text for the response to this question states that "there areparts of the design that are accessible to the wider community"! Ignoring for a moment the lack ofspace between the proposed villas and the separation between the various landscaped areas, Iaccept that the scheme would deliver on this issue.

6.9 Q1.5: Does the scheme deliver a comfortable microclimate for its occupants, neighbours andpassers-by?

6.10 C: Given current ideas about resilience to climate change, the applicants appear to bearguing that almost completely filling the backland with buildings creates lots of areas well shadedfrom the sun! That is, however, spurious because an appropriate 'buildings in the landscape'approach, complemented by a high level of tree provision and hence tree cover, would achieve theresilience aim even better and more appropriately both in general and for this particular site. Theremay also be issues of wind canyons around and between the proposed villas.

Q1.6: Has access, car parking and servicing been efficiently and creatively integrated intothe scheme?

6.11 C: Parking is not strictly a character and design issue. However, the obvious andconsiderable pressures to maximise the number of units on the site has resulted in a serious lackof space on site for parking and, as other objections have shown clearly, one result of this wouldbe some residents having to park their cars in nearby streets. That in itself would be damaging tothe character of surrounding areas. A lower quantum of buildings on the backland would result in abetter and more locally appropriate design and, in so doing, accommodate - as it surely should -enough space on the site itself for all residents, staff and visitor parking needs.

6.12 Q2.2: Does the scheme provide practical, attractive and easily accessible communal amenityspace that meets the needs of its target resident profile?

6.13 C: What is proposed is good, mainly for the future residents, although that comment must beconsidered in light of the comments above (6.4) about the unproven need in the area for furthercafes etc. (and the urban village hall not mentioned here by the applicants).

6.14 Q2.3: Does the scheme provide sufficient private outdoor space?

6.15 C: The balconies are small and many will be overlooked from nearby properties (see 3.7.3above) to the point that people may well regard them as unusable.

6.16 Q2.4: Does the scheme create attractive, well designed and well maintained private outdoor

spaces?

6.17 C: See 6.14 above.

6.18 Q2.5: Does the scheme creatively integrate children's play?

6.19 C: This may not seem relevant given the age profile of likely residents but the applicants havestated on several occasions a wish to work with the adjacent Primary School and engage childrenon the site in activities such as food growing. This is very much to be supported but it is not clearwhether the detailed design is appropriate for this.

6.20 Questions Q2.1, Q2.6, Q2.7 and Q2.8 are not relevant to this objection about overallcharacter and design.7 CONCLUSIONS

7.1 The applicants appear to have imagined that their responses to the City Design team'squestions would help their case. Unfortunately, their responses only serve to highlight even furtherthe inadequacies of their proposals.

7.2 I object to the proposals on character and design terms because the applicants have been'economical with the truth' on aspects such as the model chosen to supposedly justifyinappropriate amounts of development on the backland and misleading calculations of density,and fundamental mistakes such as the heights of the proposed villas and their proximity to eachother. Other inadequacies are covered in the full text above and all of these points lead to theinevitable conclusion that these proposals should not secure planning permission.

Westbury Park Community Association have previously made two submissions relatingto the proposed low provision of on-site parking and the adverse impact that this would have onsurrounding local roads which are already at full parking capacity. This further submission is beingmade in response to the applicant's response, as set out in Technical Note 3, to the parkingcomments dated 13th February made by the City Council's Transport Development Management(TDM)Team.

In our previous submissions we estimated that the site parking requirement would be of the orderof between 86 and 101 with residents requiring at least 58 spaces, staff requiring between 16 - 22spaces and visitors requiring 12 - 15 spaces. These estimates now look to be on the low side onthe basis of new information that has more recently been provided by the applicant relating to staffparking requirements and the resident parking figures contained in the unpublished studycommissioned by McCarthy and Stone and referred to in paragraph 5.13 of the Technical Note

Staff numbers provided by the applicant suggest that 23 spaces are required for employed staff(TDM reference below paragraph 5.18 in the Technical Note). This figure is higher than thatpreviously stated by the applicant and higher than the original WPCA estimate of staff parkingrequirements.

The applicant incorrectly uses the BCC parking standard for resident care homes to determine thenumber of spaces required for visitors in an independent living scheme - an altogether differenttype of development. However, the derived figure of 19 spaces might still be considered a

reasonable assessment of the number of spaces that will be needed to accommodate healthprofessionals and staff plus private visitors.

It is with regard to the parking needs of residents that the applicants calculations can be mostquestioned with the technical note concluding in paragraph 5.25 that just 24 spaces will berequired for residents. With almost all the proposed units comprising two bedrooms aa many as200 residents could be living on the site. Does the applicant really believe that 24 dedicatedspaces for up to 200 residents will be sufficient - a ratio of just 0.12 spaces to residents. Thisfigure is totally at odds with the evidence we and SCAN have previously presented on carownership figures in comparative schemes, is less than in most of the questionable examples ofcomparative schemes previously cited by the applicant and is clearly at odds with the analysispresented in the Technical Note in paragraphs 5.13 and 5.14 relating to the McCarthy and Stoneschemes where car ownership is calculated to be 41.3%.

Paragraph 5.14 states that 48 spaces would be required at St. Christopher's by applying the 41.3% figure to the 116 units. How this figure morphs into the resident parking figure of 24 inparagraph 5.25 is not made clear - it looks like a simple arithmetic adjustment to accommodate theincreased levels of staff and visitor parking requirements while keeping the total number of spacesat 65.

Even the 48 spaces figure is inaccurate as it has been calculated by reference to the number ofunits rather than the total number of residents. The figure would be as high as 80 spaces if appliedto the number of residents (possibly as many as 200 residents). Given the projected age profile ofresidents at St. Christopher's compared with McCarthy and Stone schemes a provision in therange 60 - 70 spaces might be sufficient to satisfy the demand for parking spaces from residents..

Paragraph 5.14 also contains the statement that only 10% of residents drove regularly butapplying the figures cited in the previous paragraph (139 out of 390 residents reported that theydrove regularly) the correct figure is 35%.

Making sense of all the calculations (and miscalculations) of the parking needs of residents, staffand visitors and reaching a robust estimation of the total parking requirement is not easy but onthe basis of estimates previously made by the Community Association and the new information setout in Technical Note 3 we now believe that a total in the range 100 - 110 spaces would berequired to minimise the risk of overspill parking on surrounding roads.

rented properties, with a majority of 1-bedroomed apartments and studios1. Most of them are owned

by Housing 21, a Housing Association describing themselves as a “provider of Retirement Living and

Extra Care for older people of modest means.” This is not the St Christopher's target market.

The data referenced also shows that for the majority of sites there is no alternative parking close to

the scheme. Evidently, if developments have limited on-site parking, in areas where there is no other

parking available, then it is self-determining that occupancy is restricted to residents who don’t have

cars! Unfortunately, this will not be the case at St Christopher’s.

The applicant also refers, in 5.14, to an unpublished study produced by another developer in 2010. As

this study was unable to be published, it is not possible to determine the nature of the accommodation

and locations, or the means of selection of survey participants, so its validity as a comparison is limited

to say the least. However, the referenced HLIN document noted (Page 19) that half the respondents

were over the age of 85, and fewer than 10% were under the age of 75. This selected profile cannot

expect to be replicated at St Christophers.

And finally, the sites selected from TRICS (referenced in 5.32) are almost exclusively social rented,

primarily 1-bedroomed apartments, owned by Housing 21 and other charitable housing trusts.2

There is an obvious and fundamental flaw in basing the number of parking spaces on that provided at

other sites: in that it is not possible to know whether the number of spaces at other sites is actually

sufficient to avoid overspill in those locations (ie, whether residents may actually use other available

parking close-by, or alternatively whether the location itself prevents overspill), and therefore other

sites’ figures cannot simply be extrapolated to suggest that they will be sufficient to prevent overspill

at St Christopher’s.

However, if comparisons are to be made, it is almost unbelievable that the applicant continues to refer

almost exclusively to comparison sites with such a demonstrably different demographic from their

target market. At the same time, they dismiss out of hand the data from The Vincent and Westbury

Fields which, although not identical to St Christopher’s, are considerably more similar than the

comparison sites they choose to use.

We are sure that the applicant must be aware that most of their affluent target market will be deterred

by being told they cannot bring a car (in fact, they acknowledge in 5.2 that marketing the similarly

priced apartments at The Vincent has been dependent on offering on-site parking). The only potential

reason for their lack of concern must be that they expect to be able to tell potential purchasers that

there is free parking available on the roads surrounding the site.

If the applicant does need help determining the parking needs of their target market, we refer them

to the 2018 ONS dataset referenced in our original statement, which shows that 89% of retired couples

(with private income) own one, two or more cars.

We trust that BCC will continue to consider the fundamental question of the likely levels of car

ownership of residents at St Christophers. Given the key features:

● a target demographic who can afford properties with an average price of £740,000

● primarily 2-bed apartments and houses

● likely large proportion of couples, where only one needs to be over the age of 65

● a location where there is free/unrestricted parking on the surrounding roads

there is obviously a high likelihood that purchasers will choose to keep their cars, on the basis that if

they don’t get an on-site space, they can park close-by. Why wouldn’t they?

1 See Appendix for detailed data and references 2 See Appendix for detailed data and references

Staff Parking

The applicant continues to ignore independent research, seen as reliable by a PINS-selected

independent adviser on retirement living, showing there is an average of 12 hours care per week per

resident in extra care accommodation. They prefer to refer to their minimal requirement of 2 hours

(and imply a maximum average of 4), in the face of all common sense, since a selling point of the

development is the ability to increase the amount of care as the residents’ needs change, up to 24-

hours as required. They also ignore the likely peak hours for care which would result in higher numbers

of staff on site at those times.

Public Visitors to Community Facilities

The applicant still does not consider the parking needs for public visitors, despite promising community

access to a range of on-site facilities, preferring to hope that “most users would walk or cycle”.

Unfortunately local travel patterns show that this is simply not the case, much as we would like it to

be. With no parking on site, visitors to the “Urban Village Hall” and other facilities are most likely to

try to park in the closest place to the entrance on The Glen.

Lack of Capacity on Surrounding Roads

It is now well-established that there is no capacity for the neighbouring roads to safely absorb any

overspill. It is frankly bizarre that the applicant continues to ignore or dismiss all evidence referred to

by the TDM – as well as what must be their own knowledge of the location – relying instead on surveys

undertaken between 10pm and midnight to suggest availability of parking spaces. It is even odder that

they also refer to a separate local survey (undertaken during the 2020 lockdown, in the absence of

commuter traffic) which was submitted as part of a recent appeal, ignore all other related information,

and then consider it valid to use this to draw a completely different conclusion to that reached by

either BCC or PINS.

As noted before, the applicant is ultimately unable to control the three key factors affecting the parking

demand, which are the number of residents wishing to retain cars, the amount of care which residents

will choose to use, and the number of visitors driving to the site. Basing the on-site parking on

optimistic and speculative hopes, such as are peppered through this technical note, as well as on

unrealistic comparisons, would mean that by the time the on-site parking is shown to be insufficient,

it will be too late to increase this, and the neighbouring roads will have to suffer the consequences

indefinitely.

Access

The applicant has still not stated how many on-street parking spaces would need to be removed from

The Glen (or indeed other roads) to implement their plans, worsening the existing parking stresses in

this area. Simply showing an updated road-sweep diagram with the new yellow line and one parked

car (page 12) does not do this (although it does show that a fire engine would hit the parked car, as

well as leaving insufficient room for parked cars on the other side).

They continue to ignore the impact on The Glen of providing the only vehicular access point to the

entire rear of the site, which will encourage its use as a drop-off/pick-up point, as well as for parking

for residents (and their visitors) of the closest blocks.

They dismiss the evidence related to the existing problems in The Glen and Belvedere Road, missing

the point that this demonstrates the challenges already faced by these roads, which the new access

point can only make even worse. It is genuinely disappointing that the applicant has so little concern

about causing detrimental impact to the site’s closest neighbours.

Summary

To recap, we have tried to keep this statement as short as reasonably possible and have therefore not

listed all the detailed issues in the applicant’s Technical Note. We hope it suffices to reiterate that the

applicant has said nothing which adequately addresses either the TDM’s comments or the concerns

raised in our earlier statements, which therefore remain. We have provided evidenced estimates in

our earlier statements showing that, for the proposed number of apartments, at least 126 spaces are

likely to be required to reduce the risk of overspill on to surrounding roads.

We have also raised concerns about the over-concentration of units on site; it should go without saying

that by substantially reducing the number of units the developer would also be able to reduce the

parking demands and the risk of overspill.

Appendix – Comparison sites referred to by the applicant

The following sites were referred to by the applicant in Technical Note 3 and have been checked by us

to identify whether or not they are comparable to St Christophers.

1) Sites referenced in paragraph 5.15 of Technical Statement 3: These are identified on page 20

of the document entitled “Better planning for car ownership and well-being in old age”

produced by Housing Learning & Improvement Network in 2016, and shown in the

corresponding footnote (75) at:

http://planning.northwarks.gov.uk/portal/servlets/AttachmentShowServlet?ImageName=26

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Marigold Court, Gateshead – Housing 21

Willowbank, Cambridge

Cedar Court, South East London – Housing 21

Lonsdale Court, Cumbria – Housing 21

Staveley Court, Bradford – Housing 21

Brookside House - Ash Grange, Liverpool – Housing 21

Hillside Court, Bristol – Housing 21

Fountain Court, Gateshead – Housing 21

Priory Court, Gateshead – Housing 21

Winton Court, Gateshead – Housing 21

Hill View Manor, Knaresborough

Cedar Court, Scarborough

The Orchards, Northallerton

2) Sites referenced in 5.32 and shown on pages 45 – 46 of Technical Statement 3:

BR-03-O-01 Bluebell Gardens, Holloway Road, Bristol – Housing 21

BR-03-O-02 Hillside Court, Meg Thatchers Gardens, Bristol – Housing 21

CB-03-O-01 Woodlands, Bridge Lane, Penrith

KC-03-O-01 Bradstow Court, Rumfields Road, Broadstairs – Housing 21

KC-03-O-02 Joseph Hadlum Court, Eastern Avenue, Ashford – Housing 21

NG-03-O-01 Lark Hill Village, New Rise, Nottingham, Clifton

NS-03-O-01 Diamond Court, Diamond Batch, Weston Super Mare – Housing 21

OX-03-O-01 Stanbridge House, Ruskin Road, Banbury – Housing 21

SC-03-O-01 Mayford Grange, Westfield Road, Woking

TB-03-O-01 St Marychurch Road, Torquay

Information about these sites which is referred to above was found in:

● The Housing 21 website https://www.housing21.org.uk (for those identified as Housing 21)

● Individual websites of other developments

● Website https://housingcare.org

● http://planning.northwarks.gov.uk/portal/servlets/AttachmentShowServlet?ImageName=26

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Dear Madame/Sir,

As a resident of the area concerned, I would like to urge the Committee to reject thedevelopment plans, which are clearly very unpopular, and quite incongruous. The scaleand height of the buildings is far too large. Additionally there needs to be far fewerretirement flats to allow better provision for the special needs school as originallyintended.Thank you for listening and acting accordingly. Yours sincerely,

Dear Sirs, In response to the latest revisions referred to in your email 23/02/2023 pleasenote my comments as follows:I refer to my original objections which still stand - little or no change to the Developer'sProposals confirms the fact that they are still not listening to our concerns or thoseexpressed by neighbours, local residents and the wider community. Many times I havecommented on the 'overlooking', 'over-powering' and 'over-shadowing ' of our propertyfrom every proposed adjacent unit and dwelling. Multiple windows and balconies lookdirectly into our habitable rooms and garden resulting in a complete 'invasion of privacy'.How can this proposal possibly be considered in a conservation area?I refer to the fact that there are no 'eye height sight lines' (ref Drg No 2008 and 2009)shown from the 'Top Floor Juliet Balconies' of villas C and D into our garden. One canonly assume it is not in the Developer's interest because this would add further to theunacceptable 'loss of privacy' created by the heights of these unitsThe revised 'Cross Sectional Drawing' No 2009 rev B, dated 20/02/03 shows the roofheights of 'Cottages H01' higher than the roof of 15 The Glen. We were assured at theconsultation stage that these 'so called cottages' would be no more than single storeywith possible accommodation in the roof. Repeated errors and revisions to drawingsrelevant to the H01 cottages and position of trees etc confirms that the Developerscannot be relied on to present a clear and accurate picture.Yet again I urge you to refuse these outrageous and unacceptable proposals.

I still consider the use of this site for a " Luxury Retirement Village"as

totally inappropriate with such a negative impact in so many ways andwould

hope it can be rejected.

Having received notification of the latest minor amendments to theplans,

I note there has been no mention of any changes in consideration of the

residential amenity of the Royal Albert Road residences adjacent to the

boundary wall at the rear of Grace House.

Grace House was built as a teaching unit and with respect for theresidents

was only used at school times on weekdays, leaving the residentialproperties

with peace and privacy in the evenings and weekends.

Without any restrictions to the glazing of the upper floor rear windowsof

Grace House the Royal Albert Road residences will lose all privacy inthe

properties and gardens.

Also, with the planned construction of all the machinery to serviceGrace House

sited adjacent to the garden walls there will be possible 24 hour noisepollution

(vibration, smell etc).

The result of this plan will result in a totally negative impact on the

residential amenity of these properties which has been enjoyed for 140years.

Thank you for letting me know about the 'revised details' the developers havesubmitted.

These details can be readily summarised by the phrase 'Lipstick on a pig'.

It is not my intention to be unkind to pigs. Rather I use this phrase as it summarises in four wordsall that is wrong with this truly pointless submission from the developers. Lipstick on a pig meansmaking superficial or cosmetic changes to a proposal in a futile effort to disguise its fundamentalfailings. I would emphasise, in this context, the word futile.

On the plus side, by producing these 'revised details', the developers have revealed, for the firsttime in eighteen months, that many of the homes neighbouring the site are located on land that isat a much lower level than the site level. Local citizens were already deeply alarmed by theproposal to build ludicrously large blocks of entirely inappropriate flats in the middle of adesignated Conservation Area. Now they know that the proposals are actually far worse than theyhad previously imagined.

The cross-sections of the site reveal that the buildings proposed would impose an entirelyunacceptable loss of privacy and amenity on residents living in Bayswater Avenue, The Glen,Westbury Park, and Royal Albert Road. These truly massive blocks of flats would tower over localhomes and gardens and do irreversible harm to the local townscape and the historic heritage ofWestbury Park.

The views of Historic England

It is gratifying to record that Historic England, the independent national heritage body set up by theBritish Government to protect the historic environment of England, has noticed how unacceptablethis development proposal is. They have now indicated, for the third time, that the developer'sproposals would be 'harmful' to the Conservation Area as well as to the setting of Grace House,the Grade II listed building, which is a key feature of the site. Their objections to this misguidedproposal were made on: 12/4/22; 19/12/22; and 24/2/23. They could be forgiven for becomingimpatient at having to say the same thing to these developers' time and time again.

Anyone familiar with city planning practice will know that just one message from Historic Englandsaying that a proposal is 'harmful' means the scheme so mentioned is already in deep trouble. Toreceive a second 'harmful' message indicates a startling failure on the part of the developerconcerned to show any understanding of the critical importance of the views expressed by HistoricEngland in decision making relating to planning applications. A third 'harmful' message fromHistoric England (which is very rare) means that, should the developer decide to appeal againstrefusal of planning permission by Bristol City Council, the local authority will be able to explain tothe Planning Inspectorate that the developer has ignored a remarkable 'Three in a row' set ofwarnings from Historic England. This track record, demonstrating an astonishing failure to listen tothe experts charged with caring for the historic environment of England, will mean that a refusal ofpermission by Bristol City Council would be certain to be upheld by the Planning Inspectorate (ifthe developers decide to appeal).

The developers have known how awful the impact of their scheme would be on Westbury Parksince 2021, when their proposals were roundly rejected by residents and other stakeholders atvarious public meetings.

I lend my full support to the objection to the 'revised details' submitted by SCAN.

In closing I would like to offer a few comments on the flawed design philosophy presented by PRPArchitects in the 'revised details' submitted by the developer.

The flawed design philosophy presented by PRP Architects

PRP is the architectural firm working for the FORE Partnership, the developers behind thismisguided planning application. The drawings provided in the 'revised details' have been preparedby PRP. It seems clear that the design work that PRP has done over the last eighteen months onthe St Christopher's School project is so bad that their architectural reputation would now appearto be threatened.

Private Eye, the long-established satirical magazine, has a section called Pseud's Corner in which

they publish examples of pretentious, pseudo-intellectual quotations. It seems clear that the textwritten by PRP Architects in the 'Sketch Elevation Villas A and B - Response to Grace House'(January 2023) presentation would qualify for early publication in this column.

For those unfamiliar with the details, Grace House, a fine Grade II listed building, which lies at theheart of the site, is an impressive example of brutalist architecture. Brutalist buildings, whichemerged in the 1950s (Grace House was built in 1966), are characterised by designs thatshowcase the bare buildings and structural elements - they eschew decorative design anddelicacy.

This seems to have escaped the attention of PRP architects. They open their presentation of'Sketch Elevation Villas A and B - Response to Grace house' by suggesting that their design aimsto respect this fine building as follows: 'A key thought was to translate the "delicacy andfenestration tallness" of the listed building'. (Slide 2)

This is followed by a claim that Villas A and B are designed to 'translate the delicacy of the listedbuilding into key moments of the proposed architecture'. (Slide 3)

This text is clearly well above the 'Private Eye Pseud's Corner' level of nonsense on three counts.

First, Villas A and B are not actually villas at all, they are multi-storey blocks of flats (4 and 5storeys high respectively). The St Christopher's Action Network (SCAN) pointed this out to PRPArchitects in a meeting in November 2021, and it is quite remarkable that they have not revisedtheir drawings to reflect this incontestable statement of fact. The OED defines a villa as: 1) Acountry residence, or 2) A detached or semi-detached house in a residential district.

Astonishingly, PRP Architects continue, without any justification, to falsely claim that the huge andvery bulky blocks of flats that dominate their designs are 'villas'. This is demonstrably not the case,and the continued use of the word 'villa' by PRP Architects is offensive. It represents a clear anddeliberate attempt to mislead people looking at the drawings.

Second, the suggestion that these truly massive and overbearing blocks of flats are designed to'translate the delicacy' of anything at all is utterly ludicrous.

Third, 'moments' are short periods of time, whereas architecture is designed to last for decades.Why PRP refers to 'moments' is for them to explain.

In Slide 5 we are told that the revised elevations that they have prepared create 'a rhythm acrossthe façade and references the bladed fins and recessed brick panels seen on Grace House'. Asthe presentation goes forward the architects become even more detached from reality.

The text on Slide 6 states that their design creates a 'proportional element' that is repeated

between the listed building and the new architecture. This is demonstrably not the case.

The scheme they have proposed envisages startlingly large blocks of dumpy flats slap up againstGrace House, the highly prized Grade II listed building. This proposal is, then, not at all'proportional'. It would destroy entirely the context for this important listed building. This is not justa personal view. Design West (the independent advice service provided by architects and urbandesigners in the South-West) said this more than once in their detailed submissions to thedevelopers.

If the architects really respected this important listed building, they would bring forward proposalsin which every building on this site would be below, possibly well below, the height of GraceHouse.

As the local community has explained, on many occasions, an acceptable scheme for this siteneeds to be landscape-led, and any new buildings need to be subservient to Grace House and thesurrounding 2-storey properties in Westbury Park.

St Christopher's redevelopment plan Westbury Park

My view on this is the same as the majority of objections voiced already re parking,wildlife and the scale of the plans.

I want to add that here in our house on we cannot trim or chop any treedown in either our front or back garden without permission.

This was all to preserve the Downs Conservation Area.

If this development is approved, it beggars belief that we had to do this as a but that a proposed development on this scale is even

being considered. It's breaking all of the rules that have been put in place and enforcedso rigorously over the years to stop exactly this type of proposal.

In response to your recent email, and the revision to some aspects of the proposals:

 We note the minor revision regarding the windows of the so-called “cottages”(houses) along the Bayswater Avenue boundary.

 We note there are factual inaccuracies within the drawings which undermine thecredibility of the rest of the plans - in particular the house numbering is wrongand the indication of the wall heights on the boundary are misrepresented.

 We highlight in particular the fact that only one of the proposed row of fourhouses facing the rear gardens on Bayswater Avenue has the adjusted windowangle and another has had a first floor window removed.

 While we welcome these changes on behalf of our neighbours, we also see thisas an admission that these two end houses are way too close to neighbouringproperties in the first place, if such measures are needed.

 We also note that the change of the angled window actually results in increasedoverlooking

- see screenshots of images below. In all, the windows on three ofthe four houses in this row will

 We note while the window aspects of the houses facing numberhave been amended/removed, the remaining windows on two of the

houses Considering the distances between the proposed houses and both

are equal, it's confusing why only certainwindows in the row of houses have been removed or angled. They have all beenadjusted on the side facing block B to reflect the extreme proximity on thatwestern side.

See screenshot below:

 We maintain that even minor adjustments like angled (or evenobscured/removed) windows still fail to deal with the unacceptableproximity between the proposed houses Ifsuch measures as angling/obscuring or removing first floor windows are needed,then this is a clear indication and acknowledgement that the houses along thisboundary wall are unacceptably close in the first place. Also no amount ofangling or removal of windows improves the shadowing impact which remainsunacceptable, particularly bearing in mind the ground level height difference andthe effective 3 storey height (when considered also with pitched roof) of theproposed houses.

We conclude that not only does the proximity of these proposed houses and their remain unacceptable,

but that these minor adjustments fail to deal with the fundamental problems ofthis application as previously mentioned in our earlier objections.

These proposals continue to be an excessive, insensitive and inappropriateoverdevelopment of the entire site that will cause significant harm by failing toprotect & respect the site's unique environment, heritage and SEND legacy.

Therefore, we strongly object to these proposals.

Please confirm receipt of this email.

Finally, we would like to thank Paul Chick for his recent visit to our property and fortaking the time and effort to understand the geography of the site.

With grateful thanks

detailed wording of the reasons for refusal would become central to the PlanningInspectorate’s consideration of this planning application. It is essential that the reasons ofrefusal ensure that any appeal would be doomed to failure.

We thank you for considering the points raised above.

Sincerely,

The team at SCAN

The recent revisions to this planning application are trivial and irrelevant. This feels verymuch like an 'abuse of process' with minor alterations that in no way address the issues raised bythe public and local community in the huge number of objections submitted. Such revisions in noway negate my previous two objections primarily on the basis of size, scale, height, character,traffic and parking, loss of mature trees, biodiversity and loss of SEND provision. This applicationshould be refused and refused in such a way that appeal is pointless.

The changes details in these revised proposals are minimal and have not in any wayaddressed the concerns and objections detailed in the huge numbers of public objections. I sharethe views recently submitted by SCAN.

The comments we submit are necessarily focused on how the developmentwill directly affect us and are therefore somewhat negative in tone. However,as an introduction we appreciate the site needs to be redeveloped andsupport this in principle. While we therefore support the retention andconversion of the Westbury Park villas; the retention and conversion of thelisted Grace House and the opportunity that presents itself for somedemolition and new building this must be undertaken with due respect to thecharacter and appearance of the Conservation Area and the area moregenerally and the character and setting of Grace House; involve the retention(and safeguarding) of all important trees (whether the subject of a currentTPO or not) and must cause no harm to, and potentially improve, theresidential amenity of all local residents.

Within this context our first substantive comment is that the informationdisplayed at the consultation event was to a large extent indicative andtherefore vague. While the proposals have positively developed since theinitial consultation and no doubt will develop further it was genuinely difficult tounderstand what the key elements of the current proposal were. While thoseconsultants at the event, presenting on behalf of the developers wherehelpful, some questions could not be answered definitively and some left keyissues unresolved.

In the above context, our view is that describing the development as an“integrated retirement community” is vague and does not hide the fact thatwhat is proposed is simply a residential re-development. Alongside this therewas of course no reference to on-site affordable housing provision. At thisstage and while the price and management costs of the eventualaccommodation and services may dictate who can afford to live at the site, weassume that the City Council will insist on the provision of a substantialproportion of affordable housing. We also assume that as the site was boughton the open market with full knowledge of the physical and planning policycontext that no credible viability argument could be mounted against theprovision of a policy compliant percentage and mix of affordable housing. Indue course we would therefore be very interested in the form and location ofthis on the site.

The quantum of development was also unclear on the presentation boardsalthough we were separately advised that the total development was 120units (25 via conversion and 95 via new build) with “approximately” 65 parkingspaces. Also, apart from via two indicative and unscaled sections, there wasvery little detail on the scale of the buildings and their external appearance.The relevant boards looked like they had subsequently been marked in penwith storey heights noted as ranging from 4-6 storeys with 2 storey “cottages”and the conversion of the existing Villas. The nature of the use and thequantum and mix of development obviously also affects car parking and againit was unclear, with the use class undefined, how the “approximately” 65parking spaces referred to were derived. Also, the issue of public access wasalso somewhat unclear. While we support the public (or bookable) use of anyfacilities to be provided within Grace House we object to any east – westpublic vehicular or pedestrian through route, which would have the potential toadversely impact our residential amenity. Consequently, we object to theretention and upgrading of the existing access to Etloe Road / BayswaterAvenue and request that this be permanently abandoned / appropriatelyclosed.

All my previous comment and objections remain and these are additional commentsrelated to the letter I recieved notifying me of revised details, dated 23 February 2023The new information on site cross sections in drawing number 2009 ( 3403944 ) show what wasfeared but conveniently not shown in earlier site cross sections, 2009 (3357517). Due to gradientsacross the site, the proposed cottages H01 and H02 are a further 2m higher than the initialdrawings suggested, than the houses in the Glen and in Bayswater Avenue. The impact fromoverlooking of our property from the even the supposedly low build cottages is much worse thanpreviously expected.Site section 2006 (3404270) 20/2/23 revision B - The comment about a tree incorrectly obscuringthe roofline of the HO1 cottages relates to a tree that is situated behind the cottages but shows thelower edge of the canopy partially obscuring the roof line of the cottage, when the cottage is notactually situated under the canopy of the tree, hence misleading. The reply from the developer thatthere are proposed trees which would achieve this effect at maturity is incorrect.The site section 2006 still shows a large tree (twice the height of the house) behind 15 The Glenthat partially obscures the cottages. The reply from the developer that there are 'mature treesbeyond' that obscure the cottages is incorrect, as the tree must be situated between 15 the Glenand the cottages to partially obscure the cottages.Small corrections to the many errors in the drawings and adding a few privacy screens to buildingsthat are way out of proportion with the location is a massive under appreciation of the negativeimpact on a conservation area of the proposed buildings. This recently disclosed information thatthe buildings will be relatively 2 m higher than the plans suggested is unacceptable. The visualimpact assessment section 10.8 already says the impact of the taller buildings is Moderate to

Moderate Substantial (adverse). I am concerned the lack of detail in the information supplied ishiding many other undesirable features of this development as regards the immediate neighbours,so I urge the planning officers to reject this opportunist proposal.

I note the latest changes by the developers, dated 21/22 Feb 2023.I feel these latest changes are only tweaks at the edges of a totally inappropriate suggestion forthe site. My previous objections still stand. These were on the grounds of:- Inappropriate overdevelopment of the site- Proposed buildings over-dominant to those around them- Insensitivity to the historic surroundings of the Westbury Park area and the Downs Conservationarea

- Loss of mature trees- Insufficient parking provision- Extra traffic congestion and road safety issues on surrounding roads- Privacy issues for neighbours.

SJ

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:I note the latest changes by the developers, dated 21/22 Feb 2023.

I feel these latest changes are only tweaks at the edges of a totally inappropriate suggestion for

the site. My previous objections still stand. These were on the grounds of:

- Inappropriate overdevelopment of the site

- Proposed buildings over-dominant to those around them

- Insensitivity to the historic surroundings of the Westbury Park area and the Downs Conservation

area

- Loss of mature trees

- Insufficient parking provision

- Extra traffic congestion and road safety issues on surrounding roads

- Privacy issues for neighbours.

I have checked the recent revised application as it has very little changed since I firstvoiced my objections on the grounds of overdevelop site buildings, too high, not inkeeping with the surrounding area so my objection still stands on all of the above.

The minor changes to the plans do nothing to address my concerns about thedevelopment.I reiterate: lack of parking, traffic congestion, damage to trees, privacy issues, lack of affordablehousing .Bristol and the whole country is crying out for accommodation for mentally challenged people forwhich this site has proved ideal.The council should heed the objections.Sincerely,Gillian NadenMarch 2nd 2023

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:The minor changes to the plans do nothing to address my concerns about the

development.

I reiterate: lack of parking, traffic congestion, damage to trees, privacy issues, lack of affordable

housing .

Bristol and the whole country is crying out for accommodation for mentally challenged people for

which this site has proved ideal.

The council should heed the objections.

Sincerely,

March 2nd 2023

I have received an a mail concerning further minor amendments to the plans. Theseonly seem to impact on those directly overlooked. It is worrying that they indicate previous planswere inaccurate.My comments remain unchanged

Proposed St. Christopher's Square DevelopmentFurther Submission by Westbury Park Community Association

I am making this further objection on behalf of Westbury Park Community Association in responseto the note produced by KTC Transport Consultants and posted on the Planning Portal on 10thFebruary as "TECHNICAL NOTE 2.0 - HIGHWAY INFORMATION".

The technical note comprises a further assessment of (i) resident parking needs, drawing on apaper written by Churchill Retirement Living and (ii) staff levels and staff parking requirements.

We note that there is still no attempt by the transport consultants to assess the parking needs ofvisitors, an oversight that we pointed out in our previous submissions. We estimated that between12 and 15 spaces would be required for visitors in addition to spaces required for residents andstaff.

Turning to the information and arguments set out in the technical note :-

Resident ParkingThe applicant's revised Transport Statement submitted in December 2022 included reference toparking provision in a number of independent living schemes elsewhere in England in an attemptto demonstrate that the 65 spaces provision at St. Christopher's was sufficient to meet parkingspace requirements. We researched each of the four schemes referenced and found so many

basic differences between them and the St. Christopher's scheme as to make the comparisonsmeaningless. Once again we are having to query a new argument made on behalf of the applicantrelating to parking requirements, this time drawing on a paper produced by Churchill RetirementLiving in 2012.

As the paper produced by Churchill Retirement Living is nine years old it seems that the transportconsultant acting for the applicant has had to search long and hard to find any supportingevidence of low parking provision in an independent living scheme.

The Churchill paper maintained that a third of residents owned a vehicle at the time of initialoccupation: applying this ratio to the St. Christopher's scheme the transport consultant argues thatthe scheme would require 39 spaces for residents.

We believe that using the Churchill Retirement Living paper as a guide to assessing parkingrequirements at St. Christopher's is unsound for a number of reasons. In a random search ofretirement properties managed by Churchill Retirement Living we found that:-

(i) The actual ratio of parking spaces reserved for residents as a proportion of total units was not0.33 but grouped around the 0.5 mark. Applying this ratio to St. Christophers would mean that 58spaces would be required just for residents.

(ii) Most of the researched schemes were in locations where there is likely to be on-street parkingavailable nearby for staff, visitors and residents - this is clearly not the case with St. Christopher's.

(iii) The Churchill schemes comprised a much higher of one bed units (60%-70%) than isproposed at St. Christopher's (9%) so that occupancy rates per unit would be significantly higherat St. Christopher's. More residents per unit average will mean higher car owners and a higherneed for parking spaces compared with the Churchill Retirement schemes.

Staff LevelsThe technical note acknowledges that the staff levels indicated in the technical note aresignificantly higher than those stated in the Transport Statement (which raises questions about thecredibility of the Transport Statement). It is re-assuring that this new technical note accepts that upto 23 spaces will be required for staff - a figure broadly in line with the estimate made in thesubmission on parking made by the Community Association in April 2022 (see below).

ConclusionWe estimated in our April 2022 objection on the original proposals that the site parkingrequirement will be of the order of between 86 and 101 with residents requiring at least 58 spaces(a 50% requirement), staff requiring between 16 - 22 spaces and visitors requiring 12 - 15 spaces.The information set out in the technical note regarding staff levels / parking requirements and theresearch we have conducted on resident parking spaces provided in Churchill Retirement Living

schemes suggests that our parking estimates for the proposed St. Christopher's scheme aresound. Our figures also include visitor parking estimates which the applicant has still not attemptedto provide.

We therefore continue to object to the application on the grounds that the proposed on site parkingprovision will be inadequate and will result in overspill parking in surrounding roads that arealready at full parking capacity.

3. The Churchill recommendations only claim to relate to their own sites, which have different

location criteria from St Christophers:

• The paper refers to a number of essential criteria for their sites, not all of which apply to the

St Christophers site (eg the need to be located within half a mile of the town centre or close

to GPs and other healthcare facilities, neither of which apply to St Christophers);

• Churchill’s own planning applications show that they choose locations where other parking is

also available close-by to pick up any overspill. For example, in the submitted Planning

Statements for both Trewin Lodge (Yate) and Riverain Lodge (Taunton), it is stated:

o 6.42: The provision of [29/37] parking spaces for the retirement housing is considered

to be appropriate given the location of the site and its proximity to alternative

parking facilities;

• This condition is not true of the St Christophers location, which is surrounded by heavily over-

subscribed residential parking; if residents who do not get an on-site space choose to leave

their cars on the surrounding roads, it will severely increase the existing over-demand, and

resulting road safety issues, in the locality.

4. The Churchill paper’s suggested ratio of parking spaces to units is not actually applied to their own

sites, demonstrating even Churchill’s knowledge that this is insufficient for most developments.

In fact, if Churchill’s actual data is extrapolated to the St Christophers site (once adjusted for the

different split of 1- and 2-bedroomed apartments), this would result in 82 spaces being required

for St Christophers rather than the 39 presented in the Technical Note:

• The following table shows just a few of the Churchill developments, where the parking spaces

per unit is significantly more than the paper suggests:

Development Year of opening

No of units Parking Spaces

Parking spaces per unit

Riverain Lodge Taunton 2022 72 37 0.52

Edinburgh Lodge Orpington 2022 27 14 0.52

Lord Roseberry Lodge Epsom 2011 31 16 0.52

Trewin Lodge Yate 2019 62 29 0.47

Mulberry Lodge Emsworth 2010 30 14 0.47

Park View Lodge Faversham 2007 36 17 0.47

• Furthermore, as explained in paragraph 2, the number of residents (and hence cars) is more

closely related to the number of bedrooms than the number of units. The following table

shows the ratio of parking spaces per bedroom at Churchill sites (calculated for those of the

above sites where the split between 1- and 2-bed apartments is publicly available):

Development Parking Spaces

No of 1-bed No of 2-bed

No of bedrooms

Parking spaces per bedroom

Riverain Lodge 37 46 26 98 0.37

Trewin Lodge 29 42 20 84 0.34

Edinburgh Lodge 14 17 10 37 0.38

• St Christophers contains 105 2-bedroom and 11 1-bedroom apartments, totalling 221

bedrooms. Applying the median 0.37 spaces per bedroom to St Christophers would result in

82 parking spaces being provided for residents parking, considerably more than the 39 the

applicant suggests;

• However, for the reasons given in paragraphs 2 and 3 above, more spaces would still be

required for St Christophers than the 82 indicated by a simple extrapolation from the Churchill

data; ie, the different demographics of the residents, and the constraints of the St

Christophers location, would require a higher level of parking provision than at the above

Churchill locations, in order to avoid relying on overflow parking in surrounding streets.

5. The above points demonstrate that the applicant has still not provided any recent, reliable or

independent research indicating the actual parking needs of residents, but is simply relying on

unvalidated and uncomparable claims made by a similar private developer 10 years ago.

On the contrary, the figures provided by SCAN (including 88 spaces for residents and their visitors)

were based on data provided by the Office for National Statistics in 2018 (see section 1.3.1 of

“Objection from SCAN on Highway Grounds”).

6. We are grateful that the applicant has now provided more detail of their staffing requirements.

However, their day-time staff figures indicate only 10-12 staff for care/wellness (with 2 -4 at

night), which is almost certainly too low to provide the likely levels of care.

• This figure includes “a clinical manager, wellness manager, RGNs, physios, carers etc”.

Excluding the two management roles, this suggests a maximum of 10 personal-care related

staff on site during the day and 4 at night. This would provide a maximum of 1,344 hours of

care per week;

• The number of residents is estimated as at least 174 (based on at least 50% of the flats being

occupied by two people). Therefore the number of care staff suggested by the applicant would

provide (at maximum) 7.7 hours of care per resident per week.

• It is not clear how the applicant has determined this figure, and it should be noted that this is

not in their control, as residents are obviously entitled to ask for as much care as they need.

However, SCAN provided independent research (which has also been used by PINS for

determining Appeal Ref: APP/F0114/W/21/3268794) showing that “any extra care housing

scheme for older people should be based on an average of 12 hours per resident of care and

support per week” which would require a total of at least 2,088 care hours per week.

• Furthermore, care needs are not spread evenly across the day-time hours – there are peak

demands in the morning and evening hours for assisting people to get up and prepare for bed.

Allowing for this, and a lower presence over-night, would suggest an estimated 29 carers on

site during peak hours – 19 more than suggested by the applicant. (See SCAN’s statement

“Objection from SCAN on Highway Grounds” for further information on how our figure was

calculated.)

7. The Technical Note also omits to refer to any other parking needs for the site:

• The applicant is still ignoring the parking needs for visitors to the Urban Village Hall and other

facilities which they are promoting as available for public use;

• The applicant has previously also referred to 3 spaces being required for car-club cars and the

mini-bus, which they have made no allowance for in the Technical Note.

Conclusions and Updated Estimates

For the above reasons, SCAN maintains that the proposed on-site parking allowance of 65 spaces is

demonstrably insufficient for all needs.

In our statement “Objection from SCAN on Highway Grounds” we suggested a minimum parking

requirement of 115 spaces.

In the previous absence of detailed staffing information from the applicant, this figure was based on

an estimate of only 8 non-care related staff being on site during day-time hours. However, the

Technical Note now shows that there will be up to 25 non-care related staff on site during day-time

hours, leading to a total of 54 staff on-site during peak hours.

We also appreciate the applicant providing census data showing 57% of residents travelling to work

by car. We did not previously have access to this, so had under-estimated this proportion at 50%.

Adjusting our own estimating basis to take account of this further information means the requirement

for staff parking spaces increases from 19 to 30, leading to an updated total requirement of at least

126 parking spaces.

We maintain that this is a reasonable minimum for the site and trust that Bristol City Council will

recognise that the applicant’s estimates are not reliable, by taking full consideration of the information

provided in this and our earlier full statement “Objection from SCAN on Highway Grounds”,

emphasising that this is all based on independent and verifiable research.

It should be recognised that parking needs are largely driven by factors which are outside the

applicant’s control – ie, the number of residents choosing to keep their cars and the amount of care

which the residents will require. If these increase above the applicant’s hopeful estimates, there will

be unpreventable overspill on to surrounding roads, which demonstrably cannot safely absorb this.

By the time this is proved to be the case, it will be too late to force the applicant to address the issue

by adding more parking.

It is therefore essential not to under-estimate the parking needs at this stage, by accepting over-

optimistic estimates provided by private developers, who have an interest in minimising the

development space lost to on-site parking, leaving the local residents to suffer the future

consequences.

I would like to voice some serious concerns regarding the proposed redevelopment ofSt Christopher's School site Westbury Park.I manage Jonathan House, 19 Bayswater Avenue which is a Freeways residential house for 7adults with a learning disability. Our small back garden has a very tall stone boundary wall whichforms the gable end wall to one of the St Christopher's buildings (North House). My concerns are:During the construction phase the individuals we support will be negatively impacted by noise anddisruption of building work to the garden wall, which will impact for several months/years. It is likelythat the wall will need to be rebuilt and/or adapted to accommodate the new build which couldmean the loss of the use of some/ most of our small garden. The garden is in constant usethroughout the year therefore the impact will be significant and negative on their wellbeing. Someof the individuals who live at Jonathan house are very noise sensitive and at times find living nextto a school difficult therefore additional noise from the extensive building work will worsen thissituation.After the construction phase the height of the new buildings will impact on the quality of life for theresidents at Jonathan House - we are presently not over looked and therefore enjoy privacy andseclusion which is suitable for its purpose. I feel that the proposed height of the new building willhave a significant and detrimental effect our resident's livesFreeways, to date, has not had any contact from the property developers to explain any possibleimpact to the garden wall given the garden wall is covered by Party Wall Act.

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• The proposal included no affordable housing and was not supported by an unredacted Viability Appraisal to justify such lack of provision, which is contrary to the adopted Development Plan.

The stated reasoning for the lack of provision was not consistent with adopted policies or adopted supplementary planning guidance.

AMENDED PACKAGE AND SCHEME CHANGES

Following the feedback received during the formal consultation period, on the 1st December 2023, a revised application package of amended plans, supporting documents and information has been submitted by the FORE Partnership (and their associates) for the development of the site. A summary of the main changes is provided below:

• A reduction in the number of units proposed from 122 (as submitted) to 116 units, by virtue of the removal of 6 proposed units, as described below;

• A reduction in the height of villa B from 6 storeys to 5 storeys, resulting in a net loss of 5 proposed units, and lowering all villa height by 300m;

• Minor changes to the footprint and positioning (in some cases) of villas A, B, C and D;

• Replacing the 2 most northerly cottages toward the north east corner of the site with one single storey unit, resulting in the net loss of 1 proposed unit;

• Amending the façade treatment of proposed villas to reduce the visual bulk of the mansard roofs, using red brick rather than of buff, and revised window designs;

• A re-design of the landscape proposals increasing the amount of soft landscaping, particularly around Grace House;

• Removing the proposed spa extension to Grace House and relocating it along the north site boundary; and

• Maintain the current arrangement of the access from Etloe Road as serving the Western Power Distribution substation only, and instead proposing limited parking accessible via The Glen.

Unfortunately, the revised application package is still considered to be an inadequate response to the significant concerns raised over the original scheme and fails to amount to any measurable improvement. Given the extraordinary level of opposition to the original application, submitted in March 2022 and a lengthy PPA process, it is disappointing to discover that the changes the developers now propose are so modest.

The revised application demonstrates an unwillingness on the part of the developers to respond positively to the concerns that have been set out in over 620 objections to the original planning application. Since the submission of the revised application, the number of objections has risen to 1254. In percentage terms this amounts to 97.4% of all public comments with just 1.3% in support and 1.3% neutral.

Furthermore, the revised proposals continue to directly conflict with a significant number of adopted and long-established Bristol City Council (BCC) planning policies. The SCAN Group therefore maintain their strong objection to the proposal for the reasons outlined in the following sections.

IMPACT ON HERITAGE ASSETS

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S66 of Planning (Listed Buildings and Conservation Areas) Act 1990 prescribes a general duty on Local Planning Authorities in the exercise of their planning functions regarding listed buildings. ‘Special regard’ must be paid to the desirability of preserving a listed building or its setting or any features of special architectural or historic interest which it possesses.

Similarly, S72 prescribes a general duty in respect of Conservation Areas, which are also designated heritage assets. ‘In this instance, legislation requires that “special attention” should be paid to the desirability of preserving or enhancing the character or appearance of that area’.

These legislative requirements are mandatory, not discretionary. The Local Planning Authority has a statutory duty to pay special attention and regard to preserving or enhancing heritage assets within an application for development.

For clarity, the Case Law referenced in SCAN’s initial objection letter has been replicated below. This is relevant in identifying the importance of heritage considerations and provides an interpretation of how the duties should be applied. In particular:

Barnwell Manor Wind Energy Ltd v E.Northants DC, English Heritage, National Trust & SSCLG [2014] EWCA Civ 137

The judgment in Barnwell Manor emphasised that “there is a need to give considerable importance and weight to any harm…when carrying out the planning balance”.

R (on the application of) Forge Field Society & Others v Sevenoaks DC & Interested Parties [2014] EWHC 1895 (Admin)

Forge Fields reiterated Barnwell Manor’s approach, finding that the statutory duty imposed under section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 to have special regard to the desirability of preserving listed buildings and their settings requires that ‘considerable weight’ must be accorded to any harm to listed buildings or their settings. The judgment concluded:

‘The presumption is a statutory one. It is not irrebuttable. It can be outweighed by material considerations powerful enough to do so. But an authority can only properly strike the right balance between harm to a heritage asset on the one hand and planning benefits on the other if it is conscious of the statutory presumption in favour of preservation…’

Therefore, it is incumbent upon the Local Planning Authority to afford considerable importance and weight to heritage impacts when considering the applications at St. Christopher’s.

As part of the revised application package, Heritage & Planning Statement Addendum’s have been submitted, providing an overview of the revised scheme. Whilst the Addendum Heritage Assessment notes that the revised scheme is improved and results in less heritage harm overall, the same overall conclusion is maintained that the proposed development will result in ‘less than substantial harm’, at the lower end of the spectrum, to the grade II Listed Grace House and ‘no harm’ to the overall significance of the Downs Conservation Area.

The addendum notes that it is important to recognise the extent of this harm has been reduced, identifying a number of improvements compared to the originally submitted scheme. The Planning Statement Addendum maintains that approach to how the planning balance should be undertaken, set out in paragraphs 8.1 to 8.7 of the original Planning Statement remains appropriate.

In essence it is the applicant’s claim that the public benefits set out in paragraphs 8.8 of the original Planning Statement will all remain, but the heritage harm of the revised proposals is reduced, and, accordingly, the public benefits are now considered to outweigh the heritage harm. This conclusion is contended by SCAN, as explained below.

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Harm to Downs Conservation Area

Section 72(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 (the 1990 Act) requires special attention to be paid to the desirability of preserving or enhancing the character or appearance of conservation areas.

The revised application reduces the number of new housing units from 122 to 116. This amounts to a 5% reduction, a minor adjustment, one that does almost nothing to respond to the hundreds of objections stating that the scale, massing, and height of the proposed blocks of flats are entirely out of keeping with the scale and form of the adjacent, largely 2-storey, housing of Westbury Park.

Furthermore, only one block has been reduced by a single-storey, and one other by merely 300mm (the height of a ruler and almost indiscernible). Four large blocks of flats up to five stories high will remain which, along with the houses on site, are too close together, too close to neighbouring properties, and completely out of character with the Conservation Area, dominating nearby two-storey homes and stifling the Grade II Listed Grace House that lies at the heart of the site.

Such significant proposals and change to the Conservation Area cannot reasonably be considered as ‘no harm’.

It is far closer to substantial harm. Most of the other proposed revisions consist of minor cosmetic changes to the external envelopes of the proposed blocks, including slight adjustments to façade colour, design and fenestration, having little impact on the scale of the scheme, which will still dominate the site.

The LPA asked for a ‘landscape-led’ scheme; however, it is clear upon review of the revised Landscaping Plan that large apartment blocks and houses still dominate the site, leaving minimal green space, with any discernible change to landscaping and greenery a result of tinkering around the edges of the site.

Whilst these revisions to the proposal can be considered slightly positive in nature, they do not reduce the heritage harm caused to a remotely justifiable level. It is self-evident that the scheme remains overwhelming, overbearing and densely populated, and that the distinctive character of the local townscape would be very seriously and permanently damaged if this revised scheme were to be permitted.

Historic England objected to the original planning application on precisely the same grounds as the ones set out by SCAN. In their formal objection (submitted on 12/4/22) they also drew attention to Section 72(1) of the 1990 Act and stated that the proposals do not preserve or enhance the character of the Downs Conservation Area:

‘This is a high-density scheme that we consider to be harmful to the character and appearance of the Conservation Area. We believe that the site is capable of being redeveloped in a manner that responds positively to the setting of Grace House, while delivering a layout, massing and design that is clearly more contextual than that currently proposed’ (Historic England objection, 12/4/22 p.3).

In their comments on the revised planning application (submitted on 22/12/22) Historic England indicate that the concerns they expressed relating to the original application have not been adequately addressed. In short, Historic England continues to take the view that this revised scheme will be harmful to the character and appearance of the Conservation Area. This clear professional guidance from the national authority responsible for protecting the historic environment of England, suggests that BCC should reject this planning application summarily.

As stated in Michael Gove’s (SoS) recent open letter to Council’s on December 5th 2022, ‘local authorities will not be expected to build developments at densities that would be wholly out of

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character with existing areas or which would lead to a significant change of character, for example new blocks of high rise flats which are entirely inappropriate in low-rise neighbourhood’.

Fundamentally, because the revised planning application continues to envisage an entirely unacceptable level of over development of this sensitive site, it would not ‘preserve’ or ‘enhance’ the character of the Downs Conservation Area at all. On the contrary it would do irreversible harm, for which no reasonable justification has been provided.

Again, and notwithstanding the above position, SCAN consider that ‘less than substantial harm’ is at a higher degree than as stated within the submission, principally due to the quantity, height, mass, and bulk of new buildings proposed in the Conservation Area, which will be an intrusive and unwelcome addition to the built fabric within The Downs Conservation Area. On this basis, the level of justification required, in accordance with NPPF 200, is at an even higher scale than what is already absent from the application.

Harm to Listed Buildings

Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 prescribes a duty on local planning authorities in the exercise of their planning functions regarding listed buildings. This requires planning authorities to pay ‘special regard’ to the desirability of preserving a listed building or its setting.

BCC’s Conservation and Urban Design Officers were extremely critical of the original scheme. In their statement (dated 24/2/22) they concluded that: ‘…the building scale, form, massing, grain and landscape of the proposed development indicates the current proposals are unacceptable in their current form’.

Given that the revised planning application is very similar indeed in building scale, form, and massing to the original application, it is reasonable to expect that the BCC Conservation and Urban Design are likely to conclude that the revised application remains unacceptable, as per the as the original application.

As previously stated, Historic England considers this high-density scheme ‘to be harmful to the character and appearance of the Conservation Area’. They point out that the excessive density of the proposals will have a damaging impact on the heritage assets of the site.

The impact of this scheme on Grace House, a Grade II listed building, should be highlighted as it continues to be entirely unacceptable. Visualisations of the impact of this proposal on the setting of Grace House, provided by SCAN, show, and this fact cannot be contested, that if this scheme is permitted, Grace House will be surrounded by tall blocks of flats, including one 5-storeys high, that are unreasonably close to the heritage asset.

Whilst the revised planning application makes some minor adjustments to improve the setting of Grace House, such as the removal of the spa extension, the adjacent blocks will still dominate the 2/3 storey Listed Building of St. Christopher’s causing irreversible harm to the building itself, its setting and significance - NPPF para 199 and 200 show any harm should be afforded great weight.

It is clear upon review of the revised application package that, whilst the Heritage Addendum has provided a response to the numerous concerns raised through consultee responses, the fundamental issues of height, mass, bulk and proximity highlighted have not been addressed. There remains no satisfactory assessment of the impact of such large blocks of flats set in close proximity to the listed building.

Accordingly, SCAN consider that the proposals will cause ‘less than substantial harm’, towards the upper end of the spectrum of this classification. The revised planning application shows no understanding, at all, of the importance of protecting the heritage assets of this remarkable site.

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This fundamental weakness, in and of itself, provides grounds for the outright rejection of this planning application.

The term ‘less than substantial harm’, derives from the NPPF and does not indicate that such harm is of low importance. Quite the reverse is true, as explained in case law identified above, which is reflected within NPPF para 199.

In Paragraph 18 of the Heritage Addendum, in responding to the comments received from BCC Conservation Officer’s the applicant recognises the ‘Barnwell’ decision in that the finding of harm to a designated asset gives rise to a strong presumption against the granting of planning permission, further referencing ‘Forge Fields’ in that: “The presumption is a statutory one. It is not irrebuttable. It can be outweighed by material considerations powerful enough to do so”. It is clear in this instance, that the harm caused to the heritage assets is far greater than that stated by the applicant, and not outweighed by any material considerations powerful enough to do so.

In conclusion, the proposals are clearly contrary to Policies BCS22 and DM31. The proposal will result in an unacceptable level of heritage harm to designated heritage assets, which has not been adequately justified, which do not conserve or enhance the assets themselves nor their settings.

LOSS OF SEND SCHOOL PROVISION

At the moment there are no replacement school places on site to make up for the loss of the vital community asset. The Planning Statement Addendum notes that work is ongoing to investigate the feasibility to make space within the development available for the provision of SEND spaces, however, this vague offer amounts to the possible occasional and shared use of a room within what is described as an ‘Urban Village Hall’.

Expert Advice received has informed SCAN that this arrangement would not work from a safeguarding perspective and is not the significant SEND provision which Bristol desperately needs, undermining the legacy of St. Christopher’s which served the city’s vulnerable children for more than 70 years. It should be noted that the current lawful use of this land is, then, as a school for children with special educational needs.

Bristol City Council explained this background to the applicant in 2021 and, in formal Pre-Application guidance provided to the applicant (8/11/21), the council stated that there would be ‘a need for an ongoing Education/Community use of this site’ for special education needs. The BCC guidance went on to state:

‘As the site was formerly in educational use, it will be essential for you to fully explore the potential for SEND provision in your proposals’.

The applicant has completely failed to respond to this formal demand from the city council. The developer has, instead, set aside this clear guidance and attempted to argue, in the face of abundant evidence to the contrary, that there is no need for any SEND provision on this site. They arranged for a planning consultant, based in London, to write a report to justify this claim. Upon examination this report was roundly criticised by the Council’s Specialist Places Team (See Jessica Taylor letter attached), who highlighted numerous significant flaws in the data presented, emphasising that the findings of the report could not be used with any certainty.

In practice, there is a very serious and evidenced shortfall in provision within Bristol. The level of SEND need within Bristol has increased by 16% within the last year, compared to 10% nationally and 6% within neighbouring planning authorities. Bristol City Council readily acknowledges this under provision, with councillors at a recent cabinet meeting (06/12/22) deciding to approve a tender process for an education provider to deliver 30 SEND placements for children with complex needs (to be delivered by an INMSS - independent and non-maintained special school) at a cost of £10m+.

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It is unclear, however, whether these placements are intended to be residential or day care, with many children previously attending St. Christopher’s requiring around the clock residential care. SCAN are of the understanding that currently there is no remaining residential care for children with complex special needs within Bristol. The below extract from the meeting demonstrates the severity of the existing situation, highlighting the need to provide SEND spaces to young people in Bristol who currently have ‘no other offer’:

‘Whilst it is understood that it is proposed to bring children who are already receiving education, outside of Bristol back into the area and that it may reduce more costly out of 7 area spend on alternative provision, it is also offer school places to some young people who have no other offer. On this basis this may not substitute existing spend and there is a risk additional cost pressures on the High Needs Block. This contract will therefore need to substitute existing high needs spending or will create an additional further budget pressure on £10.5m.’

The growing SEND demand, specifically that of the ‘High Needs’ children previously served by St. Christophers, is further evidenced by the increased allocation (10% increase) to ‘High Needs’ block funding at the last Bristol Schools Forum Meeting (29/12/22). Despite this additional funding, the High Needs block continues to be under significant pressure, with the current spending levels in 2022/2023 indicating the increased allocation in 2023/2034 will not cover current year forecast shortfalls and will not provide any additional funding for historic deficits. The same document from the Bristol Schools Forum Meeting advocates a target of 450 additional SEND places in Bristol by 2024.

The current situation is such that, as revealed in the Bristol Post (18/01/23), the Government has ordered Bristol City Council to fix its “fractured relationship” with parents of children with special educational needs (SEND). City Hall bosses are finalising an “accelerated progress plan”, which needs to be submitted to the Department for Education (DfE) by February 1st (2023), following a re-inspection by Ofsted and the Care Quality Commission (CQC) in October.

(https://www.bristolpost.co.uk/news/bristol-news/government-orders-bristol-city-council-8042842)

In the revised planning application, the applicant claims to be providing space, in a so-called ‘Urban Village Hall’, to be used by local children, ‘including those with special education needs’. This suggestion has not been agreed or discussed with Westbury Park Primary School, who have made it clear that such an offer would not be feasible on safeguarding or health & safety grounds. Whilst it may have been discussed with specialist education experts at Bristol City Council, as demonstrated in the accompanying email by Jessica Taylor (Council’s Specialist Places Team), there is still variance between BCC and the applicant in regard to SEND provision.

Simply put, no formal offer has materialised or more importantly been agreed upon, yet the above proposal is included in the revised planning application to give the false impression that, in relation to SEND needs, the applicant has listened to the council. In practice, this proposal is hollow.

SCAN has conducted an analysis of the 630 objections submitted to the original planning application. This analysis shows that 132 (21%) of the objections complain about the absence of provision for SEND children. Given that the original planning application did not refer to SEND at all, these 132 objections show that many people in Bristol have a very high level of awareness of the important role this site can play in meeting the needs of Bristol children with disabilities. It is disappointing that the FORE partnership (and their associates) has chosen to ignore the major public policy concern relating to SEND provision in Bristol.

Ultimately, the applicant has still not demonstrated that there is no longer a need to provide a SEND use on the site. In fact, evidence points towards an urgent need to expand SEND provision within Bristol. The opportunity to re-use the existing premises or re-building should therefore be afforded substantial weight.

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Consequently, the applicant has failed to satisfy the requirements of Development Plan Policies BCS12 & DM5 regarding the protection of community facilities and therefore there is an in-principle policy conflict.

LACK OF AFFORDABLE HOUSING

The applicant has argued, for over a year now, that the Land Use Class for their scheme is C2 (residential institution) rather than C3 (residential dwelling). The Planning Statement Addendum notes that following confirmation from the council that the proposed development falls into Class C2, the application has been absolved from providing affordable housing on site.

In practice, there is ambiguity in UK planning law. When it comes to ‘integrated care’ projects that deliver both housing and social care, it is not always easy to distinguish between the C2 and C3 Use Classes. It is the case that so-called ‘extra care’ schemes in different parts of the country have blurred the boundary between these two Use Classes.

However, even though BCC have accepted the applicant’s claim that their scheme is Use Class C2, this does not necessarily absolve the developers of their responsibility to provide affordable housing on the St Christopher’s School site. The relevant legal finding here is the decision of the High Court (24/8/20) in the ‘Rectory Homes Limited v SSHCLG and Oxfordshire District Council’ dispute. The High Court found that ‘extra care developments within Use Class C2 are not exempt from providing affordable housing solely by virtue of falling within that use class’.

Therefore, it is SCAN’s contention that the application is still subject to Policy BCS17 (Affordable Housing Provision) of the Bristol Core Strategy (2011), requiring the applicant to arrange for 40% of the housing in their scheme to be affordable. BCC guidance requires developers (see the Affordable Housing Practice Note 2018) to ‘provide affordable homes on site without any public subsidy in line with the Council’s affordable housing policy’.

Moreover, the application provides no explanation of why the model of care proposed cannot cap the service charge on 40% of the new homes. Doing so may enable the scheme to meet the 40% affordable housing target. The applicant claims that the scheme will not be financially viable if affordable housing is included. However, this claim relating to financial viability is inaccurate.

The applicant was required to provide a Financial Viability Assessment (FVA) within the original submission package in March 2022, however, failed to do this. Following numerous requests, an FVA was provided in June 2022, of which SCAN provided a detailed review, submitting comments on it to the BCC Planning Portal on 12/7/22. The SCAN review shows that the submitted FVA, contains some significant flaws. In essence, the developer’s FVA claimed to show a deficit of £1.9 million on the scheme. However, the SCAN report demonstrates that this is not at all the case. Even if conservative figures are inputted to the FVA calculations, the evidence shows that the scheme proposed by the applicant in the original planning application would be expected to generate a surplus of £5.3 million (or more).

Most importantly, the SCAN financial viability assessment shows that it is perfectly possible to deliver a financially successful scheme with far fewer new housing units on this site than the developers claim. Fundamentally, this revised application package has not made it clear or provided any justification why even within a C2 category they should be excluded from Bristol City Council policy requirements to provide affordable housing. The application therefore fails to meet the requirements of Policy BCS17 and should be refused accordingly.

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OTHER STATED CONCERNS

Alleged community ‘benefits’

SCAN would also like raise objections against the developers' claim to be offering ‘community benefit’, with there being scant detail or evidence of this within the proposed application package and less evidence still that their claimed "benefits" - e.g., of a cafe which would be open to the 9 public, and meeting rooms which could be used for community events - are either needed or wanted by the community.

SCAN Group would like to make it clear that these vague, unspecific offerings in no way compensate for the very serious and concerning issues that are still outstanding as outlined above. There has been no meaningful discussion with the community about their real priorities and needs; consequently, what the developers seem to be offering is not seen as needed or even particularly beneficial.

Westbury Park already has a multitude of popular and well supported cafes, often run by people living locally - therefore another cafe on site does not meet a ‘need’ in the community. Similarly, there are also plenty of meeting rooms within the churches and schools in Westbury Park - and these charities rely heavily on rental income as revenue. Furthermore, the most useful community asset currently on the St Christopher's site is the large hall. This is the only part of the site that has had any genuine community use recently and it would be far more beneficial to retain this but sadly, this is set to be destroyed.

Lastly, the distinction between the public and private realm is still undefined, and there is a lack of clarity or detail about access arrangements the community would actually have once the development is completed and the reality of 200+ vulnerable elderly adults moving in becomes clear.

Vagaries and omissions of detail within the application package

Another objection raised by SCAN Group relates to the litany of errors, omissions of detail and misleading information contained within the application package, as well the lack of proper consultation during the process. Whilst individually many of these discrepancies may appear minor in nature, accumulatively they show a disregard by the applicant to present the community with basic factual information surrounding the scheme. Several examples of which are provided below:

• Height of H01 Cottages in site section drawing 2006 rev A - During consultation with the developer these were described to us as single storey with accommodation in the roof. The rooftops now line up with the top of a 1930s house so are more like a townhouse with two full storeys and a roof above, and will be significantly higher than the current single storey building.

• Site section drawing 2006 – The top of roofline of the H01 cottages has been obscured by tree branches to disguise their height. In fact, there is no tree that can obscure the front of these cottages, so the view is misleading and incorrect.

• 2006 site section – this section is still showing the two very large trees tree 52 and tree 65 which elsewhere in the proposal says are to be removed for sewer works. The inclusion of these trees makes the scene deceptively green, and this error was pointed out in the first consultation, however, has not been remedied.

• Landscape addendum – Shows the ground as level between the rear boundary of the proposed Cottages and the rear of 15/16/17 The Glen. This is incorrect, with there being a change in ground level, with the proposed cottages being higher.

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Highways impacts

It should be noted that the scope of this letter does not contain the full extent of concerns held by SCAN in regard to the submitted application. SCAN maintain the concerns raised in their previous representations to the original application package regarding highways impacts, however, to be succinct, these have been addressed in separate submission which should be read in conjunction with this letter, notably:

• Updated Objection from SCAN on Highways Grounds Document

SCAN would also like to refer the LPA to the recent Appeal decision ref. APP/Z0116/W/22/3299847 relating to Belvedere Road, one of the roads next to the neighbouring site. The appeal, which resulted in an increased parking demand of only an estimated 4 cars, was rejected by PINS on the 30th January 2023 due to the effect on ‘highway safety and congestion, having regard to on-street parking in the locality’.

The following commentary from the Inspector’s Report is relevant in this instance:

"there is no dispute that on-street parking in the area is at a premium with a high level of demand" and that the proposal "would result in additional demand for parking, exacerbating the existing problems. This would risk further vehicles blocking footways and dropped kerbs...[and] would result in conflict with moving vehicles and risk the highway safety of road users."

The issues with parking referred to by the Inspector within this appeal demonstrably exist throughout the whole area neighbouring the St Christopher’s site. It is therefore SCAN’s contention that the Inspector's Appeal decision should be given weight in the determination of the proposed scheme, which will likely result in an increased demand of at least 50 cars and thus should be similarly rejected.

SUMMARY & CONCLUSION

This formal representation has been prepared by Rapleys LLP for and on behalf of St. Christopher’s Action Network (SCAN) and has been provided in response to the revised application package submitted on the 1st December 2022 pertinent to planning application ref: 22/01221/F.

Unfortunately, the revised application package forms a completely inadequate response to the significant concerns raised over the original scheme and fails to amount to any measurable improvement.

The revised application has demonstrated an unwillingness on the part of the developers to respond to the feedback received from BCC internal consultees and Historic England, as well as the serious concerns raised in over 1250 objections. None of the concerns raised by SCAN in their original objection have been satisfactorily addressed, with the application remaining inappropriate for the following reasons:

• The proposed scale, mass and bulk of the proposals remain wholly inappropriate within this sensitive heritage context and will give rise to a high level of unacceptable impacts on heritage assets and townscape;

• The applicant has not demonstrated that there is no longer a need to provide a SEND use and continues to disregard the increasing need for SEND accommodation in Bristol, therefore failing to satisfy the requirements of BCS12 and DM5;

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• The extent of tree loss proposed remains inappropriate, particularly so in terms of high-quality individual specimens which make a valued contribution to the character and appearance of the Conservation Area;

• The proposal remains inappropriate in transport and highway terms, owing to insufficient on-site parking provision and inappropriate access/egress arrangements, which will increase the road safety risks in an area where there is already a significant concern;

• The proposal includes no affordable housing, which is contrary to the adopted development plan. Upon review, the submitted Viability Appraisal to justify such lack of provision is not considered to be reliable, with the stated reasoning for the lack of provision in conflict with adopted policies and adopted supplementary planning guidance;

• The alleged community benefits are not proved to be either needed or wanted by the community and in no way compensate for the very serious and concerning issues that are still outstanding; and

• The application package is littered with vagaries and omissions of detail, showing disregard to present the community with basic factual information surrounding the scheme.

For these reasons, it is considered that the submitted application should be summarily refused by the Local Planning Authority.

Yours faithfully,

Rapleys LLP

consultees and statutory bodies. Astonishingly, the FORE Partnership has not even bothered to consultthe community about these amended plans. This unwillingness to fully engage in a meaningful way iscompletely unacceptable as well as deeply frustrating, given the time and effort people have spent overthe last year communicating, time and time again, with the applicant about their views. It is also worthnoting that the application itself is littered with errors and misleading information; many of which someof our members have pointed out but which have failed to be addressed. Much like the flawed andbiased consultation process, this approach shows a blatant disregard for the community.

This planning application must be robustly refused by Bristol City Council for the following six reasons.

1) Harm to the heritage of Westbury Park

The proposed scale, mass and bulk of the proposals remain wholly unacceptable & inappropriate withinthis designated Conservation Area. The scheme would cause irreversible harm to the heritage assetsand townscape of Westbury Park. There is a statutory duty for the local authority to protect our city’sheritage.

2) Loss of SEND provision

The applicant has entirely failed to demonstrate that there is no longer a need to provide services forchildren with special educational needs on this site. The applicant has ignored Bristol City Councilguidance and continues to disregard the increasing need for SEND accommodation in Bristol, and withno firm offer of replacement provision, is therefore failing to satisfy the requirements of BCS12 and DM5.

3) Damage to the environment and to biodiversity

The extent of tree loss proposed remains utterly unacceptable, particularly so given the many very, highquality mature trees on the site. These trees make a highly valued contribution to the character andappearance of the neighbourhood, and they also contribute to the biodiversity of the DownsConservation Area.

4) Road Safety Risk

The proposal remains inappropriate in transport and highway terms, owing to insufficient on-siteparking provision and inappropriate access/egress arrangements, which will increase the road safetyrisks in an area where there is already a significant concern. Please refer to our separate objectionsetting out our concerns purely on Highways grounds.

5) Lack of Affordable Housing

The proposal includes no affordable housing, which is contrary to the aims of the city council, theadopted development plan and national policy. We have reviewed the Financial Viability Assessment(submitted five months late by the developers, in July 2022). This purports to justify such lack ofprovision on the grounds that this would make the scheme ‘technically unviable’. This is demonstrablynot the case. The stated reasoning for not providing affordable housing is flawed and does not stand upto scrutiny.

6) False claims about alleged ‘community benefit’

There has been no discussion with the community about their real priorities and needs and, therefore,there is no evidence to support the claims made by the developer that the so-called ‘benefits’ of a cafeand/or meeting rooms are either needed or wanted by the community. It is our contention that theproposed scheme does not deliver genuine benefit to the community. It is reasonable to ask, if thescheme is delivering ‘community benefits’; why are more than 97% of the formal comments on thescheme opposing this application?

In conclusion

This revised planning application does not comply with multiple core Bristol City Council policies, nor ourown Community Planning Principles drawn up jointly with the Westbury Park Community Association,and submitted to Bristol Council on 3/11/21. These wise principles for the development of the site areentirely in line with established Bristol City Council planning policies, and were included in the PreApplication guidance given to the developer by Paul Chick on behalf of the council on 8/11/21.

We urge the councillors to recognise the validity of our concerns, which are based on wellestablished council policy and to indicate that this application should be robustly refused.

We would like to stress our belief that the application should be refused on all the grounds that wehave laid out and the refusal should be extensive, detailed and specific. We hope this would helpavoid future applications wasting both the council and community’s time and resources due toonly making minimal changes, as well as being vitally important to ensure that any furtherproposals for this site, by this developer or any other, appropriately reflect the constraints of the siteand comply with all established Bristol City Council Policies.

With many thanksThe Team at SCAN

This is to add some new information to my earlier objection.

I would like to note the result of Appeal Ref APP/Z0116/W/22/3299847 (BCC application reference22/01529/F) relating to Belvedere Road, one of the roads neighbouring the site, directly adjoiningThe Glen. This shows that an application resulting in an increased parking demand of only anestimated 4 - 5 cars was rejected by PINS on 30th January 2023, due to the effect on "highwaysafety and congestion, having regard to on-street parking in the locality".

The Inspector particularly commented that "there is no dispute that on-street parking in the area isat a premium with a high level of demand" and that the proposal "would result in additionaldemand for parking, exacerbating the existing problems. This would risk further vehicles blockingfootways and dropped kerbs...[and] would result in conflict with moving vehicles and risk thehighway safety of road users."

As SCAN and many residents have raised, the proposed new access to St Christophers from TheGlen cannot help but increase the parking demands on The Glen and the adjacent BelvedereRoad, due to:

- Likely usage by residents, visitors and staff of St Christophers, in light of the insufficient on-siteparking. This is particularly likely for users of Block D, as most of the limited on-site parking iseven stated by the applicant to be "a long distance from their front door" (Planning StatementAddendum 4.52) so it would be closer, cheaper and more convenient for them to park on The

Glen, easily accessed through the pedestrian gate

- Likely usage by visitors to the Urban Village Hall, which borders The Glen and has no on-siteparking, encouraging visitors to try to park in The Glen and walk through the pedestrian gate

- Removal of some existing on-street parking spaces to allow access to the site for cars andemergency vehicles, reducing the number of available spaces.

The existing over-demand for parking in this locality, and the resulting road safety risks, have beenraised and evidenced in many objections, and the recent Appeal shows that these concerns havealso been witnessed and endorsed by the Planning Inspector.

Furthermore, the issues with parking referred to by the Inspector demonstrably exist throughoutthe whole area neighbouring the St Christophers site, which clearly is unable to absorb theoverspill parking from St Christophers without impacting road safety, as further evidenced insubmissions from SCAN and other residents.

In summary, it should be clear that the issues raised by the Planning Inspector relating to thisearlier application would equally apply to:

- Additional parking demand placed on The Glen and Belvedere Road due to the new access pointfrom The Glen

- Additional parking demand (estimated as at least 50 cars at peak times) placed on allsurrounding roads due to the insufficient on-site parking

and PINS' dismissal of Appeal APP/Z0116/W/22/3299847 evidently supports that these are validgrounds for refusing this application.

This site has been specialist education provision for children and young people withSEND for decades. The proposals from this developer tell us that this legacy is currently'ongoing to investigate the feasibility to make the space within the Urban Village Hall available forthe provision of SEND spaces, or, if that is not possible, a proportional financial contribution forSEND places in North Bristol, secured via a S106 Agreement'SEND provision is by definition in need of being fully understood by the designers in order to meetthe needs of those attending. The statement, apparently updated, does not provide me withconfidence that the needs of the children are being considered as central to the proposals. SENDprovision can only be effective when these needs are central, this is further backed up in thestatement involving S106 funds for off-site provision - this developer is not interested in providingSEND provision.SEND is this council's largest budget deficit year on year with much caused by the need for out-of-area provision - our children need more specialist provision, not less. If SEND provision is lostfrom this geographical location now it will never return. Children and their families need localprovision in their communities not somewhere in 'North Bristol' as the developer states.I refer the committee to the comments made by the Education officer that describes the claimsmade by the developer as demonstrating a 'limited understanding of SEND' that there are 'seriouserrors in the data' used by the developer in relation to SEND needs of Bristol's children that thedeveloper makes 'incorrect statements', that 'Table 2 is incorrect', that whole sections of the reportare 'wholly inaccurate' and 'incorrect'.

I also object to the 0% of affordable housing proposed. This developer quotes an apparent letter

from the council agreeing that 0% is needed. As a member of that council I disagree that anydevelopment can be permissible without affordable housing to at least that required in policy.

Whilst I agree with the repurposing of the site to 'high density' retirement flats (better forthem to move from large properties so that these can be recycled to families), I see no realevidence that there is any effort to encourage use of public transport, etc.

Due to this (and staff need for parking - same reason), the already severe parking issues aroundWP will be further accentuated. The developers need to work with BCC/WoECA & car rentalcompanies to ensure;

i) bus frequency guaranteed/improved (2 & 2a?) into town/Cribbsii) multiple short-term car hire slots on the siteiii) a resident's parking scheme setup - across 24hrs period.

wall is jointly owned and we have had no request to do any work to it) andpropsals for the planting of small trees against this boundary. Without sectionsthere is no clear indication of whether merely retaining the existing wall willindeed be at all adequate to maintain and provide adequate private amenity.

In the revised proposal dated 1 December the proposed Cottages (H02) havemerely been moved slightly (2m) along parallel to the boundary but are still fartoo close resulting in a significant adverse impact on our outlook and a whollyunacceptable physical relationship resulting in mutually unacceptableoverlooking and overshadowing. Also, the provision of active public gardenspaces directly on our boundaries will compound the above by reason ofnoise and general disturbance.

Our back garden at No. 25 is very shallow with its principal private amenityspace being to the North. Nos. 23 and 21 have more typical back gardens butNo. 23’s is still shallow. Our gardens are approximately 1 to 2m below thelevel of the application site such that our garden walls are part retaining.

All three properties (No. 21, 23 & 25) are typical two storey but all also haveroof space accommodation and dormer rear elevation windows. All three ofour properties have ground floor kitchen and living accommodation and firstand second floor rear bedrooms. These first and second floor bedrooms havedirect line of sight down into and over the application site.

Our current outlook is pleasant with open areas and significant trees andrelated wildlife interest. At the present time there is no unacceptable windowto window overlooking or overshowing and our gardens are private.

The proposed “Cottages” (H02) are two storey, but despite our previouscomments, we still do not know at what level they are proposed. If we assumethey are built at ground level then they will have a dpc between 1 and 2mhigher than our properties. As we state above we cannot see any directlyrelated section(s) to accurately illustrate the relationship.

The “Cottages” H02 have not moved away from our property and therefore,our measurement of “back to back” and window to window distances scaledfrom the submitted Proposed Ground Layout plans are unchanged:-

 15m from northernmost plot of H02 terrace rear elevation to gardenboundary of No. 25 and between 16.5 and 17.5m to rear elevation;

 A 10.5m garden depth and a distance of 15.5m from the rear elevationof H02 terrace to the rear kitchen of No. 23 and 20m and 21m to therear elevation;

 An 8m garden depth and a 21.5m distance to the rear elevation of No.21.

The above distances are reflective of the oblique relationship of both theproposed and the existing development to the dividing boundary. Thedistances demonstrate that the development is far too close even if this werea flat site with a standard 1.8m boundary and a parallel relationship. However,the application site is higher that the ground level in Nos. 21-25; therelationship is oblique and we all have second floor roof accommodation. Wedisagree with the Addendum Planning Statement 4.25 opinion that “…this was

acceptable as submitted.” Even with the addition of obscured glazing our sideand rear private amenity areas will be severely overlooked; there will besevere overlooking to and from rear elevation windows; the new rear gardenswill be severely overlooked by our first and second floor bedroom windowsand we will all be overshadowed by the proposed “Cottages”.

The provision of “active public areas” on our boundaries will also add noiseand disturbance particularly for Nos. 25 and 21 and the scale of developmentand proposed small trees immediately on the boundary willresult in overshowing. The submitted report says that the development iscompliant with BRE Guidelines and that there is thus no unacceptableovershowing / loss of light. We do not see the evidence to support this. Indeedin the submitted Daylight & Sunlight Report (28 November 2022) Appendix 2shows significant (30-50%) reduction in both summer and winter daylight intoour main living areas of No. 25 and a reduction in sunlight and daylight to allthe windows in Nos. 23 (NB: there are still no figures published for No. 21).

On the basis of the above and as many people and SCAN and WPCA havesaid the proposal is an “overdevelopment” with too much and too highdevelopment too close to the site boundaries. While we accept and havepreviosly stated that we do not oppose redevelopment in principle, inaccordance with both National and Local Policy this must be done while bothdelivering acceptable and protecting existing residential amenity.

The developers pre-application consultation and response to the originalproposal has turned out to be a sham with promised quality and applicationdetail not forthcoming. This manifests itself in the lack of level and sectiondetail submitted and the hollow words in supporting reports, acknowledgingadverse impact but concluding that this is the best that can be done and istherefore acceptable.

We do not agree that the impacts, whilst reduced, are either acceptable oroutweighed by the socio-economic benefits potentially delivered byredevelopment.

Bristol Core Strategy Policy BCS21 states that development will be expectedto, “Safeguard the amenity of existing development and create a high-qualityenvironment for future occupiers.”

Paragraph 4.21.13 of the plan supporting Policy BCS21 then states, “A highquality built environment should consider the amenity of both existing andfuture development. Consideration should be given to matters of privacy,outlook, natural lighting, ventilation and indoor and outdoor space.”

Bristol Development Management Policy DM26 states in relation to Infilldevelopment that proposals will be expected to have regard to, “..theprevailing character and quality of the surrounding townscape….Infilldevelopments on return frontages should be compatible with the opencharacter of corner sites and be subservient in height, scale and massing tothe primary frontage building” In relation to “backland” development it statesthat development, “..will be expected to be subservient in height, scale, massand form to the surrounding frontage buildings. It should not prejudice theopportunity to develop the adjoining land of similar potential nor should the

proposed access arrangements cause adverse impacts to the character andappearance, safety or amenity of the existing frontage development.”

Policy DM27 states that development “…will be expected to….enable existingand proposed development to achieve appropriate levels of privacy, outlookand daylight; and policy DM29, interestingly referenced in the residentialamenity section of the Planning Statement but not more formally in thePlanning Policy section, states that development, “will be expectedto…..ensure that existing and proposed development achieves appropriatelevels of privacy, outlook and daylight”.

Overarching local policy is consistent with guidance in the NPPF whichchampions “good design” and states at paragraph 130 that, “Planningpolicies and decisions should ensure that developments: create places thatare safe, inclusive and accessible and which promote health and well-being,with a high standard of amenity for existing and future users.”

On the basis of our review we conclude that the revised proposal is still a poorresponse to site context and an overdevelopment. This manifests itself incritical adverse impact on our residential amenity by reason of direct andperceived overlooking both to private gardens and by reason of direct windowto window distances; overshadowing and the additional harm caused byreason of the location of quasi public spaces immediately on our boundaries.

These direct future impacts are compounded by the loss of existing trees andthe erosion of the residential amenity and outlook we currently enjoy.

The revised proposal lacks detail and on that basis we reserve our position toreview and comment again on any additional information provided. Howeveron the basis of the revised application submitted on 1 December assubmitted we consider that it is by reason of adverse residential amenityimpact contrary to prevailing planning policy and should be refused onthis basis alone.

Yours sincerely

Appendix A: letter to FORE Partnership 22 December 2021

Appendix B: Consultation response – OBJECTION – 16 May 2022

22nd December 2021

FORE Partnership

Reference: St Christopher’s Public Consultation

Following our attendance at the St Christopher’s Public consultation. We theresidents of have grouped together toprovide a single shared response to the consultation.

These are independent of any comments you may receive at this stage fromthe WPCA and SCAN groups. Notwithstanding, we are aware of the 6“principles” agreed by WPCA and SCAN and we support these.

• RESPECT THE LOCAL HISTORY AND CONTEXT: Recognise thetwo distinct parts of the site – enhance and protect the villas at thefront, and ensure that development in the rear land, behind the villas,reflects the scale and character of the 2-storey housing in adjacentstreets.

• DO NOT MAKE OUR TRAFFIC AND PARKING ANY WORSE:Ensure that any development will not lead to any additional traffic orparking in surrounding streets - road safety must be prioritised.

• RESPECT OUR HOMES: Safeguard the privacy of propertiessurrounding the site - no new buildings should be taller than existingbuildings in the rear land.

• BE GENUINELY GREEN: There should be a net gain in biodiversity;protecting existing trees, landscape and wildlife. Plans must respond tothe current global climate and ecological emergencies.

• DO NOT OVERDEVELOP THE SITE: This largely green space shouldnot be overdeveloped but should maintain and enhance the unique andspecial character of Westbury Park, which is a designatedConservation Area.

• KEEP OUR CHILDREN SAFE: Recognise that, in the interests ofpublic safety, there should be no access to the site from BayswaterAvenue or The Glen.

Thank you for undertaking this pre-application consultation and we appreciatethe time, effort and cost associated with running such events. However, ourrepresentations submitted now are Without Prejudice to any comments wemay make to the submitted Planning and Listed Building Consent applicationsin due course.

The comments we submit are necessarily focused on how the developmentwill directly affect us and are therefore somewhat negative in tone. However,as an introduction we appreciate the site needs to be redeveloped andsupport this in principle. While we therefore support the retention andconversion of the Westbury Park villas; the retention and conversion of thelisted Grace House and the opportunity that presents itself for somedemolition and new building this must be undertaken with due respect to thecharacter and appearance of the Conservation Area and the area moregenerally and the character and setting of Grace House; involve the retention(and safeguarding) of all important trees (whether the subject of a currentTPO or not) and must cause no harm to, and potentially improve, theresidential amenity of all local residents.

Within this context our first substantive comment is that the informationdisplayed at the consultation event was to a large extent indicative andtherefore vague. While the proposals have positively developed since theinitial consultation and no doubt will develop further it was genuinely difficult tounderstand what the key elements of the current proposal were. While thoseconsultants at the event, presenting on behalf of the developers wherehelpful, some questions could not be answered definitively and some left keyissues unresolved.

In the above context, our view is that describing the development as an“integrated retirement community” is vague and does not hide the fact thatwhat is proposed is simply a residential re-development. Alongside this therewas of course no reference to on-site affordable housing provision. At thisstage and while the price and management costs of the eventualaccommodation and services may dictate who can afford to live at the site, weassume that the City Council will insist on the provision of a substantialproportion of affordable housing. We also assume that as the site was boughton the open market with full knowledge of the physical and planning policycontext that no credible viability argument could be mounted against theprovision of a policy compliant percentage and mix of affordable housing. Indue course we would therefore be very interested in the form and location ofthis on the site.

The quantum of development was also unclear on the presentation boardsalthough we were separately advised that the total development was 120units (25 via conversion and 95 via new build) with “approximately” 65 parkingspaces. Also, apart from via two indicative and unscaled sections, there wasvery little detail on the scale of the buildings and their external appearance.The relevant boards looked like they had subsequently been marked in penwith storey heights noted as ranging from 4-6 storeys with 2 storey “cottages”and the conversion of the existing Villas. The nature of the use and thequantum and mix of development obviously also affects car parking and againit was unclear, with the use class undefined, how the “approximately” 65parking spaces referred to were derived. Also, the issue of public access wasalso somewhat unclear. While we support the public (or bookable) use of anyfacilities to be provided within Grace House we object to any east – westpublic vehicular or pedestrian through route, which would have the potential toadversely impact our residential amenity. Consequently, we object to theretention and upgrading of the existing access to Etloe Road / BayswaterAvenue and request that this be permanently abandoned / appropriatelyclosed.

Only “approximately” 65 parking spaces are referred to and there was nobreakdown between allocated residents parking, visitors or staff or servicevehicle parking. Only 65 parking spaces for 120 apartments is approximatelyhalf the maximum standard required by the Council (if all the units were 1 bed)and this does seem woefully inadequate even allowing for the potential ageprofile and sustainable location of the site. If on site parking is in any wayinadequate to serve this housing development; if the existing Etloe Road /Bayswater Avenue access is retained and upgraded or if a “public” throughpedestrian / cycle or vehicular access is proposed, then there will besignificant direct and indirect highway, residential amenity and security impactfor us and the other local residents.

All existing trees of any merit (whether TPOd or not) must be retained andprotected from harm immediately and in the long term. The trees are visuallyand environmentally important to the character and appearance of the area;biodiversity and existing residential amenity. This will also assist the “net zero”claims; bio-diversity gain requirements and sustainability generally.

We welcome the proposed restoration of the old cottage maintaining itscurrent footprint and form and proposed use by the community.

The plans displayed showed two terraces of “cottages” facing the rear of ourhomes but the only other detail provided was that gleaned from the indicativesection, which appeared to show a two storey scale with rear gable design(perhaps taking a reference from the dwellings on Royal Albert Road). Wehave assumed that these “cottages” are indeed single dwellings rather than acollection of apartments. We support a two storey design approach and wouldpromote that across the whole site in the interests of our and other residentsresidential amenity; the character and appearance of the Conservation Areaand the setting of Grace House. However, land levels are not clear and therear gables of these dwellings appeared to be not as wide and of a steeperpitch that those that exist along Royal Albert Road, therefore removing anyclaim that they are a design reference, and have windows shown implyingroof space accommodation.

Related to the above is the distance these properties are from the siteboundary and the rear elevations of our homes. The existing relationship isnot typical in that the boundary is at an angle and this is not reflected in thelayout. We haven’t been presented with scaled plans; accurate cross sectionsor elevations drawings but our estimate is that the proposed rear gardens areall less than 10m deep and that in some cases the rear elevation to elevationdistance may be as short as only 12m. This would clearly and obviously bewholly unacceptable for us and the residents in any new properties. Thiswould be further compounded if second floor roofspace accommodation wasalso proposed and is also in addition to our significant objection to the loss oftrees in this north eastern part of the site.

While the two storey scale of development proposed by these “cottages” issupported in principle any such accommodation must be sited sympatheticallyto the existing trees and sufficiently distant from our properties (having regardto their scale and orientation) such that reasonable landscaping can beaccommodated and our privacy and general residential amenity is unaffectedby reason of overlooking, overshadowing, noise or light spill.

The siting and orientation of these two blocks of proposed dwellings meansthat our existing verdant outlook is removed; we are significantly overlookedand are at real risk of being significantly overshadowed by development soclose to the sites eastern boundary.

We would be grateful if you could consider the above and thereforereconsider your proposals. We would be happy to review any revised plan youmay prepare but would ask that these be clear in respect of tree removal andnew landscaping, accompanied by appropriate existing topographicalinformation; be drawn to scale and be clearly marked with proposed levelsand dimensions.

Yours sincerely

16 May 2022

Development Management

Bristol City Council,

City Hall,

PO Box 3399,

Bristol

BS1 9NE

FAO Paul Chick

Planning Application 22/01221/FSt Christopher’s, Westbury Park

We refer to the above and Object to the proposals. Whilst we think the siteneeds to be developed, this letter specifically addresses our residentialamenity we also support the WPCA and SCAN objections both in principleand in detail.

We took part in the pre-application public consultation and previolusly wrotewith our neighbours to the Fore Partnership on the 22 December 2021. Forinformation we attach a copy of this letter as Appendix 1 and do not thereforerepeat its contents. This letter is quoted in the Statement of CommunityInvolvement (SOCI pages 192/193) but the objections set out in that letterhave unfortunately not been satisfactorily addressed.

The application is vague in parts and lacks detail especially in relation toproposed land levels and relevant cross sections. This information waspromised to local residents during the consultation process (see SOCI page79) and while some further information was published with the final round ofpublic consultation (December 2022 e.g Site Section C-C, stated distancesand some level information) this has not been revised and submitted with theformal application. Without reasonably accessible levels information andaccurate cross sections it it is difficult to fully assess the relationship of theproposed “Cottages” (H02 and H03) to our properties and visa versa. As aspecific point we cannot see any section drawings through the proposedCottages to our properties that accurately reflects the differing land levels and“back to back” distances. We estimate that the land within the site is between1 and 2m higher than our garden levels (but there are no proposed land anddpc levels readily apparent on the submitted plans).

It is also unclear where the boundary is between “private” rear gardens and“”active semi public” spaces and how such “active semi public” spaces would

be managed (see Desifgn and Access Statement (DAS) pages 61, 95 and106). Also, there is a note on the Landscaping Masterplan drawing simplystating that our existing rear garden stone boundary wall will be retained andmade good (NB: this wall is miss described as a 2m high brick wall on thetopographical survey embedded as an Appendix in the Drainage StrategyReport. Also this wall is jointly owned and we have had no request to do anywork to it) and propsals for the planting of small trees against this boundary.Without sections there is no clear indication of whether merely retaining theexisting wall will indeed be at all adequate to maintain and provide adequateprivate amenity.

The documents submitted acknowledge that the boundary to BayswaterAvenue is “sensitive” (DAS page 42) and that design constraints are imposedby existing development (page 43). This is indeed well illustrated by an aerialphotograph in the DAS (page 38); the fourth picture on page 40 and the fourthVerified Image. The Verified image clearly illustartes how close and dominantthe Cottages will be to our properties and in the image, combined with theblock beyond, how grossly overlooking, overbearing and contrasting they willbe particularly to the private side garden of No. 25 but also to all the rearelevations and indeed the public street itself.

Since the Consultation Event the proposed Cottages (H02) have merely beenslightly angled away from the boundary but both blocks are still far too closeresulting in a significant adverse impact on our outlook and a whollyunacceptable physical relationship resulting in mutually unacceptableoverlooking and overshadowing. Also, the provision of active public publicgarden spaces directly on our boundaries will compound the above by reasonof noise and general disturbance.

Our back garden at No. 25 is very shallow with its principal private amenityspace being to the North. Nos. 23 and 21 have more typical back gardens butNo. 23’s is still shallow. Our gardens are approximately 1 to 2m below thelevel of the application site such that our garden walls are part retaining.

All three properties are typical two storey (it is not clear whether this isacknowldeged – see DAS page 41) but all also have roof spaceaccommodation and dormer rear elevation windows. All three of ourproperties have grond floor kitchen and living accommodation and first andsecond floor rear bedrooms. These first and second floor bedrooms havedirect line of sight down into and over the application site.

Our current outlook is pleasant with open areas and significant trees andrelated wildlife interest. At the present time there is no unacceptable windowto window overlooking or overshowing and our gardens are private.

The proposed “Cottages” are two storey but we currently do not know at whatlevel they are proposed. If we assume they are built at ground level then theywill have a dpc between 1 and 2m higher than our properties. As we stateabove we cannot see any directly related section(s) to accurately illustrate therelationship. The SOCI in this respect makes reference only to “increasingdistances” (page 45) and “respected and preserved as much as possible”(page 50 our undelyning). The DAS at page 59 states, “The heights of theproposed cottages are lower than the existing heights in Bayswater Avenueand The Glen.”, but again the actual heights are not illustrated having regard

to existing ground levels. (NB: this is also not consistent with the previouslypublished Section C-C, which shows the “Cottages” at the same height as ourproperties even allowing for the garden level differences.) The PlanningStatement at para 6.47 states, “…significant overlooking or overshaowingdoes not occur…” and “…buildings have been re-orinetated to seek to reduceimpacts on neighbours.” (again our underlyning). The language used is notbased on stated distances and acknwowledges harm but considers it areasonable impact.

Our measurement of “back to back” and window to window distances scaledform the submitted Proposed Ground Layout plan are:-

• Between 8.5 and 9.5m from rear elevation of H03 semi-pair to gardenboundary of No. 25 and a 15m angled view from rear elevation to side(north) elevation of No. 25;

• 15m from northernmost plot of H02 terrace rear elevation to gardenboundary of No. 25 and between 16.5 and 17.5m to rear elevation;

• A 10.5m garden depth and a distance of 15.5m from the rear elevationof H02 terrace to the rear kitchen of No. 23 and 20m and 21m to therear elevation;

• An 8m garden depth and a 21.5m distance to the rear elevation of No.21.

The above distances are reflective of the oblique relationship of both theproposed and the existing development to the dividing boundary. Thedistances demonstrate that the development is far too close even if this werea flat site with a standard 1.8m boundary and a parallel relationship. However,the application site is higher that the ground level in Nos. 21-25; therelationship is oblique and we all have second floor roof accommodation. Wedisagree with the Planning Statement that “…proposed offset distances areconsidered to be acceptable and would not cause an unacceptable loss oflight or amenity to surrounding neighbours” (para 6.47). Our side and rearprivate amenity areas will be severely overlooked; there will be severeoverlooking to and from rear elevation windows; the new rear gardens will beseverely overlooked by our first and second floor bedroom windows and wewill all be overshdowed by the proposed “Cottages”.

The provision of “active public areas” on our boundaries will also add noiseand disturbance particularly for Nos. 25 and 21 and the scale of developmentand proposed small trees immediately on the boundary willresult in overshowing. The submitted report says that the development iscompliant with BRE Guidelines and that there is thus no unacceptableovershowing / loss of light. We do not see the evidence to support this. Indeedin the submitted Daylight & Sunlight Report (22 February 2022) drawings2613 03-01, 02 and 03 (Appendix 1) do appear to show significantovershadowing to at least the side garden of No. 25. Also, in the publishedfigures (Appendix 2) there is a noted reduction in sunlight and daylight to allthe windows in Nos. 25 and 23 (NB: there are no figures published for No.21). Then in Appendix 4 there is no reference at all to Nos. 21-25.

On the basis of the above and as many people and SCAN and WPCA havesaid the proposal is an “overdevelopment” with too much and too highdevelopment too close to the site boundaries. While we accept and havepreviosly stated that we do not oppose redevelopment in principle, in

accordance with both National and Local Policy this must be done while bothdelivering acceptable and protecting existing residential amenity.

The developers pre-application consultation has turned out to be a sham withpromised quality and application detail not forthecoming. This manifests itselfin the lack of level and section detail submitted and the hollow words insupporting reports, acknowledging adverse impact but concluding that this isthe best that can be done and is therefore acceptable.

We do not agree that the impacts are either accepotable or ourtweighed bythe socio-economic benefits potentially delivered by redevelopment.

Bristol Core Strategy Policy BCS21 states that development will be expectedto, “Safeguard the amenity of existing development and create a high-qualityenvironment for future occupiers.”

Paragraph 4.21.13 of the plan supporting Policy BCS21 then states, “A highquality built environment should consider the amenity of both existing andfuture development. Consideration should be given to matters of privacy,outlook, natural lighting, ventilation and indoor and outdoor space.”

Bristol Development Management Polciy DM26 states in relation to Infilldevelopment that proposals will be expected to have regard to, “..theprevailing character and quality of the surrounding townscape….Infilldevelopments on return frontages should be compatible with the opencharacter of corner sites and be subservient in height, scale and massing tothe primary frontage building” In relation to “backland” development it statesthat development, “..will be expected to be subservient in height, scale, massand form to the surrounding frontage buildings. It should not prejudice theopportunity to develop the adjoining land of similar potential nor should theproposed access arrangements cause adverse impacts to the character andappearance, safety or amenity of the existing frontage development.”

Policy DM27 states that development “…will be expected to….enable existingand proposed development to achieve appropriate levels of privacy, outlookand daylight; and policy DM29, interestingly referenced in the residentialamenity section of the Planning Statement but not more formally in thePlanning Policy section, states that development, “will be expectedto…..ensure that existing and proposed development achieves appropriatelevels of privacy, outlook and daylight”.

Overarching local policy is consistent with guidance in the NPPF whichchampions “good design” and states at paragraph 130 that, “Planningpolicies and decisions should ensure that developments: create places thatare safe, inclusive and accessible and which promote health and well-being,with a high standard of amenity for existing and future users.”

On the basis of our review we conclude that the development is indeed a poorresponse to site context and an overdevelopment. This manifests itself incritical adverse impact on our residential amenity by reason of direct andperceived overlooking both to private gardens and by reason of direct windowto window distances; overshadowing and the additional harm caused byreason of the location of quasi public spaces immediately on our boundaries.

These direct future impacts are compounded by the loss of existing trees andthe erosion of the residential amenity and outlook we currently enjoy.

The proposal lacks detail and on that basis we reserve our position to reviewand comment again on any additional information provided. However on thebasis of the application as submitted we consider that it is by reason ofadverse residential amenity impact contrary to prevailing planningpolicy and should be refused on this basis alone.

Yours sincerely

Appendix 1: letter to FORE Partnership 22 December 2021

106). Also, there is a note on the Landscaping Masterplan drawing simplystating that our existing rear garden stone boundary wall will be retained andmade good (NB: this wall is mis-described as a 2m high brick wall on thetopographical survey embedded as an Appendix in the Drainage StrategyReport. Also this wall is jointly owned and we have had no request to do anywork to it) and propsals for the planting of small trees against this boundary.Without sections there is no clear indication of whether merely retaining theexisting wall will indeed be at all adequate to maintain and provide adequateprivate amenity.

The documents submitted acknowledge that the boundary to BayswaterAvenue is “sensitive” (DAS page 42) and that design constraints are imposedby existing development (page 43). This is indeed well illustrated by an aerialphotograph in the DAS (page 38); the fourth picture on page 40 and thefourth Verified Image. The Verified image clearly illustartes how close anddominant the Cottages will be to our properties and in the image, combinedwith the block beyond, how grossly overlooking, overbearing and contrastingthey will be to the private gardens of No. 21, 23 and 25 but also to all the rearelevations and indeed the public street itself.

Since the Consultation Event the proposed Cottages (H02) have merely beenslightly angled away from the boundary but both blocks are still far too closeresulting in a significant adverse impact on our outlook and a whollyunacceptable physical relationship resulting in mutually unacceptableoverlooking and overshadowing. Also, the provision of active public publicgarden spaces directly on our boundaries will compound the above by reasonof noise and general disturbance.

No. 25 has a very shallow back garden with its principal private amenity spacebeing to the North. Nos. 23 and 21 have more typical back gardens but No.23’s is still shallow. Our gardens are approximately 1 to 2m below the level ofthe application site such that our garden walls are part retaining.

All three properties are typical two storey (it is not clear whether this isacknowldeged – see DAS page 41) but all also have roof spaceaccommodation and dormer rear elevation windows. All three of ourproperties have ground floor kitchen and living accommodation and first andsecond floor rear bedrooms. These first and second floor bedrooms havedirect line of sight down into and over the application site.

Our current outlook is pleasant with open areas and significant trees andrelated wildlife interest. At the present time there is no unacceptable windowto window overlooking or overshowing and our gardens are private.

The proposed “Cottages” are two storey but we currently do not know at whatlevel they are proposed. If we assume they are built at ground level then theywill have a dpc between 1 and 2m higher than our properties. As we stateabove we cannot see any directly related section(s) to accurately illustrate therelationship. The SOCI in this respect makes reference only to “increasingdistances” (page 45) and “respected and preserved as much as possible”(page 50 our undelyning). The DAS at page 59 states, “The heights of theproposed cottages are lower than the existing heights in Bayswater Avenueand The Glen.”, but again the actual heights are not illustrated having regardto existing ground levels. (NB: this is also not consistent with the previously

published Section C-C, which shows the “Cottages” at the same height as ourproperties even allowing for the garden level differences.) The PlanningStatement at para 6.47 states, “…significant overlooking or overshaowingdoes not occur…” and “…buildings have been re-orinetated to seek to reduceimpacts on neighbours.” (again our underlyning). The language used is notbased on stated distances and acknwowledges harm but considers it areasonable impact.

Our measurement of “back to back” and window to window distances scaledform the submitted Proposed Ground Layout plan are:-

• Between 8.5 and 9.5m from rear elevation of H03 semi-pair to gardenboundary of No. 25 and a 15m angled view from rear elevation to side(north) elevation of No. 25;

• 15m from northernmost plot of H02 terrace rear elevation to gardenboundary of No. 25 and between 16.5 and 17.5m to rear elevation;

• A 10.5m garden depth and a distance of 15.5m from the rear elevationof H02 terrace to the rear kitchen of No. 23 and 20m and 21m to therear elevation;

• An 8m garden depth and a 21.5m distance to the rear elevation of No.21.

The above distances are reflective of the oblique relationship of both theproposed and the existing development to the dividing boundary. Thedistances demonstrate that the development is far too close even if this werea flat site with a standard 1.8m boundary and a parallel relationship. However,the application site is higher that the ground level in Nos. 21-25; therelationship is oblique and we all have second floor roof accommodation. Wedisagree with the Planning Statement that “…proposed offset distances areconsidered to be acceptable and would not cause an unacceptable loss oflight or amenity to surrounding neighbours” (para 6.47). Our side and rearprivate amenity areas will be severely overlooked; there will be severeoverlooking to and from rear elevation windows; the new rear gardens will beseverely overlooked by our first and second floor bedroom windows and wewill all be overshdowed by the proposed “Cottages”.

The provision of “active public areas” on our boundaries will also add noiseand disturbance particularly for Nos. 25 and 21 and the scale of developmentand proposed small trees immediately on the boundary willresult in overshadowing. The submitted report says that the development iscompliant with BRE Guidelines and that there is thus no unacceptableovershadwing / loss of light. We do not see the evidence to support this.Indeed in the submitted Daylight & Sunlight Report (22 February 2022)drawings 2613 03-01, 02 and 03 (Appendix 1) do appear to show significantovershadowing to at least the side garden of No. 25. Also, in the publishedfigures (Appendix 2) there is a noted reduction in sunlight and daylight to allthe windows in Nos. 25 and 23 (NB: there are no figures published for No.21). Then in Appendix 4 there is no reference at all to Nos. 21-25.

Specifically relating to the proposed restoration of ‘North House’ (also referredto as ‘the old cottage’), this building is located directly upon the rear boundaryof No 21 Bayswater Avenue. We support the initiative to restore this buidingback to a safe and usable condition in-keeping with the style of the localconservation area, but only if there is no increase to the outside envelope

of this building, no loss of privacy due to overlooking and no potentialdisturbance from the proposed use of this building at such close proximity(less than 1 metre) to our small and currently very private garden. During thedevelopers pre-application consultation it was verbally confirmed twice thatthere would be no increase to the envelope of the ‘North House’ / OldCottage, but we have not seen any written confirmation of this. We insist thatno restoration work shall commence on our shared boundary wall, nor theparts of North House that integrate with our shared boundary, without ourprior consent.

On the basis of the above and as many people and SCAN and WPCA havesaid the proposal is an “overdevelopment” with too much and too highdevelopment too close to the site boundaries. While we accept and havepreviosly stated that we do not oppose redevelopment in principle, inaccordance with both National and Local Policy this must be done while bothdelivering acceptable and protecting existing residential amenity.

The developers pre-application consultation has turned out to be a sham withpromised quality and application detail not forthecoming. This manifests itselfin the lack of level and section detail submitted and the hollow words insupporting reports, acknowledging adverse impact but concluding that this isthe best that can be done and is therefore acceptable.

We do not agree that the impacts are either accepotable or ourtweighed bythe socio-economic benefits potentially delivered by redevelopment.

Bristol Core Strategy Policy BCS21 states that development will be expectedto, “Safeguard the amenity of existing development and create a high-qualityenvironment for future occupiers.”

Paragraph 4.21.13 of the plan supporting Policy BCS21 then states, “A highquality built environment should consider the amenity of both existing andfuture development. Consideration should be given to matters of privacy,outlook, natural lighting, ventilation and indoor and outdoor space.”

Bristol Development Management Polciy DM26 states in relation to Infilldevelopment that proposals will be expected to have regard to, “..theprevailing character and quality of the surrounding townscape….Infilldevelopments on return frontages should be compatible with the opencharacter of corner sites and be subservient in height, scale and massing tothe primary frontage building” In relation to “backland” development it statesthat development, “..will be expected to be subservient in height, scale, massand form to the surrounding frontage buildings. It should not prejudice theopportunity to develop the adjoining land of similar potential nor should theproposed access arrangements cause adverse impacts to the character andappearance, safety or amenity of the existing frontage development.”

Policy DM27 states that development “…will be expected to….enable existingand proposed development to achieve appropriate levels of privacy, outlookand daylight; and policy DM29, interestingly referenced in the residentialamenity section of the Planning Statement but not more formally in thePlanning Policy section, states that development, “will be expectedto…..ensure that existing and proposed development achieves appropriatelevels of privacy, outlook and daylight”.

Overarching local policy is consistent with guidance in the NPPF whichchampions “good design” and states at paragraph 130 that, “Planningpolicies and decisions should ensure that developments: create places thatare safe, inclusive and accessible and which promote health and well-being,with a high standard of amenity for existing and future users.”

On the basis of our review we conclude that the development is indeed a poorresponse to site context and an overdevelopment. This manifests itself incritical adverse impact on our residential amenity by reason of direct andperceived overlooking both to private gardens and by reason of direct windowto window distances and significant overshadowing.

These direct future impacts are compounded by the loss of existing trees andthe erosion of the residential amenity and outlook we currently enjoy.

The proposal lacks detail and on that basis we reserve our position to reviewand comment again on any additional information provided. However on thebasis of the application as submitted we consider that it is by reason ofadverse residential amenity impact contrary to prevailing planningpolicy and should be refused on this basis alone.

Yours sincerely

Appendix 1: letter to FORE Partnership 22 December 2021

22nd December 2021

FORE Partnership

Reference: St Christopher’s Public Consultation

Following our attendance at the St Christopher’s Public consultation. We the residents ofNos 21, 23 and 25 Bayswater Avenue have grouped together to provide a single sharedresponse to the consultation.

These are independent of any comments you may receive at this stage from the WPCAand SCAN groups. Notwithstanding, we are aware of the 6 “principles” agreed by WPCAand SCAN and we support these.

• RESPECT THE LOCAL HISTORY AND CONTEXT: Recognise the two distinctparts of the site – enhance and protect the villas at the front, and ensure that developmentin the rear land, behind the villas, reflects the scale and character of the 2-storey housingin adjacent streets.

• DO NOT MAKE OUR TRAFFIC AND PARKING ANY WORSE: Ensure that anydevelopment will not lead to any additional traffic or parking in surrounding streets - roadsafety must be prioritised.

• RESPECT OUR HOMES: Safeguard the privacy of properties surrounding the site- no new buildings should be taller than existing buildings in the rear land.

• BE GENUINELY GREEN: There should be a net gain in biodiversity; protectingexisting trees, landscape and wildlife. Plans must respond to the current global climateand ecological emergencies.

• DO NOT OVERDEVELOP THE SITE: This largely green space should not beoverdeveloped but should maintain and enhance the unique and special character ofWestbury Park, which is a designated Conservation Area.

• KEEP OUR CHILDREN SAFE: Recognise that, in the interests of public safety,there should be no access to the site from Bayswater Avenue or The Glen.

Thank you for undertaking this pre-application consultation and we appreciate the time,effort and cost associated with running such events. However, our representationssubmitted now are Without Prejudice to any comments we may make to the submittedPlanning and Listed Building Consent applications in due course.

The comments we submit are necessarily focused on how the development will directlyaffect us and are therefore somewhat negative in tone. However, as an introduction weappreciate the site needs to be redeveloped and support this in principle. While wetherefore support the retention and conversion of the Westbury Park villas; the retentionand conversion of the listed Grace House and the opportunity that presents itself for somedemolition and new building this must be undertaken with due respect to the characterand appearance of the Conservation Area and the area more generally and the characterand setting of Grace House; involve the retention (and safeguarding) of all important trees(whether the subject of a current TPO or not) and must cause no harm to, and potentiallyimprove, the residential amenity of all local residents.

Within this context our first substantive comment is that the information displayed at theconsultation event was to a large extent indicative and therefore vague. While theproposals have positively developed since the initial consultation and no doubt willdevelop further it was genuinely difficult to understand what the key elements of thecurrent proposal were. While those consultants at the event, presenting on behalf of thedevelopers where helpful, some questions could not be answered definitively and someleft key issues unresolved.

In the above context, our view is that describing the development as an “integratedretirement community” is vague and does not hide the fact that what is proposed is simplya residential re-development. Alongside this there was of course no reference to on-siteaffordable housing provision. At this stage and while the price and management costs ofthe eventual accommodation and services may dictate who can afford to live at the site,we assume that the City Council will insist on the provision of a substantial proportion ofaffordable housing. We also assume that as the site was bought on the open market withfull knowledge of the physical and planning policy context that no credible viabilityargument could be mounted against the provision of a policy compliant percentage andmix of affordable housing. In due course we would therefore be very interested in the formand location of this on the site.

The quantum of development was also unclear on the presentation boards although wewere separately advised that the total development was 120 units (25 via conversion and95 via new build) with “approximately” 65 parking spaces. Also, apart from via twoindicative and unscaled sections, there was very little detail on the scale of the buildingsand their external appearance. The relevant boards looked like they had subsequentlybeen marked in pen with storey heights noted as ranging from 4-6 storeys with 2 storey“cottages” and the conversion of the existing Villas. The nature of the use and the quantumand mix of development obviously also affects car parking and again it was unclear, withthe use class undefined, how the “approximately” 65 parking spaces referred to werederived. Also, the issue of public access was also somewhat unclear. While we supportthe public (or bookable) use of any facilities to be provided within Grace House we objectto any east – west public vehicular or pedestrian through route, which would have thepotential to adversely impact our residential amenity.

Consequently, we object to the retention and upgrading of the existing access to EtloeRoad / Bayswater Avenue and request that this be permanently abandoned / appropriatelyclosed.

Only “approximately” 65 parking spaces are referred to and there was no breakdownbetween allocated residents parking, visitors or staff or service vehicle parking. Only 65parking spaces for 120 apartments is approximately half the maximum standard requiredby the Council (if all the units were 1 bed) and this does seem woefully inadequate evenallowing for the potential age profile and sustainable location of the site. If on site parkingis in any way inadequate to serve this housing development; if the existing Etloe Road /Bayswater Avenue access is retained and upgraded or if a “public” through pedestrian /cycle or vehicular access is proposed, then there will be significant direct and indirecthighway, residential amenity and security impact for us and the other local residents.

All existing trees of any merit (whether TPOd or not) must be retained and protected fromharm immediately and in the long term. The trees are visually and environmentallyimportant to the character and appearance of the area; biodiversity and existing residentialamenity. This will also assist the “net zero” claims; bio-diversity gain requirements andsustainability generally.

We welcome the proposed restoration of the old cottage maintaining its current footprintand form and proposed use by the community.

The plans displayed showed two terraces of “cottages” facing the rear of our homes butthe only other detail provided was that gleaned from the indicative section, which appearedto show a two storey scale with rear gable design (perhaps taking a reference from thedwellings on Royal Albert Road). We have assumed that these “cottages” are indeedsingle dwellings rather than a collection of apartments. We support a two storey designapproach and would promote that across the whole site in the interests of our and otherresidents residential amenity; the character and appearance of the Conservation Area andthe setting of Grace House. However, land levels are not clear and the rear gables ofthese dwellings appeared to be not as wide and of a steeper pitch that those that existalong Royal Albert Road, therefore removing any claim that they are a design reference,and have windows shown implying roof space accommodation.

Related to the above is the distance these properties are from the site boundary and therear elevations of our homes. The existing relationship is not typical in that the boundaryis at an angle and this is not reflected in the layout. We haven’t been presented with scaledplans; accurate cross sections or elevations drawings but our estimate is that the proposedrear gardens are all less than 10m deep and that in some cases the rear elevation toelevation distance may be as short as only 12m. This would clearly and obviously bewholly unacceptable for us and the residents in any new properties. This would be furthercompounded if second floor roofspace accommodation was also proposed and is also inaddition to our significant objection to the loss of trees in this north eastern part of the site.

While the two storey scale of development proposed by these “cottages” is supported inprinciple any such accommodation must be sited sympathetically to the existing trees andsufficiently distant from our properties (having regard to their scale and orientation) suchthat reasonable landscaping can be accommodated and our privacy and generalresidential amenity is unaffected by reason of overlooking, overshadowing, noise or lightspill.

The siting and orientation of these two blocks of proposed dwellings means that ourexisting verdant outlook is removed; we are significantly overlooked and are at real risk ofbeing significantly overshadowed by development so close to the sites eastern boundary.

We would be grateful if you could consider the above and therefore reconsider yourproposals. We would be happy to review any revised plan you may prepare but would askthat these be clear in respect of tree removal and new landscaping, accompanied byappropriate existing topographical information; be drawn to scale and be clearly markedwith proposed levels and dimensions.

Yours sincerely

I support the redevelopment of the school but not on this scale. The buildings are toohigh, there are too many dwellings and not nearly enough parking spaces for the residents. Thestreets in this location are too narrow to cope with the traffic that will be generated and the impacton the local wildlife will be too great.

The proposed buildings are too high for the site.

Local street parking will be terribly impacted as a result of less than a fifth of the necessary carparking spaces being provided. It is already near impossible for visitors and tradespeople to parknear our home.

I am a regular visitor to the Glen and I am extremely concerned that the proposeddevelopment will make an adverse impact on the area.Also the current situation with street parking is difficult will get much worse with the residents,visitors, delivery vehicles and ambulances that will visit the site.Further work is required in order to :- Make the character of the proposed development more acceptable and sympathetic with theexisting residential houses in the area.- Come up with a proposal to deal with the increase in traffic and parking in the area, especiallyThe Glen; and- Ensure that, if anything, the tree cover is increased not decreased.

I am a regular visitor to the Glen and I am extremely concerned that the proposeddevelopment will make an adverse impact on the street. The green character of the site currentlywould change to scenery of dense urban oppressive buildings. The developers own report statesthat the visual impact on the Glen is 'moderate to substantial adverse', and the existing houses willbe dominated and overlooked by buildings out of character with the currently pleasant area ofBristol. The amount of greenery and the loss of trees proposed is incredible at a time when weneed to increase biodiversity in Bristol. We understand that the current very difficult parkingsituation will get much worse with the residents, visitors, delivery vehicles and ambulances that willvisit the site, through the narrow heavily parked side street.Further work is required in order to :- Make the character of the proposed development more acceptable and sympathetic with theexisting residential houses in the area.- Come up with a proposal to deal with the increase in traffic and parking in the area, including TheGlen; and- Ensure that, if anything, the tree cover is increased not decreased.

I just moved to the area and have become aware of this incredibly insensitivedevelopment plan. It's entirely out of keeping with the neighbouring properties and the localheritage, some of it seems incredibly cramped up against the remaining buildings and I am veryupset to see that so much green space, and so many trees will be lost. Not least, it would appearthat it's going to cause more parking issues in an already blighted area.

It's obvious the developers are just trying to maximise their profit by insensitively compressing toomany flats into too small a space. They can walk away from it, those left living in the area can't.

I think this will be a positive development for the area.

Having looked at the revisions, I find that my previous objections still stand and theapplication should be refused for the reasons previously stated.The 'revisions' are extremely small, and frankly cynical.The scheme is simply too large in footprint and far too dense.There is insufficient parking for the number of proposed dwellings, with a guaranteed knock-oneffect to congestion and road-safety concerns in the immediate neighbourhood.There are still plans to remove far too many mature trees. The scheme is by no objective view'landscape led' which I believe is part of the requirement. In fact it is only 'profit led' do thedetriment of nature and the environment.Furthermore, there is no affordable housing within the scheme.In summary these revisions are entirely insufficient.Yours sincerely.

Peter Lord (C0-founder and director of Aardman Animations)

The developers are obviously not committed to addressing our concerns or nationalstandards. It appears that they are treating this planning process like a game and have no respectfor the faculties of the Council planners.

I have reviewed the revisions submitted by the developer and my previous objections still stand.

A number of the revisions are cosmetic and do not address the concerns in any meaningful way:There is a minimal reduction in the number of unitsBuildings are crowded with respect to the area and neighbouring propertiesThe heights of buildings have been reduced by 30cm; this is laughable as it has minimal impact onvisual impactInsufficient parking and the new parking will have an impact on the residents of The Glen

The developers are obviously not committed to addressing our concerns or nationalstandards. It appears that they are treating this planning process like a game and have no respectfor the faculties of the Council planners.

I have reviewed the revisions submitted by the developer and my previous objections still stand.

A number of the revisions are cosmetic and do not address the concerns in any meaningful way:There is a minimal reduction in the number of unitsBuildings are crowded with respect to the area and neighbouring propertiesThe heights of buildings have been reduced by 30cm; this is laughable as it has minimal impact onvisual impactInsufficient parking and the new parking will have an impact on the residents of The Glen

To Bristol City Council

Re: Planning Application ref no 22/01221/F

I wish to object to the derisorily inadequate revised plans for 'after care' homes on the former StChristopher's School site which is in a CONSERVATION AREA.

I have been an owner and resident of my home in Royal Albert Road for over 37 years. Before Iexpress my objections, I wish to make the following comment.

In my previous communication about the Original Plans, I cited my objection to the proposedvehicle entrance to the site from Bayswater Avenue. This proposal was cynically submitted by thedevelopers, knowing that its proximity to a nursery, infant and junior school, a repair garage, and aroad junction (at times very busy) would ensure its rejection, thereby enabling the Revised Plans(for an alternative entrance) to appear to offer a huge concession. Westbury Park residents arenot fooled by this.

I object to the Revised Planning Application because it does NOT address the real concernspeople have expressed. The revised plans are largely cosmetic 'tweaks': a) 116 homes instead of122 (a reduction of only 6); b) blocks of flats still 5 storeys high; and c) Parking spaces on site foronly 65 cars (but with up to 200 residents on site!).

Objection 1) Traffic and parking CHAOS that will be caused.

Having up to 200 residents and only 65 parking spaces on site will inevitably cause overspillparking in adjacent roads in an area already plagued with such problems.

Parking on site will be needed for:

- Live-in staff- Maintenance workers- Cleaners- Gardeners- Cooks/café workers- Swimming pool attendants- Administrative staff- Visiting doctors/nurses/podiatrists etc- Friends and relatives visiting residents- Delivery vans bringing food and other supplies

With the decline of the high street and the advance of online shopping there will be manydeliveries by Ocado, Deliveroo, Amazon etc.

The obvious and inevitable overspill onto adjacent roads will be catastrophic in an area of largelyVictorian/Edwardian houses in need of constant maintenance. Maintenance workers and buildersneed parking space near to the houses they are working on because of having to carry heavyequipment.Many septuagenarians and octogenarians are opting to pay for 'care at home' rather then moveinto a residential home, or 'after care' facility. Carers, who may need to come three times a day,need somewhere to park.

There is an abundance of care homes already in this area, very many with many vacancies asevidenced by leaflets arriving through our letter boxes all the time informing us of this.

Objection 2: Increased traffic will be injurious to health and safety.

The increase in traffic will be injurious to all who live in the area, and especially the young whoeither attend one of the three local schools or walk (as recommended by Bristol City Council) tosecondary schools (opting for a healthy lifestyle).

Objection 3: Over development - never good but in a Conservation Area should not becountenanced.

The number of housing units has only been reduced by 6, from 122 to 116. Certainly the 4 and 5

storey buildings are not in harmony with the existing architecture of Westbury Park. In addition, 5-storey buildings are incomprehensible in an 'extra care' home for the elderly. The elderly opt for aflat on the first or second floor. Lifts are no inducement to living on the 3rd, 4th or 5th floor as liftscan break down, and the Grenfell Tower disaster is in everyone's mind.

Inevitably, too many trees will be sacrificed in the construction process and wild life will bedecimated. Wild life will not return to this concrete land.

Conclusion

Finally, I would like to record my disgust at the deliberate publication of the revised plans and theinvitation to reply at the busiest, most frantic time of the year, namely the Christmas and New Yearperiod. These are busy, stressful times in any year with queues at supermarkets and a hundredand one things to do to make these occasions happy ones for all.

This year (with the NHS at breaking point, with travel chaos arising from industrial action, aneconomic crisis, not to mention political instability and the war in Ukraine) it seems particularlycruel, cynical timing.

I hope that Bristol City Council will reject these 'tweaked' plans.

Happy New Year.

The Henleaze Society objects to the amended planning application no. 22/01221/F.

The revised plans would still create overdevelopment of this site, within the Downs ConservationArea. The number of proposed housing units reduced merely by 5% to 116 is insufficient. Therewould still be excessive height and bulk of apartment blocks up to 5 storeys, which are out-of-character in Westbury Park.The Grade II listed Grace House would be dwarfed by the proposed 4 apartment blocks nearby.There would be too few on-site parking places leading to parking and more traffic on theneighbouring, narrow streets, which would be unsafe for vehicles and pedestrians.Access from The Glen is inappropriate and unsafe. Access to the site by large emergency vehicleshas not been properly considered.This revised planning proposal would still lead to extensive loss of green space, mature trees andhabitats for wild life. Environmental matters have not been fully taken into account.There is a lack of provision of some affordable houses in this development plan.The loss of SEND school facilities on this site is disappointing, since SEND school places areneeded.

Commenter Type: Amenity - Residents Group

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:Having looked at the revisions, I find that my previous objections still stand and the

application should be refused for the reasons previously stated.

The 'revisions' are extremely small, and frankly cynical.

The scheme is simply too large in footprint and far too dense.

There is insufficient parking for the number of proposed dwellings, with a guaranteed knock-on

effect to congestion and road-safety concerns in the immediate neighbourhood.

There are still plans to remove far too many mature trees. The scheme is by no objective view

'landscape led' which I believe is part of the requirement. In fact it is only 'profit led' do the

detriment of nature and the environment.

Furthermore, there is no affordable housing within the scheme.

In summary these revisions are entirely insufficient.

Yours sincerely.

Having objected to the original development, I just as strongly object to these revisedproposals which do not in any sufficient way reflect on the grave concerns of the local community.The developers continue to show just as much contempt for the community, disingenuously timingthe second round of public consultation during the festive period in an attempt to reduce theamount of objections to their plans. Their "revised" proposals are minimal and in many ways aninsult to the local community which has from the beginning attempted to work with the developersto find a reasonable way forward for the site. Such attempts have only led to developersattempting to deceive local residents of the scale of their plans and publicly fear for their "businessmodel" if significant changes were to be made.

Firstly, I am particularly horrified about the proposal for vehicle access to be added to the site fromThe Glen. This street is a cul de sac and narrow in width. There has been a longstandingagreement with the site that the gate at the end of The Glen is to never be used and only inemergency cases. For many years, it has been a well used space in the local community withyoung children using the road to ride bikes, exercise and enjoy the outdoors. With this in mind Ihave grave concerns about the safety of any proposed vehicle access, with the clear dangers offast moving cars regularly coming in and out of the development presenting a great risk to thesafety of local children. Road safety is a very important issue for Westbury Park, with multipleincidents where children have been hurt or put at risk by fast moving traffic. In 2018, my sister washit by a car at the zebra crossing on Coldharbour Road - a crossing that is regularly used bychildren of both primary and secondary school age multiple times every day. This incidentinvolving my sister led to an A&E visit and long-lasting mental effects. The dangers of an

increased flow of traffic in an area populated by many young families, with multiple schools andnurseries just minutes from the proposed development, is a key reason for its unsuitability to ourarea. However, more specifically, the proposal to add vehicle access to The Glen presents furtherdangers on a small road on which many young children use every day. Alongside the road safetydangers, The Glen also has a well-documented issue with parking going back at least a decade.The proposed development - with a clear lack of parking for such a large development - will onlyworsen the parking issues around Westbury Park, but the proposal for vehicle access on The Glenwill mean this road is particularly hard hit. Furthermore, the plans to take away 6 parking spaceson The Glen in order to widen the road for emergency access to the site is also completelyunacceptable. Once again, The Glen has an unsustainable parking issue - with many residentsforced to regularly park many streets away from their homes. Taking away 6 parking spaces issimply not feasible. The design of the cul-de-sac simply means there is not the space for vehicleaccess on The Glen. It is inappropriate and unacceptable and betrays a promise the developersmade to the local residents.

The amendments that have been made by the developers are minor, if not insulting. The fact thatthe changes have been deliberately timed to coincide with the festive season, with the hope thatthis would lead to fewer objections is yet more evidence of the developers contempt for the localcommunity. Their unflinching desire to put profit ahead of the concerns and needs of the people ofWestbury Park is completely out of place with the values of Bristol as a city and the council thatstrives to represent us.

The proposals remain a clear overdevelopment, with a reduction of only 6 housing units and areduction of one floor in height of the highest block completely insufficient in meeting the needs ofthe local area, a designated conservation area. The development still continues to only provide 65parking spaces for now 116 units of housing. The overspill of cars and road safety consequencesof such on the local area is undeniable. The proposal of vehicle access from The Glen wouldmean this street would bear the immediate brunt of the chaos. As outlined in my previousobjection, original proposals for pedestrian access from The Glen (and vehicle access fromBayswater Avenue) were also hugely inappropriate. The developers originally promised the localcommunity that there would be no access, pedestrian or vehicle, from The Glen and this promisehas been twice broken now by the proposed developers. It is yet another example of thedevelopers refusing to listen to the community and instead looking to secure as much profit fromthe site as possible.

As a young person with special educational needs, I would like to particularly address the loss ofSEND provision on this site that comes with this proposed development. The vague offer of ashared room for special educational need usage is an absolute insult to the 70 year legacy ofSEND provision provided on site. Bristol has some of the worst SEND provision in the country andthe closure of this site will only worsen this issue. In my view, this site should not be developed forany usage other than SEND provision unless such provision is replaced elsewhere in Bristol.

I am also appalled by the continued proposals to fell around 40% of trees onsite, including twomature trees that the council arboricultural officer has said must be protected due to their culturalsignificance. Furthermore, fewer replacement trees are now being planted on site because there issimply not enough room for them to grow amongst the hugely dense buildings. The proposedreplacement trees will now potentially be planted miles away from the site, further worsening theclimate impacts of this development. Such environmentally harmful plans not only show a hugelevel of arrogance on behalf of the developers but also clearly disregards the council pledge to putthe climate emergency at the heart of all decision making. On this matter alone, the council mustreject these proposals or otherwise break their promise to the people of Bristol. It is a matter oftrust.

The developers' undeniable greed can also be seen in their continued refusal to include any kindof affordable housing within the development - they have told local residents that any such planswould be "incompatible with their business model". Furthermore, they have disingenuously pushedfor their proposed luxury retirement complex to be designated as a residential care home (ClassC2) as this therefore supposedly absolves them from providing any affordable housing, despiteprevious legal precedent.

I would also like to fully endorse the scathing criticism as submitted by Professor Robin Hambleton(TBD/TBD/TBD) and the objection of the St Christopher's Action Network (SCAN) (TBD/TBD/TBD)which both accurately capture the public outrage within the community at this proposeddevelopment, as well as exposing such as completely inappropriate and unacceptable for ourarea. Throughout this process, the local community has sought to engage with the developers in agood willed way to reach a reasonable understanding for the development of the site, recognisingthe need for the site to be developed in some way. In return, the developers have treated the localcommunity with deception and disdain, repeatedly ignoring the loud concerns that have beenraised as well as lying to local residents about the proposed plans for the site. There is noquestion that the developers values are out of step with those of the local community and thepeople of Bristol that Bristol City Council strives to represent. This amended proposal must berejected.

I have also attached my original objection below which was submitted on TBD/TBD/TBD. Icontinue to stand by my original objection in opposition to these "amended" plans.

I strongly oppose this development. I believe it is clear that the proposed overdevelopment is notonly completely inappropriate for and inconsistent with the character of the area, but that theattitude of the developers has been in conflict with the values of Bristol City Council and thepeople it represents. When local residents have previously raised concerns with the developersregarding their proposals, we have been told that changes would "not be compatible with their

business model". It is a concern of mine that this approach from the developers has beenextremely damaging and has led to a proposal that is completely inappropriate for our community.

The proposal of over 120 housing units would be across three large buildings, ranging betweenthree and six stories high. The current site consists of low rise buildings, as is appropriate for thearea and indeed Bristol as a whole. The tallest building would be visible from The Downs and thiswould therefore clearly be a completely inappropriate development for The Downs ConservationArea. The huge overdevelopment would also have a negative impact on surrounding streets,including The Glen. The proposed buildings would be significantly closer than the current onesand the overshadowing of neighbouring properties would have a big impact on noise, privacy, andlight.

The huge overdevelopment would also have another significant impact on the local community inthe form of cars and pollution. With over 120 housing units, the proposed plans only provide 65on-site parking spaces. The impact of cars on the surrounding area would be undeniable.Westbury Park already has a significant problem with parking, traffic and road safety. Most roadsare double parked with cars, with many residents regularly unable to find a parking spaceanywhere near their home. The large number of cars is already having a dire impact on roadsafety. In 2019, my sister was hit by a speeding car on the zebra crossing of Coldharbour Road,one of the closest main roads to the proposed development. This resulted in being taken to A&Efor medical care, and has left a lasting psychological impact on her. There have also been otherfamilies I know in the local area who have also had family members, including young children, hitby cars. The idea of more cars descending on the area, one that is full of young families, schoolsand nurseries, is absolutely horrifying. It is important to be aware of the fact that the 65 parkingspaces will not only be completely insufficient for the 122 housing units present onsite, but also forvisitors, carers, office and maintenance staff, and deliveries.

I also have particular concerns about the proposed pedestrian access at the end of The Glen. Ithas long been the case that the door to the St Christopher's site at the end of The Glen is foremergency uses only. To have permanent pedestrian access at the end of The Glen wouldunfairly change the nature of the cul de sac. With many young families living on the street and inthe area, young children use the road to play and bond. Pedestrian access to the site from TheGlen would lead to an increase in car flow on the road as residents, staff and deliveries search fora parking space before popping through the pedestrian access. Due to my family's pastexperience with my sister being hit by a car on the roads close to the proposed development thisis of particular concern to me.

I am also very disappointed and concerned about the environmental impact that this hugeoverdevelopment would have on the local community. It is incredibly disappointing that thedevelopers have not taken any sufficient steps to increase the number of trees or amount ofbiodiversity present on the site. In actual fact, over 50% of the trees on the site would be brutallycut down including many beautiful, mature specimens that would take decades to replace.

Furthermore, the plans would mean an overall loss of biodiversity of 7.3% and this is not compliantwith the Emergency Action Plan that puts the Climate and Ecological Emergencies at the heart ofall decisions. The supposed plans to replace the over 50% of trees that will be destroyed duringthis development are also not in line with Bristol City Council policy. The site is home to a hugeamount of wildlife, including woodpeckers, owls, bats and foxes. The proposed plans, along withthe undeniable increase that we would see in vehicles, traffic and air pollution would have a brutalimpact on the surrounding environment of the site and local area. These plans once again seem tobe in stark contrast to the values of the local community, one that deeply cares for ourenvironment. Given that the council has promised to put the climate emergency at the heart of alldecisions, it would be incredibly disappointing to see them support this development.

It is also incredibly disappointing that the developers have offered no provision for affordablehousing within this proposal, even though Bristol City Council and the government have bothclaimed that this is a "key target" of theirs. In actual fact, when local residents have previouslyshared their concerns with the developers regarding the overdevelopment and the lack ofaffordable housing within it, we have been told that affordable housing is "not compatible with theirbusiness model". This approach from the developers raises serious questions about a conflict ofvalues of the council and the surrounding community, and that of the developers.

The plans also fail to guarantee any provisions for young people with Special Educational Needsand Disabilities (SEND). In light of the legacy of St Christopher's School, which provided care forhundreds of children over a seventy year period, it is incredibly disappointing that this use of thesite is not addressed by the developers. There are already many care homes and older agefacilities within the area providing valuable care for seniors, and this is therefore perhaps not themost suitable use of the site. Following the previous comments from the developers regardingaffordable housing not being compatible with their business model, I am concerned that thisattitude has meant they have failed to adequately consider what the best use of the site wouldactually be, and have instead focused simply on what they believe would deliver them the mostprofit. Despite the fact that Bristol City Council have said that they are attempting to improve thequality of service for SEND young people in the city, there are no longer any residential careplaces in Bristol for children who need support. The St Christopher's site is also directly next doorto a local primary school, Westbury Park Primary School, who have long been interested in havingmore space for their students. It is incredibly disappointing to me that the developers have failed totake a more holistic approach to their development, and have not considered what use of the sitewould be most valuable to the community. Local residents have been very understanding of theneed to develop the site, but the huge overdevelopment that has been proposed is completelyinsensitive to and inappropriate for the local area.

For these reasons, I am strongly opposed to the proposed development. Planning permissionshould be refused.

Having objected to the original development, I just as strongly object to these revisedproposals which do not in any sufficient way reflect on the grave concerns of the local community.The developers continue to show just as much contempt for the community, disingenuously timingthe second round of public consultation during the festive period in an attempt to reduce theamount of objections to their plans. Their "revised" proposals are minimal and in many ways aninsult to the local community which has from the beginning attempted to work with the developersto find a reasonable way forward for the site. Such attempts have only led to developersattempting to deceive local residents of the scale of their plans and publicly fear for their "businessmodel" if significant changes were to be made.

Firstly, I am particularly horrified about the proposal for vehicle access to be added to the site fromThe Glen. This street is a cul de sac and narrow in width. There has been a longstandingagreement with the site that the gate at the end of The Glen is to never be used and only inemergency cases. For many years, it has been a well used space in the local community withyoung children using the road to ride bikes, exercise and enjoy the outdoors. With this in mind Ihave grave concerns about the safety of any proposed vehicle access, with the clear dangers offast moving cars regularly coming in and out of the development presenting a great risk to thesafety of local children. Road safety is a very important issue for Westbury Park, with multipleincidents where children have been hurt or put at risk by fast moving traffic. In 2018, my sister washit by a car at the zebra crossing on Coldharbour Road - a crossing that is regularly used bychildren of both primary and secondary school age multiple times every day. This incidentinvolving my sister led to an A&E visit and long-lasting mental effects. The dangers of an

increased flow of traffic in an area populated by many young families, with multiple schools andnurseries just minutes from the proposed development, is a key reason for its unsuitability to ourarea. However, more specifically, the proposal to add vehicle access to The Glen presents furtherdangers on a small road on which many young children use every day. Alongside the road safetydangers, The Glen also has a well-documented issue with parking going back at least a decade.The proposed development - with a clear lack of parking for such a large development - will onlyworsen the parking issues around Westbury Park, but the proposal for vehicle access on The Glenwill mean this road is particularly hard hit. Furthermore, the plans to take away 6 parking spaceson The Glen in order to widen the road for emergency access to the site is also completelyunacceptable. Once again, The Glen has an unsustainable parking issue - with many residentsforced to regularly park many streets away from their homes. Taking away 6 parking spaces issimply not feasible. The design of the cul-de-sac simply means there is not the space for vehicleaccess on The Glen. It is inappropriate and unacceptable and betrays a promise the developersmade to the local residents.

The amendments that have been made by the developers are minor, if not insulting. The fact thatthe changes have been deliberately timed to coincide with the festive season, with the hope thatthis would lead to fewer objections is yet more evidence of the developers contempt for the localcommunity. Their unflinching desire to put profit ahead of the concerns and needs of the people ofWestbury Park is completely out of place with the values of Bristol as a city and the council thatstrives to represent us.

The proposals remain a clear overdevelopment, with a reduction of only 6 housing units and areduction of one floor in height of the highest block completely insufficient in meeting the needs ofthe local area, a designated conservation area. The development still continues to only provide 65parking spaces for now 116 units of housing. The overspill of cars and road safety consequencesof such on the local area is undeniable. The proposal of vehicle access from The Glen wouldmean this street would bear the immediate brunt of the chaos. As outlined in my previousobjection, original proposals for pedestrian access from The Glen (and vehicle access fromBayswater Avenue) were also hugely inappropriate. The developers originally promised the localcommunity that there would be no access, pedestrian or vehicle, from The Glen and this promisehas been twice broken now by the proposed developers. It is yet another example of thedevelopers refusing to listen to the community and instead looking to secure as much profit fromthe site as possible.

As a young person with special educational needs, I would like to particularly address the loss ofSEND provision on this site that comes with this proposed development. The vague offer of ashared room for special educational need usage is an absolute insult to the 70 year legacy ofSEND provision provided on site. Bristol has some of the worst SEND provision in the country andthe closure of this site will only worsen this issue. In my view, this site should not be developed forany usage other than SEND provision unless such provision is replaced elsewhere in Bristol.

I am also appalled by the continued proposals to fell around 40% of trees onsite, including twomature trees that the council arboricultural officer has said must be protected due to their culturalsignificance. Furthermore, fewer replacement trees are now being planted on site because there issimply not enough room for them to grow amongst the hugely dense buildings. The proposedreplacement trees will now potentially be planted miles away from the site, further worsening theclimate impacts of this development. Such environmentally harmful plans not only show a hugelevel of arrogance on behalf of the developers but also clearly disregards the council pledge to putthe climate emergency at the heart of all decision making. On this matter alone, the council mustreject these proposals or otherwise break their promise to the people of Bristol. It is a matter oftrust.

The developers' undeniable greed can also be seen in their continued refusal to include any kindof affordable housing within the development - they have told local residents that any such planswould be "incompatible with their business model". Furthermore, they have disingenuously pushedfor their proposed luxury retirement complex to be designated as a residential care home (ClassC2) as this therefore supposedly absolves them from providing any affordable housing, despiteprevious legal precedent.

I would also like to fully endorse the scathing criticism submitted by Professor Robin Hambletonand the objection of the St Christopher's Action Network (SCAN) (03/01/2023) which bothaccurately capture the public outrage within the community at this proposed development, as wellas exposing such as completely inappropriate and unacceptable for our area. Throughout thisprocess, the local community has sought to engage with the developers in a good willed way toreach a reasonable understanding for the development of the site, recognising the need for thesite to be developed in some way. In return, the developers have treated the local community withdeception and disdain, repeatedly ignoring the loud concerns that have been raised as well aslying to local residents about the proposed plans for the site. There is no question that thedevelopers values are out of step with those of the local community and the people of Bristol thatBristol City Council strives to represent. This amended proposal must be rejected.

I have also attached my original objection below which was submitted on 22/04/2022. I continue tostand by my original objection in opposition to these "amended" plans.

I strongly oppose this development. I believe it is clear that the proposed overdevelopment is notonly completely inappropriate for and inconsistent with the character of the area, but that theattitude of the developers has been in conflict with the values of Bristol City Council and thepeople it represents. When local residents have previously raised concerns with the developersregarding their proposals, we have been told that changes would "not be compatible with theirbusiness model". It is a concern of mine that this approach from the developers has been

extremely damaging and has led to a proposal that is completely inappropriate for our community.

The proposal of over 120 housing units would be across three large buildings, ranging betweenthree and six stories high. The current site consists of low rise buildings, as is appropriate for thearea and indeed Bristol as a whole. The tallest building would be visible from The Downs and thiswould therefore clearly be a completely inappropriate development for The Downs ConservationArea. The huge overdevelopment would also have a negative impact on surrounding streets,including The Glen. The proposed buildings would be significantly closer than the current onesand the overshadowing of neighbouring properties would have a big impact on noise, privacy, andlight.

The huge overdevelopment would also have another significant impact on the local community inthe form of cars and pollution. With over 120 housing units, the proposed plans only provide 65on-site parking spaces. The impact of cars on the surrounding area would be undeniable.Westbury Park already has a significant problem with parking, traffic and road safety. Most roadsare double parked with cars, with many residents regularly unable to find a parking spaceanywhere near their home. The large number of cars is already having a dire impact on roadsafety. In 2019, my sister was hit by a speeding car on the zebra crossing of Coldharbour Road,one of the closest main roads to the proposed development. This resulted in being taken to A&Efor medical care, and has left a lasting psychological impact on her. There have also been otherfamilies I know in the local area who have also had family members, including young children, hitby cars. The idea of more cars descending on the area, one that is full of young families, schoolsand nurseries, is absolutely horrifying. It is important to be aware of the fact that the 65 parkingspaces will not only be completely insufficient for the 122 housing units present onsite, but also forvisitors, carers, office and maintenance staff, and deliveries.

I also have particular concerns about the proposed pedestrian access at the end of The Glen. Ithas long been the case that the door to the St Christopher's site at the end of The Glen is foremergency uses only. To have permanent pedestrian access at the end of The Glen wouldunfairly change the nature of the cul de sac. With many young families living on the street and inthe area, young children use the road to play and bond. Pedestrian access to the site from TheGlen would lead to an increase in car flow on the road as residents, staff and deliveries search fora parking space before popping through the pedestrian access. Due to my family's pastexperience with my sister being hit by a car on the roads close to the proposed development thisis of particular concern to me.

I am also very disappointed and concerned about the environmental impact that this hugeoverdevelopment would have on the local community. It is incredibly disappointing that thedevelopers have not taken any sufficient steps to increase the number of trees or amount ofbiodiversity present on the site. In actual fact, over 50% of the trees on the site would be brutallycut down including many beautiful, mature specimens that would take decades to replace.Furthermore, the plans would mean an overall loss of biodiversity of 7.3% and this is not compliant

with the Emergency Action Plan that puts the Climate and Ecological Emergencies at the heart ofall decisions. The supposed plans to replace the over 50% of trees that will be destroyed duringthis development are also not in line with Bristol City Council policy. The site is home to a hugeamount of wildlife, including woodpeckers, owls, bats and foxes. The proposed plans, along withthe undeniable increase that we would see in vehicles, traffic and air pollution would have a brutalimpact on the surrounding environment of the site and local area. These plans once again seem tobe in stark contrast to the values of the local community, one that deeply cares for ourenvironment. Given that the council has promised to put the climate emergency at the heart of alldecisions, it would be incredibly disappointing to see them support this development.

It is also incredibly disappointing that the developers have offered no provision for affordablehousing within this proposal, even though Bristol City Council and the government have bothclaimed that this is a "key target" of theirs. In actual fact, when local residents have previouslyshared their concerns with the developers regarding the overdevelopment and the lack ofaffordable housing within it, we have been told that affordable housing is "not compatible with theirbusiness model". This approach from the developers raises serious questions about a conflict ofvalues of the council and the surrounding community, and that of the developers.

The plans also fail to guarantee any provisions for young people with Special Educational Needsand Disabilities (SEND). In light of the legacy of St Christopher's School, which provided care forhundreds of children over a seventy year period, it is incredibly disappointing that this use of thesite is not addressed by the developers. There are already many care homes and older agefacilities within the area providing valuable care for seniors, and this is therefore perhaps not themost suitable use of the site. Following the previous comments from the developers regardingaffordable housing not being compatible with their business model, I am concerned that thisattitude has meant they have failed to adequately consider what the best use of the site wouldactually be, and have instead focused simply on what they believe would deliver them the mostprofit. Despite the fact that Bristol City Council have said that they are attempting to improve thequality of service for SEND young people in the city, there are no longer any residential careplaces in Bristol for children who need support. The St Christopher's site is also directly next doorto a local primary school, Westbury Park Primary School, who have long been interested in havingmore space for their students. It is incredibly disappointing to me that the developers have failed totake a more holistic approach to their development, and have not considered what use of the sitewould be most valuable to the community. Local residents have been very understanding of theneed to develop the site, but the huge overdevelopment that has been proposed is completelyinsensitive to and inappropriate for the local area.

For these reasons, I am strongly opposed to the proposed development. Planning permissionshould be refused.

The build will worsen traffic and parking in the area, which is already difficult, and affectwildlife.

• This site (and others) must be redeveloped in a way that meets the density policy, not only to meet that specific policy requirement, but in order to provide the homes that the Bristol community needs, as set out in the Core Strategy.

• At 1.9ha, the 116 dwellings proposed equate to a density of 61 dwellings per hectare. This is toward the lower end of what the Local Plan requires and is a result of an assessment of site constraints and other factors.

We made an argument in our original objection about overdevelopment (points 4.2 to 4.9) that applying a single density to a site with two such different parts (frontage and backland) is very poor practice. Using our approach, commonly applied across the country, the density on the backland area would be c.180 dwellings per hectare, above the City Council’s maximum level for this area of Bristol.

The importance of maximising previously developed land is, of course, recognised but as the recent letter (1st December) to local authorities from Michael Gove, Secretary of State for Levelling Up, Housing and Communities states: “Developments that are not well-designed should be refused planning permission and housing targets should not be used as a justification to grant them permission.” We agree with this.

The Unacceptable Scale and Impact of the Proposed Development

• The total number of homes is now 116 (down from 122). • The height of Villa B has been reduced by one storey and height of all the other villas

has been reduced by 300mm. • Footprints of Villas A & B have been reduced and additional chamfers added to façades

facing Grace House. Footprints of each of new build blocks have been reduced. (This is confusing; it is not clear if all footprints have been reduced or just those for Villas A and B.)

• The eastern row of cottages has been moved south. These cottages are at an oblique angle. Measuring from the Bayswater Avenue properties to the proposed cottages the dimension varies between 18m to 22.8m.

• The two cottages adjacent to the Bayswater Avenue access have been replaced with a single storey bungalow to reduce the impact on Grace house, (with) obscured glazing to its first-floor windows with an addition(al) clear glazed window to its north elevation facing away from Bayswater Avenue.

• New blocks have been offset from the existing Lodges where possible providing views from within the lodges towards open garden spaces.

• Amenity space for residents in the refurbished Grade II Listed Grace House, with elements open to the wider community, and in what we are calling an ‘Urban Village Hall’ where we will curate activities for Westbury Park and beyond.

The proposed marginal reduction in the number of units makes no basic difference at all to the overall bulk, scale and ground coverage of the proposals. The part of the backland covered by buildings is still almost the same as in the original scheme and this approach is clearly not ‘landscape-led’ as the City Council are seeking and which we fully support.

One storey has been removed from Villa B but, as the amended Verified Views report shows clearly (and as did the original report), this still leaves the other three blocks inappropriately high and seriously visually intrusive all around the site. Though views from surrounding houses are not something to be formally taken into account, the visual impact on those residents will be horrendous.

The reduction of Villa B from six to five storeys might prevent visibility of this block from The Downs but it will still exceed the height of the Lodges and be visually conspicuous from many other viewpoints (also see Grace House section below).

Removing from the original scheme the two northernmost cottages to the east is an improvement, especially in terms of tree loss (see later section). However the replacement of the two cottages by a single bungalow called “Woodland Glade Cottage” is a clear step back. A glade is ‘an open space in a wood or forest’ allowing light to penetrate. That space would now be filled with a building and that building and small garden would be almost permanently deprived of sunlight.

The 300mm (just one foot!!) parapet height reduction, chamfering, offsetting the new Villas etc. are all completely inconsequential to the basic point about the amount and heights of the proposed development and their negative visual and intrusive impact on the predominantly two storey surrounding residential areas.

In addition:

No mention is made in any of the revised scheme documents of the distances between the blocks; a key point in the comments from the City Council Conservation and Design Team. Though some improvements have been made as a result of reduction in building footprints, there are still a number of occasions where window to window (and certainly balcony to balcony) distances are below, sometimes almost half of, the necessary 20 metres. The applicants also acknowledge that some of the distances between Bayswater Avenue houses and the eastern cottages are less than the standard (in fact they point out that some are more than 20 metres and some less, almost implying that averaging out is acceptable).

We wish to re-affirm our objection concerning the amount of development crammed inappropriately into this site, the height of all the new blocks and the distances between the new blocks and from the new blocks to surrounding properties. This is massive overdevelopment which damages the recognised character of this area as a whole. And, of course, it damages the Conservation Area (see Listed Building section).

Design

• Entrances to the new villa blocks are now defined with a contextual interpretation of the Victorian villa entrance. The entrances to the new villa blocks are on the side of the buildings, reflecting the side entrances to the existing Victorian Lodges.

• The proposed façades have been refined following further analysis of the fenestration on the neighbouring frontage villas along Westbury Park. The proposed windows now combine a vertical emphasis and variety of sizes to achieve vertical and horizontal hierarchy, better reflecting the frontage villas along Westbury Park.

• The proposed roof form reflects the mansard roofs found on neighbouring villas along Westbury Park which is their primary reference. There are a number of mansard-like roof forms along Westbury Park, these include dormers and slate roof tiles, all of these aspects have been reflected within the proposed design.

• Following further analysis of the Westbury Park frontage villas, the facing materials have been changed to red brick.

We do not wish to dig into matters of detailed design but:

1. We are not aware of anybody actually asking for chamfered corners, for changes to the fenestration pattern or for entrances that reflect the side entrances to the Lodges.

2. There is clearly an attempt to try to secure support for the new Villas by constantly referring to design details from Westbury Park (the street) rather than – as we believe should be the case for the backland area - from the houses in Royal Albert Road, Bayswater Avenue, The Glen and Blenheim Road.

3. The design changes are based on formal elevations, which is not how people experience buildings when walking along.

We object to the applicant’s use of selective design references in a forlorn attempt to ameliorate the impact of the proposed overdevelopment of the site. Grace House

• The previously proposed spa extension has been removed from Grace House. The new spa building now sits to the north of Grace House, along the boundary, and is no longer attached to the listed building.

• Views of Grace House will be opened up on entering the site from both Westbury Park and Bayswater Avenue, making the building more visible within its enhanced green setting.

• In order to retain the original shadow gap around Grace House a carefully conceived edge detail will be developed to keep any raised levels set back from the original building. This will allow the shadow gap to be appreciated by those in close proximity to the building edge when the full height of the building will continue to be appreciated.

• The chamfers on the entrance façades of Villa blocks A & B gently undulate in and then out again on the approach to Grace House; this visually and physically frames the view of the listed building on approach from Westbury Park with deliberate yet subtle and expressive geometries. The eastern corner of villa A aligns with the SW corner of Grace House.

• The proposed amendments to the area behind Grace House includes consolidated service/plant areas and relocation of the refuse store along the boundary which, together with the removal of the external fire escape, allows for the introduction of more soft landscape along this edge. A simple green roof pavilion building extends along the boundary in place of the existing sheds; this pavilion building includes a combination of ancillary and wellbeing spaces.

• The expressive splayed dormers at roof level make a gentle reference back to the more eccentric roof of Grace house without detracting from the primacy of the listed building.

Relocating the spa building may help in terms of safeguarding the character of Grace House but it would mean that users of the facilities in Grace House would have to walk in the open from across to the spa.

Opening up better views to Grace House, emphasising the ‘shadow gap’, chamfers, tidying up the buildings to the north and splaying dormers may all be simple design improvements but they make absolutely no difference to the overall balance between Grace House and the proposed new Villas. This is also about the issue of distances between buildings (as in the Overdevelopment section above). The key issue here is the distance between Grace House – specifically at its main entrance – and Villa B, probably around 10/12 metres. The photo overleaf is from the entrance to Grace House (note the railing at the front). The sketch is taken directly from the photo so can be regarded as appropriately accurate. It shows the appalling impact on the setting of Grace House of the five storey Villa B at this location (note the entrance railing again and the need to significantly raise the eyeline in order to show the height of the new Villa).

We wish to re-affirm our objection to the proximity of the proposed Villa B to Grace House and to the failure to provide an appropriate setting to Grace House.

Landscape

• The landscape setting has been redesigned so as to retain and enhance the verdant nature of the site and wider conservation area. This also allows for the retention of an additional five existing trees.

• The northerly cottages have been replaced with a single storey cottage which sits within the footprint of the existing building to enable trees to be retained in this location.

• Through the retention of trees and a new approach to the landscape design, the sylvan setting is retained and enhanced to create a woodland glade around Grace House.

• The new landscape design proposals make a clear definition between the public and private realm.

• The shadow gap around Grace House will be screened by the lush new landscaping which will enhance the overall setting of the listed building

• Overall layout changed so that the setting of Grace House within its wooded area setting is appreciated. The landscape around the building is a wooded area/natural setting that is enhanced with additional tree planting.

• The overall landscape has been reviewed, minimal intervention proposed to the existing setting access and new tree planting complementing and enhancing the existing wooded area.

• The villas and its landscape have been designed as individual precinct respecting the original villa boundaries with the landscape becoming a landscape to be viewed as a visual amenity with minimal intervention. Existing trees are retained with a wild flower meadow introduced to the front and edge of the site. A sculpture/piece of art introduced within the revived historic frontage respecting the villa setting.

• A clear access and wayfinding strategy has been progressed that creates a special moment as one walks their way through the site. The East/West connection has been defined to create a cohesive route.

• Trees have been strategically located and a thorough strategy has been devised. The built form now sits proudly with a clear strategy for public and private landscape edge.

• A thorough review has been carried out in regard to future canopy spread of proposed trees.

• Tree planting strategically done and accords with the NHBC Trees near building standard.

(Some of the comments above could also apply to the Overdevelopment and Grace House sections.)

In general, the landscape layout and design has been improved as per several of the responses noted above, including in relation to aspects of the setting of Grace House (but see comment and photos above).

We note that, in their response to the original masterplan, the City Council commented that the enclosure ratio of 1:1 is too uncomfortable and not appropriate in a verdant Conservation Area and will overshadow the public realm. We agree with this assessment and are of the view that the revised proposals do not respond sufficiently to this criticism.

The comment about retaining an additional five trees is ‘economical with the truth’, because the amended arboricultural report notes the five trees to now be retained but then mentions a further two to be removed. A total of 39 trees were to be removed with the previous scheme and the changes still mean the removal of an unacceptable number of 34 trees out of 82.

We have commented above about the bizarre notion of introducing a ‘glade’ to the north east then filling it with a permanently shaded building!

There is minor but no fundamental improvement in the ‘clear definition between the public and private realm’.

The ‘wayfinding’ comment is valuable but hardly a ‘strategy’. No explanation is given anywhere for what is, what is not and at what times the site or parts of it are open to ‘the community’.

Despite some minor improvements, we re-affirm our objection to the removal of such a large number of often good condition and certainly visually important trees. And the scheme is still not (as we and the City Council wish to see) ‘landscape-led’.

Parking

In submitting the revisions the applicant has either reiterated or made several new statements about parking:

• The proposals include 65 spaces, which is over the standard. The extra spaces will reduce the risk of overspill parking onto residential roads.

• Whilst the number of units has been reduced from 122 to 116, the number of proposed parking spaces remain the same, so the ratio of parking spaces per unit (0.56) has increased marginally.

• The parking survey (Transport Statement - Appendix G) demonstrates that although the site has more parking provision than is needed, there are spaces available off-site should there be any overspill.

• Parking is now provided off The Glen, in response to confirmation from Highway officers that they will not support use of the Etloe Road access for parking (other than related to substation maintenance).

• We have also looked nationally at a number of Integrated Retirement Living schemes. Applying the parking ratio of these schemes to the proposed development the proposed site would require 56 spaces.

The applicant states that there are 65 spaces but the revised Transport Statement paras. 6.7 and 6.9 lists just 62 spaces, i.e. 37 resident spaces, 10 staff spaces, 4 accessible spaces, 8 charging points, 2 car club spaces and I minibus space.

In April 2022 the Community Association objected to the original application on a number of grounds including that the 65 parking spaces proposed by the applicant was insufficient and would lead to overspill parking on surrounding roads which are already at full parking capacity.

We also queried the claim that the 65 spaces figure was over the standard as this claim was based on the incorrect application of Bristol City Council’s C2 resident care home parking standards (see earlier comments on C2 land use designation). The parking standard for care home visitors was mistakenly used to assess the parking requirement for St. Christopher’s residents, an independent living scheme. Additionally, the staff parking requirements were underestimated while no attempt at all was made to assess visitor parking requirements for either those visiting residents or for non- residents attending community facilities and events at Grace House and the proposed urban village hall. (NB. One of the ‘selling points’ of the development is that non residents will be allowed to use the facilities and enjoy the grounds.)

We estimated that a total of between 60 and 70 spaces would be required for residents’ parking, between 16 and 22 spaces for staff, between 12 and 15 spaces for visitors and three spaces for the car club and minibus making the overall requirement for spaces in the range 91 – 110 spaces with the actual number required within this range depending largely on staff (FTE) numbers, shift patterns and changeovers, and the age profile of residents.

In our previous submission we pointed out that the applicant had acknowledged that there might be overspill parking by stating that the proposed provision would “reduce the risk of overspill parking”. The applicant has now further acknowledged the risk of overspill parking by stating that “although the site has more parking provision than is needed there are spaces available off-site should there be any overspill”. This statement is based largely on night time parking surveys conducted in November 2022, the results of which are presented in Appendix G of the applicant’s Transport Statement

The parking surveys were conducted on a Monday and Wednesday at night – between 10.00 pm and midnight. We can only assume that this time frame was selected as it was calculated that this would be the most advantageous time as far as the applicant was concerned in demonstrating the availability of on street parking spaces in the vicinity of the St. Christopher’s site. Indeed, the surveys did show 30 and 27 free spaces respectively on the two survey nights. A survey(s) conducted during daylight hours when residents, visitors and staff are far more likely to be looking for spaces would have shown a very different picture with virtually no spaces available within 150 metres (as demonstrated by several community surveys conducted in recent years) and obviously clear to anyone who has tried to park in nearby roads during the day and at night.

Most of the available spaces revealed by the two night time surveys were along Westbury Park which is fully parked up during the day by commuters and freed up at night. Westbury Park is some distance from houses and is therefore best avoided by local residents at night for safety and security reasons (as it would likely be by future St. Christopher’s residents). The surveys actually indicated that the roads closest to St, Christopher’s and likely to be

most affected by any overspill parking (Belvedere Road, The Glen, Bayswater Avenue) had very few available spaces, confirming parking surveys conducted in recent year by the Community Association and by local residents.

On a technical note it would appear that the parking survey extended to a 150 metres distance from the respective edges of the St. Christopher’s site and thus included roads and parts of roads which would be well beyond a 150 metres distance that future residents living in most parts of the site would have to walk to reach their cars.

The new proposal for vehicle and pedestrian access to the St. Christopher’s site from The Glen will increase even more the likelihood of overspill parking in The Glen, Belvedere Road and nearby roads. With this access it will be easier for residents to walk to and from surrounding roads should they choose not to pay for an on site parking space or are unable to find an available space within the site. In addition, attendees of events at the proposed Urban Village Hall and SEND related visitors will almost certainly be drawn more towards parking in The Glen etc. because of their proximity to this facility.

The Transport Statement submitted with the revised proposals included a new table and analysis (para. 6.17, page 22) which attempted to demonstrate that the parking provision proposed is sufficient by reference to four integrated retirement schemes elsewhere in England.

The choice of the four cited schemes is somewhat surprising for the schemes do not in any way support the argument that 65 spaces on the St. Christopher’s site will meet the parking needs of residents, staff and visitors. Three of the schemes were, unlike the St. Christopher’s site, close to city/town centres and involved a variety of car parking regimes (lift systems etc.) that would almost certainly act as a disincentive to owning a car: the fourth scheme, Beechmoor Nurseries, had a relatively generous overall parking provision compared with what is being offered at St. Christopher’s. Details of each scheme are included in the Appendix but the conclusion is clear – 65 parking spaces is inadequate.

For the reasons stated in our previous submission and for the reasons / arguments/ counter arguments set out in this submission we still hold strongly to the view that that the proposed parking provision is too low and will inevitably lead to overspill parking on surrounding streets which are already at full parking capacity.

Community Engagement and Imagery

The applicants state in their December 2022 newsletter that:

“After extensive consultation and engagement with the community over the last 18 months including numerous in-person and virtual events, written submissions, broad reaching surveys, and electronic comments, we have taken on board the feedback received and have amended our plans in response.”

We made very, very clear in our own report on the community engagement prior to the original application that, although the range of engagement activities was acceptable, their delivery in detail was hopelessly inadequate – the workshops descended into farce, the exhibitions offered very limited scope for commenting and the surveys were seriously rigged to get the results the applicants wanted.

In relation to the revised application, we note that, although the revisions would have been developed well before their submission, no further community engagement of any kind was undertaken during this period. This is also despite the fact that a Planning Performance

Agreement was being developed (and is now in place) and both national and Bristol City Council requirements for a PPA include community engagement prior to application.

We re-affirm the extensive critique of community engagement in our original objections and object to the complete lack of necessary community engagement on the revisions.

Both our original objection on overdevelopment and our report on the submitted Statement of Community Involvement also criticised the imagery used, not just in the application material but also at all stages during the engagement period.

In the material submitted for the original application, in the revisions to the application and in the applicant’s recent newsletter, there is very limited imagery, especially imagery that shows the new Villas in relation to one another, in relation to the Lodges and in relation to surrounding streets and properties. Given that all this material is CAD-based where it is extremely easy to produce very good quality or even just basic images, this can only be a deliberate ploy to make it difficult for lay people to properly interpret the actual, as experienced, implications of the proposals.

The amended Design and Access Statement includes just two images, one (p.6) using the dark, almost twilight format used in the original application and one (p.17, repeated in the newsletter) showing a new view from the ‘woodland glade cottage’ towards Grace House* and Villa B. The 3D versions of the blocks (pp.24-27) provide some help in assessing building relationships but that is very limited. (*It had been agreed with the applicants, several months ago, that the inclusion of Grace House in imagery would no longer take place because, even in the latest image, it distorts the overall effect of the four huge Villa blocks. It is unclear why they have ignored that agreement.)

We object to the imagery used in the revised proposals and to the overall lack of imagery to show the all-important relationships between the new Villas, the Villas in relation to the Lodges, the Villas in relation to Grace House and the Villas in relation to surrounding streets and properties.

The View of the Secretary of State

Having elaborated our objections, we think it appropriate to end by quoting further from the December 2022 letter referred to earlier from Michael Gove, Secretary of State for Levelling Up, Housing and Communities. In the letter he states the following:

• “…. all development that is not good design should be refused, especially where fails to reflect local design policies.”

• “ …. councils to set clear standards for what they and the local community find beautiful and refuse what they find ugly”.

We trust that Bristol City Council will also take these statements fully into account when determining this application.

APPENDIX

The four schemes cited in the revised Transport Statement as examples where parking provision was lower than that being proposed at St. Christopher’s are detailed below.

Epsom This application was refused on appeal but a second application for 305 care units and 24 key worker units was subsequently approved on appeal. The proposed development is close to Epsom town centre so that there is less need for residents to own a car compared with the more suburban St. Christopher’s site. The scheme involves an automated parking system requiring residents to drop off their vehicles using a lift system – hardly an inducement to owning a car. On a point of accuracy, the number of proposed parking spaces was 156 rather than the 150 indicated in the table in paragraph 6.17 of the Transport Statement. Bath This application on the former Homebase site was allowed on appeal. The site is close to Bath City Centre and so a lower level of parking provision was deemed acceptable by Bath City Council as it reflected the 0.5 level of car ownership per dwelling in Bath City Centre revealed by the 2011 Census (By way of comparison St. Christopher’s is in Henleaze Ward where car ownership per dwelling in 2011 was 0.84 per dwelling in the adjoining Redland Ward the respective figure was 0.79 per dwelling.) The 136 space residents’ car park comprises a double and triple stacking system requiring residents to drop off and collect their cars from a valet. With a further 16 spaces proposed at street level the total provision is 152 spaces rather than the 136 indicated in the Transport Statement. The Bath site is in a commercial area with strict parking restrictions and the nearest residential streets are in a residential parking zone (unlike the residential areas closest to St. Christopher’s). The nearest available on-street spaces are more than 500 metres away. Walton-on-Thames This application, comprising 196 extra care units and 26 nursing home care units, was refused by Elmbridge Borough Council on several grounds (including insufficient on-site parking) and subsequently allowed on appeal. The proposed 122 spaces included 98 basement spaces accessed via a car lift – again rather a disincentive for owning a car. In respect of the parking provision it was mentioned in the appeal decision letter that (i) there were two car parks within easy walking distance available for visitors and possibly staff to use and (ii) a number of surrounding roads were private roads which could not be used for unauthorised parking. Beechmoor Nurseries This application was refused by Chester West and Chester District Council but allowed on appeal. The scheme comprised not just 85 assisted living apartments but 25 care bungalows as well – a total of 110 units. The total parking provision was 87 spaces including visitor spaces. To equate to this level of parking provision the St. Christopher’s scheme would require approximately 90 spaces rather than the 65 spaces proposed.

Once again developers submitted an application that they expected to be refused andnow have revised their plans with a view to getting acceptance for what is largely thesame proposal. I submitted my objections to the original plans and follow here with myobjections to the current proposals. Bearing in mind the position and importance of thissite in relation to the Downs, and it being a conservation area I state:A reduction of 6 units i.e. 5% is totally inadequate, the scale and size of the newbuildings is totally unacceptable for the site. Many of the buildings proposed are still tooclose to existing houses and to each other. (See national standards on this point.)Reducing the height of Villa B means you can't see it from the Downs, but it is still toolarge and intrusive. Similarly reducing the footprint of Villas A,B,C and D does not getaway from the fact that the site as planned is very overcrowded. Reducing the height by300mm (1 foot) is a joke.Parking is still inadequate. 65 spaces in total will not cope with residents' and staffparking. The surrounding streets are already at capacity.I welcome the reduction in the number of trees to be felled, but don't see any signs ofthe 'landscape-led' scheme as preferred by the Council.

We write in objection to the revised plans for the site submitted under the originalreference.we are concerned that these proposals are presented as if they are significantly different from theoriginal submission. We do not believe that to be the case as they reflect only minor changes andthe mass of the building and its impact on neighbouring residents remains unacceptable. Whist thechanges are a small step to improving the application they fall well short of addressing residentsconcerns.

We are also unhappy with the timing of the submission and its impact on residents' ability torespond over the festive period. Any reduction in the number of objections is likely to be as a resultof this timing and not due to change in opinion of those affected.Our position remains as previously recorded. We welcome the concept of accommodation forolder residents within the community. However, we are very aware that this area of Westbury Parkis unique and the current plans do not recognise the importance of the proximity to the Downs andthe impact on the neighbouring houses which are already situated more than a metre below thesite, so will be overwhelmed by the proposed structures. It would still be daunting if the proposedbuildings were aesthetically pleasing, but is not surprisingly upsetting affected residents in itscurrent form.Apart from concerns about the overdevelopment. the loss of trees and so much green space isalso a matter for concernThe area is already saturated for parking, and we have no way of assessing whether thedevelopers claims are justifiable. It would appear that access to and exit from the site will bedifficult, as none of the local roads provide clear access or have capacity for delivery vehicles.

During construction and subsequent occupation there will inevitably be more traffic flow and anattempt to find more parking spaces. The area is already under commuter pressure as the areajust outside of a parking zone close to the main bus routes, and we see nothing that will helpalleviate this pressure in the proposals.We remain of the view that this application is not appropriate

Cllrs Geoff Gollop Sharon Scott and Steve SmitCouncillors for Westbury-on-Trym and Henleaze

This development (even with the minor amendments) is a gross overdevelopment of thesite. The tall buildings, increased traffic and inadequate parking provision will all damage thenature and lifestyle of the area. Access of such an increased volume of vehicles throughresidential areas will be hugely detrimental to the quality of residents life.

I submitted an objection to the original planning application and this still stands for thisnew proposal.

The changes proposed are minimal and mostly cosmetic and go nowhere near to addressing thevery real concerns of the local community:

Overdevelopment. Reducing the number of homes from 122 to 116 and still building 4- & 5- storeyblocks of flats is only a token amendment to the original plan. The scale of this development is stilltoo big, too dense and too high and totally unsuitable for the Westbury Park area and the widercommunity.

Traffic. The site is surrounded by narrow streets. Residents take up most of the parking spacesand commuters the rest. This will lead to overspill and safety hazards in an already verycongested residential area. Building 6 fewer homes will not adequately address these traffic,parking and road safety issues.

Loss of trees and habitat wildlife. There are still too many mature being felled - the number hasbeen reduced but not significantly - which will have a serious impact on the biodiversity of thisbeautiful conservation area.

Harm to heritage. The scheme is totally out of character with our neighbourhood and disregardsthe fact that this is a designated Conservation Area.

I therefore continue to believe that this planning application should be refused for the reasonsstated.

Flats are too high, and there are huge issues relating to parking. Westbury park is adensely populated area and local residents find it impossible to park as it is.

I object to the revised proposals to develop the St Christopher's school site.

- The revisions that the developers have made since previous objections were received are notmaterial and do not properly or adequately address the objections made. An example of this is thereduction in the number of dwellings from 122 to 116 - that is not even a 10% reduction, thechange is minimal and immaterial; this is a clear example of the developer apparently trying toshow changes to address objections but in fact making changes that are merely window dressing.This is not acceptable and the "revised" plans should not be allowed through given this.- I particularly object to the complete removal of SEND provision from a site that has historicallyprovided this vital service to vulnerable children in the Bristol community. The site contains GraceHouse which is a building of historic importance (acknowledged by its listing in 2019) and whichwas architecturally designed as a one off Steiner teaching building, with its design aiming tospecifically provide for disabled children and to physically express the Steiner educational ethosand philosophy. This is surely a precious, unique resource that the council and community shouldstrive to retain and improve. I understand that the original building was designed to sit in an opengarden setting. The current plans do not respect this, let alone improve on it. It seems instead thata mass of large, tall buildings will overshadow Grace House and use up much of the existinggarden/open land and trees so that Grace House will no longer sit within and provide access to anatural outdoor setting. It seems that the current plans provide only cursory provision towardsanything that could be used for SEND provision. I think plans for the site should give this a fargreater prominence, they should respect the historic SEND provision on the site, improve on it anduse and improve Grace House for the purposes for which it was designed - it could become a

beacon of excellence in SEND provision. It is also known that intergenerational living is beneficial,so if there is to be a retirement community which sounds like a good idea, then having this alsowith SEND provision and enabling interaction between the two would be an innovative wayforward.- The current plans are not in keeping with the nature and scale of buildings in Westbury Park andthe conservation area within which they sit. The four large blocks leave inadequate green space.They will negatively affect views from the Downs and having insufficient green space willnegatively impact the people living in the blocks.- I understand the plans will involve removing around 40% of mature trees on the site. Maturetrees provide a natural habitat for plants, insects, birds, fungi etc which is instantly lost when theyare felled and which by its nature takes decades to replace because mature trees are decadesold. Planting a sapling and getting it to the point of growing into an independent tree is a resourceintensive exercise as seen from the constant efforts to keep replanting trees around the Downsetc, and with climate changes leading to long droughts such as last summer it is particularlydifficult to get new trees established. Taking down numerous mature trees is therefore aneconomically and ecologically negative exercise. Having mature trees growing together in a groupas on this site also has special extra benefits for habitat and it is increasingly understood that treesthat have grown together for many years work together via their roots and other systems.- Having such a large density of new residences with inadequate parking does not seem to havebeen properly thought through and this needs further work and improvement before any plans cango ahead.

I think this proposal is a massive overdevelopment of a sensitive site overlookingDurdam downs. The area is already highly congested with passing traffic throughout the day. Thisoverdevelopment will make it much worse. It also represents a sad loss of much needed SENDeducation and the loss of historic buildings. It has nothing in it's favour and offers no much neededaffordable housing. This is the wrong development and council must do the right thing and reject itoutright.

I wish to object to this development on the following grounds.

Although there has been some reductions in the number of units , this is very very small comparedto the overall number.It is still too large for this site and dominates the neighbourhood and particularly those propertiesthat surround the site.

Another very big problem is that if traffic and parking. There is not enough onsite parking to meetthe needs of the residents, let alone all the staff that will b working there. The roads in that areaare already congested causing parking problems for local residents. There is also safety concernsrelating to emergency vehicles..

There will also be a loss of trees and the effect that that will have on wildlife in this area.

.There is no provision for affordable housing which surely is very necessary as there is such ahuge need for this throughout our city.

The amendments, made by the development company, to it's original plans are minimal and go noway to answer the great concerns that people in Westbuty Park have.

Thank you,Myra Jones

There needs to be more parking. Local roads are terrible for parking as it is. Should beunderground parking. Also main building is too high, doesn't fit with adjacent buildings.

Reasons I object to development:-1. Too many flats that are too high and the design is not in keeping with the houses in surroundingarea.

2.Insufficient parking.3.Lack of SEND provision.4.Detrimental effect on wildlife in the area.

Commenter Type: Neighbour

Stance: Customer made comments in support of the Planning Application

Comment Reasons:

Comment:Comments for Planning Application 22/01221/F

I am repeating the submision I made last April in SUPPORT of the St Christopher application.

thank you

Comments Details

Commenter Type: Neighbour

Stance: Customer made comments in support of the Planning Application

Reasons for comment:

Comments: St Christopher's site

I support the proposal. I have lived in Westbury Park for 54 years.

1) I think the concept of an Extra Care development is excellent. I like the fact that it will

incorporate at its heart in Grace House, facilities for creativity, learning and socializing; all

contributing to a well-lived old age. Best of all, I'm enthusiastic about the emphasis on links

between the retirement village and the local community:

a) access to and from the site via Westbury Road, Bayswater Avenue and The Glen.

b) the café, the pool and other facilities open to the local community.

c) a connection with the local primary school via a gate in the wall they share so that a tarmac-only

school will be able to enjoy grass, trees and gardening; and pupils will have contact with old

people to their mutual benefit.

In all, the value to the mental health of the residents and the local community will be worth more

than gold. Inter-generational contacts are life enhancing. Anathema for me would be a gated

development of luxury homes for the very rich on this site.

I have no evidence to mistrust the Developer's promises.

2) Trees: more trees will be planted on this site by the Developer than have been planted in the

whole history of Westbury Park as a suburb of Bristol. Any loss of trees is sad but the gain in

ecological terms will be immense. I have no evidence to mistrust the Developer's promise.

3) Releasing Existing Houses: many 3 and 4 bedroom houses in WP are lived in by couples or

single people who moved there long ago with young families. Some may wish to stay there; others

would like to move to a smaller property and not leave this loveliest of all Bristol suburbs. St

Christophers will give them the choice and inevitably release some local houses for families.

4) Parking: I do not believe this is a long-term problem. Car use and our subservience to the car is

changing all the time. It will continue to do so. The plan allows for one space per property. Many

residents will not want a car and there will be spare places for staff and visitors. Many residents

may like to join a car-share scheme. That will free more spaces. Perhaps the Developer could

increase the 65 places. Traffic problems do not appear to me to be made any worse by this

development. I don't want to throw out the baby with the bath water.

5) Height and "Overdevelopment": I constantly remind myself that we live here in an urban

environment and not on Salisbury Plain. The proximity of new buildings to the existing can be

unsettling. I think the 6 and 5 storey buildings should be reduced in height. Would a reduction in

the larger blocks be possible and economically viable and therefore make the development more

acceptable?

In my opinion, the benefits of this development to residents and the local community far outweigh

the drawbacks.

Thank you.

Kind regards

Commenter Type: Other

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:

I wish to object to this development on the following grounds.

Although there has been some reductions in the number of units , this is very very small compared

to the overall number.

It is still too large for this site and dominates the neighbourhood and particularly those properties

that surround the site.

Another very big problem is that if traffic and parking. There is not enough onsite parking to meet

the needs of the residents, let alone all the staff that will b working there. The roads in that area

are already congested causing parking problems for local residents. There is also safety concerns

relating to emergency vehicles..

There will also be a loss of trees and the effect that that will have on wildlife in this area.

.There is no provision for affordable housing which surely is very necessary as there is such a

huge need for this throughout our city.

The amendments, made by the development company, to it's original plans are minimal and go no

way to answer the great concerns that people in Westbuty Park have.

Thank you,

Having reviewed the planning documents, I wish to re- state my earlier objection.

In addition, I make the following comments on the amended planning application:-

*The total number of planned units has been reduced from 122 to 116. This is a 5% reduction andnowhere near significant in terms of reducing the damaging scale / bulk of new buildings.

- Fewer cottages are planned close to Bayswater Avenue. However, some cottages are still tooclose to existing houses according to national standards and the 'Villas' are still way too close toeach other.

- Villa B would be intrusive when viewed from The Glen.The five storey building would be 10/12metres away from the listed Grace House.

- The heights of the proposed villas have only been lowered by 300mm .

- The landscape proposals have been revised to increase the amount of soft landscaping,particularly around Grace House. However, there is no reduction in the amount of space betweenthe blocks as a whole. It is certainly not 'landscape-led' as the City Council want it to be.

- Fewer trees would be removed but that number is still very high. This represents too manyprotected, mature trees brung felled.

- There is no planned increase in the number of parking spaces. Even with the marginal reductionin the number of dwelling units 65 spaces will be insufficient to meet the demand for spacescreated by 116 new dwellings and will lead to overspill parking in surrounding roads.

*Bristol City Council have now agreed Use Class C2 (residential care homes and other institutionalhousing) so there is no longer a requirement for the developer to provide any affordable housingas part of the development. Provision for Special Educational Needs remains unresolved.

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that this planning application should be refused for the reasons Istated before. Namely these are:Overdevelopment and disfigurement of the nature of the area which is a conservation area;deleterious effect on wildlife habitats; loss of old and much treasured old trees and green space.Potential traffic congestion at the exit of Westbury Road onto the roundabout, insufficient parkingspaces on the site which will effect the already over parked narrow streets; safety concerns forlocal school and pre school children and other pedestrians; increased stress on the currentinhabitants of Westbury Park resulting from the parking and traffic chaos, let alone the disruptionof years of building work noise and congestion.

The Glen and Belvedere Rd are afforded no protection from permit parking. In addition,the two care homes in Belvedere Rd require parking for ambulances,visitors, staff and deliveries atall timesAny additional access granted to either of these roads would be disastrous to this conservationarea.

The proposed development of the site will have a significant, negative bearing on the immediateneighbourhood which is already very congested. Having recently moved to the area we areconscious of the high level of traffic on the roads nearby: Etloe Road, Bayswater Avenue andRoyal Albert Road in particular. With the proposed plan there will be spaces for 65 cars for thenew residents of the 116 living spaces - and, in addition, their visitors. Both traffic and noise levelswill consequently increase. The health and safety aspect impact on two nearby nurseries, oneprimary school and all local residents will be profound. These local roads at rush hours/dropoff/pick-up times are often overrun with cars. Even more vehicles will potentially create ahazardous zone, with accidents waiting to happen, that should be avoided at all cost. Myobjections, furthermore, concern the visual impact of the proposed site. At present there is awonderful array of ancient trees, the sight of which brings great pleasure to many. The proposedplan includes the removal of several of these. Their loss will not only have a detrimental effectvisually but also on the environment.

All my comments in my previous objection from last year still stand despite changes tothe plans: these changes appear minor.My comments related and still relate essentially to insensitive and overly intensive development ofthe site: plans reflect construction entirely out of keeping with anything in the near and wider localarea, with significant loss of amenity and biodiversity.We all would love this site to be developed for appropriate future use for future generations butthese plans fairly clearly put high population density at the top of the priority list at the expense ofamenity/biodiversity/practicalities of logistics and services.

I strongly object to the revised plans for the St Christopher's site. The changes to theplans have been so small and have made no difference to the fundamental issues raisedoriginally. The site is overdeveloped. The height of the proposed buildings are too high and do notfit with the existing developments surrounding the site. I'm extremely concerned about the impactof vehicle access. The surrounding roads are already heavily used for parking which has been andcontinues to be a huge problem in the area. More vehicles coming and going and not being able topark on site will only add to the difficulty.

I have written previously regarding this proposed development. Essentially, my viewsremain the same. This proposal although in principle is to be welcomed, the detailed design is not.'Over development' of the site is being proposed, and this is evidenced via for example, thebuildings being too high, inadequate car parking being provided on site etc. The lack of car parkingon site for residents, carers, visitors etc will only exacerbate the very considerable problems ofinadequate off road car parking in Westbury Park. Local residents will be substantially andadversely affected, and given the character of the 'urban form' in the area, the problem ofinadequate car parking cannot be solved. The subject proposals for the St Christopher's site needto take in to account the wider ambience/character of the area. The scheme proposed does not dothis at present, therefore I believe that these revised design details are unacceptable, and theplanning application should be refused.

Buildings of 4 or 5 storeys are out of keeping with the general construction of the area. Itwould seem, that as usual, the developers are trying to maximise their profits, and are notconcerned with the aesthetics or practicalities of their development. Insufficient parking, pooraccess, increased traffic, loss of habitat and wildlife, do not seem to concern the developers in anyway. There are actually many examples of recent such developments that are very good; the oneat Failand comes to mind, without a 4 storey building in site. They have plenty of low buildings,greenery, parking and proper access, and presumably making a profit. It shows it can be done, sowhy can't these developers?

Dear Sirs

I would like to object in the strongest terms to the atrocious revised plans for developing the old StChristopher's site in Westbury Park. Whilst not opposed in principle to appropriate futuredevelopment of the site - and certainly not wanting to stand in the way of progress in improving theprovision of affordable residential facilities for older (or any age) people in the local or wider area -this planned development is far from "appropriate" in my view.

Anyone living in this area will know that it is already densely populated with insufficient parkingand a network of old roads already too narrow to cope with the volume of traffic. Any developmentthat significantly exacerbates this situation should be avoided. In this respect the proposeddevelopment is still too big, too dense and too tall, with blatantly too little provision for additionalparking spaces.

In addition, this development will undoubtedly lead to a significant change and deterioration in thecharacter of this old and much treasured residential area, to an unforgivable reduction in thepopulation of trees and therefore wildlife habitat in the area and to a loss of facilities for specialneeds provision.

In my view this development in its currently envisaged form must be opposed and stopped - andreplaced by a substantially revised plan involving fewer and less tall and imposing residentialunits, greater provision for additional and directly associated parking facilities and significantly

reduced impact on local wildlife.

I strongly object to the planning application on the following grounds:

1. The proposed development is still too big and too dense.2. There are too many trees being removed, leading to a loss of wildlife.3. There are not enough parking spaces, leading to overspill and road safety hazards.4. As the parent of someone with a learning disability, I object to the almost total loss of SpecialEducational Needs provision, which is woefully inadequate, with only occasional shared use of aroom.

5. The scheme is totally out of character with the neighbourhood.

Please reject this application out of hand.

Without at least 1.2 parking bays per flat, This proposal should be denied. Parking isalready a problem in this area.Also the proposed building look so ugly, make them lower and more in keeping with the area

I ask the developers if they would really be happy for this development to built at theend of their gardens? In their neighbourhood?

Whilst I support the need for St Christopher's site to be developed and a retirement village is, inmy opinion, a good option. I feel the buildings planned are too tall and invasive to the localcommunity. I object to the cutting down of so many trees, we need to keep our trees and plant aLOT more. I also think the revised development if it goes ahead will put too much pressure on thelocal area particularly the parking. I teach at the local Westbury Park primary school and I wouldreally like the development to include more space both inside and outside for the school. However,I am not sure how a peaceful retirement village works along side a very noisy playground! Believeme, it is very noisy!

It is absolutely impossible to park by our house at the moment, with the huge number ofextra vehicles the build would bring, it would cause absolute congestion in an area that alreadyhas huge congestion problems.

This project, with proposed 5 storey buildings is totally out of character in thisconservation areaThe lack of on site parking provision will cause an increase in requirement for on street parking

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that this planning application should be refused for the reasons Istated before'.

My main concerns, which I outlined in my previous response have NOT been addressed by thevery minor, superficial amendments to the planning application.

Specifically.

I was concerned that the scale, mass and bulk of the proposals was inappropriate, would situncomfortably within the plot with the tall and uninteresting form standing out amongst the heritageassets in the Conservation Area adjoining the Downs and unacceptably altering the existingcharacter of the area. This concern has NOT been remotely addressed by the reduction of one ofthe four tall buildings by one story and another by a mere 30 cm.

The extent of the tree loss in particular of high quality trees, although slightly reduced is still notjustified.

Parking provision is wholly inadequate, with the revised proposal including no more spaces andparking spaces in total of 65 for 116 dwellings (6 less than previously) and no additional spaces forvisitors, staff etc. The nature of the location, closely surrounded by residential roads, combinedwith the inadequate parking provision on site means that residents and staff would seek to park on

neighbouring roads impacting residents and creating traffic hazards.

In the context of the need for increased SEND accommodation in Bristol the proposal only offers avague proposal for shared use of a room in the "Urban Village Hall" which is wholly inadequate.

Unless major substantive changes are made to the application, it should be rejected in its entirety.

Regards,Imogen

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that this planning application should be refused for the reasons Istated before as very minor modifications have been proposed.The plans remain completely out of proportion in size and scope and will have a devastatingimpact on the health and well being of this community, in an important conservation area.

In light of re submitted plans we still have some concerns:

1.Noise and Air Pollution during construction

The scale of the construction will naturally involve significant building works despite revised plans.Whilst we recognise the developer will respect the appropriate legislation we would like to highlightthe close proximity of the school to the site. Some of our pupils suffer from severe asthma and wehave a number of children with sensory needs that would need additional care if noise/disturbancelevels become too much.

To lessen the impact on the children's health and wellbeing, we would propose that:

· Any preparation works near to the school take place during the school holidays.· The best screening and dust dampeners are used to protect the children's and staff's health.· The school is offered regular access to clean up teams who will clean the windows, playgroundsetc. to lessen the impact of the construction works.· There are opportunities for the children to learn about building and design practices withsustainability at their heart. This could be facilitated through the construction phase.

2. Increase in traffic

It is good to see there will be no vehicular access from Bayswater Avenue except for access to the

sub-station. We still have concerns that in an already very narrow and busy area, even a smallincrease in traffic, especially during school pick up and drop off times, will add considerable risk tochildren's journey to and from school. Cars already line the pavements, which can forcepedestrians onto the road and makes crossing safely more difficult.

Mitigations may include the following:

· addition of double yellow lines,· a pedestrian crossing or zebra crossing· safety beacon lights and· better school signage for Bayswater Avenue and surrounding roads.

3. Urban Village Hall and specialist provision

We have not been consulted about the plan for an occasional use specialist provision andtherefore do not fully understand the intention and purpose of North House. Our experience ofinclusion suggests any impactful use of North House would require significant resourcing andplanning especially around safeguarding.

Multiple reasons associated with overdevelopment have already been clearlyarticulated. I concur with all these. The development is so inappropriate.Looking at the proposals as they have modified (marginally) over time appears to indicate that thedevelopers have made little effort to take on board the requirements of the Council or the wishesand aspirations of the local community. Above all, at best only lip service appears to be paid to thehistory of the location as a rare educational capability, and claims regarding biodiversity and'green' credentials appear hollow and perhaps cynical.I hope this development does not go ahead even close to the current proposal.Thank you

The proposed redevelopment of the former St Christopher School site remainsdisproportionate to the surrounding area in regards to building height and density. It is not inkeeping with the Westbury Park area and the Downs and will impact negatively on neighbours.This is not only cosmetically but also with regards to the resulting increased traffic which bringsnoise and air pollution to this quiet residential area. It is already very difficult to find parking on theside of the road and I fear this large development will cause more parking problems. It is alsoalready challenging as a pedestrian to cross Westbury Park Road to the Downs and this would beworse with more traffic in and out of the new development. I fear accidents could be caused withcars parking on the side of Westbury park road and obstructing the view of cars pulling out of thedriveways of the development.In addition I note that no provision has been made for affordable housing or Senco which is theheritage of this site.

I objected to the previous planning application for this site in May 2022 and all myprevious objections are still relevant. The plans have been changed by so little that everything Isaid before still applies. The claimed 'reduction in scale and massing' by the developers is utterlyminimal, with one building being reduced by one storey and a few other cosmetic changes.Specific comments in relation to this latest application, are as follows:1. The fundamental issues of overdevelopment, lack of sensitivity to the Downs ConservationArea, insufficient parking spaces and loss of trees have barely been addressed. There is no waythis proposal has the feel of 'being close to nature' or 'in keeping with the existing landscape',which the developers claim.2. The proposed Blocks remain as over-dominant structures for the area, in scale and form. Eventhe so-called 'cottages' would be overbearing to their near neighbours.3. The proposed development still results in a significant loss of mature trees and their resultantwildlife, which should be cherished. Young trees are more susceptible to disease and drought, soit is difficult to replace the old faithfuls.4. The new vehicle entrance created from The Glen will cause road safety issues and furtherparking stresses on The Glen and Belvedere Road, which are known already to suffer fromparking difficulties, blocked roads and dangerous vehicle turning issues.5. The proposal to provide fire engine access to the rear of the site via the Glen means thatseveral of the precious road parking spaces will be lost to provide unrestricted access for the fireengine (see page 67 of the transport plan).6. The local area is already struggling for parking, with an RPZ nearby preventing locals fromparking further away from the development site. Thus, the development needs to be completely

self-serving in relation to parking. I believe this would be in the region of 115 spaces.7. No action has been taken to alleviate the lack of privacy to the houses in The Glen, particularly15, 16 and 17, which back directly onto the site.8. No heights are given for the 'cottages' near The Glen but one of the site sections (seeLandscape Addendum, page 23, illustrative section BB) shows them as two storey buildings with afull height roof on top, which will be significantly higher than the current single storey building.Could the 'cottages' fulfil their purpose if they were changed to bungalows?9. Site section 3357517 B-B is untruthful in at least two respects: A) the big lime tree on the left iswell behind the 'cottages' and will therefore NOT be able to soften their roofline. B) The drawingshows a large tree behind the house marked 15 The Glen which appears to be around twice theheight of the house, which gives the impression that the cottages are quite small. There is only asmall tree of around a third higher than the house actually within the vicinity of 15 the Glen.10. Verified view 3353026 from The Glen shows Block D changing the character of the road bydominating the end of the cul de sac and being out of keeping with the locality. The developersown report states that the visual impact on the Glen is 'moderate to substantial adverse'.Specific to 16 The Glen:- A row of five 2-storey 'cottages' are proposed at the back of 16 The Glen, with windows lookingEast directly towards the large windows of our main living areas, main bedrooms and also ourback garden. This would result in a serious loss of privacy in our main rooms and amenity space,which is where most of our time is spent.- Block C (5 storeys high) and Block D (4 storeys) are tall and over-dominant buildings, taking theplace of a number of tall, mature trees and would look incongruous in the area. Block C wouldhave multiple windows and balconies with views towards the main windows of no 16 and Block Dlooks directly towards the private back garden. Again, this would be detrimental to our privacy.- 16 The Glen has nearly all its habitable rooms facing west, all with large windows facing directlytowards the cottages and diagonally towards block C. We use the private garden at the back of No16 frequently throughout the year for gardening and recreational purposes. We currently enjoy ahigh degree of privacy, which we value greatly.- I am also concerned about the potential for light pollution into our home from windows, stairs,and outside lighting on the site.- In short, the proposed development would significantly impact upon the privacy of both theupstairs, downstairs and private garden space of 16 The Glen, for ourselves and any futureresidents.

I fully support SCAN and Westbury Park Community Association in their work and comments onthe proposals.SJ

There are not enough parking spaces included in this development for residents andvisitors. This will lead to overspill. This is a problem as there is already a lack of parking in thesurrounding streets.

Unnecessary overdevelopment leading to increased traffic, parking issues and safetyconcerns, especially for children.

I have no problem with the proposed use, but the impact on the environment and existingcommunity need to be more measured. The new junction is a major concern and an unnecessaryaddition. The traffic, especially during rush hour on the streets up the the proposed junction will bea disaster.

It seems that the initial feedback from the community was not fully respected and addressed. Thetrees on the site are beautiful and must remain. I feel for those that live next to the site, especiallywith the height of the proposed buildings.

If this goes ahead the council needs to review the need for residential parking on the nearbystreets. I believe this is needed.

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that this planning application should be refused for the reasons Istated before and which I have included again below.

We strongly oppose this.We live on St Helena Road and object to this development which is out of place in our area as it isnot in keeping with its historic character and overall size and type of buildings. It will also createmuch busier and noisier surroundings in what is currently a quiet area.

We have always loved the quiet, peaceful, local character of the area, and the historic nature ofthe buildings and the conservation area. This is what we have chosen to live in, not a much busierarea which is inevitable with the proposed development.

Similarly, this will also impact on the tranquility of Durdham Downs where I go for regular walksand take my grandson to play. At the moment it is a quiet and never too busy safe space which Iwould like to keep that way. It will also spoil the view from the Downs.

Parking and traffic are already an issue with narrow streets and often a lack of on street parking.The last thing the area needs is increased traffic and more cars trying to park. It will also make itless safe for the children attending the local primary school and nursery. Increased traffic will alsoincrease pollution locally.

The further environmental impact of the proposed development, with 50% of trees being felled andimpact on biodiversity is also completely unacceptable.

I object on the ground that parking is extremely difficult already around here, I amdisabled and have not yet applied for disabled parking, but will have to if this goes ahead, theextra congestion will make the area unpleasant to live in due to pollution and lack of safety forpedestrians especially children on their way to the local schools,

The development itself does not have enough parking spaces for the number of units, and I thinkthis could become an old people's ghetto, not a village if they are trapped with lack of transport,the lack of parking for the number of units also becomes problematic for the number of health careprofessionals.

I also object to the loss of wildlife habitat, the loss of trees, and the proposed density of housing.

I am concerned about the fact send provision on this sight will be lost, particularly because I haveused send myself as a young person.

This development is out of character with the rest of the housing in this area.

My original objection still stands.

This re design still represents a complete over development in height and scale and will blight theWestbury Park conservation area.

The number of flats will result in additional traffic on our already congested roads and exacerbatean existing parking problem.

Overspill parking, additional traffic and access on/off Westbury Park (road) along with road safety,still seems to have been ignored.

This scheme needs a complete rethink and should NOT be granted planning permission

The revised scheme proposed by the developers of the St.Christophers Park site is stillnot appropriate for the area. It doesn't address parking or amenity concerns and it does not "giveback" to the community (SEN or otherwise) in any meaningful way. No doubt it will also be aneyesore in a Conservation Area, not in keeping with the surrounding architectural style, but I wouldbe more inclined to accept this if there was a proven need for the type of residences beingprovided and if the local infrastructure (ie roads, utilities and Council provided services such asrubbish collection) was not already under strain from an area that is more densely populated thanwas anticipated

My original objection still stands.

This re design still represents a complete over development in height and scale and will blight theWestbury Park conservation area.

The number of flats will result in additional traffic on our already congested roads and exacerbatean existing parking problem. Overspill parking, additional traffic and access on/off Westbury Park(road) along with road safety, still seems to have been ignored.

This scheme needs a complete rethink and should NOT be granted planning permission

I am concerned about the proposed plan to this site. The environmental impact of somuch extra traffic in an area that is already heavily congested will have negative consequences fornearby residents, and the environment.The Downs is an important green space for the whole city and a proposed high rise block willchange this landscape and the sanctuary that this green space provides for all.There is already a lot of provision for retirement living in the area, much of which is still vacant. Forexample The Vincent on Redland Hill. Any proposed development should be in character withexisting buildings and enhance the facilities available in the wider community.

Kind regards

I am writing on behalf of my mother in law, Mrs Joyce Wilkins, with her full consent andapproval, who has been resident at 17, The Glen since 1962. Mrs Wilkins, who is now in her 90s,is outraged and distressed at the impact this development will have on her and her neighbours.

Community Impact: The Glen has always been a very peaceful and neighbourly road, within in aconservation area, where many of the residents have lived for many years. Most are either elderlyor have young children. The peacefulness of the road has been a boon to both, despite the manyissues with parking that already exist. To create an entrance from The Glen into the newdevelopment, removing its cul de sac status, so that it becomes a through road, will completelychange the nature of this street, making it a hazard for young children and pets, not to mentiongreatly increasing the noise and pollution that will be suffered by all. As St Christopher's has adouble entrance opposite the Downs, which has proved more than sufficient to date, it is hard toimagine why creating another entrance, which will prove highly disruptive and dangerous, is trulyrequired.

Parking: With the amount of cars already parked primarily by non residents (most of the residentshave driveways) and the increased number of through traffic, The Glen will become extremelydifficult to navigate and cause the residents endless challenges as they try to manoeuvre in andout of their own homes. It is clear that the application does not include enough parking to supportthe number of individual properties included within the proposed development and so the onus ison the developers to rectify this situation without imposing further constraints on the alreadystretched parking capacity of The Glen.

Invasion of Privacy: I would also like to flag the invasion of privacy and blocking of light that will besuffered by residents on the north side of The Glen which includes No. 17, by the height of theproperties that will back onto them, causing further distress to the residents who have livingpeacefully in The Glen for many years.

This is a development funded for commercial gain. It does not offer any social housing or anyfacilities that might be of benefit to the wider community. It is a huge space and should be able tobe developed without imposing so drastically on a neighbourhood that has shown itself throughoutthe years to be a supportive and peaceful community.

I very much hope that the Council will register this impact and call upon the developers to rescaletheir plans so that many people are not caused distress, property value impact and impairedquality of domestic life in order to fund their profits.

The plans have hardly changed! The traffic and parking around St Christopher's andnearby roads is already horrendous and extremely dangerous. It is near to a primary school andhas many secondary school pupils passing the area each day too. My own son has had to bepushed into the road in his wheelchair (when he had to use one) due to the antisocial parking andpeople parking on pavements. The walk to school is a dangerous one with Cara using these roadsas a rat run and there being low visibility to cross roads due to people parking on corners and dropkerbs. I worry immensely how bad it'll be be with all the extra proposed accommodation andtherefore cars having park in surrounding roads. It is already dangerously busy with residents ofthe area and those parking to get the bus into town. We have no room for more cars on theseroads and I truly fear for people's safety. It is already very hard to park anywhere near my house.The height and scale of the proposed buildings will be an eyesore in a beautiful area. The wildlifewill be affected, nature and green spaces ruined and trees cut down. It is awful to think about theaffect this will have on this area and the people living here. The privacy of direct neighbours will beruined with the height and size of these monstrosities. It smacks of greed on the developers sideto cram as many people as possible in one place and to have no thought about how it affectsothers.Please, please, please do not let these plans go through. The safety of our children is at stake.They should be able to walk to and from school in a safe environment and be able to feel safe. Wehave no space for more cars, whether they are driving to or parking here. Thank you

I am very concerned about the lack of parking on the site, which is in an unsustainablelocation and, despite being aimed at the older generation, will lead to parking pressures forresidents and visitors on the surrounding streets, which are already full to capacity with on streetparking. This in turn will lead to highway safety issues, particularly on The Glen where there is noturning facility at the end of the cul de sac street, and associated noise and general disturbancefrom the comings and goings of vehicles. The scheme overall represents a significantoverdevelopment of the site and should be drastically reduced in scale and size to minimise theimpact on existing residents from overlooking/overshadowing, as well as on the character andappearance of the conservation area.

As a regular visitor to my daughter in Redland l think it will be very bad with a largedevelopment in the area. It will increase traffic and cause a problem with parking in an alreadybusy area.

My previous comments re the windows from a row of very tall cottages overlooking ourproperty and garden, the large blocks towering over our house and garden with balconies andwindows facing our house, light pollution affecting us from the tall blocks remains unchanged asthe proposal has not changed in that respect.These further comments are on review of the rather scant detail that has been supplied in theamended proposal.Height of H01 Cottages in site section drawing 2006 rev A. During consultation with the developerthese were described to us as single storey with accommodation in the roof. The rooftops now lineup with the top of a 1930s house so are more like a townhouse with two full storeys and a roofabove, and will be significantly higher than the current single storey building. There are nodimensions on the drawings, they can only be estimated using a ruler against the drawing scale.The latest site section shows a gradient over the length of the cottages (H01) of 1.7m, howeverthe cottage roof line appears to be level. We have a significant and I believe justified concern thecottages could end up being 1.7 m higher if the ground is built up over the length to be level,instead of excavated to achieve level ground.Site section drawing 2006 - The top of roofline of the H01 cottages has been obscured by treebranches to disguise their height. In fact, there is no tree that can obscure the front of thesecottages so the view is misleading and incorrect.Site section drawing 2006 - the drawing shows a large tree behind the house marked 15 The Glenwhich appears to be around twice the height of the house, which gives the impression that thecottages are quite small. There is only a small tree of around a third higher than the house actuallywithin the vicinity of 15 the Glen. The drawing may have included trees on the Westbury park road

boundary in the far background which will not in practise provide the same view from the house.2006 site section - this section is still showing the two very large trees tree 52 and tree 65 whichelsewhere in the proposal says are to be removed for sewer works. The inclusion of these treesmakes the scene deceptively green, and this error was pointed out in the first consultation, and thesignificant error has been conveniently repeated.Verified view 3353026 - the view of the Glen shows Block D changing the character of the road bydominating the end of the cul de sac and being out of keeping with the locality. The developersown report states that the visual impact on the Glen is 'moderate to substantial adverse'. As thechosen viewpoint is some way up the street, the visual impact will worsen as we approach ourhouse, which is nearer to the end of the street.The inclusion in the addendum of a road vehicle entrance from the Glen presents further problemsfor Glen residents. The 6 parking spaces that are proposed is nowhere near enough for all theresidents at the back of the site where the Glen is the nearest road, so will try to park in the roadwhich already has significant parking issues.The need to provide fire engine access to the rear of the site via the Glen means that around 6 ofthe precious road parking spaces will be lost to provide unrestricted access for the fire engine (refpage 67 of the transport plan).The plan to create a village hall from the building that has been described as the old laundrysounds interesting but seems quite impractical due to the size, and will add further pressure toparking on the road as there is no provision on site.There may be a connection from the end of the Glen to the school, via the village hall. This mayencourage parents to try and drop off and pick up children using cars driven and parked in theGlen. A cul de sac with reversing cars would not be a safe place for children to be waiting forparents to pick up.Delivery vans may try to deliver packages to residents as it would be the shortest road route andthere would increased vehicle reversing and congestion in the road.Parking in Westbury Park road - already a busy road and during the recent covid vaccinationsessions held in st christophers, there was car parking on the grassed area of Downs land, onboth sides of the road, which is against byelaws, unsightly and caused further traffic disruption,and indicates the scale of the problem if the occupancy of the site is increased as proposed.The summary of the amended proposal states that less trees will be removed, I am unable todetermine how many less than the 58 proposed trees are to be felled. I have read that a furtherOak tree is to be felled but cannot see any reference to that.

Specific comments to 16 The Glen:- A row of five 2-storey 'cottages' are proposed at the back of 16 The Glen, with windows lookingEast directly towards the large windows of our main living areas, main bedrooms and also ourback garden. This would result in a serious loss of privacy in our main rooms and amenity space,which is where most of our time is spent.- Block C (5 storeys high) and Block D (4 storeys) are tall and over-dominant buildings, taking theplace of a number of tall, mature trees and would look incongruous in the area. Block C wouldhave multiple windows and balconies with views towards the main windows of no 16 and Block D

looks directly towards the private back garden. Again, this would be detrimental to our privacy.- 16 The Glen has nearly all its habitable rooms facing west, all with large windows facing directlytowards the cottages and diagonally towards block C. We use the private garden at the back of No16 frequently throughout the year for gardening and recreational purposes. We currently enjoy ahigh degree of privacy, which we value greatly.- I am also concerned about the potential for light pollution into our home from windows, stairs,and outside lighting on the site.- In short, the proposed development would significantly impact upon the privacy of both theupstairs, downstairs and private garden space of 16 The Glen, for ourselves and any futureresidents.

These plans would have a negative impact on the environment, there would be evenmore cars on already busy roads, and make parking worse, affecting families who already live inthe area.The 'look' of the new buildings is not in keeping with the area and are excessive for the size of thesite.Local infrastructure will not be able to cope.Roads onto Westbury Park are also already too busy.

The amendments to the original application are minor and insufficient to negate myprevious objections. Therefore my same objections stand

As residents of Bayswater Avenue, overlooked by the proposed development, westrongly object to the revised planning proposal ref 22/01221/F. This latest proposal makes nosignificant alterations to the previous one and the objections in our previous letter dated 16th May2022 still stand.

We echo submissions made by the St Christopher's Action Network (SCAN) and the WestburyPark Community Association (WPCA) relating to wider community concerns. Whilst we supportsensitive development of the site in principle, we object to the height and density of the proposednew buildings, which are not in keeping with the local conservation area. The gardens, maturetrees and wildlife form an important setting for Grace House, which we believe should be protectedas part of Bristol's architectural heritage. We object to the height of the new cottages, and theirproximity to the boundaries of Bayswater Avenue dwellings, which we believe have beencommunicated in a misleading way (by not measuring the closest dimensions). We object to theloss of light and privacy to our small rear garden and directly overlooking windows to the rear ofour house. In fact we believe the proposed "cottages" (H02) will result in a mutually unacceptableoverlooking and overshadowing.

The boundary wall of 21 Bayswater Avenue (our property) is directly integrated into the existingNorth House/Gardener's Cottage. It would appear this is now proposed to become an 'UrbanVillage Hall', which leads us to question what noise impact this will have on us.

There has still been no clarification provided regarding land levels. We estimate that the site is

between 1 and 2m higher than garden levels on Bayswater Avenue and we are thereforeconcerned that the proposed new buildings will tower over those on Bayswater Avenue.

We believe the serious lack of adequate parking provision will further exacerbate traffic andparking issues in the area and create additional safety risks to local school children.

Fewer trees are due to be felled in this latest proposal; however the number of mature trees due tobe removed is still very high which will be detrimental to the character of the neighbourhood.

In summary, the development is too dense, too high and too close to site boundaries with toomany mature trees being removed. There is clearly a serious lack of parking provision leading toincreased traffic in an area with two nurseries, a pre-school and a primary school in closeproximity.

I wish to register my objection to the proposed development on St Christopher's site.Having recently moved to Royal Albert Road, I can see how the impact of these proposals wouldhave a very negative impact on the area - and its residents. Firstly, further vehicular traffic willimpact on the already congested roads around the adjoining streets. There is very limited parkingas it is for residents, without the added number of vehicles which would inevitably be fighting forspaces. I've found I often have to park quite a distance away from my house, and know this to betrue for my neighbours too. Alongside this, the general congestion of cars clogging up the streets -delivery vehicles, removal vans and such like find it difficult to negotiate the roads with vehiclesbanked up on pavements and often unable to pass. To develop a site needing outside car parkingspaces is just adding to an already well established problem.Secondly, having viewed the plans I cannot see how this would be in keeping with the surroundingperiod architecture, the vista for many would be a complete eyesore.Thirdly, the number of established trees that would need to be cut down is unreasonable, whenthe idea is to preserve our trees for the benefit of living more ecologically, and preserving what wealready have.I am strongly against these new proposals.

Don't build this scar on the landscape near green areas that are treasured by people allacross Bristol. Building these retirement homes will increase congestion in an area with alreadybad traffic problems and narrow roads. Renovating the current St Christopher's building wouldalready yield many apartments too. They would be highly coveted since the current building is solarge and beautiful.

My previous objection still stands as this revised scheme goes nowhere near toreducing the size and scale of the development that the Community wants.

The height and size of the development would simply dwarf the original Victorian villas and thisjust isn't in keeping - or appropriate - for a Conservation Area.

Whilst fewer trees are planned to be removed, the number is still alarmingly high and when youlook at this in conjunction with the increase and density of traffic a development of this size willinevitably incur, then this is certainly a juxtaposition to Bristol's policy to become a "cleaner air"city.

Furthermore, the proposed parking provision for the residents is woefully inadequate and thealready congested roads surrounding the area will be used to meet the demand, resulting ingreater traffic and parking issues and a risk to safety.

This application should simply not be allowed to go ahead.

As a local resident, I am opposed to the current plans for development of the StChristopher's site for the following reasons:

- Impact of increased traffic accessing the site, resulting in detriment to local residents and safetyof pedestrians and pets. Safety, noise and pollution concerns, it will make our quiet residentialstreets much busier.- Impact to parking - there doesn't appear to be sufficient parking provision within the plans tosupport no. of residents, visitors and associated staff, overflow would be onto local streets that arealready crowded with no RPZ in place- Impact to privacy of surrounding properties with proposed height of development. This is out ofkeeping with properties in the area which is a conservation area. Proposed height of buildings willbe visible far from the site. Height should not exceed that of existing buildings (standard regulationwhen rebuilding on existing site). although plans have been revised, height of buildings is still outof keeping with surrounding housing.- Impact on biodiversity with removal of trees and wildlife habitat if development goes head to thedetriment of the environment.

A five storey building(s) is ridiculous for this area. This could set a precedent foreverand must be rejected.Parking anywhere in this locale would be a great challenge not only for residents but also forvisitors and people who already live in the area and have to park on the surrounding area. This isalready a challenge particularly at school drop off and collection times.The increase in vehicular traffic would be a massive challenge as some of these roads arebasically one lane due to cars parked there already. More traffic could easily end in gridlock.Please reject this application in the form that it is submitted. It is neither suitable nor welcome.Thank you.

As a parent of two children who go to Westbury Park Primary School, I can say thatparking near the school is difficult half of the time. Should the planning permission were granted tothe site at St Christopher's, it would no doubt put more pressure on the users of roads in the area,making more people frustrated and angry every day. I hope the plan could be changed to makethe new development self sufficient in terms of parking. Thank you!

The scheme has made no substantive attempt to respond to original objections. Densityis still an issue, leading to dangerous traffic issues. The skyline of an important Conservation Areain Bristol is threatened, with the height of the development wholly inappropriate for the area. It willset a precedent for further development and fundamentally change the character of the area. Theloss to wildlife habitat through development is not in line with Bristol's commitment as a green city.

I understand that there is a demand for housing in Bristol, but maximising housingdensity should not be the only objective. This has to be balanced against Bristol's quality of lifeand my objection is on two grounds, the loss of mature trees and inadequate on-site parking.

Our mature city trees are increasingly scarce and should be highly valued, the loss of trees here isunacceptable.

The streets of Bristol are overrun with cars. Pavement parking is endemic leaving less and lessspace for pedestrians. Perhaps less of an issue for the fit adult, but very hard on those walkingwith young children, the elderly and the disabled.

65 parking spaces for 200 residents is a crazy idea. The streets around the area are already full ofvehicles, so this can only lead to more antisocial parking.

This scheme needed to revised so that it provides adequate parking and protects the trees.

I am appalled that the current application for redevelopment of the site has reached thisfar. It is so clearly out of keeping with the locality and would be a blight on the Downs. It is simplytoo big, too high, too invasive, too ugly!(For many visitors to Bristol their first view of the city is on their journey via the Downs - this wouldruin that!)The destruction 0f 40% of established on-site trees is iniquitous, given their carbon-absorbingcapabilities - and this at a time when Bristol aims to be a greener city.Car parking in the surrounding area is already a huge problem and allocation of sufficientadditional spaces on the site - for residents and staff is utterly inadequate.Special needs provision is poor in the city. The development of the site site should at least attemptto provide some proper facilities to compensate for the loss of St Christopher's School.We really do not need or want yet another luxury housing provision.Let us get our priorities right and veto this!

The density of the blocks is improved but and still out of character with the conservationarea.

The elevational treatment is poor with a lack of hierarchy to the flats. Little regards have beengiven to residents' amenity, and in particular the visual and physical connection of the ground floorunits and gardens.

I do however welcome the proposed use of the site for sheltered accommodation.

I would encourage a financial contribution, by thedevelopers, to the creation of a 'Home Zone' along Bayswater Avenue, part of Etloe Road andRoyal Albert Road. This will slow traffic and enhance the environment.

We wish to express our concern with regard to the proposed development of this site.Specifically, the density of housing & significant increase in parking demand in an already crowdedroad space, so close to a busy shopping area as well as commuter parking.

As previously mentioned in my original support statement, Bristol is badly in need ofhousing, and the diverse mix of retirement and extra care homes proposed would be a goodaddition to the area. Local residents would also have access to the facilities and gardensproposed. Having seen the original plans there is an emphasis on sustainability and biodiversity.The revised plans offer some appeasement to the objectors but most of them seem to be carobsessed, thinking only of their own situation and not addressing the lack of suitable and availablehousing for retirement and extra care in the area. Further improvements could be made, eg asproposed by the police for crime prevention, but I support this development for its overall benefit tothe community at large.

I am a regular visitor to the Glen and am appalled at the proposed development whichwould have a tremendous adverse impact on the street. The current green character of the sitewould change to urban oppressive buildings with removal of much of the natural scenery. Thedeveloper's own report states that the visual impact on the Glen is 'moderate to substantialadverse', and the existing houses will be dominated and overlooked by buildings out of characterwith this currently pleasant area of Bristol. The amount of greenery and the loss of trees proposedis incredible at a time when we need to increase biodiversity in Bristol and in the country as awhole. Parking is also a big issue. The Glen is already used by cars trying to avoid resident onlyzones, and I frequently have trouble finding anywhere to park when I am visiting. This can only getworse if residents, visitors, delivery vehicles and ambulances visit the site through the narrowheavily parked side street.

Although I submitted this once, as i pressed 'SEND', it timed me out, so I was not ableto save a copy. Hence an abbreviated presentation.

-development is too big and too hi

I wish to register my opposition to the above plans. The proposed buildings are still toomany, too big and too overbearing for the space, and out of character for the neighbourhood.There will be too great a loss of trees and damage to the safe space which the local wildlife hasenjoyed for many years. Parking in the area is already extremely difficult. We cannot absorb theextra pressure on parking space, and the likely effect on road safety, especially in this area wherewe have a primary school and nursery.

I have checked over the application, and considered the objections. My parents used tolive in a OAP complex, and in reality, not many of them had cars. So, the impact i think will beminimal.Discussions i have had suggest the businesses in the area, are concerned parking spaces will getused up. Note not many of the businesses have car parks, so we can't just reject the application,to save parking spaces for them. If they need parking spaces, then create them on their ownareas. When i have discussed planning in the area previously, i have mentioned parking, andalways advised it is not a problem.There are other buildings in the area that are 5/6 stories - take the old Lloyds bank building onnorth view.The site has a number of trees, and some to be taken out. I can understand for the proposal somemay need to go. That is regrettable - perhaps some trees could be added on the perimeters as asuggestion. People objecting could look to plant further trees themselves.

Overdevelopment and disfigurement of the nature of the area which is a conservation area;deleterious effect on wildlife habitats; loss of old and much treasured old trees and green space.Potential traffic congestion at the exit of Westbury Road onto the roundabout, insufficient parking.Intrusive to nearby properties.spaces on the site which will effect the already over parked narrow streets; safety concerns forlocal school and pre school children and other pedestrians; increased stress on the currentinhabitants of Westbury Park resulting from the parking and traffic chaos,of years of building work noise and congestion.Uneccassary removal of trees.incursion onto the protected status of the Downs.I believe the grass border between Westbury park road and the front wall of the lodges is includedin the Downs area and should not be reduced.

These comments are on behalf of FODAG (Friends of the Downs and Avon Gorge) anamenity groupwhich represents the interests of users of the Downs. Note, the proposed development of StChristophers into an extra care facility is seen as a favourable use for the tranquil site immediatelyadjacent to the Downs, where more people will be able to benefit from the amenity of the BristolDowns. There are the following concerns about the proposed implementation in the amendedproposal.The loss of many trees and hedgerows that provide valuable green biodiversity in the Downsconservation area. The st Christophers site is recognised as a connected biodiversity corridor totheDowns and the substantial vegetation that is to be removed will have a significant adverse impact.Overspill parking from residents and visitors to the site may lead to parking on the Downs landgrassed areas as was seen during recent Covid vaccination sessions that were held inCarisbrookelodge hall. Parking on the grass causes the soil structure to deteriorate and become unsightly,whichis expensive to remediate, which is necessary so that parking there doesn't become the norm.Note,the grass border between Westbury park road and the front wall of the lodges is part of the Downsand must be protected under the 1861 Downs act.The increased vehicle movements to the site and the large size of the more regular waste disposalvehicles, and other service vehicles including fire engines, will mean loss or damage to the Downs

grassland to accommodate the vehicle turning swept path at the site entrance and exit.The reduction in height of one of the 4 tall buildings does reduce the risk of the buildings beingvisible from the viewpoint used for the verified views. Even with the reduction of one storey, thebuildings which still up to 4m higher than the lodges, which are the frontage to the Granny Downs,may be visible from other viewpoints such as from Whitetree roundabout direction where the tallbuildings will be visible behind the lodges. A more detailed visual impact assessment is needed toensure that the character and views of the conservation area aren't permanently and adverselyaffected. Note, some of the tree canopies which help to conceal the new buildings in the verifiedview pictures are to be removed in the proposed development plans.The occupancy of the site will be considerably higher than the previous usage and increasedvehiclemovements in and out of the site and along Westbury park will detract from the tranquil nature ofthe Granny Downs area.Provision for car parking is planned in front of the lodges which may impact the views of thehistoricbuildings, and which could be a significant detriment if vans or minibuses were parked there, thereisno detail as to how the visual impact of these vehicles is to be minimised.

Excuse the bullet points:-

- too big and too high; a blight on the Downs and local surrounds

- loss of trees (40% destructed) is both shameful and iniquitous

- loss of wildlife is equally iniquitous

- trees are anti-pollutants, extracting CO2 from the air

- reduced Special Needs provision for the most vulnerable is almost criminal. The site should offermore than luxury housing and profit for 'greedy' developers

- increase in cars and motor traffic, and insufficient parking can only lead to increased pollutionand congestion

- finally - it is TOTALLY out of character with the surrounding neighbourhood

We no longer live in the Westbury Park area, but we still spend much of our time there,particularly supporting the local St Albans Church.

Our view is that proposed development at St. Christopher's is out of keeping with the rest of thearea. The accommodation proposed is too high density and this is particularly significant in theheights of some of the proposed buildings. This high density accommodation will not only lead toincreased through traffic in a quiet residential area, but also to increased parking locally, making acongested parking area even more congested.

As a result we would be in favour of a re-design that was more sympathetic to the localneighbou4hood.

I do not feel the revised plans have addressed any of my concerns. There is still noprovision for affordable housing. There are still insufficient parking spaces. There is stilldestruction of wildlife habitats. We do not need another expensive retirement complex in the area.We need affordable homes for young families!

The streets around my son's school (Westbury Park) are already filled with cars withnowhere for residents to park. This is exacerbated by having the school and nurseries in closeproximity, add in the fact these streets are the last without residential parking permits thereforeyou have commuters parking here as well. This all adds up with cars using every inch of the roadsand pavements, I can't fathom adding to this deeply unsafe mess further with this newdevelopment.

The revised 'minimal alterations' that have been made to the planning permission are aninsult to the locals' intelligence.

I object to the large number of properties being built for the following reasons:

More congestion on already narrow busy roads (Westbury Park and Bayswater Avenue) leading tothe a White Tree roundabout.

Inadequate parking facilities will cause a knock on effect for residents all down Redland Road andthe Westbury Park area.

The area as a whole cannot take any more inhabitants. As it is a high percentage of properties areconverted to flats or multiple occupancy all allowing several cars per residence.

The Westbury Park area is already over inhabited.

This is my first direct objection to this development. It is disappointing this resubmissionappears to retain all of the problems with the previous one and the developers have not acted ingood faith on the feedback from the community.

My main concerns are:- The plans continue to result in a large increase in households with flats up to 5 stories high.- Parking remains too limited for this number of properties and households.- traffic concerns are not addressed to prevent additional traffic in an already busy area for roads -I am particularly concerned about traffic safety issues given proximity to Westbury Park school.- environment will be disrupted with too many mature trees being removed.

Please reject the application and request any resubmission to be a complete redesignrepresenting much lower density housing

Regards

Paul

I am in principle in favour of appropriate open access development of this area for a welldesigned retirement village that will permit the engagement of the residents with the widercommunity and the use of the communal facilities by the wider community. It could make a lovelydevelopment that could really further connect the community with the retirees and further augmentaccess to he Granny Downs which all would welcome for their green spaces.

I do agree though that the parking arrangements are inadequate taking into care the staff andcarers that will also work on site. I also consider that the heights of the blocks are simply toooverbearing and need realistic reduction to 3 floors taking into account the heritage andconservation status of the local area. If the plans could adapt to reflect that I believe that otherecological concerns etc are adequately addressed and I would be supportive.

It is ridiculous to erect buildings without enough parking spaces for every person whowill live and be going in and out of there. The parking around the area and the roads will be muchtoo busy.

This is not to mention that the building designs are really ugly and will be an eyesore for those wholife near.

I have lived in Westbury Park for 22 years, it is the most beautiful area, with the Downsto walk in and see all the views . I have walked up past the St Christophers site for all these yearsand to now know this development will kill all those lovely views I see on my walk is heartbreaking. It adds huge wellbeing to the community to be able to walk in such a lovely Green openspace. I have no words what this will do to Westbury Park.

The destruction of wildlife, trees, birds, bugs and habitat also adds to this. Taking one story off anaggressive high rise building which doesn't fit into the beautiful area surrounding the Downs andclaiming reducing the 122 flats to 116 by taking off one level and enlarging the foot print of theblock , they have actually increased the flats by one to 123.This is a beautiful piece of the South West unspoilt area which includes the Downs which is aheritage site and is used by families and we need this area to remain in its beautiful setting as it is,not overshadowed by high rise buildings.

I live in Redland so the area in which the development is proposed is relatively close tomy home, even though I would probably not count as a neighbour. The proposed developmentappears out of extraordinarily out of keeping with the existing neighbourhood. Living well with ourneighbours in communities should be the goal, and developments should support and enhance lifeand well-being both for the neighbours and the wider city. Please rethink this

Ongoing concerns around existing tree retention, there needs to be way more parkingfor a site of this size not the standard for a council run facility - no overspill into the current roadsshould be accepted. Current planned buildings are too high for a residential area especially givenits position close to the downs.

Hello - I do believe that the proposed use and design is the best use of this site. It isclear though, that there are too many units and not enough parking. Really, this is all there is to it.In the current market, the unit prices seem depressed, cost not doubt max inflated to showguaranteed profit levels (at the max of the range) can only be met at these volumes with noaffordable housing.We all know this is not the case.The developer with either make super profits (hidden in the cost base or visible) and could affordaffordable housing / less units. We also all know that if we start doing something and the costs goup then we cannot demand the same max profit margins ... and yet....

There are too many units and not enough parking - how clear can this be? It is not possible tojustify a lower ratio of parking to property than for elderly use,,, but folks have friends / famliy /carers and some cars. There is no room for these cars on the surrounding jammed streets, whereaccidents have happened since he first application and have needed police support already - suchas next to the Bayswater nursery that closed the road last year.

Playing a planning game of using a bonkers start point - so you can conceed to look morereasonable (see ridiculous suggestion of opening the road next to the nursery or the crazy originalunit volume) - is merely a game to entangle planning officers.

These new plans should be reviewed ignoring previous bonkers application. At this point, we willstill see the units / risk free profit demands / parking ratios are too much.

Unit prices will be higher - lets watch the estate agents in the future should we?? - The concept of"guaranteed" profit margins (how nice - other businesses probably wish they could achieve thesame!) should be ignored.

This is the right use.The volumes are too high, parking too low and, even if this was maintained, affordable housing isaffordable.

BCC Planning team are better than this game - we know this..

Using the vacant facility as Covid vaccination centre or to house refugees should not be seen asswaying the argument. This is great but it has nothing to do with the development / developerbeing reasonable and should not influence our decisions (which no doubt they are hoping it will).This planning decision will live with our city & community for many. many years - after thisdeveloper has long left our city boundaries.

The parking issues have not really been addressed. The developer proposed lease forthe parking spaces and even with reduced number of properties this will ultimately mean to savecosts residents/staff/visitors will park on already overcrowded neighbouring roads.I really can't see the residents (being an assisted retirement facility) using bikes to get about assuggested in the plans. So the amount of added traffic in the area will be an issue and also safetyconcern as there is a school right round the corner.

This development will increase the need for more parking the area is alreadyovercrowded.The new proposal hasn't address any of my concerns about the traffic or parking.The site developments are not in keeping with the area with high rise buildings

We can't believe that these plans have put in again with so little actual changes and thecynicism of the developer doing this just before Christmas.There are still too many trees being felled, extensive building which is still five storeys high (this isa conservation area as you know), insufficient parking provided for new dwellings and opinionsand needs of the local community being disregarded.

As someone who has had a very close connection to the St Christopher's site, I objectto these plans on a variety of grounds. They do not serve the legacy of the site in providingschooling for SEND children. The residential development plans are not in keeping with the beautyof the site as the housing units are too dense and too tall; too many trees would have to be cutdown without the possibility of them being replaced. There is far too little provision for parking forresidents, and none for staff. Vehicle access points have not been given careful consideration andwould create traffic chaos and hinder access by emergency vehicles. Most importantly, thecommunity and city of Bristol would be losing a wonderful site for a school, when there is adesperate need for SEND provision. As one local councillor said recently on Twitter "There areSEND kids in Bristol desperately needing suitable provision. The St Christopher's site is aSCHOOL. Our children's needs should have priority over developers' profits." Finally, I do not thinkthis area needs more luxury housing; any housing development should focus on providingaffordable housing. This would be more in keeping with the legacy of the site. Please DO NOTALLOW THIS PLAN TO GO AHEAD.

Howdy!

I am a regular visitor to the Glen and am appalled at the proposeddevelopment which will make a tremendous adverse impact on the street. The green character ofthe site currently would change to scenery of dense urban oppressive buildings. The developersown report states that the visual impact on the Glen is 'moderate to substantial adverse', and theexisting houses will be dominated and overlooked by buildings out of character with the currentlypleasant area of Bristol. The amount of greenery and the loss of trees proposed is incredible at atime when we need to increase biodiversity in Bristol. We understand that the current very difficultparking situation will get much worse with the residents, visitors, delivery vehicles and ambulancesthat will visit the site, through the narrow heavily parked side street. Please reject this proposeddevelopment which is out of character with such a pleasant conservation area.

Nothing has fundamentally changed as far as I'm concerned.

I'm afraid that the destruction of all of the trees and the environmental impact of this scheme is stillnot acceptable

This is certainly not a 'Landscape-led' scheme. The idea that the developers are creating a newwoodland and new meadow is laughable.

If they reduce the number for units, reduce the size and scale of the development and then veryeasily they will have more space for all things green.

The conservation area of Westbury Park deserves better. This scheme should not be accepted.

Minor changes made, but still too big, too dense and too high for the area.

1. Damage to Heritage: The proposals amount to severe overdevelopment in a conservation area.The proposed scale, mass and bulk are inappropriate within the sensitive heritage context ofWestbury Park and the listed Grace House, and the scheme will give rise to unacceptable impactson the townscape.2. Damage to the Environment: There will be too many trees lost and a detrimental impact onnature & wildlife, losing high quality specimens that make a valued contribution to the characterand appearance of the Conservation Area.3. Road Safety, Traffic & Parking: The proposal is not appropriate in transport and highway terms,owing to insufficient on-site parking provision and inappropriate access/egress arrangements,which will increase the road safety risks in an area where this is already a significant concern. Noincrease in parking spaces, so the increase in traffic will be an additional hazard for local residentsand the children who attend the local nursery, pre schools and schools in the area.

4. Lack of Affordable Housing: The proposal includes no affordable housing and is not supportedbyany evidence to justify such a lack of provision.5. Loss of SEND provision: In the context of an increasing need for SEND accommodation inBristol,the developers have failed to comply with council policies that seek to safeguard community

facilities.

Minor changes made, but still too big, too dense and too high for the area.

1. Damage to Heritage: The proposals amount to severe overdevelopment in a conservation area.The proposed scale, mass and bulk are inappropriate within the sensitive heritage context ofWestbury Park and the listed Grace House, and the scheme will give rise to unacceptable impactson the townscape.2. Damage to the Environment: There will be too many trees lost and a detrimental impact onnature & wildlife, losing high quality specimens that make a valued contribution to the characterand appearance of the Conservation Area.3. Road Safety, Traffic & Parking: The proposal is not appropriate in transport and highway terms,owing to insufficient on-site parking provision and inappropriate access/egress arrangements,which will increase the road safety risks in an area where this is already a significant concern. Noincrease in parking spaces, so the increase in traffic will be an additional hazard for local residentsand the children who attend the local nursery, pre schools and schools in the area.

4. Lack of Affordable Housing: The proposal includes no affordable housing and is not supportedbyany evidence to justify such a lack of provision.5. Loss of SEND provision: In the context of an increasing need for SEND accommodation inBristol,the developers have failed to comply with council policies that seek to safeguard community

facilities.

Developers' need to rethink their new plan and stop taking the micky out of theWestbury Parkresidents. Massively over developed the site, too much destruction of wildlife, trees, birds, bugsandhabitat.Taking one story off an aggressive high rise building which doesn't fit into the beautiful areasurrounding the Downs and claiming reducing the 122 flats to 116 by taking off one level andenlarging the foot print of the block , they have actually increased the flats by one to 123.I am sure the developers have looked at the surrounding roads and access and 65 onsite parkingspaces they know will not be enough and probably know there will be a need for 50 more required.

where will those extra 50 plus cars park in an already very, very congested residential area?This is a beautiful piece of the South West unspoilt area which includes the Downs which is aheritage site. Families use this every day and to see Gigantic huge tower blocks that over look this

and private residents homes that have lived here for a long time is unacceptable.St Christophers was always a school for 70 yrs for SEND( special Educational Needs orDisability).How is the one communal room going to help as a mixed room to serve these needs?The developers need to go back to the drawing board and look at maximum two floor tower blocks

so people can enjoy the views from the downs instead of looking at concreate tower blocks.

The objection I submitted to the original planning application still applies to this proposal(the proposal is still largely the same as the original one). I continue to believe that this planningapplication should be refused for the reasons I stated before.

My parents live in the area and we are frequent visitors both to their house as well as DurdhamDowns.The proposed development is completely out of character with the conservation area, and toohigh, too big. It would also spoil the quietness of the area and create far too much traffic, parkingproblems and and pollution.It would also negatively affect the wildlife on site and too many trees would be lost.There is also insufficient SEND provision.

I strongly oppose the proposed development.

The building development is too big and higj and out of character for the area. Suchdensily populated scheme will increase traffic burden in an already busy residential area, willreduce the availability of parking for existing residence and add to the air quality concerns andincrease road safety concerns of the area. The loss of the greeny and wildlife is a huge concern asWestbury Park and Redland are known to be green areas which protect the trees and spaces.Trees take decades to grow and should be protected by all means. Influx of housing and thecongestion will also devalue existing housing in the area.

Totally unsupportive of the scheme.

The proposed development at the site of St Christopher's School is entirelyinappropriate for this Victorian residential neighbourhood. Five-storey blocks of flats are far toobig. The number of residential units is far too high, and the impact on traffic and parking will bedisastrous for the neighbourhood. Disastrous too will be the impact on the natural beauty of thearea with the removal of ancient trees and the loss of wildlife habitats. The proposals aregrotesquely out of proportion with the character of Westbury Park.

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that this planning application should be refused for the reasons Istated before'.

My main concerns, which I outlined in my previous response have NOT been addressed by thevery minor, superficial amendments to the planning application.

Specifically.

I was concerned that the scale, mass and bulk of the proposals was inappropriate, would situncomfortably within the plot with the tall and uninteresting form standing out amongst the heritageassets in the Conservation Area adjoining the Downs and unacceptably altering the existingcharacter of the area. This concern has NOT been remotely addressed by the reduction of one ofthe four tall buildings by one story and another by a mere 30 cm.

The extent of the tree loss in particular of high quality trees, although slightly reduced is still notjustified.

Parking provision is wholly inadequate, with the revised proposal including no more spaces andparking spaces in total of 65 for 116 dwellings (6 less than previously) and no additional spaces forvisitors, staff etc. The nature of the location, closely surrounded by residential roads, combinedwith the inadequate parking provision on site means that residents and staff would seek to park on

neighbouring roads impacting residents and creating traffic hazards.

In the context of the need for increased SEND accommodation in Bristol the proposal only offers avague proposal for shared use of a room in the "Urban Village Hall" which is wholly inadequate.

Unless major substantive changes are made to the application, it should be rejected in its entirety.

Regards,

Ella Ward Parsons

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that this planning application should be refused for the reasons Istated before'.

My main concerns, which I outlined in my previous response have NOT been addressed by thevery minor, superficial amendments to the planning application.

Specifically.

I was concerned that the scale, mass and bulk of the proposals was inappropriate, would situncomfortably within the plot with the tall and uninteresting form standing out amongst the heritageassets in the Conservation Area adjoining the Downs and unacceptably altering the existingcharacter of the area. This concern has NOT been remotely addressed by the reduction of one ofthe four tall buildings by one story and another by a mere 30 cm.

The extent of the tree loss in particular of high quality trees, although slightly reduced is still notjustified.

Parking provision is wholly inadequate, with the revised proposal including no more spaces andparking spaces in total of 65 for 116 dwellings (6 less than previously) and no additional spaces forvisitors, staff etc. The nature of the location, closely surrounded by residential roads, combinedwith the inadequate parking provision on site means that residents and staff would seek to park on

neighbouring roads impacting residents and creating traffic hazards.

In the context of the need for increased SEND accommodation in Bristol the proposal only offers avague proposal for shared use of a room in the "Urban Village Hall" which is wholly inadequate.

Unless major substantive changes are made to the application, it should be rejected in its entirety.

Regards,

Ella Ward Parsons

My original objection made on the 17th May 2022 still stands. The latest planssubmitted by the developer have not made any material difference to lessen the harm theirproposed development would have.

The proposed design plans are too big, too dense and too high. It will cause significant visualharm, in a highly valued and protected conservation and heritage site of Bristol. No other propertyowner would be allowed to build such a visually and environmentally harmful development on theDowns. The developer's reason to build at this scale and mass appears to be that they need tomake their financial business model work. That is not an acceptable justification. The LPA shouldcounsel the developer to help them find a more suitable and sympathetic design plan.

The Conservation panel strongly objects to the proposals and states they will cause "significantdamage"

I therefore resubmit below my original objection, as none of my reasons for objecting have beenaddressed or mitigated in the latest design plans the developer has submitted: -

ObjectionWhile the principle of an appropriate and acceptable development at this site has merit the currentapplication, due to its sheer amount, height, mass, bulk and stark out of character form will causeenormous visual harm and cannot be considered to conserve or enhance the character of theDowns Conservation Area and is therefore contrary to Section 72 of the Planning (Listed Buildings

and Conservation Areas) Act 1990 and policies BCS22 and DM31.

It is also clear that the proposed development would give rise to an unacceptable level of transportand road safety issues, loss of residential amenity by an overwhelming sense of overbearing andloss of biodiversity due to unnecessary extensive removal of high-quality mature woodland trees inthe highly valued Downs Conservation area.

The development also does not contribute towards the Affordable Housing targets or SENDprovision, which Bristol clearly needs.

What is the justification for developing at this scale, mass and amount in the context of a highlyvalued conservation area?It appears the applicant is stating their commercial business model can't operate, as desired, ifthey sympathetically adjust their design plans and have less flats.

The below was reported in The Bristol Cable last December at a public consultation, the developerwas quoted as stating: -"The total number of units has been reduced to 125 to 120, which are made up of a mixture ofcottages and apartment blocks. But Martin said this total can't be reduced further, becauseotherwise the care model won't work, as residents will have to be charged more for their servicecharge. "

However, this appears to be an issue for the applicant's own financial decision making and not aplanning justification to approve a multi harmful development in a heritage conservation area,where no other application would stand a chance of being approved.

Furthermore, the applicant has not provided a viability assessment to qualify this position. Withoutsuch information Bristol City Council are unable to verify the justification for development at thisscale. They are being asked to establish that a developer's individual business model, and needfor financial return by building large bulky blocks of flats on The Downs, is more important thansafeguarding the conservation status of a heritage asset for future generations. If established,Bristol City Council may well then have no control over similar applications that might be submittedby other residential care developers in the location who want to build overbearing bulky new flatroof apartments to make their own operating model work.

Would the proposed development be out of scale or context with the surrounding area?

Section 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 indicates thatdevelopment proposals should conserve or enhance the character and aesthetic of designatedConservation Areas.

Policy BCS20 sets out the development should exhibit densities informed by characteristics of the

site and local context.

Policy BCS21 states that new development should deliver high-quality urban design whichcontributes towards the character and identity of the area.

Policy BCS22 states that development proposals should not undermine the character, significanceor setting of any designated heritage assets.

Policies DM26-27 (inclusive) of the Site Allocations & Development Management Policies requiredevelopment to contribute to the character of an area through its layout, form and building design.

Policy DM30 states that development proposals should respect the character, scale and form ofthe host property and preserve traditional architectural features.

Policy DM31 states that development proposals should not give rise to any unacceptable impactson the character or setting of designated heritage assets.

Any site visit taken by Planning Officers or City Design Group members will clearly identify theapplication design is in conflict with all these policies. The unsympathetic design is not in keepingwith the aesthetic of the Conservation Area and would cause visual harm from both long, andshort-range, views. To suggest otherwise by the applicant's own Heritage Assessment Statementwould be inaccurate.

Bristol City Council City Design Group and Planning Offices should consult with the applicant toidentify a high quality, conservation style design which respects and enhances the character of thearea.

In its current form the development would reinforce poor quality design which would be visuallyincongruous to the character of the buildings and its immediate surroundings.

Is the impact of the proposed development on transport and highways acceptable?

Policy BCS10 states that development should be designed and located to ensure safe streetswhere traffic and other activities are integrated.

Policy DM23 outlines that development should not give rise to unacceptable traffic conditions andwould be expected to provide safe and adequate access onto the highway.

Policies BCS10 and DM23 outline that development should not give rise to any impact on parkingor vehicle access.

The application does not accord with these policies. Owing to insufficient on-site parking provision

and inappropriate access/egress arrangements, which will increase the road safety risks in anarea where this is already a significant concern.

Bristol City Council Transport Development Management should be highly concerned and has aDuty of Care over road safety. It is not acceptable in terms of highways and transport impacts.

Would the proposed development give rise to any unacceptable impacts on residential amenity?

Policy BCS21 states that new developments should safeguard the amenity of existingdevelopments.

Policy DM30 states that development proposals should not prejudice the existing and futuredevelopment potential of adjoining sites.

The proposed development would be of an unacceptable scale and mass and would give rise toan unacceptable sense of overbearing. The proposed new build section will unreasonablyoverlook and dominate all the surrounding homes on the roads affected.

Does the proposed development give sufficient consideration to its environmental impact?

While the development is likely to accord with sustainable design and build standards such asPolicy BCS13, BCS14 and BCS15. There will be a significant, unjustified, loss of many maturewoodland trees and a detrimental impact on nature & wildlife. Losing high-quality specimens thatmake a valued contribution to the character and appearance of the Conservation Area. Thisunique area requires safeguarding for future generations.

Furthermore, the lack of SEND provision and Affordable Housing creates an imbalance in the localcommunity.

While there is merit for an acceptable and appropriate development at this site, the harm thisparticular application will cause in its current form and scale cannot be considered acceptable andwarrants being refused.

The proposed development at the site of St Christopher's School is utterly unsuitable forthis elegant Victorian residential district. To build five-storey blocks of flats is absurdly out ofproportion. The number of residential units is far too high, the reduction of only 6 units after theconsultation comes nowhere near what is required, and the impact on traffic and parking will meangridlock for the neighbourhood. The impact on the natural beauty of the area, with the removal ofancient trees and the loss of wildlife habitats, would be irreversible. I would like to object in thestrongest terms.

I am very much against the development. The building development will not fit intoneighbourhood style. Also it will be too big and out of place. It will create extra traffic and reducethe availability of parking for existing residence. The loss of the greeny and wildlife is a hugeconcern as Westbury Park and Redland are known to be green areas which protect the trees andspaces. Trees take decades to grow and should be protected by all means.

I see there has been some concessions. But I love so close by and walk by the areaevery day. I am very anxious - the plans are still TOO big for the area. They must re think andscale back on all front. Smaller and for fewer people. Please do not let this pass.

We object to the proposal for a number of reasons as noted below.

We appreciate that there have been some changes to the original proposal, however these do notaddress the main concerns regarding this development. Fundamentally it is still too dense andover developed and not in keeping with the conservation area. The impact that this scale ofdevelopment would have on the existing strained road networks would be devastating.

Housing DemandsIt is noted in the application that this development will be aiding the housing shortage, howeverthis accommodation is high end housing and not the type that is required as there are similarfacilities in the area with considerable vacancies. If this development was market housing, a muchneeded affordable housing provision would be incurred, the density of the site would besignificantly lower due to residential design requirements and the parking allocation would be morerealistic.Application TimingWe also note that the timing of this application for comments, with the majority of the period overthe Christmas holiday, was restrictive. An extension would be a good idea considering manyresidents and community members (eg school users and local businesses) might not have seen /had the time to review the updated documents properly.Parking & TrafficAlthough there are 6 fewer units and the parking has not changed, this is still a huge underprovision for parking. Visitors, residents and workers of the site will park on the adjacent streets.

Fundamentally, Westbury Park road (in effect a single lane road due to parking on one side) is notadequate for the purpose and any increase in traffic or parking will be hugely problematic to thearea. This has been highlighted recently when St Christophers site was used as a vaccine clinicand the traffic on this road led to road blocks and huge traffic jams. The updated transportstatement uses a 2 day survey at night (22.00 - 00.00) however this is not appropriate to the trafficand parking issues of the area. These are predominantly during the daytime due to the competingneeds of parking residents, visitors, workers, local commerce, staff at local schools/ nursery andcommuters benefiting from free parking and using local transport to travel into work in town.Due to the large scale of this development (116 units and café & facilities), there will be asignificant increase to the local traffic (Residents, Staff, Visitors & Deliveries). The parkingprovision of 65 spaces for 116 units, Staff and visitors is laughably inadequate. In contrast, thenearby Vincent development at Queen Victoria House (Planning Reference 15/01681/F) providingnew accommodation for assisted living for older people comprised of 65 homes with 66 carparking spaces.The applicant proposal is a high-end residential development for occupants aged from 65 yearsold. A high proportion of them will still be driving and wanting the independence of their own carand for shopping. The parking provision should therefore be based on normal residentialdevelopments, not care home standards. There is nothing in place to stop theoccupants/staff/visitors from utilising overspill parking on the adjacent streets, which are stretchedto breaking point. This is more likely given the parking spaces provided on site are rented to theusers at a cost.

Scale & Density update.The proposal is still far too over developed & too dense for the site. Although there has been areduction of units and the ridiculous 6 storey villa B has been reduced to 5 storeys, this is just atoken gesture by the developers and overall it is still too dense for the scale of the site.

We live nearby and our children attend Westbury Park School adjoing the site. Weobject very strongly on the grounds that it will further compound issues of traffic and parking in theneighbourhood. The development will alter the character of the area, being so large and high rise,and due to the clearing of mature trees on the edge of the leafy downs.

The residents of Belvedere Road have had problems in finding parking spaces for along time as it is not in an RPZ. It is used by commuters and others who leave their cars thereduring the day. There are also many vehicles parking and manoeuvring associated with thenursing homes. Extra pressure on parking spaces caused by the proposed development wouldmake the situation intolerable for residents.

It is a shame that such a monstrous development might even be considered forapproval. There are no other buildings close to this height in the area and developers areproposing something not at all in keeping with the surrounding neighbourhood. Even the existinghouses on site which overlook the Downs would be dwarfed by the buildings proposed. Please,please don't give approval for these plans which are clearly motivated by greed and trying to packas many people in as possible purely for profit. It just isn't right and nobody who lives in WestburyPark wants this extreme over development to happen. Surely this should matter.

There are already far too many cars on the roads here and this will bring even more.Also bad for the environment

My two grandchildren attend Westbury Park School and I regularly do the school run.Bayswater Road and the pavements narrow and restricted by trees so that the road often has tobe used to allow groups of people to pass. With the development there would be more traffic andmore parked cars with the limited number of parking places on the site presenting more danger toschool children. I also object to the proposed felling of mature trees. The revised plans do notsolve anything and I object to the development.

This scheme will cram huge numbers of luxury housing into an area already underpressure for services and parking. The scheme will destroy a large number of mature treesreducing air quality and causing detrimental environmental impact. Views to the downs will beobstructed and parking space allocated is insufficient for the development. There is also noaffordable options which is much needed in this area of bristol. I cannot see anything positiveabout this development and strongly object to it.

I must express my objection to the revised plans proposed for the St Christophers site.

There appear to have been very minor changes from the original plans

The proposed plans appear to be overdeveloping this site with too many housing units, andbuilding blocks that are too high and out of keeping with the surrounding area and overbearing tothe surrounding property and area. The plan to reduce many of the blocks by 30cm clearlyrecognises that this is an issue, but completely fails to address it.

There is not nearly enough parking provision. The impact this will have on the surrounding roadswhich are already overcrowded with parked cars is likely to become a safety hazard, particularly inview of the primary school nearby.

Far too many mature trees are planned to be felled and site will be too densely built on to replantthe trees on this site, changing the aesthetics of this site greatly

It also seems very wrong that there will be no concrete special educational needs provision giventhe history of this site and the real need for this provision in bristol

Dear Sir/ Madam,

I live adjacent to the site and the latest changes to the scheme are minor and address non of theoriginal issues. The developers have ignored the concerns raised by the local community and acomplete redesign is required. The surrounding roads are dangerous due to high volumes of trafficand pavements are blocked on a daily basis. Please object the scheme. Thank you.

Proposed development is too large and overbearing. Especially since it's overlookingthe Downs which is really an amenity for all of Bristol not just the local area.

The new proposed development is still far too big . It is totally out of keeping with thelocal area .This area is a haven for wildlife, with regular sightings of bats, owls, foxes , badgers etc etc -thedevelopment with have a hugely detrimental affect on the wildlife.Please rethink this development.

The planned development for this site would have a very negative impact on thesurrounding area and residents. The plans and revised plans are building far too many propertieson this site, with buildings that are too large and overbearing to the surrounding area. This alongwith the plans to cut down so many trees will be completely out of keeping with a conservationarea.

I have real worries that in a densely populated area with already congested roads, adding thisnumber of properties along with the transport needs of the care staff will have a very negativeimpact on the health and safety of the surrounding residents and lead to overspill parking on thealready overcrowded surrounding roads

My original objection to this development was mainly that the scale and density of thisdevelopment was completely inappropriate for this site. This was was concern for the density ofbuilding and related effects on roads and parking.

The revisions now proposed are modest in the extreme in addressing these concerns. My viewremains that the entire scale of the development needs drastic reduction to make it acceptableeven within its own aims.

The number of units is hugely too great for the Highways capacity of the surroundingfour roads.The main frontage road Durdham Down needs widening to two lanes plus parking space widthand full highways standard entrance junctions and sight lines.The developer should be funding a traffic scheme for the other three roads.

I am a regular visitor to the Glen and am appalled at the proposed development whichwill make a tremendous adverse impact on the street. The green character of the site currentlywould change to scenery of dense urban oppressive buildings. The developers own report statesthat the visual impact on the Glen is 'moderate to substantial adverse', and the existing houses willbe dominated and overlooked by buildings out of character with the currently pleasant area ofBristol. The amount of greenery and the loss of trees proposed is incredible at a time when weneed to increase biodiversity in Bristol. We understand that the current very difficult parkingsituation will get much worse with the residents, visitors, delivery vehicles and ambulances that willvisit the site, through the narrow heavily parked side street. Please reject this proposeddevelopment which is out of character with such a pleasant conservation area.

Reducing the No of residents by 6 will solve none of the added congestion or parkingproblems. Also the amount of traffic near the local primary school and nursery will increase.The flats are still to high for the area and will spoil the local skyline and views of the downs.In our world today there are already to many mature trees which help our environment being lost,(No more).

Commenter Type: Other

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:I am writing on behalf of with her full consent and

approval, since 1962.

Community Impact: The Glen has always been a very peaceful and neighbourly road, within in a

conservation area, where many of the residents have lived for many years. Most are either elderly

or have young children. The peacefulness of the road has been a boon to both, despite the many

issues with parking that already exist. To create an entrance from The Glen into the new

development, removing its cul de sac status, so that it becomes a through road, will completely

change the nature of this street, making it a hazard for young children and pets, not to mention

greatly increasing the noise and pollution that will be suffered by all. As St Christopher's has a

double entrance opposite the Downs, which has proved more than sufficient to date, it is hard to

imagine why creating another entrance, which will prove highly disruptive and dangerous, is truly

required.

Parking: With the amount of cars already parked primarily by non residents (most of the residents

have driveways) and the increased number of through traffic, The Glen will become extremely

difficult to navigate and cause the residents endless challenges as they try to manoeuvre in and

out of their own homes. It is clear that the application does not include enough parking to support

the number of individual properties included within the proposed development and so the onus is

on the developers to rectify this situation without imposing further constraints on the already

stretched parking capacity of The Glen.

Invasion of Privacy: I would also like to flag the invasion of privacy and blocking of light that will be

suffered by residents on the north side of The Glen which includes No. 17, by the height of the

properties that will back onto them, causing further distress to the residents who have living

peacefully in The Glen for many years.

This is a development funded for commercial gain. It does not offer any social housing or any

facilities that might be of benefit to the wider community. It is a huge space and should be able to

be developed without imposing so drastically on a neighbourhood that has shown itself throughout

the years to be a supportive and peaceful community.

I very much hope that the Council will register this impact and call upon the developers to rescale

their plans so that many people are not caused distress, property value impact and impaired

quality of domestic life in order to fund their profits.

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:The objection I submitted to the original planning application still applies to this

proposal. I continue to believe that this planning application should be refused for the reasons I

stated before'.

My main concerns, which I outlined in my previous response have NOT been addressed by the

very minor, superficial amendments to the planning application.

Specifically.

I was concerned that the scale, mass and bulk of the proposals was inappropriate, would sit

uncomfortably within the plot with the tall and uninteresting form standing out amongst the heritage

assets in the Conservation Area adjoining the Downs and unacceptably altering the existing

character of the area. This concern has NOT been remotely addressed by the reduction of one of

the four tall buildings by one story and another by a mere 30 cm.

The extent of the tree loss in particular of high quality trees, although slightly reduced is still not

justified.

Parking provision is wholly inadequate, with the revised proposal including no more spaces and

parking spaces in total of 65 for 116 dwellings (6 less than previously) and no additional spaces for

visitors, staff etc. The nature of the location, closely surrounded by residential roads, combined

with the inadequate parking provision on site means that residents and staff would seek to park on

neighbouring roads impacting residents and creating traffic hazards.

In the context of the need for increased SEND accommodation in Bristol the proposal only offers a

vague proposal for shared use of a room in the "Urban Village Hall" which is wholly inadequate.

Unless major substantive changes are made to the application, it should be rejected in its entirety.

Regards,

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:The objection I submitted to the original planning application still applies to this

proposal. I continue to believe that this planning application should be refused for the reasons I

stated before'.

My main concerns, which I outlined in my previous response have NOT been addressed by the

very minor, superficial amendments to the planning application.

Specifically.

I was concerned that the scale, mass and bulk of the proposals was inappropriate, would sit

uncomfortably within the plot with the tall and uninteresting form standing out amongst the heritage

assets in the Conservation Area adjoining the Downs and unacceptably altering the existing

character of the area. This concern has NOT been remotely addressed by the reduction of one of

the four tall buildings by one story and another by a mere 30 cm.

The extent of the tree loss in particular of high quality trees, although slightly reduced is still not

justified.

Parking provision is wholly inadequate, with the revised proposal including no more spaces and

parking spaces in total of 65 for 116 dwellings (6 less than previously) and no additional spaces for

visitors, staff etc. The nature of the location, closely surrounded by residential roads, combined

with the inadequate parking provision on site means that residents and staff would seek to park on

neighbouring roads impacting residents and creating traffic hazards.

In the context of the need for increased SEND accommodation in Bristol the proposal only offers a

vague proposal for shared use of a room in the "Urban Village Hall" which is wholly inadequate.

Unless major substantive changes are made to the application, it should be rejected in its entirety.

Regards,

The objections I submitted on the 13/04/2022 to the original planning application stillapplies to this proposal. I continue to believe that this planning application should be refused forthe reasons I stated before.We were pleased to see the entrance to the site next to daisychain nursery has been removedfrom the revised planning application.The revised planning application should be refused on the following points:The proposed development still results in a significant loss of trees and wildlife.Traffic and parking remains a significant safety risk as per my previous comments (inc photos).No Special educational needs provision.The proposed scheme is totally at odds with the character of the surrounding neighbourhood anddisregards the fact that this is a designated conservation area.The planning application is far too over developed the planned buildings are too high, too denselysituated and too large.The applicants for this proposal have clearly not listened to the concerns raised by the localcommunity, local group and national bodies as they have made largely token changes to the initialplanning application. They clearly have no regard for the area and have profit as their only focuswith regards to this development. There is no affordable housing.Please reject it.

Although not a close neighbour to the site I know the area well having lived here forover 20 years. During that time due to houses being turned into HMO and the introduction of aCPZ traffic and parking through the entire area has steadily deteriorated massively. The effects ofthe recently introduced CAZ have yet to be felt but being on the edge of the area there aredoubtless already extra vehicles using the narrow residential streets to avoid the charging zone.This ugly development does not have enough parking for the residents let alone theirvisitors/carers. Rush hour could see the area grind to a standstill with people trying to get to thenearby nursery and primary school. Extra danger will be presented to those trying to walk to theselocations by even more badly parked and driven motor vehicles due to overspill from the proposeddevelopment.

The proposed changes to the planning application are purely cosmetic and do nothingto address the impact on the local area. The height of the main buildings are too high and willimpact greatly on the surrounding residents. A site of this size will greatly impact traffic flow andparking problems that already exist in this area. The application is definitely not in keeping with thearea and is trying to cram too much into the site

Dear Sir,

I wish to register my objection to this insensitive and inappropriate proposal.

The plan is simply too large , too high and is pure overdevelopment. it offers no social housing andis only available to elderly rich folk who will lock themselves away behind its gates like a tribe ofprotected fossils. Do we really need this ?

No doubt the Bristol planners will mysteriously support it as they did last year for another appallingdevelopment Land At Home Gardens.

Yours faithfully

Andrew Sutton

The amendments to the plan are in no way satisfactory. This site should be redevelopedfor some type of facility for people with learning difficulties. This was the original purpose fir thisarea and we no longer would have that facility.In addition the plans proposed will create more traffic and parking problems in an area where thereare already problems.I have other objections to these plans such as the height of the buildings ( still too high)

Having attended two 'open days' for the St Christopher's development I was assuredBOTH times by more than one member of the development team that there would be NOVEHICULAR ACCESS at the rear of the development onto Bayswater Road/Etloe Road/St HelenaRoad junction. A nursery and primary school are immediate neighbours and adding more traffic toan already very busy T-junction would make it even more dangerous for pedestrians, lots of whomwill be children, as well as other motorists. Vehicular access CAN ONLY SAFELY BE FROM THEDOWNS ENTRANCE. Indeed pedestrian access must also be denied from BayswaterAvenue/Etloe Road to avoid St Christopher's staff attempting to park there and put additionalpressure on parking in the area.

Parking is already a huge problem in this area - cars are even left parked on pavements with EtloeRoad as a case in point! There will be no on street parking available for residents or staff! Anyparking required MUST BE SUPPLIED ON SITE.

While I appreciate the site needs to be developed I believe it must be done to complement itssurroundings. The existing villas can be refurbished to their original standard and any other newconstruction should complement them and certainly not be six storeys high!! Three storeys wouldbe ample any taller would constitute over development, totally swamp the site and severelyoverlook the homes and gardens of local residents - impeding not only on their privacy but also theprivacy of residents in St Christopher's.,

Being careful not to overdevelop this site would also enable the fantastic mature trees to remain in

situ. We need to continue to support and further develop the wildlife in this urban area as well asbenefit from the wonderful air cleansing properties of these trees. Bristol is proud to promote itselfas a green city and the council planners should stand by its beliefs.

I object on the grounds that a 5 storey high building will be significantly higher that thesurrounding buildings in a Conservation Area and will therefore have a significant impact of thecity landscape. I note that whilst there has been a proposed reduction in height from 6 to 5 storeysthe mews cottages have been increased in size and these cottages are in very close proximity totheir neighbours.Also note the removal of 33 trees and a number of hedgerows. The re-planting of new trees whichhave a poor survival rate doesn't make up for the destruction of beautiful and mature trees such asT65 & T52. Also the landscaping will not compensate for the loss of what some would classify asurban woodland. Bristol is facing an ecological disaster as was declared by the Mayor 2 or 3 yearsago. This site falls within the West of England Nature Recovery Network Wookland and isthererfore important ecologically.Other objections: Red brick doesn't go with the surrounding buildings.Too high a density which will lead to traffic problems due to the lack of imagination and willingnessto approach transport issues (the targetted age group often have lots of carers popping in and out& don't use scooters!).This development will not be providing affordable homes.

Bristol Civic Society lodged an objection to the earlier proposal. We acknowledge thatthere has been some reduction in height and massing which is welcome. However, the amendedproposal has not moved far enough and the basis of our objection remains the same.

We still believe that the proposal, because of its height, massing and design, would be harmful tothe character of the Conservstion Area in this location and harmful to the setting of the ListedBuilding. The Society is not opposed to the principle of development on this site to enable it tocontribute to the housing supply in Bristol but a less intensive approach more sensitive to theConservation Area, Listed Building and biodiversity is required.

Overdevelopment in this area, 116 residential units are too many.Loss of SEND provision which this site is particularly known for.Lack of parking provision for residents, their carers and visitors.Unimaginative buildings, not in keeping with the neighbourhood, ie, cube blocks of flats, whichhave too many storeysLoss of trees and wildlife.Increase of traffic on residential streets.The scheme is totally out of character with the neighbourhood and disregards the fact that this is aConservation Area

I object to the revised proposals for development on the site of St Christophers Schoolfor the following reasons.

1. The development is still far too dense for this Conservation area- only a small reduction on theoriginal proposal2. Totally inadequate parking spaces available - traffic will make the area more dangerous andchaotic3. The buildings are far too high and out of keeping with the area.4. Loss of mature trees and wildlife - far too little greenery in the development.5. There is no affordable housing in the development - we don't need more 'luxury' housing6. The loss of SEND educational places is not mitigated.

I objected to the first proposal to this development and cannot see any substantialchanges in the new proposal. My objections still stand.There are only 6 fewer homes in the new proposal.It is an overdevelopment on the site.It includes too many high-rise blocks.Very little provision has been made for parking in the area.There will be an increase in traffic on residential roadsThe development will be extremely disruptive to the area.Loss of trees and wildlife.Loss of SEND provision, for which St Christopher's is particularly well known.

I think the revised plans for now five storey blocks represents overdevelopment of thissite and that the proposed parking provisions are wholly inadequate given the existing congestionon local roads.

I wish to confirm my objection to this development which has not changed with therevised plans. I object for the following reasons:

1. There is a plentiful supply of retirement property in the area. This is clear from the number ofproperties on Rightmove. Particularly there is absolutely no need for yet more 'luxury' retirementproperty, vis the number of unsold flats in the Vincent and Audley Redwood. This is just a moneymaking scheme offering no amenity to the area. However there is a huge need for more familyhomes, single person dwellings and some more basic retirement dwellings mixed in with thecommunity.There is no way that any commitment of the government to the ideal of affordable housing isworkable in the current plans. What we need is a smaller amount of balanced housing to addbenefit to the community.2. This is a beautiful area of the city. This development pays no respect to the environment. Highrise, cutting down of trees, overcrowding. It will be a scar on the city and an enemy to wildlife..3. No attention has been made to the reality of traffic and parking. Even if older people do not owncars they generate a lot of vehicles in their properties, and I speak from experience here. Thereare care workers and cleaners who have to rely on their cars. There are frequent visits fromfriends and family, necessary to raise the elderly from depression, these will sadly reduce if thereis no parking. The streets around the site are already overbearingly parked. There must beenough parking spaces on site.4. No allowance seems to have been made for access of heavy lorries during the building works.These are all narrow heavily parked residential roads. How on earth are the vehicles going to get

through that without considerable damage to the roads and danger to the kids walking to and fromschool each day?

I'm incredibly concerned about the proposed development. The planned buildings aremuch too large and high, and are totally out of keeping with this beautiful and historic area.

As a mother of two young children, I'm also very concerned about an inevitable rise in traffic dueto the development, and the impact of this on the safety of the many children living locally. Thestreets here are narrow and parking is already very difficult.

I am also concerned about the loss of mature trees and wildlife. The scheme seems totally out ofplace in our neighbourhood, which is a conservation area.

I strongly believe that this application should be refused, for the reasons stated above.

I'd like to object to this application. I'm concerned with the loss of mature trees. I'd like tosee a new proposal that made a real effort to preserve trees since this is an important priority.Mature trees are irreplaceable. Financial contributions are unsuitable since they often go unusedand cannot make up for severe environmental damage. Birds can't nest in developer's money.I'm also concerned with the Loss of SEND provision, Lack of Affordable housing and lack ofemergency vehicle access.Surely the developers can come up with a better proposal that addresses these concerns.

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that the planning application should be refused for the reasons Istated before

The revised proposals do not deal with the many real concerns expressed by localresidents. The adjustments are minor 'window dressing' and not 'real' or 'serious'.eg The reduction in the number of units from 122 to 116 represents less than 5%. The reduction inheight of the villas by 300mm is negligible.

My principle concern is that of overdevelopment. This has inevitable knock-on effects with regardto the visual impact, the loss of trees/impact on wildlife, traffic/parking.

A real reduction in the density of the development would ease all these pressures and allow for amore creative use of a wonderful space.

Thank you.

I have concerns over the traffic that this will cause. There are not sufficient parkingspaces for the number of probable residents. It will impact the local flora and fauna, which isdiminishing all the the time in the city

The reasons for my previous objections still stand.Parking. 65 parking spaces for now 116 housing units. As before there is not enough parking.Opening Saint Christophers into the Glen will cause utter chaos with even more drivers findingthere is no parking and having to turn round unless they reverse to Belvedere Road all this is anaccident waiting to happen, there is parking on both sides of The Glen leaving only enough roomfor one car at a time to drive along.Overdevelopment. Developers one block reduced by 30cms!!! Historic England has it absolutelyright four storeys maximum as otherwise the impact is too great this is a designated conservationarea. Does this really mean nothing?Trees. The proposed removal of so many mature trees is scandalous with the needs of the planetat this time.SEN. The vague offer of a shared used space or room in the "urban village hall" that could beused for special education needs is just paying lip service to what is really required urgently.I could continue but I will save you from reading anymore as I think that you will see by the numberof people who are objecting we feel very strongly as a community.

This development should not be allowed to be giving planning permission.

It is also totally unprofessional to make these dead lines over the New Year period.

The project is far too big, not enough car spaces, as our area is already overcrowded.

On the whole I do not object to the development of the site however, we already havehorrible parking problems in and around our property specifically on The Glen, Belvedere Road,Redland Road and Blenheim Rd. This could be solved in one of 2 ways... 1. Add more dedicatedparking to the proposal; 2. Make these streets specifically part of the CN parking zone whichwould prevent residents, visitors or workers to the new site from being able to park here with norestrictions. This seems like a simple solution to the parking issue if BCC were willing to listen tothe concerns of local residents that we have been telling you about for years!

I am commenting on this planning application in much the same terms as I did to theprevious failed application. It is both disappointing and shocking that the changes made betweenthe two applications are so small as to be insignificant, which suggests that the developers haveno interest in listening to the views of the large numbers of local residents, heritage andconservation bodies and other political and expert commentators. This shows contempt.

There are so many levels on which to object to this application that I hardly know where to begin.

HERITAGE AND ENVIRONMENT IMPACTS

Perhaps the worst aspects are the proposed impacts on Heritage and Environment. The proposalswould bring very acute overdevelopment in this conservation area. The proposed scale, mass andheight of the buildings are incongruous within the vulnerable heritage context of Westbury Parkand the listed Grace House. These buildings would be visible all over Westbury Park and beyondand would be oppressive and ugly for Westbury Park residents. I dread it.

Of course, this overdevelopment can only be made at the expense of the trees and habitats thatexist within the proposed development site. Too many trees would be lost to us, many of themvaluable specimens that make an immeasurable contribution to the character and appearance ofthe area. The proposal would without question make a very harmful impact on the nature andwildlife of Westbury Park.

LOSS OF SEND PROVISION / TOO MUCH RETIREMENT PROVISION

I am familiar with both of these.

First, I have known people who have had children resident at St. Christophers and my wife and Ibrought up a niece with Special Educational Needs. We know well that there is a critical shortageof Special Educational Needs and Disability infrastructure and facilities in the Bristol Area. Ourcommunity should not be losing SEND provision; it should be growing it.

Second, my wife was admissions manager at the enormous St. Monica Trust, a world famous careand dementia home, just a few hundred yards away from Westbury Park, across the Downs. Alsowithin a few hundred yards are numerous other, smaller care homes and facilities offeringexcellent service and coverage. It is clear that we have adequate Retirement Provision in the areaand would be damaged by being swamped by more, densely packed into this development.

ROAD SAFETY, TRAFFIC AND PARKING IMPACTS

Five members of our family, over two generations, have attended Westbury Park School.

Both of our two daughters live in roads that enter Bayswater Avenue and Etloe Road.

We are very familiar with the dangerous traffic environment in which the school has to operate andalso the dreadful parking crisis in Bayswater Avenue and Etloe Road.

The proposal is totally inadequate in its provision for transport, parking and highway access. Thisis because there is very self-evidently insufficient on-site parking provision for the circa 200residents, their carers, staff and visitors and inappropriate access arrangements to the site.

The proposed means of access onto Bayswater Avenue/ Etloe Road near the Daisychain Nurseryand opposite the entrance to St Helena Road causes the greatest concern over the dangers that itwill create to school children and residents. The whole proposal. will increase the road safety risksin an area where this is already a significant concern.

Parking is already a serious issue in Bayswater Avenue and Etloe Road. There is no sparecapacity to accommodate the road parking of large numbers of residents of the proposeddevelopment.

We already suffer from non-resident commuters parking in our community before onward travel towork in Bristol. We have no more capacity for non-residents, such as the potential occupants ofthis development.

LACK OF AFFORDABLE HOUSING

There is no provision in the proposal for affordable housing for our younger community membersand no cogent reason is given for this lack of provision.

CONCLUSION

I object forcefully to this planning application and can find nothing in it to benefit or enhance ourcommunity.

Residents of Westbury Park are thoroughly switched on and are aware of the likely huge anddamaging impact on the Westbury Park Community and wider Bristol if this application should beapproved in anything like its current form.

This cannot be allowed to progress.

The developer has made only token changes to the plans already submitted, and so mypreviously stated objections all remain in place. This is an insensitive, overly-intensivedevelopment which will, if given planning permission, change forever the character andappearance of the area, with five storey apartment blocks in an area of predominantly periodbuldings. Provision for parking is inadequate and parking will spill over onto streets alreadystruggling to cope with existing residents' parking. There will be an increase of traffic requiringaccess to the site on the small surrounding streets which will not be able to cope with suchincrease. Many of these roads are currently quieter alternatives for walking and cycling that themain roads surrounding them. Increased traffic and pollution on these streets will be to thedetriment of walkers, cyclists and residents alike. The loss of mature trees to make way foraccommodation is unacceptable: as well as the loss of wildlife habitat, there is also the loss ofCO2 absorption (an estimated 40 tons of CO2 per annum per tree) and the city cooling effectafforded by mature trees.Please do not accede to developer greed by granting consent to this planning proposal.

The revised planning application should be refused for the following reasons: Theproposed development still results in a significant loss of trees and wildlife. Traffic and parkingremains a significant safety risk. No Special educational needs provision. The proposed scheme istotally at odds with the character of the surrounding neighbourhood and disregards the fact thatthis is a designated conservation area. The planning application is far too over developed theplanned buildings are too high, too densely situated and too large. There is no affordable housing.It is abundantly clear that the applicants for this proposal have clearly not listened to the concernsraised by the local community; local groups and national bodies. They have done nothing morethat make only token changes to the initial planning application. They clearly have no regard forthe area and have profit as their only focus with regards to this development. Please reject it.

It seems the revised plans have barely changed and therefore my previous concernsstill stand.

The height of the proposed buildings is not sympathetic to the surrounding structures and woulddominate the skyline. Laughable given the difficultly residents have adjusting the height of adormer window!

Too many proposed residents with not enough parking, before taking into account staff andvisitors, will inevitably lead to more parking and safety issues in surrounding roads.

The provision for SEN children is an ill thought out token gesture. As a father of an SEN child, Ifind it quite insulting that developers use the SEN badge to justify a project when that is clearly nottheir priority.

I think that a development for the site would be good but because of the complex nature of theenvironment any developer needs to spend more time on design and less time trying to forcethrough basic and unsuitable proposals.

Thanks

This is clear overdevelopment of an already very crowded and popular area for profitand not sustainability.

I object to this revised planning application on the same grounds as I objectedpreviously. It is unconscionable in this climate emergency to cut down mature trees, there is noparking on the Downs as it is, and this overdevelopment will make that problem exponentiallyworse, and the proposed development is out of keeping with the area. Do Conservation Areasmean nothing nowadays?

I have lived close to the site all my life and object to the effect of more cars on theneighbouring roads.

The fact that for each unit only one on site parking place is to be provided means there will be anumber of cars parked outside the development. There will also be considerably more traffic onthe adjoining roads which are already inadequate

My previous objections have not been met by the slightly altered recent application. Mymain objection concerns the prospect of blocked roads, traffic jams and more parking on thepavements of streets near to the site. Living close nearby I have already noticed a worseningtraffic situation. Proximity to Westbury Park Primary School reinforces my objections . Primaryschool children should be moving forward towards self.

Inappropriate development in size and nature.Will cause traffic and parking problems ifallowed.The felling of mature trees is not acceptable.

Please note all previous comments still stand as the planning laws clearly state thisdevelopment is not appropriate and everyone having to spend time and effort on this overChristmas is outrageous.Additionally, the drawings are not to a correct scale in places so one can't determine the exactscale, heights & distances, especially considering drawings have been deceitful as mentioned onmultiple occasions in the past.Its perplexing that a development which had such a huge negative response can be resubmittedwith so few minor changes made.My previous comments still stand as outlined below:This proposed development displays a complete lack of consideration for the heritage andconservation of the existing landscape, especially in relation to neighbouring buildings.In particular the proposed buildings are too high next to the neighbouring houses with too muchdensity and too close. They over power and over shadow existing homes and in particular thehouses in the Glen.Additionally, the area simply cannot take the volume of cars and traffic associated with such adense site. Westbury Park Road is already gridlocked during rush hour and busy throughout theday and this is before most people return to working in the office again. The surrounding roads, inparticular The Glen, are already difficult to navigate and any extra traffic from the development -and potentially opening access ways such as the proposed emergency and pedestrian access atthe end of The Glen - would make it dangerous.As stated in many comments on the application process, I would reiterate the opinion that thedevelopers have not conducted a fair and appropriate consultation process: it has been done to

push an agenda.In summary, I cannot object strongly enough to this proposal.

My previous objections have not been met by the slightly altered recent application. Mymain objection concerns the prospect of blocked roads, traffic jams and more parking on thepavements of streets near to the site.

Living close nearby I have already noticed a worsening traffic situation. Proximity to WestburyPark Primary School reinforces my objections . Primary school children should be moving forwardtowards self sufficiency and autonomy in walking to school, and learning to cycle safely. Reallycongested streets with more people parking their on the pavements already is worsening withoutthe great increase envisaged by cars of residents of the proposed homes. The proposed reductionin resident numbers is derisory in my opinion.

Extra congestion due to many more cars, delivery and construction and health workers vehicles aswell as visitors to the site will inevitably add much more road traffic and pressure on theneighbourhood.

Air pollution, too, would increase. Many trees could presumably be planted on the Downs, but theimmediate impact of many more vehicles passing by should not be ignored.

I am not against the development in principle , but in relation to its proposed implementation. I amalso concerned that there is to be no affordable housing provision, and no constant or appropriateSEND provision. Educational ends should be respected and met, especially given the history ofeducational provision on the site. The Bristol Council report underpins my objection. Lip service or

vague aspirational aims will not suffice.

The objections submitted previously still apply to this proposal together with theadditional following concerns and comments. We would ask you to consider these points inconjunction with all the previous reasons provided which included that the development, asproposed, would conflict with Policies BCS18, BCS21 and the aims of the Development Plan.Please note that the previous objections were submitted after consultation with CSJ PlanningConsultants together with their details, and all concerns listed.

Additional concerns.

Proposed Cottages H.O.1. ( ref drgs No's 2004,2005 and 2006. Nb: Developers drawing notavailable showing Floor Plans or Elevations of these cottages and no new 'Distances Plan'available as previously submitted. Certain information taken from H.O.2 cottages drawing No2021)The developers purport these as ' Cottages'. They are not - they are a 'Wall of 5 Terraced Houses'sited to the rear of our home and garden. If scaled correctly according to developer's drawingsthey are greater in height than our subject house which has, as I understand, never been classedor referred to as a 'Cottage'. These 'so called cottages' should be no higher or closer than thesingle storey units that exist on the proposed site location and be arranged as individual dwellingswith a balanced layout to create an appealing site line. Bungalow style units would be moreappropriate here.Similarly, this I believe should also apply to the H.O.2 cottages proposed adjacent to residents inBayswater Avenue.

Villa 'C'. Proposed 5 Storey Unit. (ref drg No's 2004,2015,2016 and 2017.)This unit has East facing side windows and balconies which look directly into our habitable roomsand rear garden. Nothing here should be above 2 storey and certainly not be so imposing and ofsuch high density. Any dwellings for consideration on such a sensitive border must surely bescaled and proportioned accordingly.

Villa 'D'. Proposed 4 Storey Unit (ref drg No's 2005 and 2019.)This Multi Storey Apartment Block is positioned overlooking the full length of our home includingthe front and rear gardens. It is outrageous to suggest having this monstrosity with multiplewindows ( dozens in fact ) and balconies looking directly into our habitable rooms and garden.Again, nothing here should be above 2 storey and contrary to a design and density appropriate tothe site, especially being in a conservation area. As pointed out in the previous objection,reference drawing No 2019, Fig 3 shows the fenestration arrangement of these unacceptablenumerous windows and balconies. Again, we reiterate the fact that any dwelling considered onsuch a sensitive border must surely be scaled and proportioned appropriately.

Summary.As stated in our previous submission, the foregoing siting of all proposed dwellings results in a'hemming in' of our home from every angle, amounting to a complete invasion of privacy. We areoverlooked, over-powered and over-shadowed from every proposed adjacent unit and dwelling.We would again also draw your attention to the previous 'Daylight and Sunlight Assessment' whichis considered not to provide sufficient evidence that the proposal is acceptable, with some roomsexperiencing a 28% reduction in daylight. Also previous 'Overshadowing' statements wereincluded, referring to an unacceptable loss of daylight .We have fully engaged with the developers, attending every possible meeting and consultation butwe do not feel that any of our concerns have been addressed or acted upon. This is highlighted bythe fact that generally only superficial adjustments have been made and no follow-onneighbourhood consultation process has been provided to us after submission of the most recentplans.Together with the foregoing points we draw your attention to all previous relevant commentsincluding:- Increased traffic and lack of parking especially in 'The Glen'. This is dire.-General over development of the entire site.- Loss of certain trees and wildlife.- Unacceptable Harming of a "Heritage Site" particularly in a Conservation Area.-The disgraceful loss of a long-standing established Special Needs Education School on this site.At the present time, the way this is all unravelling looks most suspicious.

We are not 'Nimbys' but please reconsider these proposals and reduce the stress and anxiety thatwe and many others are experiencing associated with these outrageous and unacceptableproposals.

Thankyou in advance.

The objections submitted previously still apply to this proposal together with theadditional following concerns and comments. We would ask you to consider these points inconjunction with all the previous reasons provided which included that the development, asproposed, would conflict with Policies BCS18, BCS21 and the aims of the Development Plan.Please note that the previous objections were submitted after consultation with CSJ PlanningConsultants together with their details, and all concerns listed.

Additional concerns.

Proposed Cottages H.O.1. ( ref drgs No's 2004,2005 and 2006. Nb: Developers drawing notavailable showing Floor Plans or Elevations of these cottages and no new 'Distances Plan'available as previously submitted. Certain information taken from H.O.2 cottages drawing No2021)The developers purport these as ' Cottages'. They are not - they are a 'Wall of 5 Terraced Houses'sited to the rear of our home and garden. If scaled correctly according to developer's drawingsthey are greater in height than our subject house which has, as I understand, never been classedor referred to as a 'Cottage'. These 'so called cottages' should be no higher or closer than thesingle storey units that exist on the proposed site location and be arranged as individual dwellingswith a balanced layout to create an appealing site line. Bungalow style units would be moreappropriate here.Similarly, this I believe should also apply to the H.O.2 cottages proposed adjacent to residents inBayswater Avenue.

Villa 'C'. Proposed 5 Storey Unit. (ref drg No's 2004,2015,2016 and 2017.)This unit has East facing side windows and balconies which look directly into our habitable roomsand rear garden. Nothing here should be above 2 storey and certainly not be so imposing and ofsuch high density. Any dwellings for consideration on such a sensitive border must surely bescaled and proportioned accordingly.

Villa 'D'. Proposed 4 Storey Unit (ref drg No's 2005 and 2019.)This Multi Storey Apartment Block is positioned overlooking the full length of our home includingthe front and rear gardens. It is outrageous to suggest having this monstrosity with multiplewindows ( dozens in fact ) and balconies looking directly into our habitable rooms and garden.Again, nothing here should be above 2 storey and contrary to a design and density appropriate tothe site, especially being in a conservation area. As pointed out in the previous objection,reference drawing No 2019, Fig 3 shows the fenestration arrangement of these unacceptablenumerous windows and balconies. Again, we reiterate the fact that any dwelling considered onsuch a sensitive border must surely be scaled and proportioned appropriately.

Summary.As stated in our previous submission, the foregoing siting of all proposed dwellings results in a'hemming in' of our home from every angle, amounting to a complete invasion of privacy. We areoverlooked, over-powered and over-shadowed from every proposed adjacent unit and dwelling.We would again also draw your attention to the previous 'Daylight and Sunlight Assessment' whichis considered not to provide sufficient evidence that the proposal is acceptable, with some roomsexperiencing a 28% reduction in daylight. Also previous 'Overshadowing' statements wereincluded, referring to an unacceptable loss of daylight .We have fully engaged with the developers, attending every possible meeting and consultation butwe do not feel that any of our concerns have been addressed or acted upon. This is highlighted bythe fact that generally only superficial adjustments have been made and no follow-onneighbourhood consultation process has been provided to us after submission of the most recentplans.Together with the foregoing points we draw your attention to all previous relevant commentsincluding:- Increased traffic and lack of parking especially in 'The Glen'. This is dire.-General over development of the entire site.- Loss of certain trees and wildlife.- Unacceptable Harming of a "Heritage Site" particularly in a Conservation Area.-The disgraceful loss of a long-standing established Special Needs Education School on this site.At the present time, the way this is all unravelling looks most suspicious.

We are not 'Nimbys' but please reconsider these proposals and reduce the stress and anxiety thatwe and many others are experiencing associated with these outrageous and unacceptableproposals.

Thankyou in advance.

Please note all previous comments still stand as the planning laws clearly state thisdevelopment is not appropriate and everyone having to spend time and effort on this overChristmas is outrageous.Additionally, the drawings are not to a correct scale in places so one can't determine the exactscale, heights & distances, especially considering drawings have been deceitful as mentioned onmultiple occasions in the past.Its perplexing that a development which had such a huge negative response can be resubmittedwith so few minor changes made.My previous comments still stand as outlined below:This proposed development displays a complete lack of consideration for the heritage andconservation of the existing landscape, especially in relation to neighbouring buildings.In particular the proposed buildings are too high next to the neighbouring houses with too muchdensity and too close. They over power and over shadow existing homes and in particular thehouses in the Glen.Additionally, the area simply cannot take the volume of cars and traffic associated with such adense site. Westbury Park Road is already gridlocked during rush hour and busy throughout theday and this is before most people return to working in the office again. The surrounding roads, inparticular The Glen, are already difficult to navigate and any extra traffic from the development -and potentially opening access ways such as the proposed emergency and pedestrian access atthe end of The Glen - would make it dangerous.As stated in many comments on the application process, I would reiterate the opinion that thedevelopers have not conducted a fair and appropriate consultation process: it has been done to

push an agenda.In summary, I still strongly object to this proposal.

The objections submitted previously still apply to this proposal together with theadditional following concerns and comments. We would ask you to consider these points inconjunction with all the previous reasons provided which included that the development, asproposed, would conflict with Policies BCS18, BCS21 and the aims of the Development Plan.Please note that the previous objections were submitted after consultation with CSJ PlanningConsultants together with their details, and all concerns listed.

Additional concerns.

Proposed Cottages H.O.1. ( ref drgs No's 2004,2005 and 2006. Nb: Developers drawing notavailable showing Floor Plans or Elevations of these cottages and no new 'Distances Plan'available as previously submitted. Certain information taken from H.O.2 cottages drawing No2021)The developers purport these as ' Cottages'. They are not - they are a 'Wall of 5 Terraced Houses'sited to the rear of our home and garden. If scaled correctly according to developer's drawingsthey are greater in height than our subject house which has, as I understand, never been classedor referred to as a 'Cottage'. These 'so called cottages' should be no higher or closer than thesingle storey units that exist on the proposed site location and be arranged as individual dwellingswith a balanced layout to create an appealing site line. Bungalow style units would be moreappropriate here.Similarly, this I believe should also apply to the H.O.2 cottages proposed adjacent to residents inBayswater Avenue.

Villa 'C'. Proposed 5 Storey Unit. (ref drg No's 2004,2015,2016 and 2017.)This unit has East facing side windows and balconies which look directly into our habitable roomsand rear garden. Nothing here should be above 2 storey and certainly not be so imposing and ofsuch high density. Any dwellings for consideration on such a sensitive border must surely bescaled and proportioned accordingly.

Villa 'D'. Proposed 4 Storey Unit (ref drg No's 2005 and 2019.)This Multi Storey Apartment Block is positioned overlooking the full length of our home includingthe front and rear gardens. It is outrageous to suggest having this monstrosity with multiplewindows ( dozens in fact ) and balconies looking directly into our habitable rooms and garden.Again, nothing here should be above 2 storey and contrary to a design and density appropriate tothe site, especially being in a conservation area. As pointed out in the previous objection,reference drawing No 2019, Fig 3 shows the fenestration arrangement of these unacceptablenumerous windows and balconies. Again, we reiterate the fact that any dwelling considered onsuch a sensitive border must surely be scaled and proportioned appropriately.

Summary.As stated in our previous submission, the foregoing siting of all proposed dwellings results in a'hemming in' of our home from every angle, amounting to a complete invasion of privacy. We areoverlooked, over-powered and over-shadowed from every proposed adjacent unit and dwelling.We would again also draw your attention to the previous 'Daylight and Sunlight Assessment' whichis considered not to provide sufficient evidence that the proposal is acceptable, with some roomsexperiencing a 28% reduction in daylight. Also previous 'Overshadowing' statements wereincluded, referring to an unacceptable loss of daylight .We have fully engaged with the developers, attending every possible meeting and consultation butwe do not feel that any of our concerns have been addressed or acted upon. This is highlighted bythe fact that generally only superficial adjustments have been made and no follow-onneighbourhood consultation process has been provided to us after submission of the most recentplans.Together with the foregoing points we draw your attention to all previous relevant commentsincluding:- Increased traffic and lack of parking especially in 'The Glen'. This is dire.-General over development of the entire site.- Loss of certain trees and wildlife.- Unacceptable Harming of a "Heritage Site" particularly in a Conservation Area.-The disgraceful loss of a long-standing established Special Needs Education School on this site.At the present time, the way this is all unravelling looks most suspicious.

We are not 'Nimbys' but please reconsider these proposals and reduce the stress and anxiety thatwe and many others are experiencing associated with these outrageous and unacceptableproposals.

Thankyou in advance.

Please note all previous comments still stand as the planning laws clearly state thisdevelopment is not appropriate and everyone having to spend time and effort on this over theChristmas period is terrible with the timed consultation over the festive period.

Additionally, the drawings are not to a correct scale in places so one can't determine the exactscale, heights & distances, especially considering drawings have been deceitful.

Its sad that a development that had such a huge negative response can be resubmitted with sofew minor changes made.

This proposed development displays a complete lack of consideration for the heritage andconservation of the existing landscape, especially in relation to neighbouring buildings.In particular the proposed buildings are too high next to the neighbouring houses with too muchdensity and too close. They over power and over shadow existing homes and in particular thehouses in the Glen.

Additionally, the area simply cannot take the volume of cars and traffic associated with such adense site. Westbury Park Road is already gridlocked during rush hour and busy throughout theday and this is before most people return to working in the office again.

The surrounding roads, in particular The Glen, are already difficult to navigate and any extra trafficfrom the development - and potentially opening access ways such as the proposed emergency

and pedestrian access at the end of The Glen - would make it dangerous.

I cannot object strongly enough to this proposal.

There were only minor changes to the original scheme.So the main objections still apply.1) This is overdevelopment with still 6 storey buildings overlooking all the 2 storey houses in thesurrounding area. They are huge in comparison to anything else and would overlook all otherproperties. They would also be clearly visible from the downs without trying to match thesurrounding area.2) Parking and traffic. There are already major parking problems in the area with very little parkingavailable. This project only supplies around 50% parking leaving all the other vehicles hunting forspaces surely each property should have parking. There are also major traffic queues at peak timealready on the road outside St Christophers and surrounding roads. This large increase in trafficwill only intensify the problems . The roads in this area cannot cope with the present trafficcreating an already dangerous situation.

I am not convinced by the most recent development plans for the following reasons:1. The existing site comprises beautiful buildings and surroundings which will be utterly ruined bythe proposed high-density development.2. Existing parking problems will be exacerbated as a result of overflow parking3. A reduction by only a handful of units is not enough to get my support

Hi, as a local resident, living a few streets down from this development plan. I do objectto the plans for the following reasons and fully support apposing this development:

Overdevelopment - still too big, too dense & too highb. Loss of Trees and Wildlife - still too many trees being chopped downc. Traffic - not enough parking spaces leading to overspill and roadsafety hazardsd. Loss of Special Educational Needs Provision- derisory offer ofoccasional shared use of a room, unsuitable due to safeguardingconcerns, fails to adequately address Bristol's growing SEND crisis.e. Harm to Heritage - the scheme is totally out of character with ourneighbourhood and this precious Conservation Area.

I strongly object AGAIN to what is a massive overdevelopment of this site.

The negative impact this would have to the surrounding area should be a major consideration.

*ROADS AND PARKINGIt is obviously not possible to widen the existing residential roads where only one vehicle can drivethrough at at a time.It is not possible to create new access roads or widen the existing one as the Downs is a protectedarea which is of benefit to everyone.Wishful thinking cannot possibly conjure up a solution to what will inevitably result in total chaosand gridlock.The resulting overspill, distressing for residents will also affect local shops.The lack of suitable access and parking facilities should be more than enough to reject theseplans.

*OTHER OBJECTIONSThere is no justifiable reason here to cut down valuable and irreplaceable mature trees.The new buildings are so wrong in terms of character and size for this area.Both comprehensively covered by other respondents.

The few minor changes must be seen for what they are - a deliberate ploy (used by manydevelopers) to get their plans approved

by hoping that fewer people will object every time they submit a new plan.Not everyone is aware that a comment has to be sent in for each application which gives thedevelopers an unfair advantage.

Planning Departments must surely consider it their duty to protect the quality of life and wellbeingof residents when considering such proposals.Greedy developers are only concerned with maximising their profit and do not care about theimpact on the communities affected.

Please send a strong and clear message that these plans have to be drastically amended.

The latest revisions do not address my previous concerns.

The height of the storey blocks is not appropriate in the local area, i.e. far too high. The number ofdwellings and the resulting number of residents is far too high for the size of the site. The localneighbourhood is saturated with parked cars, with inappropriate parking on pavements and closeto junctions, so the neighbourhood cannot support the anticipated addition of a large number ofadditional vehicles (belonging to staff, residents, visitors and online delivery drivers) There's alsothe loss of trees and the impact this will have on wildlife; and the loss of SEND provision (whichhas been a big part of history of this site).

In the developers' plans, there is the suggestion that this development will free up some of thelarge family homes because people wanting to downsize will choose this new site as their newresidence. This is guesswork, and it is a big assumption to make, and in my opinion shows acomplete lack of understanding of the local neighbourhood.

I strongly object to this proposal.

I am objecting for the first time to this proposal as the developers seem plainly to be ignoring thecommunity consensus. The community has made clear that they stand strongly in opposition tothese plans which would cause ridiculous overdevelopment, as well as cutting down mature treesin an urban community full of young people, a school, and older residents which must retain notonly its character, but its biodiversity and nature.

I am a young adult who grew up near the school. Seeing SEN children getting support, care, andeducation was fantastic, and the idea that this should be changed - purely for developers' financialgain - is appalling. The developers claim there is enough SEN provision in the rest of Bristol - thisis blatantly not true. The site should be protected and remain a site for SEN provision. If not, welose a huge amount of support and care for some of the most vulnerable members of ourcommunity - this seems unjustifiable.

I do not understand how these developers can justify a) hardly amending their plans betweenproposals, b) the large-scale over-development and chopping down of urban trees, c) the safetyconcern of road hazards with the number of people this scale of development would attract, d) thelack of regard for this site's history as an important site for SEN care in Bristol and the surroundingareas.

This my first comment on this scheme as the previous objections have represented myviews on this redevelopment of the site. I write to object now because the redrawn plans have notanswered my concerns over:The large mass of buildings have not been reduced enough to reduce the impact of the blocks asthey will continue to dominate the local residents' homes and so have a negative effect on theirlives. Reducing a 4 floor block down to 3 whilst not reducing the other blocks from their threestoreys does not answer the many objections previously made.

The car parking is inadequate as this development is not a care home but a luxury retirementhome. As a retired person who is considering downsizing to a retirement village, I know that I willretain my two cars so that my wife and I can lead independent lives. Using this as a yardstick thecar parking is inadequate therefore the excess car parking will spill outside of the complex andimpact badly on already congested streets. The developers calculations are biased and requireproper support by reviewing the parking requirements of other retirement villages.

Well, the revised plans don't suggest much of an improvement. Six fewer dwellings, andnot much reduction in height. Really too dense a development, at the expense of the open andgreen nature of the housing on the edge of the Downs. Do we really want the fringes of the Downsto look like a third rate version of Central Park, New York? We already have a tall residential blockand the old Spire hospital at the junction of Westbury Park and Belvedere Road. Parking provisionis inadequate. I think it works out at about one parking space for two dwellings. Visitor parkingdoesn't seem to have been considered. I doubt the residents of The Glen will be happy withoverflow parking outside their houses. Bicycle parking is a laugh. My mother used to cycle 4 milesto the nearest town for shopping, and brought it back balanced on her handlebars. She gave it uplong before she was eligible for the market this development is aimed at!

I object to the application and revised plans for the reasons stated in my previouslysubmitted objection, which still stands.

A primary reason remains the inadequate on-site parking. It is evident that the small reduction innumber of apartments will make no significant difference to this, and there would still be asignificant overspill on to the surrounding roads, which already suffer from over-demand due to thelocation being on the border of the RPZ.

Additionally the revised plans now propose vehicular as well as pedestrian access from The Glen(despite earlier assurances that this would not happen), and for this to provide the only vehicularaccess to the rear of the site - 24 apartments in Block D, 4 two-storey "cottages and the new"Urban Village Hall".

Given the shortage of on-site parking, concentrated at the front of the site, the new entranceincreases the likelihood of The Glen being used for free parking for residents, particularly those inthe units at the rear of the site, as well as for their visitors and carers. It also encourages thoseresidents to arrange drop-offs and deliveries at the end of The Glen - including potentially using itfor removal vans on moving in/moving out days, rather than having to park at the other end of theSt Christophers site.

The Glen is a narrow cul-de-sac which is already filled to capacity with parked cars. There is noturning space, so cars trying to access the St Christophers entrance would have to reverse back

down the road, past the junction with Belvedere Road, whose corners are frequently obstructed byparked cars, and from where vehicles also reverse back on to The Glen due to the regularblockages in Belvedere Road itself. This can only increase risks to pedestrians (including childrenwalking to the nearby school) in an area already acknowledged by BCC and the PlanningInspectorate to suffer from "significant hazards".

It is also very difficult to see how fire appliances could safely access the site from the end of TheGlen - with all the double parking, parking on corners of junctions, and road blockages due to theNursing Homes on Belvedere Road, access to the site cannot be guaranteed to be possible at alltimes.

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that this planning application should be refused for the reasons Istated before

My previous objection still stands. The plans have barely been changed, and none ofour feedback has been addressed.

I am not happy with the extra floors to buildings

There are enough HMO's in the area already ,creating parking and traffic problems. Tothen put an extra 200 residents with little thought to the parking on site is very bad planningdecision by the developers. The removal of tree's and green spaces to create these high rise flatswill change the sky line for many people who enjoy walking on the downs.

I write to express my concerns about this development as follows:

Overdevelopment - still too big, too dense & too high - just 6 fewer housing units than before andstill no affordable housing

Loss of Trees and Wildlife - still too many protected mature trees being chopped down

Traffic - still not enough parking spaces leading to overspill and road safety hazards

Harm to Heritage - the scheme is totally out of character with our neighbourhood and disregardsthe fact that this is a designated Conservation Area.

I urge the Planning department to reject the development as is it still not suitable for WestburyPark and the wider community. Thank-you.

The revised plans have made very little difference to the impact this development willhave on the local community. Hence I am objecting for a second time.

My reasons for objecting still remain the same from the initial proposal. The vast overdevelopmentof a small site, even the reduction by just 6 flats will still lead to huge traffic and parking overspill inan area already blighted by commuter parking from the Downs parking restrictions and local RPZschemes. The number of parking spaces on site still remains just 65 for 116 flats this isn't enoughfor all the owners, workers etc. estimated at over 200 people. Road safety will still be a huge issuewith local primary school and nursery on Etloe road with this increased traffic and hunt for parkingspaces.

The loss of mature trees and green space will be lost and the local view spoilt by thisoverdevelopment.

What makes this proposal worse is they have not listened to any of the comments from the councilor residents before resubmitting the plans with almost negligible changes.

The proposed development will have an immensely negative impact on the historic areasome of which is a conservation area.It is not in keeping with the architecture, and proposes buildings that are far too tall and out ofplace. Four storeys should be the maximum allowed.Traffic and parking are already issues and it would be inevitable that this would greatly increase.Similar local facilities have at least one parking space per dwelling, and this ratio could beachieved by reducing the number of dwellings.

Further there will be negative impact to the wildlife, and it is inappropriate to propose the felling ofso many trees.Replacement trees to be planted don't make up for this in any sustainable way and is incompatiblewith BCC's climate change targets.

I write to object to the proposals as amended. I and my family have lived close to theapplication site for over 25 years and thus we know the site and its environs very well. In myprofessional career I have been involved in developing new buildings and extending old buildingswithin conservation areas and in a World Heritage city. Having looking at theplans/images/documents, I make the following comments in objection to the proposals: Density:the buildings are clearly to high, too big and too close together. In short, they are trying to squeezetoo much on to the site. Environment: the Downs and the surrounding streets contribute much tothe environment through the many trees in the area. Whilst one understands that it may benecessary to fell some trees to undertake the redevelopment of the site, this should be limited toimmature and/or diseased trees, leaving the mature and healthy trees in place. Too many maturetrees are planned to be removed. Traffic & Transport: one only has to walk around the area toknow that the roads close to the site are already busy and fully occupied with parked vehicles. Theproposals would add to the congestion on the roads and the parking problems the communityalready encounters. There are too many units of accommodation (most of which are likely to haveat least one or maybe two cars), and not enough parking spaces. Conservation Area/Heritage: theWestbury Park/Henleaze area is blessed with some fine buildings, those proposed would not fallinto that classification. They are ugly, unsympathetic and out of keeping. In conclusion, whilstredevelopment of the site is to be welcomed, the current proposals should not be grantedpermission for the reasons I and many hundreds of others have elucidated.

Whilst I don't object to a nursing/ residential development in principle, I feel theproposed plan is unsuitable for the following reasons:Insufficient parking places on site, leading to more congestion in an area where it is already verydifficult for local residents to park.

The traffic at the Whitetree roundabout already backs up Westbury Rd at busy times; additionaltraffic will make this route from Redland a nightmare and make the air pollution even worse.

There is a primary school and a nursery in Bayswater Road ; both of these will be affected by theextra traffic and parking issues.YoursSarah Cheetham

I wish to object to the redevelopment of the St Christophers site on the followinggrounds:- It is an overdevelopment in this area. It is out of character with the rest of theneighbourhood and will result in far too many cars being parked off site. As it is out road is alreadyfilled with commuter parkers - often across driveways making access difficult. Too many maturetrees will be removed.I dislike the apparent cynical attitude of the developers and their method of operating.

The changes made by developers since the last application are minor, the mainobjections by the neighbours of overcrowding of the site, loss of biodiversity, and buildings that aretoo high and will loom large and overlook homes and gardens in The Glen have not beenadequately addressed.

However to two principal reasons for objection are1) Loss of a purpose built site for children with Special Educational Needs and Disabilities at atime when hundreds of children in Bristol with SEND are without a school place, and children arebeing off-rolled from mainstream schools who cannot provide adequately, or the children cannotcope in mainstream school. The permanent change of use of this site would be a travesty.2) parking - there is nowhere near enough provision for the proposed number of dwellings plusstaff and visitors, and the surrounding streets are already dangerously overcrowded due to beingjust outside the boundary of the Cotham North residents parking zone. The site is very close toseveral schools and nurseries, as well as 3 nursing homes on Belvedere Rd adjoining the Glen,none of which have parking either. Furthermore, people use the area as permanent storage motorhomes as well as park and ride parking. I have witnessed cones put out on the Glen for scaffoldinglorries being moved by someone who parked up and then pulled a fold out bike from their boot andcycled off to work. The council will not extend the RPZ, and the situation is already chaotic anddangerous. An accident happened recent;y at the junction of Bayswater Rd and Ladysmith Rd,and so the developers have withdrawn their access proposal for Bayswater, but now proposeaccess from The Glen. This is very worrying for residents who are desperate when we alreadyhave bin lorries having to reverse down the length the street, damaged vehicles, inability for

contractors to park, ambulances getting stuck and blockages on a daily basis. The site needs toensure there will be no overflow parking as there is nowhere to overflow to.

The revised plans don't change the fact that there will be additional pressure on localroads from a traffic, safety, pollution and parking perspective. The site is located next to a schooland nursery and increases the risk to individuals travelling to and from these educationalestablishments.

The changes proposed do not address the many issues previously raised by many; damage tolocal ecosystem through removal of green spaces, imposing designs out of keeping with existingneighbourhood, inadequate parking onsite, lack of SEN provision to name a few.

Further to the objection that I previously submitted for this planning application.

The amendments made by the developers are minimal (and I might add, cynical), and do notaddress the fundamental issues which these proposals throw up. Namely that the proposedbuildings are totally out of character with the surrounding area - the Downs being an importantconservation area. These new buildings would be visible from the Downs and would alsoovershadow the Grade 2 listed building - Grace House. This application shows no consideration toeither of these objections and therefore must be rejected.

In principle I continue to support the provision of this type of housing in Westbury Park.However, in my view the amended planning application does not address the concerns I havepreviously expressed about the proposed development.- the provision of 116 units on the site continues to be an overdevelopment of the site.- provision of 65 parking spaces for the proposed new units remains the same and insufficient forthe number of units, residents and staff, with the likely impact on the already busy surroundingstreets.- the move of resident parking access from Bayswater Avenue does not address previouscomments about access from The Glen.- community engagement for these revised plans has not been extensive as suggested bydevelopers.- other proposed amendments appear to be cosmetic only.

The revised plans for the development of the former St Christopher's School still seemtoo overdeveloped for the site, having reduced the number of homes by only 6 to 116, still with noaffordable housing.The planned 65 parking spaces for the 116 homes seem insufficient to accommodate all residents,staff and visitors, thus creating additional pressure on already crowded nearby roads.The revised plans for the height of the apartment blocks will still overshadow nearby homes andalter the view from The Downs permanently.The revised plans will still result in too many mature trees being felled, impacting massively onwildlife and nature.

The new proposed plans still don't address the parking issues where Westbury Parkroad is already a difficult drive from Royal Albert Road to Redland Road due parked carsessentially making the road a virtually single track road. So in almost every occasion due tovolume of traffic going down Westbury Park Road to Whitetree roundabout trying to drive upWestbury Park Road to Claypit road means having to pull in to spaces between parked cars toallow traffic to pass safely before resuming the journey - additional traffic into and out of theproposed site and additional parking will severely impact the route from Royal Albert road toRedland Road.

The height of proposed of buildings still too high for the neighbourhood

Still too many trees being removed

Our main concern is the overdevelopment of the site with buildings not in keeping withthe character of Westbury Park. The traffic and associated parking will be very problematic in thenarrow streets with many cars already parking on the pavements. The close proximity of a primaryschool and two nurseries is also a concern with increased traffic. The loss of any green space inthe city along with the removal of mature trees and destruction of natural wildlife habitats would bevery disappointing.

I very strongly object to the plans and building of the new development of the former stChristopher's school for the new building put forward and to be built.

I objected originally and the new plans have not made much difference to the area landscape,increased amount of traffic that will cause and also the over subscribed amount or parking that willimpact the local surrounding roads that is already over populated.

Also the felling of the mature trees on the site.

The height of the buildings will also have a major impact on the local residents.

The objections I submitted to the original planning application still apply to this proposal.I continue to believe that this planning application should be refused for the reasons I statedbefore and because the 'modifications' to the proposal represent no substantive change.

To whom it may concern

I would like to register my objection to the proposed development of the former St Christophersschool.My address is Flat C, 45 Florence Park, Westbury Park, Bristol, BS6 7LT and I overlook the sitefrom my living room window.Apart from the fact that the school should never have been closed in the first place and is anabsolute scandal, the development is completely out of character with the surrounding area. Whatis the point of designating an area a Conservation Area if it is completely disregarded bydevelopers and the council planning department.After the recent debacle/environmental tragedy at the Bristol Ferry station near Temple Meadswhen mature Weeping Willows were cut down I would like to think that any more tree removalwould be extremely limited.This is a low scale neighbourhood of mostly 2 to 3 storeys, not 5 or 6 and from an admittedlyselfish point of view will completely ruin/dominate the view from my living room window, as forothers, there homes/gardens will be overlooked leading to an unacceptable loss of privacy.With regards to the lack of parking I recently received my Covid 19 Booster Jab at the site and theextra traffic it generated caused chaos on Westbury Park road, a precursor of what will come Ithink. It is already bad enough on that road in the morning when I drive to work.Please reject this proposal.Yours sincerelyMr. Simon Boddy

I find it astonishing that so little has been modified to rectify the first plans and addressthe numerous valid objections to this application.As I have outlined before, the negative impact on the area as far as parking availability and trafficoverload will be immense. I feel it has not been thought through logically, for the long term, for thisalready challenged area. This development will drastically increase traffic congestion and pollutionand is furthermore likely to endanger pedestrians generally and furthermore local infant andprimary school pupils.The aesthetic of such a build will severely impact on the immediate and surrounding area, it sadlymakes a mockery of the protected conservation area scheme requirements - what is this for but toprotect spaces from such inappropriate and greedy development.The proposed development will have a negative affect on nature and wildlife in this wonderful andunique natural space. This, and the planned loss of those mature trees seems to transgress allcurrent thinking for the protection of the natural environment.I strongly object to these most recent plans.

Over development, excess traffic, loss of send, height of planned buildings grossintrusion on existing residents and no provision of affordable housing.

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that this planning application should be refused for the reasons Istated before. The ammendments they propose do not actually address any of the issues andappear to be bare minimum token gestures to give the impression to casual observers that thedevelopers are being responsible when they are not.

I have looked at the revised plans and still cannot support them. One of my concernshas hardly been addressed. There is still only 65 parking spaces on site , the parking in mine andsurrounding roads will be even worse than it is at present. There will be a massive overspill intoour roads. With over 200 residents and carers all wanting spaces ... The traffic is the area willvastly increase and road safety will be even more of an issue.The site is still being completely overdeveloped. The beautiful mature trees and green spaces fornature and wildlife will be lost.The light pollution from the hallways in the blocks of flats and pathways will be awful.

The developers claim that the revised plans mean:

A: Fewer homes.The reality is that this is just 6 fewer homes - there would still be 116 housing units. And still noaffordable housing.

This is not acceptable.

B: 'Improved' parking ratio.The reality is that there are still only 65 spaces for 116 luxury homes - all the staff, carers, visitors,deliveries, etc. will also need to park. Overspill is inevitable.

This is not acceptable.

C: The revised scheme is smaller & less visible.The reality is that:One block has lowered by 30 cm or less than one foot!Another block has been reduced by a single storey, but there would still be 4 huge apartmentbuildings - up to 5 storeys high - overwhelming the listed Grace House, nearby homes and theDowns.

This is not acceptable.

Nb: The Council's own Conservation Panel 'strongly' objects to these revised plans saying theywill cause 'significant damage'.

D: The revised scheme would retain more trees.The reality is that still too many protected, mature trees will be felled - including a wonderful oldoak tree. It will take decades for any new saplings to provide the same benefit to nature andwildlife.

This is not acceptable.

E: An "Urban Village Hall" will be created with space for community groups - with possible use bychildren with special education needs (SEN).The reality is that this is a vague offer of a shared-use space or room. Experts advise that thisarrangement won't work from a safeguarding aspect.

The proposal doesn't come close to addressing the great need for SEN school places and doesn'tcompensate for the loss of St Christopher's - a much valued community asset.

This is not acceptable.

I believe it's entirely possible for this site to be developed in a far more sensitive and sustainableway - providing much needed housing in Bristol (including affordable housing).

What the developers are currently proposing is not acceptable.

Although the developers have revised the plans for the redevelopment of StChristopher's, I would like to resubmit my original objections submitted earlier in the year andcopied below the following introductory paragraph.

My reasons are as follows:

The revisions are very minor and do not diminish the fact that overall, the plans are for excessiveoverdevelopment of a site in a conservation area which includes the important listed building ofGrace House. The fact that the proposed number of units has been reduced by 6 from 122 to 116is hardly significant. The other revisions are extremely slight and although they present a smallimprovement the fact remains that the proposals are out of character with the original site, wouldresult in a cramped development and would add greatly to the parking problems in Westbury Park,already under incredible pressure from existing residents. The fact that a high number of maturetrees would be felled is also in contravention of the City Council's green agenda.

My original objections submitted earlier in April/May 2022 and which largely still apply:

Although extra-care residential developments are needed to fill the gap for those with a specificspecial need living in society with carers visiting daily and those who live in care homes, theproposal to build such a facility on the former St Christopher's site is completely out of place.

I strongly oppose the siting of such a development because of the negative impact the proposals

would have on the Downs as a heritage site and on the local residential area. According to plansthe development would result in excessively high extra buildings that would dominate the skylineand the existing homes of residents in Westbury Park and would be completely out of place withthe local neighbourhood.

I am also strongly opposed to the negative arboreal impact of the development across the site andparticularly in the area close to Bayswater Avenue, Etloe Road and St Helena Road. The existingtrees are magnificent and are well over 100 years old and even if replaced by saplings of the samevariety they would clearly take many decades to even approach the magnificence of those alreadyin situ.

The site and its surrounding area are within the Downs conservation area and clearly the felling oftrees and additional buildings on the site would inevitably have a detrimental impact on bio-diversity which would clearly fail to meet any requirement for a net gain in this area.

In addition, Westbury Park is an area under extreme pressure with regards to parking. Terracedhousing with some homeowners requiring two cars due to work commitments already make lifeincredibly difficult for those living in the area. The proposed 65 parking spaces on-site fall wellbelow what would be needed to provide for those who would live, work and visit the extra-carefacility. Clearly there would be overspill into streets in the local area whilst existing space would bereduced by the extra vehicular access into and from Bayswater Avenue with the necessary spacerequired for turning left or right.

As a regular visitor to this area I cannot believe that this application is even beingconsidered. It is a dinosaur of a development, totally out of keeping with the area and downrightugly. It will not improve Bristol at all or the beautiful area and parking is already a nightmare. Badplanning!!!!

My previous objections still stand as the revised plans do not address them adequately.The proposed development is out of character and totally out of proportion with the surroundingbuildings.The loss of mature trees and green space will be damaging to the environment at a time that weare all called upon to be mindful of environmental issues.The impact on the local roads and parking will be massive.This is a development that is not needed.

Having studied the revised plans for St Christopher's School development, I would liketo express my objections to the very small changes that have been made to date, and which donot go far enough to mitigate the concerns which have been expressed by local residents groups.These concerns include lack of parking spaces, height of new buildings, loss of wildlife habitat andlack of affordable housing.

We are residents of one of the roads near to, though not directly bordering the StChristopher's site.

We set out our views on the original planning application previously, and have copied these belowfor ease of reference.

We believe that the revised planning application should be refused for the reasons stated then, asthe revisions are not of a scale to change our views. In particular we consider that the number ofunits, and limited parking on site, will result in intolerable strain on parking for local residents.

In the hopefully unlikely scenario of the application being approved, we plead strongly that thecouncil expands the Residents' Parking Scheme areas to include the streets on both sides ofNorth View, as far as the Henleaze Road.

Submission to previous planning application given below:

We are supportive in principle of the site being used for the purpose set out. We have an elderlyparent living locally (1/4 mile) in a smaller scale retirement community, and we think many aspectsof the proposal together with the location would appeal strongly to the developers' target market.

We have some concerns that the height of the tallest buildings may dominate the area. We were

also unimpressed at the way in which the company putting forward the application seemed toavoid showing any artist impressions that gave a clear impression of how the site would look fromdifferent angles on the Downs.However, our primary objection relates to the number of accommodations proposed and to theresultant traffic and parking issues.

Firstly we think that the developers are hugely over-optimistic in their view that the residents - whowill typically be relatively wealthy independent people who remain somewhat active - will willinglygive up their cars to the extent claimed. We have not seen that in the local retirement communitywe know, where the residents are on average less wealthy and less active. And that community isa shorter walking distance to a wider variety of shops and activities than the St Christophers site.

The developers have suggested that the elderly residents may use bikes instead. It is possible thata few may, but anyone who lives around here will know that these roads are not particularly safefor any but more experienced and confident cyclists. Other retirement communities in the area donot have significant take-up of cycling, you only have to live here to realise that although there isquite a significant number of cyclists on the roads there are few elderly ones despite many olderpeople in the local population. Again we think the developers are using over-optimisticassumptions.

So we think the likelihood that the number of cars retained will only be about half the number ofaccommodation units is very low.

Then there is the question of staff parking. While the developers say they will provide shuttlebuses to help staff get to work, and that is good, it would be incredibly naïve to think that most staffwill use these. We are used to a number of care home staff parking near to our house - if there isfree parking available nearby, even if not much of it, that is what most staff are likely to use unlessthey happen to live very close to the shuttle bus route.

Finally there is the question of visitor parking. There appears to be little or no visitor parkingprovided on site. We are aware of local retirement communities with 1 visitor space for every 5-10resident units.

Overall we consider that the development as proposed will lead to a significant amount ofadditional demand for parking on the residential streets nearby. This will obviously have a negativeeffect on local residents, businesses and of course Westbury Park School. We are thereforeopposed to the development as it stands, and request that planning consent is not given unlessthere is either a significant reduction in the number of residential units or a significant increase inthe on-site parking.

If the application is approved, we request that the council expands the Residents' Parking Schemeareas to include the streets on both sides of North View, as far as the Henleaze Road.

The revised proposal for the development of the St. Cristopher School site is onlymarginally altered, leaving key negative impacts largely unresolved. Foremost, with 65 parkingspaces for 116 units, traffic is likely to substantially increase in the neighbourhood. Westbury Park,just outside the Redland and Cotham North parking schemes, is already used for parking by asignificant number of commuters resulting in heavy traffic, lack of resident parking during the dayand air pollution. This being a neighbourhood with many young families, traffic safety is anadditional concern. The last thing this neighbourhood needs is additional traffic. Because of thequality of Redland Green School, the neighbourhood is already gentrifying rapidly, resulting in afurther loss of healthy social diversity. The last thing the neighbourhood needs is 116 luxuryretirement homes to accelerate this trend. I would like to strongly encourage you to reject therevised planning application. Thank you very much for your consideration.

Upper Redland and Westbury Park are just outside the Residents' Parking Zone. It isnecessary to recognise that on-street parking has become a major issue in these suburbs, with acombination of daily commuters and long-term parking by students. Whatever from and intensityany development of the school site takes, it must not generate even more cars.

Overdevelopment of site.Parking facilities inadequate for the size and density of the development. This will result in furthercongestion on local roads.Where do the staff ,support staff etc park. ?Loss of trees and wildlife.No provision or plans for social housing or local housing to fulfil a need.

- There is very little change to the previous plans submitted and the objections remain- the planned development is to dense and overbearing for the surrounding residential area.- no affordable housing with the scheme.- the area already has plenty of luxury retirement homes. the area requires more family homes andaffordable housing- high storey blocks of flats are out of character for the srrounding conservation area and existingresidential housing- the area cannot support this dense development of mainly flats and there will be no additionalinfrastructure to support- there is not enough parking for the development which will lead more parking issues on thealready over crowded roads- lack of SEND education places in bristol cannot be ignored. the school provided a vital lifeline tochild in need- the traffic flow to the development will be a danger to the surrounding areas mainly populated byfamilies and surrounding school/nurseries- the large loss of trees/greenery will impact the air quality. the area needs more trees to beplanted not for them to be chopped down. Any replacement trees are unlikely to be planted in thearea

- this development will provide no benefit to the surrounding community of Redland and WestburyPark and will instead have a detrimental impact.

I sent in my objection to the first plans and those objections still stand. From looking atthe revised plans I can see very little has changed and nothing has changed to alter my originalobjections.

The developers claim that the revised plans mean:

A: Fewer homes.The reality is that this is just 6 fewer homes - there would still be 116 housing units. This ishousing is far too dense for the area.

This is not acceptable.

B: 'Improved' parking ratio.The reality is that there are still only 65 spaces for 116 luxury homes - all the staff, carers, visitors,deliveries, etc. will also need to park. Overspill is inevitable.

This is not acceptable.

C: The revised scheme is smaller & less visible.The reality is that:One block has lowered by 30 cm or less than one foot!Another block has been reduced by a single storey, but there would still be 4 huge apartment

buildings - up to 5 storeys high - overwhelming the listed Grace House, nearby homes and theDowns.

This is not acceptable.

Nb: The Council's own Conservation Panel 'strongly' objects to these revised plans saying theywill cause 'significant damage'.

D: The revised scheme would retain more trees.The reality is that still too many protected, mature trees will be felled - including a wonderful oldoak tree. It will take decades for any new saplings to provide the same benefit to nature andwildlife.

This is not acceptable.

E: An "Urban Village Hall" will be created with space for community groups - with possible use bychildren with special education needs (SEN).The reality is that this is a vague offer of a shared-use space or room. Experts advise that thisarrangement won't work from a safeguarding aspect.

The proposal doesn't come close to addressing the great need for SEN school places and doesn'tcompensate for the loss of St Christopher's - a much-valued community asset.

This is not acceptable.

I believe it's entirely possible for this site to be developed in a far more sensitive and sustainableway - providing much-needed housing in Bristol (including affordable housing).

What the developers are currently proposing is not acceptable.

I strongly object due to the revised planning application. I believe that this planningapplication should be refused for the following reasons;- huge 5 storey high building will be a massive change to the neighbourhood area with views fromthe downs altered forever- mature trees and green space fur nature and wildlife will be lost- increase in traffic due to not enough parking spaces being available, leading to overspill and roadsafety hazards. How can anyone plan just 65 spaces on site when there will be about 200residents and their caters, staff and visitors, all trying ti find a space in an already limited parkingarea!!!!!!- loss of SEND provision, offer of shared use of a room is an insult to the 70 Yeats's legacy ofspecial needs education on this site- harm to heritage, disregards that this is a designated conservation area

It is an absolutely ridiculous planning application that I'm ashamed is even being considered!

I object to the proposed buildings on a number of fronts:1. The new buildings themselves will be out of character with the environs and alter the characterof the area2. The felling of wonderful, mature and treasured trees will contribute to our global climate crisis aswell as having a detrimental effect on our local environment with wildlife losing habitat, and naturebeing taken from us.3.The parking overflow, as there are only 65 designated parking spaces on site, will cause trafficgridlock in the surrounding roads.4.There is no affordable housing offered5. There is no meaningful replacement SEND provision for Bristol's children. St Christopher's wasa much need resource. Where will children with additional needs get support?

The current revised plans are unacceptable and should not be allowed to proceed.There are many issues regarding density, parking, ratios etc which need greater analysis. Thecurrent proposals are not viable.

I strongly object to the proposal for the revised building works at the site of StChristopher's school. The suggested changes continue to have a very negative impact. There areonly 6 fewer houses in the revised plan. There continues to be a safety concern with no parkingprovision in a built up residential area near a local school. With inadequate parking due to trying tobuild too many homes in a restricted area there is a safety concern with too much traffic cominginto the area and a risk to pedestrians and school children. There will be a negative impact on theenvironment, with loss of protected trees and damage to both animal and plant habitats. There willbe a negative impact in an important conservation area. The proposal will result in the permanentloss of an important SEN education facility in the local area.

The revised proposals don't seem to have taken any material feedback into account,just a token gesture.

Dear Sir or MadamI wish to object to the planning application, in its revised November 2022 form, to redevelop the StChristopher's School site in Westbury Park because:

Overdevelopment.The size and number of buildings will still dwarf/overshadow the existing residential buildings thatsurround the site, The existing residents adjoining the site must be fearing for loss of privacy, lightand quiet enjoyment of their properties. And, of course, the proposed height of the buildings, eventhough slightly reduced, will be clearly visible from the Downs and will be overbearing relative tothe villas along Westbury Park. Surely, being a conservation area, any new buildings should be inkeeping with the area into which they are being inserted i.e. of appropriate size and sympatheticdesign. A lesser number of buildings which are no higher than the surrounding buildings would bemuch better.

Heritage:Large parts of Westbury Park are designated as a conservation area and as such surely theproposed buildings are overbearing/out of keeping/inappropriate in the context of the existingbuildings. In particular the villas on Westbury Park will be dwarfed by the proposed buildings, as,of course, will all the other surrounding dwellings. Well designed buildings in sympathetic materialsand of no greater height than the surrounding buildings would not raise an objection.

Traffic, Parking and Road Safety:

The proposed parking provision of 65 spaces must be wholly inadequate for a development of 116units, the staff that will support the residents and, of course, the residents visitors.

The majority of residents will surely want to retain their independence, which could mean say 100cars, way more than the 65 proposed, and to which should be added parking for staff and visitors.The developers assertion that the residents will not want cars is 'wishful thinking' - It is entirelycommon for 70 and 80 year olds to be driving cars, not least because public transport will not takethem to places they want to go e.g. out of the way National Trust properties. Just 2 car shares willdo little to alleviate the need for cars.

There will of course be a conflict between the residents wishing to use the proposed minibus andthe staff needing to get to work, always assuming the staff are conveniently located.

The impact of inadequate parking provision will mean increased demand for on-street parking inthe surrounding streets, which are already overcrowded. This impact will also have a 'knock-on'effect into streets not immediately adjacent to the development. The increased demand for on-street parking will likely lead to road safety issues such as parking on pavements and on cornersof junctions affecting visibility.

I do not think pursuing a policy of increased cycle use or walking is entirely appropriate for theelderly; whilst some might enjoy the exercise, many/most will not be able to use this form oftransport, especially to carry out their weekly shopping. A further but real reduction in the size ofthe development will reduce this concern, but, I suspect, not remove it completely without asignificant increase in on-site parking provision.

St Christopher's Square, and Environmental:The revised scheme retains a few more trees but the revisions are surely just 'tinkering' and do notshow any significant increase in green space - the loss of any of the mature trees would be hugelydetrimental and, of course, take many many years to replace. Even the revised scheme does notpresent an area that could be described as (an open) 'St Thomas's Square' which with theproposed loss of so much green, seems a lost opportunity.

Yours faithfully

John Franklin15 Dundonald RoadWestbury ParkBRISTOLBS6 7LN

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that this planning application should be refused for the reasons Istated before'.

My main concerns, which I outlined in my previous response have NOT been addressed by thevery minor, superficial amendments to the planning application.

Specifically.

I was concerned that the scale, mass and bulk of the proposals was inappropriate, would situncomfortably within the plot with the tall and uninteresting form standing out amongst the heritageassets in the Conservation Area adjoining the Downs and unacceptably altering the existingcharacter of the area. This concern has NOT been remotely addressed by the reduction of one ofthe four tall buildings by one story and another by a mere 30 cm.

The extent of the tree loss in particular of high quality trees, although slightly reduced is still notjustified.

Parking provision is wholly inadequate, with the revised proposal including no more spaces andparking spaces in total of 65 for 116 dwellings (6 less than previously) and no additional spaces forvisitors, staff etc. The nature of the location, closely surrounded by residential roads, combinedwith the inadequate parking provision on site means that residents and staff would seek to park on

neighbouring roads impacting residents and creating traffic hazards.

In the context of the need for increased SEND accommodation in Bristol the proposal only offers avague proposal for shared use of a room in the "Urban Village Hall" which is wholly inadequate.

Unless major substantive changes are made to the application, it should be rejected in its entirety.

RegardsAndy Parsons

Developers' need to rethink their new plan and stop taking the micky out of theWestbury Park residents. Massively over developed the site, too much destruction of wildlife,trees, birds, bugs and habitat.Taking one story off an aggressive high rise building which doesn't fit into the beautiful areasurrounding the Downs and claiming reducing the 122 flats to 116 by taking off one level andenlarging the foot print of the block , they have actually increased the flats by one to 123.I am sure the developers have looked at the surrounding roads and access and 65 onsite parkingspaces they know will not be enough and probably know there will be a need for 50 more required.where will those extra 50 plus cars park in an already very, very congested residential area?This is a beautiful piece of the South West unspoilt area which includes the Downs which is aheritage site. Families use this every day and to see Gigantic huge tower blocks that over look thisand private residents homes that have lived here for a long time is unacceptable.St Christopher's was always a school for 70 yrs for SEND( special Educational Needs orDisability). How is the one communal room going to help as a mixed room to serve these needs?The developers need to go back to the drawing board and look at maximum two floor tower blocksso people can enjoy the views from the downs instead of looking at concreate tower blocks.

1. The existing narrow vehicular access to the site via Etloe Road/ Bayswater Avenue has verylittle/ ad-hoc vehicles passing through this access; namely service vehicles for access to thesubstation, and also provision for ambulances to access. This narrow access is directly adjacent tothe main front door entrance to Daisy Chain Nursery. Since living on Coldhabour Road anddropping off and picking up my children from Daisy Chain Nursery over the last 4 years I havenever seen a vehicle access this entrance. The developer's proposal to make this a pedestrianaccess to the site may result in visitors/ staff looking for parking/ parking their vehicles onBayswater Avenue/ Etloe Road where parking is already a premium in the area. Myrecommendation is to keep this entrance for access to the substation only i.e. similar to its currentuse and not include pedestrian access.

2. As the site was a previous educational setting, inadequate provision has been made in theproposed development for an outdoor/ open space and a facility for SEND use and use by theWestbury Park School and Daisy Chain nursery (which adjoin the development site), noting thatDaisy Chain has limited outdoor space. Daisy Chain and Westbury Park School would greatlybenefit from the use of a green outdoor space, e.g. a playing field, being included in a revisedproposed development. Whilst the planning application makes reference to looking at SENDoptions, there is nothing concrete to hold the developers to account on providing such facilities.

3. Noting that the proposed development only provides c.60 parking spaces for c. 116 dwellings(potentially c. 232 residents), plus staff, plus visitors, the transport plans presented in the transport

related document provided in the developers planning applications do not clearly state howresidents, visitors, and staff will be encouraged to use alternative means of transport and not usetheir own vehicles to/ from the re-developed site, and therefore there is risk that there will begreater on-street parking in the local area, which is already suffering from a lack of on-streetparking and potential increased traffic flow from the recently introduce CAZ. More on site parkingprovision should be provided.

Yours faithfully,

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that this planning application should be refused for the reasons Istated before'.

My main concerns, which I outlined in my previous response have NOT been addressed by thevery minor, superficial amendments to the planning application.

Specifically.

I was concerned that the scale, mass and bulk of the proposals was inappropriate, would situncomfortably within the plot with the tall, uninteresting, out of character design standing outamongst the heritage assets in the Conservation Area adjoining the Downs and unacceptablyaltering the existing character of the area. This concern has NOT been remotely addressed by thereduction of one of the four tall buildings by one story and another by a mere 30 cm.

The extent of the tree loss in particular of high quality mature trees, although slightly reduced isstill not justified.

Parking provision is wholly inadequate, with the revised proposal including no more spaces andparking spaces in total of 65 for 116 dwellings (6 less than previously) and no additional spaces forvisitors, staff etc. The nature of the location, closely surrounded by residential roads, combinedwith the inadequate parking provision on site means that residents and staff would seek to park on

neighbouring roads impacting residents negatively and creating traffic hazards.

In the context of the need for increased SEND accommodation in Bristol the proposal only offers avague proposal for shared use of a room in the "Urban Village Hall" which is wholly inadequate.

Unless major substantive changes are made to the application, it should be rejected in its entirety.

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that this planning application should be refused for the reasons Istated before. The changes in the ammended plans are simply not enough to justify the projectgoing ahead. Residents deserve better and we must put people before profit.

I am in agreement with the general principle behind the development; however I feel therevised plans still leaves the site overdeveloped.

The objection I submitted to the original planning application still applies to the revisedproposal. I believe that the application should be refused for the reasons I stated before. Thechanges to the application are minimal; only six fewer homes, too many mature trees beingchopped down, not enough parking spaces, minimal SEND provision, the scheme is out ofcharacter for the neighbourhood.

I think that the new proposals have changed little from the original scheme which waspoorly designed. There has only been a tiny reduction in the number of homes from 122 down to116, this is a derisory decrease and will still lead to an overbearing estate in our midst, with a veryhigh density of homes which is not in keeping with the local area. The buildings will be 5 storeyshigh which in my opinion is too high and overbearing and not in keeping with the adjacentproperties. The area is already densely populated and this will add considerably to the trafficproblems in the area as well as the chronic lack of parking. Aesthetically it looks poor and will havea detrimental effect on the beautiful views that we have of the Downs. The character of the Down'slandscape will be altered forever in a bad way rather than being enhanced. All of these problemswill detract from the quality of life and vistas enjoyed by those living in the area as well as thosevisiting the Downs for recreational reasons from the rest of Bristol and beyond!The chopping down of trees is a crime against nature and will result in the degradation of our localwildlife. All of this along with the excess traffic, will destroy the feel of the area and also jeopardisethe safety of the children living and attending the local school and playgroup. All in all it is adisaster and a complete rethink is necessary rather than a few cynical cosmetic changes just to beseen to be doing something. The council should refuse the new proposals and get the developersto go back to the drawing board and think up a less destructive scheme which shows sympathy forthe local landscape, wildlife and people.

I find it astonishing that so little has been modified to rectify the first plans and address the numerous valid objections to this application.As I have outlined before, the negative impact on the area as far as parking availability and traffic overload will be immense. I feel it has not been thought through logically, for the long term, for this already challenged area. This development will drastically increase traffic congestion and pollution and is highly likely to endanger pedestrians generally and furthermore local infant and primary school pupils.The aesthetic of such a build will severely impact on the immediate and surrounding area, it sadly makes a mockery of the protected conservation area scheme requirements - what is this for but to protect spaces from such inappropriate and greedy development.The proposed development will have a negative affect on nature and wildlife in this wonderful and unique natural space. This, and the planned loss of those mature trees seems to transgress all current thinking for the protection of the natural environment.I strongly object to these most recent plans.

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:Whilst I don't object to a nursing/ residential development in principle, I feel the

proposed plan is unsuitable for the following reasons:

Insufficient parking places on site, leading to more congestion in an area where it is already very

difficult for local residents to park.

The traffic at the Whitetree roundabout already backs up Westbury Rd at busy times; additional

traffic will make this route from Redland a nightmare and make the air pollution even worse.

There is a primary school and a nursery in Bayswater Road ; both of these will be affected by the

extra traffic and parking issues.

Yours

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:To whom it may concern

I would like to register my objection to the proposed development of the former St Christophers

school.

and I overlook the site

from my living room window.

Apart from the fact that the school should never have been closed in the first place and is an

absolute scandal, the development is completely out of character with the surrounding area. What

is the point of designating an area a Conservation Area if it is completely disregarded by

developers and the council planning department.

After the recent debacle/environmental tragedy at the Bristol Ferry station near Temple Meads

when mature Weeping Willows were cut down I would like to think that any more tree removal

would be extremely limited.

This is a low scale neighbourhood of mostly 2 to 3 storeys, not 5 or 6 and from an admittedly

selfish point of view will completely ruin/dominate the view from my living room window, as for

others, there homes/gardens will be overlooked leading to an unacceptable loss of privacy.

With regards to the lack of parking I recently received my Covid 19 Booster Jab at the site and the

extra traffic it generated caused chaos on Westbury Park road, a precursor of what will come I

think. It is already bad enough on that road in the morning when I drive to work.

Please reject this proposal.

Yours sincerely

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:Dear Sir or Madam

I wish to object to the planning application, in its revised November 2022 form, to redevelop the St

Christopher's School site in Westbury Park because:

Overdevelopment.

The size and number of buildings will still dwarf/overshadow the existing residential buildings that

surround the site, The existing residents adjoining the site must be fearing for loss of privacy, light

and quiet enjoyment of their properties. And, of course, the proposed height of the buildings, even

though slightly reduced, will be clearly visible from the Downs and will be overbearing relative to

the villas along Westbury Park. Surely, being a conservation area, any new buildings should be in

keeping with the area into which they are being inserted i.e. of appropriate size and sympathetic

design. A lesser number of buildings which are no higher than the surrounding buildings would be

much better.

Heritage:

Large parts of Westbury Park are designated as a conservation area and as such surely the

proposed buildings are overbearing/out of keeping/inappropriate in the context of the existing

buildings. In particular the villas on Westbury Park will be dwarfed by the proposed buildings, as,

of course, will all the other surrounding dwellings. Well designed buildings in sympathetic materials

and of no greater height than the surrounding buildings would not raise an objection.

Traffic, Parking and Road Safety:

The proposed parking provision of 65 spaces must be wholly inadequate for a development of 116

units, the staff that will support the residents and, of course, the residents visitors.

The majority of residents will surely want to retain their independence, which could mean say 100

cars, way more than the 65 proposed, and to which should be added parking for staff and visitors.

The developers assertion that the residents will not want cars is 'wishful thinking' - It is entirely

common for 70 and 80 year olds to be driving cars, not least because public transport will not take

them to places they want to go e.g. out of the way National Trust properties. Just 2 car shares will

do little to alleviate the need for cars.

There will of course be a conflict between the residents wishing to use the proposed minibus and

the staff needing to get to work, always assuming the staff are conveniently located.

The impact of inadequate parking provision will mean increased demand for on-street parking in

the surrounding streets, which are already overcrowded. This impact will also have a 'knock-on'

effect into streets not immediately adjacent to the development. The increased demand for on-

street parking will likely lead to road safety issues such as parking on pavements and on corners

of junctions affecting visibility.

I do not think pursuing a policy of increased cycle use or walking is entirely appropriate for the

elderly; whilst some might enjoy the exercise, many/most will not be able to use this form of

transport, especially to carry out their weekly shopping. A further but real reduction in the size of

the development will reduce this concern, but, I suspect, not remove it completely without a

significant increase in on-site parking provision.

St Christopher's Square, and Environmental:

The revised scheme retains a few more trees but the revisions are surely just 'tinkering' and do not

show any significant increase in green space - the loss of any of the mature trees would be hugely

detrimental and, of course, take many many years to replace. Even the revised scheme does not

present an area that could be described as (an open) 'St Thomas's Square' which with the

proposed loss of so much green, seems a lost opportunity.

Yours faithfully

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:The objection I submitted to the original planning application still applies to this

proposal. I continue to believe that this planning application should be refused for the reasons I

stated before'.

My main concerns, which I outlined in my previous response have NOT been addressed by the

very minor, superficial amendments to the planning application.

Specifically.

I was concerned that the scale, mass and bulk of the proposals was inappropriate, would sit

uncomfortably within the plot with the tall and uninteresting form standing out amongst the heritage

assets in the Conservation Area adjoining the Downs and unacceptably altering the existing

character of the area. This concern has NOT been remotely addressed by the reduction of one of

the four tall buildings by one story and another by a mere 30 cm.

The extent of the tree loss in particular of high quality trees, although slightly reduced is still not

justified.

Parking provision is wholly inadequate, with the revised proposal including no more spaces and

parking spaces in total of 65 for 116 dwellings (6 less than previously) and no additional spaces for

visitors, staff etc. The nature of the location, closely surrounded by residential roads, combined

with the inadequate parking provision on site means that residents and staff would seek to park on

neighbouring roads impacting residents and creating traffic hazards.

In the context of the need for increased SEND accommodation in Bristol the proposal only offers a

vague proposal for shared use of a room in the "Urban Village Hall" which is wholly inadequate.

Unless major substantive changes are made to the application, it should be rejected in its entirety.

Regards

This is still huge over development of the site. The amendments are minor. The scale ofthe development will cause a major impact on all the surrounding infrastructure.

Having re-read my strong 'objection' to the first set of plans submitted by the developer,back in April 2022, I feel entirely justified in cutting and pasting those same comments as the basisfor this equally strong objection. The developers simply have not listened to the feedback receivedfrom the local community, or indeed the council and other expert bodies. The small changes theyhave made do not change my views whatsoever. I am amazed at the arrogance, they simply donot 'get it'.

I wish to register my strong objection to this planned development based mainly (but notexclusively) on the scale of the development. The plans as they are today are still a significantoverdevelopment of this valuable site, with impacts on the character of the area, road safety andparking, and the ecology or the area overall.

I have lived in Bayswater Ave and before that in Etloe Rd for over 30 years, so know the area andits character very well. I still am very concerned a development of this size is going to change anddamage the area in a way that is both dramatic and irreversible.

Whilst I would prefer to see the site used for the SEND needs of the city, I am comfortable that thechange of use to it being an integrated retirement community is a reasonable one.

What I am appalled and concerned about here is the sheer scale of the development. It is simplytoo big for the site. Commercial needs for profit seem to be blind to practical realities. Thebuildings still are too big, there are still too many flats, and priority seems to be given to more

buildings rather than adequate provision of parking on-site. A site twice the size might be moreappropriate if this is what the developers need to feed their financial ambitions. Plans for this siteneed to be significantly scaled back if it is to get my support. Smaller and fewer buildings, moretrees, more parking.

The Downs Conservation Area is not going to be conserved if these huge carbuncles are built. Ialso feel for those home owners and residents whose properties backs directly onto the site. Theirhomes are going to be blighted by being overlooked, overshadowed by such huge buildings, manyvery near the perimeter. Noise pollution, light pollution, removal of 58 trees, privacy violation, alldamaging and irreversible.

I am also very concerned about traffic and road safety in the area as a whole and the impact on acommunity whose roads are only just able to copy right now. I refer you to the parking surveyscarried out in March'22 by local residents. These show very clearly that today, there are very fewparking spaces available in any road surrounding the site. This leads already to many examplesevery day of illegal and dangerous parking of vehicles - across junctions, on double yellows, onschool zig-zags, on the pavement. If drivers had space available to park, they would clearly notpark in such dangerous and antisocial ways. Clearly at many times, they have no choice. Havingstudied the plans for development closely, it is clear that there is nowhere near enough parkingprovided on-site, so the developers think the surrounding neighbourhood will be able to absorb theextra cars and vehicles who need to park. These roads cannot absorb this increase.Bayswater Ave is home to two children's nurseries, a primary school, an active church and church-hall. Safety is going to be compromised for all these if the new development does not make moreway for parking on-site.

In summary, I am not against this site becoming an integrated retirement community. But the plansas they are a simply too big, and do not allow anywhere close to adequate parking.

Please help us preserve the very special character of Westbury Park and the Downs.

I object on grounds of : - large numbers of trees still to be chopped down; extra trafficand congestion (and pollution) in local roads that will be generated; lack of character in buildingsappropriate to area; loss of provision of S.E.N.D.S. Westbury Park is a real haven of peace and itscharacter will be forever changed (and lost) with this development.

Retirement homes are needed for the increasing elderly in the atea.The retiring people will hopefully make available for sale their own homes and this free up homesfor younger families in the area

I refer to my previous objections & comments which remain the same and I repeat them.

The revised plans only barely minimally reduce the impact of the proposed development. Theymake no significant response to the concerns of me and many other residents.

The revised parking provision makes no meaningful change to the harmful impact on thesurrounding roads. Residents and staff on this development will obviously & inevitably usesurrounding roads for parking, adding to congestion & taking the space used by existing residents.

The scale & volume of the development is still grossly out of keeping with the surrounding areaand will overpower the existing community in appearance & character. It will disproportionatelyincrease the local population.

There is no need for the suggested amenities on the site for existing residents of this area - wealready have shops, cafes, and many other local businesses that we wish to support, not tosubject to the intrusion of anonymous corporate providers.

The loss of trees and the damage to the green spaces is still unjustifiable even on the revisedplan.

Bristol City Council is well aware of the traffic, safety & environmental concerns in this vicinity - soshould also be actively concerned about the impact on existing residents.

Concerned about traffic near the school and impact on environment. The revised plansdon't adequately address concerns.

The new 'revised' proposal is still a grave concern for residents like me. The retirementhomes have only been cut down by 6.How on earth is this going to make any difference ? With only 65 spaces on site - where are the200 or more residents and staff going to park ? These narrow streets are already full to capacity.During the Westbury Park school pick up and drop off times, it is absolute 'bedlam' alongBayswater Ave and surrounding roads.Extra staff and residents driving along and trying to park along these narrow and alreadyoverflowing roads is going to cause real problems.5 storey buildings will STILL be an eye sore and change for the worst what is a beautiful area ofthis city. This area of natural beauty needs to be protected, not exploited.

I object to the current application.The development of the site is not in keeping the surrounding area:It is situated between a neighbourhood conservation area and the Bristol Downs, a very specialgreen amenity for nature, people and wildlife.The effect of extra parking and traffic due large number of future residents and visitors would beextremely detrimental to the surrounding area.The Buildings are too tall, overbearing and not attractive.The whole development is far too intensive.I am disappointed the the wonderful heritage of Bristol is being destroyed bit by bit. It should bevalued and respected by everyone involved in planning, developing sites etc.Elizabeth Bloomfield

Yet another developer proposal which implies much but delivers nothing, again failing toaddress the significant concerns of local residents.

Are councilors bought so easily this will be waived through planning consent again?

In short: ill-conceived (other than to maximise significant profit for the developer) with unecessaryand devastating impact on the environment, the local community and the already oversubscribedroad network.

The plans themselves will dwarf existing buildings, parking would need to be increased by at least4 times to accommodate the proposed volume of housing - such a high-density proposal iscompletely inappropriate for the area.

Morally and ethically wrong.

I cannot recall if I objected to the previous application but if I did not I would have likedto do so.My reasons for objecting are :a) Bristol is surely heading for an over supply of flats at the present time. The number and size ofthe developments already in existence or planned are disproportionate to the demand for flats aspart of overall housing provision. Developers would no doubt argue that the demand is there butinsofar as this is correct it will be because the focus on building flats has excluded the availabilityof other types of housing provision, ie. people have reduced or no choice.b) The construction of flats in this particular location, particularly 4 or five storey blocks, isparticularly objectionable. The location is leafy and open. The existing structures are attractiveperiod properties which will be dominated and overshadowed by the proposed development.c) A relatively open space, (in terms of the distances between the existing period properties), willbe lost and replaced by densely packed buildings in comparison.d) The area in question, already has flat block developments at Redland Hill.e) Traffic congestion will be badly affected. As it is, all available parking provision along RedlandRoad extending down Westbury Park to White Tree is regularly taken up. The traffic queue to joinWhite Tree extends for a quarter mile on occasion. The proposed intensive development will makematters a lot worse.

The revised plans put forward for this development do not address the main issuesaround the development. The number of flats has been reduced by 6 but there will still be 116 newflats with only 65 car parking spaces on site. This is nowhere near enough parking for residents,carers, staff and visitors. The overflow of cars into an already chaotic road layout will make manypeoples daily lives unbearable.The height of the building is still too high. In a layout of traditional 2 story houses, a 5 story block offlats is going to have a negative impact on peoples views and access to daylight in their homes. Itwill also be completely out of keeping with the rest of the area.

The area is a great development opportunity but the current plans make no sense in relation to thearea they are planned for.

I an concerned about the loss of trees and the change to the Downs views.I am concerned about the impact on local services eg parking, local traffic . I am also concernedabout the level of local gp provision

The amendment to the revised plans are negligible and I plead with you to rethink thispreposterous plan.The roads are congested already, a danger to children going to the nearby schools and nurseriesand impossible for emergency vehicles to pass through the parked cars.It will affect the visual aspect of the whole area and the immediate neighbours will have to sufferduring any construction work.Please be realistic!

For all the reasons my wife and I gave in our original objection to the Proposed StChristopher's Square development, we continue to object in the strongest possible terms - addedto which the developers have tried to confuse the community by submitting their allegedamendments over Christmas/New Year. Actually we are not confused, or in the least bit amused.This remains a terrible plan and deserves to be refused at the earliest opportunity to save us allfurther concern and worry.

The objection that I submitted previously still applies for the following reasons.

I have reviewed the changes proposed and I believe that there were no substantial alterations andthe changes were minimal. For example, Villa B was only reduced by one storey, meaning it willstill be a five storey building with excessive height in comparison to the surrounding area. All theproposed large blocks of flats remain not in keeping with the Conservation area and will also doharm to the heritage of the St Christopher's site especially with Grace House being a listedbuilding.

The newly proposed access through The Glen is totally unacceptable - the residents made thisvery clear during the consultation process. I am a resident on Belvedere Road, the parking andhighway issues on The Glen and Belvedere Road are well known and well documented over theyears. We already face dangerous highway situations everyday due to too much traffic and lack ofparking, e.g. regular parking on corners and delivery vehicles / ambulances frequently blockingroads causing drivers to have to reverse all the way onto the main road. Hence any accessthrough The Glen will encourage more road users to nearby roads and worsening the situation.Since there is insufficient parking proposed on the St Christopher's site, access from The Glen willalso encourage site users such as residents, visitors and staff to use The Glen and BelvedereRoad as free parking due to those roads not being in the RPZ. Therefore, I believe the proposedaccess through The Glen will exacerbate the already unacceptable and dangerous highwaysituation on nearby roads.

I confirm my objection to the latest proposal for the St Christopher's site for the reasons explainedabove.

The changes in this amended application are small. This area is already busy withcars,vans and caravans parking. The road is therefore narrow, and dangerous for cyclists. Tohave parking for 65 cars when there are far more residences is going to cause chaos in the area,with visitors, deliveries and carers hoping to park inside.Little has been changed regarding the tree. A well loved oak tree is to be destroyed. I regard thatas criminal. I could name more objection, but instead will place my trust in our authorities.

I object to the revised plans for the development as the height and scale is still too bigand will drastically alter the character of the neighbourhood. The parking also remains inadequateand is a huge cause for concern given that parking is already really difficult in this area. There areno permits so anyone can park on our streets without living here and this development will makethings worse.

My primary objections relate to:- The scale and height of the development. It is out of keeping with the neighbourhood (aConservation Area) and would be very detrimental to the currently attractive, perimeter of theClifton Downs- The relatively low amount of car parking that will inevitably cause even more congestion and overcrowded streets in the area

I am supportive of the development of this site, just not in its current proposed form.

As per previous objection, my comments remain:- single aspect, north-facing homes on blocks B and D are not acceptable for a development ofthis quality, particularly one which proposes to be net zero carbon.- noted that the developer has reduced some height; however it is noted that plant enclosures arenot noted on all sections and elevations which it misleading - this will, in essence, add anotherstorey to the building. While surrounding buildings onto Westbury Park may be grand, it must beremembered that the buildings on all other sides are terraced houses and these buildings will havea significant impact at this height

Positives:- I don't have an issue with parking. We all have issues parking; the council may considerexpanding the residents' parking permits into Westbury Park. The retired folk moving into thisdevelopment are likely to have fewer cars than if family homes.- This site is underused and could be a really positive new addition to the area.

I am writing to express my strong objection to the revised planning application for thedevelopment of St Christopher's School.

The reduction in the number of dwellings from 122 to 116 is tiny in terms of the impact the schemeis likely to have on the surrounding area. Likewise, the proposed reduction in height of a smallnumber of units is negligible. It does nothing to change the fact that the proposed development isoverbearing and out of all proportion to the surrounding properties including Grace House.I am also concerned at the proposal to cut down 40% of the trees on this naturally mature andbeautiful site. This will be a huge loss in what is already an area of densely packed housing.The disappearance of this site as an educational facility is also a considerable loss the localcommunity. There is no significant SEND provision in Bristol and the replacement of the schoolwith yet more luxury retirement apartments seems hard to justify. The absence of any affordablehousing in the proposal is further evidence of the disregard of the developers for the actual needsof the community in Westbury Park or in the city as a whole.What is perhaps most concerning about the revised proposal, is the plan to provide a new accesspoint from The Glen for cars, pedestrians and emergency vehicles. The information in theTransport Statement about existing vehicle access from The Glen is plainly misleading. The gateat the end of the road was put in during the construction of the site and sealed once this wascompleted. It has never to my knowledge been used during the 13 years I have lived in The Glen.The Glen is highly unlikely to be a feasible route for fire appliances anyway, as cars are constantlyparked on both sides of the road, which would make access difficult. In addition to legally parkedvehicles, there are often cars parked on the corners of the road, while access to the end of The

Glen is frequently impossible because of ambulances and lorries delivering to the 3 nursing homeson Belvedere Road and the supported living facility in The Glen.Parking is already a huge problem in The Glen. As a consequence, the safety of pedestrians isoften compromised by cars that are parked illegally and others circling the area looking for spaces.There is no residents' parking scheme in the area, so local residents are constantly struggling tofind places to park. This scheme will greatly exacerbate this already difficult situation.The proposal in the revised plans to put a double yellow line at the end of The Glen, willimmediately remove one of the already small number of available parking spaces. Moreworryingly, the spaces at the rear of the site, to which the Glen would give access is likely to befully occupied much of the time. This will lead to an unlimited number of drivers accessing the sitespeculatively, searching for available spaces, all of them entering and leaving the site via TheGlen, all of them having to reverse down the road as there is no turning space within the proposedparking area. The danger that this poses to pedestrians and other vehicles is obvious.The proposal for 65 parking spaces to accommodate residents, staff and visitors for 116 dwellingsis clearly inadequate. Pedestrian access from The Glen will inevitably lead to people trying to parkthere as well as in surrounding roads, when on-site parking is full, with all the danger andinconvenience to local residents outlined above. The proposal for an "urban village Hall" without itsown car park, close to the entrance from The Glen will of course add to difficulty.

The objection I submitted to the original planning application still applies to thisproposal. I continue to believe that this planning application should be refused for the reasons Istated before'. plans for this proposal suggest the project is not in keeping with the local area.The building is too big and too high.My main concern is for the problem with parking, leading to overspill and causing dangerousparking and driving, especially with Westbury Park School being so close.The destruction to wildlife and trees will be a tragedy and disproportionate to the benefit of yetanother residential community.

Total over development in a conservation area. Lack of parking. Risk to protectedspecies and local wildlife in general. The Glen is totally unsuitable for the main entrance on to thesite.

It seems the developers submitted a first plan in the knowledge they could subsequentlybe seen to scale back in response to objections. The revisions are so minimal so perhaps thisshould be kept in mind by Case Officers who could look afresh, as if the revised plan was theoriginal proposal.

A high rise modern development in an architecturally traditional setting is beyond belief. Why can'tthe developer and the Case Officers see this?

How can the destruction of a natural habitat be permitted?

Is there really a need for accommodation of this category in Westbury Park and Redland whenother developments are still struggling to be filled?

The definition of support living seems very fluid which suggests the developers can open themarket in order to fill the properties.

In which case, wouldn't it be more appropriate for the developers to scale back, redesign a morefitting exterior in keeping with the existing architecture? They could build a second moderndevelopment in a less traditionally sensitive part of Bristol.

Much has been written about the obvious safety issues of an increase in people trying to park instreets that are already hazardous for parking. It's not just cars, it's the contractors' vans during

construction, delivery vans and thereafter residents and support staff. It will be just a question oftime before accidents occur.

It must be draining for Case Officers to continually receive objections, but please, pleaseunderstand the obvious problems this development will create.

Thank you.

My previous objection submitted still applies to this proposal. In particular, I think thatthe provision of so many bicycle parking spots is inappropriate for the type (age!) of residentsintended to reside here. There should be more car parking spots and maybe spaces for mobilityscooters too.I believe that this planning application should be refused for this and the reasons I stated before.

I object to this development on a number of different grounds.Firstly, I believe that this is a unique green space in Bristol and should be subject to no furtherbuilding developments of this scale. Conserving the green spaces we have in Bristol is key tomaintaining a healthy environment to live in, promoting urban biodiversity and maximising thenumber of trees.Secondly, the scale of the project is vast and would completely change the landscape of thecommunity. Bristol is a great place because of its historic buildings dominating the landscape. Thisbuilding development would completely alter and dominate the skyline of this neighbourhoodwhich as the moment is filled with trees and old spires. If the project is to go ahead, the scaleshould be vastly reduced so that it is in keeping with the heights of surrounding buildings. 3stories.Thirdly, the parking and traffic in this area is already an issue. This would increase local traffic,increase parking availability for existing residents, and decrease air quality.Further to this, Westbury Park and close surrounding areas already have a large proportion ofaccommodation for retired and elderly residents. I live in The Glen and the road opposite where Ilive already has two old peoples homes. Within a 5 minute walk there is already a luxuryretirement village with views of the downs. This city already has such a disparity in communities interms of wealth and age neighbourhoods, this should not be increased further by exclusive luxuryapartments for those of a retired age. I am in no way discriminating against more elderly residents,but I believe that for a neighbourhood to flourish it should be populated by a range of people,young working groups, families and the retired and elderly. As this area in Bristol is so expensive,young people and families are already being priced out. This should not be compounded by

exclusive luxury apartments.

The submitted plans continue to be completely at odds with the reality on the ground.Firstly, this development would constitute a major change of character within the DownsConservation Area, with multi-story blocks of flats dominating the skyline, completelyunsympathetic to the surrounding heritage buildings, not to mention the significant loss of maturetrees from the site. Secondly, it would significantly increase the amount of traffic and parkingdemand in the area, with 116 new accommodation units, plus staffing and services demand,supported by only 65 parking spaces. Together this would only increase congestion in an alreadyover-crowded local street network. Thirdly, the proposed change of use would rob the city of anexisting school site that could be utilised to help alleviate the acute pressure on SEND serviceswithin the city. I sincerely hope that the proposed development will not be approved in its currentform.

The objection I submitted to the original planning application still applies to the re-proposal. I am still of the opinion that this planning application should be refused for the reasonsstated previously.

Specifically, the reasons for my position pertains to the marked over-development of the site -nothings has substantially altered with my regard to my initial perception. I should also point outthat the re-purposed reduction of 6 homes is an insult in itself! This response from the developer istruly insufficient and represents nothing less than game playing.

Secondly, there is the issue of traffic congestion as there are not enough parking spaces forvehicles (e.g., considering visitors to the overdeveloped site), not to mention the externalcongested traffic which will result from this proposal. Traffic, especially during rush hours appearsuncontrolled as is.

Finally, it is my considered opinion that the developers, coupled with the BCC are only interestedin financial gain, vis-a-vis this project and not concerned about our neighbourhood's well-being.What a surprise!

I am not opposed in principle to the development of this site, but the revised proposalsmake only cosmetic changes to the original proposals which were out of scale and not in keepingwith the character of the area. In particular, the small reduction in the number of the proposeddwellings will do little to alleviate the potential parking problems in my own and neighbouringstreets.

I objected to the original planning application on the grounds of over development of thesite, loss of biodivesity including several mateure and well established trees, the impact on thesurrounding streets due to overspill of parking from residents, visitors, care staff etc, loss of SENSprovision and lack of affordable housing. These amended plans offer such minor alterations thatmy original objections still stand. Also I don't understand why another 'village hall' is being offeredto the community when there are already 2 well used halls at either end of Bayswater Avenue andEtloe Road.

I am objecting to this revised proposal, which I consider has only tinkered at the edgesand has not addressed local concerns.I think that the scale of the development remains far too large for the site. A reduction from 122 to116 units is minor, as are the proposed height reductions of the blocks. The overall design is out ofcharacter for the neighbourhood.I am extremely worried about the amount of traffic likely to be generated and the safety of roadsand pavements around. I believe that there is still insufficient provision for parking for theresidents, carers, visitors, taxis and delivery drivers. I am fearful that this will result in an overspillonto local roads, which are already highly congested. There are already dangerous blockedpavements and junctions and this is likely to get worse.I object also to the loss of green space and the felling of mature trees.

This revised application offers minor changes to an overbearing scheme.The tower blocks are still too high and sight lines from The Downs will still be badly affected.Please reject this application.

Objection to Planning Application 22/01221/F

I would like to object strongly to the new vehicular access to the development site from The Glen,as proposed in this application.This will be the only vehicular access to the rear of the site, as theinternal roads from the Westbury Park entrances only lead to the front block of flats. This proposednew access would have the effect of making even more dangerous the current traffic, road safetyand parking problems in The Glen and Belvedere Road. These problems have been welldocumented, are well known to the planning authorities, and have resulted in the refusal of otherplanning applications in the neighbourhood that have been similarly deemed to exacerbate analready unacceptable situation (see, for example, final paragraph to this objection below).

Specifically, this application will significantly increase traffic, parking and road safety hazards forthe following reasons:

1. The new car park to be reached from The Glen has 7 spaces intended for residents, which isevidently not enough for all the occupants of the adjacent large block of flats, as well as the rearcottages. This is likely to encourage residents who don't have a space to park in The Glen orBelvedere Rd and walk through. It may also lead to staff and visitors for the rear blocks trying touse it, and then circling and parking on The Glen or Belvedere Road if they can't find a space.

2. There is also a new proposed "Urban Village Hall" next to and accessed from the end of TheGlen, which has only 2 (disabled) parking spaces allocated. This is intended for community and

SEND activities, which is likely to lead all external visitors to try to park on The Glen andBelvedere Rd.

3. As the only access point to the rear of the site, it is also likely to be used by delivery vehiclesand ambulances for the rear blocks of flats and cottages, although they will have to actually park inThe Glen.

4. The access is also intended for fire engines needing to access the rear of the site. However,this is not possible without removing at least 6 parking spaces from the end of The Glen. (Theapplicant has not mentioned this, but it is clear from the detailed plans.) Furthermore, there is noturning space in the car park, so any fire appliance would need to reverse back down The Glen.This is contrary to the direction from the TDM (1 st August 2022) that "Swept path analysis mustbe provided for a fire tender to demonstrate that it can safely access the site and turn around andemerge in a forward gear from the main vehicular access points on Westbury Road, as well as theemergency access point on The Glen."

5. Finally, the plans have been submitted in the context of a continued shortfall of on-site parking(65 spaces for residents, staff, carers and visitors for 116 apartments), which will lead to overspillon all surrounding roads, but a particular issue for The Glen and Belvedere Road, due to theaccessibility and proximity to the rear apartment block and cottages.

I would like to point out that the applicants make a highly misleading claim. In Travel Plan 3.1.5and Transport Statement 2.3 they sate that "There is also a gated access from The Glen". In fact,the gate referred to was only allowed to be used during the construction phase of a previousapplication (02/00500/F/N and 02/00501/LC/N). The applicant at the time stated in a letter to BCC(Mr McCamphill), dated 3/4/02, "Once the work is finished the access will be sealed.... The Glenentrance cannot and will not be used even when we develop the North House" and subsequentlya condition of the approval (SC44) was that "Means of vehicular access to the permitted buildingafter construction shall be from the main entrance of Carisbrooke Lodge, Westbury Park only" andthis condition was complied with.

In conclusion, I would like to draw attention to the Council's refusal of a recent planning applicationin Belvedere Road (20/06030/F) and the upholding of the Council's decision, following appeal, bythe Planning Inspectorate. It was precisely on account of the traffic, parking and road safetyissues, referred to in this objection, that the Inspectorate upheld the decision.

I am a home care worker, and I visit clients within the area. In order do my job I need todrive my own car to and from clients parking in the area is already very difficult and I often have todrive around for 5 or 10 mins to find a space depending on the time.of day..ther is insufficientcurrent parking, so more property and vehicles in the area, will only increase the difficulty.

Having reviewed the revised proposals, I still object to the proposed development forthe same reasons outlined in my comments to the original submission. The key concerns I'd like tohighlight are;

- Overdevelopment of the site. There seems to be little to no regard for the location andsurrounding residents and amenities in the proposals. Adding this many residences to the size ofstyle of site would be a gross over development, the plans appear to be about maximising profitonly and not creating a development that will integrate into a well established community. Thereduction of only 6 proposed dwellings is frankly laughable and shows the level of care thedevelopers have in the approach.

- The lack of increased parking provision is a similar concern. The streets and area around thedevelopment is already saturated with cars and any assumption that the roads can support moretraffic is a mistake. While the movement of the road access away from the nursery entrance ispositive, this is to the detriment of residents near The Glen which is simply moving the issue.I would also strongly implore BCC to review the options around introduction of an RPZ forWestbury Park. Currently we sit on the perimeter of other RPZ's so feel the knock on effect ofhouses parking additional vehicles from nearby roads. The area was already a busy commutertrap for those driving to the area and leaving cars to travel into the city, this will only be worse withthe introduction of the CAZ.

- Any loss of trees and natural habitat should be strongly avoided. The site is already home to

considerable local wildlife and the loss of habitat including the loss of mature trees must beavoided at all costs.

- The loss of SEND provision is unfortunate and I would prefer to see the site retained for thispurpose, especially given the relative high proportion of retirement properties already in the area.

For the reasons outlined above I strongly object to the plans and hope a complete revision (not thesmall amendments proposed) for a development more appropriate to the site and surroundingcommunity is taken forwards.

My name is Dr Paul Rawlings and I live at 15 Belvedere Road (the side of the roadbacking onto the St Cristopher's site). I would like to register my strong objection to the currentslightly revised planning application and I urge you to reject it and to instruct the developer tocome forward with a significantly revised and more sympathetic scheme. My grounds for objectingare as follows:

1. The Development Will Significantly Impact Parking and Highway Safety.The parking problems in this area are well known and, in particular, the problems in the Glen andBelvedere Road. These roads have significant parking and highway safety issues as this area ison the edge of the resident parking zone and is used as a park and ride scheme into town as wellas by the staff working at the care homes in Belvedere Road (which have no parking of their own)and the delivery drivers and ambulances that regularly attend these businesses and frequentlyblock the roads. These issues have previously led to the rejection of planning applications for anextension of the Glenview Care Home in Belvedere Road (20/06030/F) and even a proposal for asingle off-road parking space (19/01251/H) was rejected with the following comments from theTransport Development Manager: "The application would create one off street parking space andthe loss of up to two on-street parking spaces. This would be a net loss in an area where there isalready over demand for parking spaces and would increase the risk of motorists parking in adangerous manner. The application is thus recommended for refusal on the grounds of highwaysafety." The proposed development should be rejected in-line with these precedents because:1.1 Lack of On-Site ParkingThe proposed development has very limited on-site parking for the residents and staff (65 places

for 116 units). This will inevitably lead to significant overspill parking in the surrounding roads andmake the current problems significantly worse.1.2 Vehicular Access from GlenThe revised proposal is now even worse than the original proposal as it has vehicular access fromthe Glen. This should not be allowed for the following reasons:- This access will be the only vehicular access to the rear of the site and will significantly increasetraffic in Belvedere Road and the Glen and will be used by delivery vehicles and ambulances forthe rear blocks of flats and cottages, although they will have to actually park in The Glen.- There is a new proposed "Urban Village Hall" next to and accessed from the end of The Glen,which has only 2 (disabled) parking spaces allocated. This is intended for community and SENDactivities, which is likely to lead all external visitors to try to park on The Glen and Belvedere Rd.- The new car park reached from The Glen has a further 7 spaces intended for residents, which isevidently not enough for all the occupants of the adjacent large block of flats, as well as the rearcottages. This is likely to encourage residents who don't have a space to park in The Glen orBelvedere Rd and walk through. It may also lead to staff and visitors for the rear blocks trying touse it and then circling and parking on The Glen or Belvedere Road if they can't find a space.1.3 Emergency Vehicle Access from the Glen.In addition to refusing general vehicular access from The Glen emergency vehicle access shouldalso be refused. The Glen will make a very poor approach road for emergency vehicles due to thedensity of parking and it is unnecessary as there will be sufficient access from the existing pointsof access at the front of the site. To enable access for fire engines through The Glen at least 6parking spaces will need to be removed from the end of The Glen which will significantly adverselyaffect parking provision and hence highway safety. The applicant has not mentioned the removalof the parking places in their submission, but it is clear that this will be the case from the detailedplans.1.4 Pedestrian Access from the GlenThe proposal contains a plan for pedestrian access from the Glen. This should not be allowed(even if it is only for residents and staff) as this will further encourage parking in the Glen andBelvedere Road. This would be made even worse if the public were to be able to use it as a cutthrough.

2. Scale of the Development and Effect on the Amenity of the AreaThe development is completely out of proportion to the area of land, the high-rise blocks willovershadow the listed buildings and change the current open and beautiful aspect from the Downsand surrounding areas and degrade this beautiful part of Bristol which is a key leisure area for thecity. The amendment to the height of one block cannot be considered a significant attempt by thedeveloper to listen to the many adverse criticisms of the scheme by bodies such as Bristol CityCouncil Conservation Panel who have called the buildings "overbearing" and saying there's solittle space between them, it'll limit natural light and impact tree growth.2.1 Privacy. The high-rise residential blocks are far too close to neighbouring properties and willovershadow and infringe their privacy.2.2 Environment. The plans will lead to the removal of a significant number of mature tress as well

as open grassy and wild areas and will adversely impact the biodiversity of the area.

3. Lack of SEND ProvisionBristol City Council Education Department have issued a report that disagrees with the findings ofthe developer's report on SEND provision and that there will be a shortfall of SEND provisionwhich needs to be addressed.

For the reasons stated above please reject this application and instruct the developers to listen tothe reasonable criticism that has been made of the scheme and to alter it significantly enough toalign with the needs of the site and residents.

I object to this application. The latest revisions are minor and improve nothing- forexample, the number of apartments have only been reduced by six. They are mere windowdressing and greenwash to appease your officers. This remains an inappropriate and harmfulapplication.The massing, height and design (blocks of flats up to five storeys high) is out of the keeping withthe area and will negatively affect views from the Downs Conservation Area, and the Grade IIlisted Grace House on site. The application will alter this area for ever.

There is no affordable housing at a time when the city is facing a housing crisis. If the site is to beredeveloped for apartments, surely it has a moral obligation to provide affordable housing, even ifthe developer has technically wriggled out of it on Use Class grounds.

This is a luxury retirement complex with no benefits for the community - the developer's offer of an'urban village hall' and access a cafe is laughable; there are plenty of cafes and two church hallsfor hire nearby.

There only 65 car parking spaces proposed which means, with 200 residents and staff andvisitors, there will be a massive overspill of vehicles into surrounding streets which already sufferfrom dangerous congestion and pavement parking. A development that will generate so muchtraffic cannot by any of the stretch of the imagination be described as 'sustainable,' however manyecobling features it includes

The loss of protected and mature trees and green space is unacceptable in a time of nature andclimate emergency and must surely fly in the face of the council's own policy. The existing site isrich in wildlife and biodiversity already and the development will damage this. It is greenwash tosay that the development will 'restore local biodiversity'.

The site should be retained for SEND education facilities- there is an acute shortage of these inthe city.

The consultation on the updated proposals has disingenuously been run over the festive period,no doubt in the hope that local people wouldn't notice- an old trick. This is bad practice.

This response follows the amendments that were recently submitted and follows onfrom my previously submitted response. Significant amendments have been made addressingprevious comments in relation to trees, massing and the cottages close to Bayswater Avenue.Further design comments now provided are that this is clearly a high quality, carefully considered,sensitive and appropriate design in a sustainable location. The principle of a retirement communityis supported, meeting important housing needs and hopefully freeing up larger houses in the areafor families.

One outstanding significant concern is in relation to parking as parking on surrounding streets issignificantly constrained and presents road safety issues with cars having to circle round the blockmultiple times trying to find spaces. However this could be addressed by bringing forward aresidents parking zone with new residents in the development not being eligible for parkingpermits. This would mean that residents buy into the scheme knowing they will not have a parkingspace therefore encouraging sustainable travel modes from the outset. If a RPZ could be boughtforward alongside this development, then the application should be supported.

The revised proposal does not resolve any of the original issues raised. There will stillbe issues with parking, road traffic, and heritage conservation.

This is a very extensive development involving a the creation of a large number ofproperties on a relatively small site. Insufficient consideration has been given to the affect on thelocal amenities, including access from already congested road network and lack of on-site parkingas well as the environmental affect of the felling of a significant of well established trees. Theproposed new buildings are higher than surrounding properties and would have a detrimentalimpact on the Downs Conservation area.The developers claim to have modified plans to take account of previous opposition, but thesechanges are minimal.- The developers say the revised scheme is smaller & less visible with fewer homes.In reality, just there are just 6 fewer homes. There would still be 116 housing units in 4 blocks upto five storeys high, dwarfing adjacent properties with a serious detrimental affect on the DownsConservation area.- They say there is an 'Improved' parking ratio.In reality there will be still only 65 spaces for 116 luxury homes with no specific provision for staffwho look after the site, carers, visitors, deliveries.- They say the revised plans would retain more trees.The reality is that too many protected, mature trees will be felled - including a wonderful old oaktree. It will take decades for any new saplings to provide the same benefit to nature and wildlife.- They say they will create an "Urban Village Hall" with space for community groups - with possibleuse by children with special education needs (SEN).In reality this is a vague offer without any substance which safeguarding issues would renderimpossible to implement. It is wrong to imply that this provision would compensate in any way for

the loss of St Christopher's, a much valued community asset for 70+ years.

I think this development, even in its revised form which would lead to a reduction ofnumber of flats from 122 to 116 and reduction in number of storeys from 6 to 5, is quite out ofplace. As I wrote in reply to the First Application re this site. This revised proposed development,even with amendments, would destroy a "green" area which, I suggest, if of great benefit toWestbury Park Residents and other locals as well as birds and beasts ~and further be a completeeyesore ~ rather like those hideous 1960's "modern" multi-storey blocks of flats behind the SpireHospital, only 300 yards away. Further, it inevitably would cause traffic congestion what withresidents, staff and visitors looking for parking.. in an area bedevilled with narrow roads andexisting parking problems not least with the growing number of commuters who park in theseroads before 0800 on workdays and catch the bus into town thereby avoiding charging zone feesand parking fees.Better, I suggest, to let rich buyers take these marvellous properties over as residences .. as hasbeen evidenced already on the Redland edge of this Site. We note that fine large Victorian houseand grounds has been bought privately and done up, splendidly; a pleasure to walk by andadmire! Let's emulate that example and I ask the planners to reject this amended application. BillChavasse; Fodag Member..former solicitor & 45 years resident of Bristol.

Just far too big.

The objection I made previously to the original planning application applies to thisproposal.I continue to believe that this planning application should be refused for the reasons Istated before.The main areas of concern are as follows1 overdevelopment. This is a major concern. There is no real change as it is still too big, too denseand too high. There are only 6 fewer homes but still 4 and 5 storey blocks of flats2 Loss of trees and wildlife. Still too many mature trees being chopped down the reduction is byvery little.3. Traffic there are insufficient parking spaces leading to overspill and road safety hazards. 6 fewerhomes will not shift the dial. This is already a very busy traffic area and there is a shortage ofparking spaces in the area.4 Loss of SEND provision- an offer of shared use of a room is an insult to the 70years legacy ofspecial needs education on this site.5 Lossof heritage. This scheme is totally out of character with our neighbourhood and completelydisregards the fact that this is a designated Conservation area.

The proposed development of the site will have a significant, negative bearing on the immediateneighbourhood which is already very congested. Having recently moved to the area we areconscious of the high level of traffic on the roads nearby: Etloe Road, Bayswater Avenue andRoyal Albert Road in particular. With the proposed plan there will be spaces for 65 cars for thenew residents of the 116 living spaces - and, in addition, their visitors. Both traffic and noise levelswill consequently increase. The health and safety aspect impact on two nearby nurseries, oneprimary school and all local residents will be profound. These local roads at rush hours/dropoff/pick-up times are often overrun with cars. Even more vehicles will potentially create ahazardous zone, with accidents waiting to happen, that should be avoided at all cost. Myobjections, furthermore, concern the visual impact of the proposed site. At present there is awonderful array of ancient trees, the sight of which brings great pleasure to many. The proposedplan includes the removal of several of these. Their loss will not only have a detrimental effectvisually but also on the environment.

The objection I submitted to the original planning application remains applicable to thisproposal as the revisions made by the developer are mere tinkering around the edges rather thana fundamental review taking into account the concerns of residents, the Council and expertbodies. I continue to believe that this planning application should be refused for the reasons Istated before'.

1 There is insufficient on-site parking to avoid overspill and associated adverse impact and road

safety concerns on neighbouring roads

1.1 Summary

The applicant does not provide any evidence or estimates of the actual expected parking needs of the

residents, staff and visitors for a new Extra Care scheme, so has not established that they have provided

sufficient parking to be able to meet these without any overspill on to surrounding roads. It is

disappointing that this has still not been addressed, despite being raised in comments responding to the

earlier application.

In summary, the information provided in Section 6 of the Transport Statement to justify the number of

parking spaces is fallacious, irrelevant and misleading, relying on:

• an interpretation of the BCC parking standards for C2 (residential care homes where residents

don't have cars);

• comparison with parking provided at a small number of non-similar schemes (eg where care is

not provided, which are socially rented, where there is a much higher proportion of single

occupancy reducing the ratio of cars to dwellings, or the minimum age is greater) and flawed

“parking accumulation” calculations;

• a comparison with four planning applications for integrated care schemes, none of which have

been built, one of which was rejected, and one superseded. Of the other two, one was approved

based on the fact that the acknowledged parking overspill could be accommodated by nearby

public car parks, and the other due to the lack of on-street parking within 500m which could be

affected. It should also be clear that planning applications for non-existent developments do not

provide any actual evidence to support that the proposed parking will be sufficient for this

development;

• parking surveys of the area undertaken between 10pm and midnight, which do not demonstrate

any capacity to absorb the overspill at the busiest times during the working day, when staff and

visitors will be searching for parking. This is despite it being well known that these roads suffer

from major over demand during the working day, when they are used by local commuters as well

as staff at the nearby schools and care homes.

Section 1.2 of this statement provides a fuller analysis of the flaws in the information provided in

Transport Statement Section 6, supporting the above points.

We are confident that BCC will not see this as sufficient evidence on which to base such a decision, where

if the on-site parking proves insufficient, it will have a major impact on road safety in a residential area.

It is almost inconceivable that the applicant, having been planning the development for more than 18

months, would not have conducted proper analysis of the actual likely demand for parking from residents,

staff, carers and visitors, so it is puzzling why they continue to base their assertions on such subjective

and non-evidenced estimates, instead of providing quantified assumptions, data and research to show

the actual likely parking requirements.

In the absence of this, Section 1.3 of this statement uses reliable data sources to indicate that a

reasonable estimate of parking requirements for the development would be 115 spaces, made up of:

• 73 spaces for residents’ cars

• 2 car club and 1 mini-bus space

• 39 spaces reserved for staff and visitors (including public visitors to the community facilities)

Given that the applicant has only included 65 spaces, this suggests there will be an overspill of at least 50

additional cars trying to park on the roads surrounding the site. It is well known that these already face

issues with over-demand of parking, and the associated road safety issues. Section 1.4 provides further

detail and evidence, including parking surveys (with photographs) undertaken throughout the working

day, which prove that there is no spare capacity to accommodate the likely overspill from the new

development, and the extra volume of cars looking for spaces will exacerbate the current safety

concerns.

Obviously, the ultimate parking needs will be based on a number of factors and cannot be predicted with

100% accuracy. However, it should be recognised that the nature of the location – closely surrounded by

residential roads – means that if the estimates lead to insufficient parking on-site, residents, staff and

visitors will seek to park on the neighbouring roads, and this impact cannot be managed by the developers

(or BCC) once the site is occupied. There must therefore be a clear onus on the applicant to provide

sufficient parking, based on realistic estimates, to reduce, as far as reasonably possible, the risk of this

occurring. Instead, their provisions are, at best, based on unenforceable best case wishful thinking. The

estimates we have provided above are based on defined and reasonable (not worst case) assumptions, as

detailed further in Section 1.3.

It is worth noting that the plans presented in the first pre-app included 120 spaces, and even then, they

referred to the potential need for a residents parking scheme to avoid overspill into the surrounding

streets. This suggests that the applicant is in fact aware of the likely number of parking spaces required

to avoid overspill, but has reduced the planned provision from 120 to 65 for their own reasons.

Overall, it is clear that there is simply no basis for assuming that the planned parking provision is

sufficient for the parking needs at this location. It is very likely there will be a significant overspill,

which will increase risks to road safety in the surrounding residential streets.

Paragraph 109 of the NPPF states that “Development should only be prevented or refused on highway

grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts

on the road network would be severe.” It is clear that the developers are not producing sufficient parking

to avoid an unacceptable impact, and the application should therefore be rejected.

1.2 Flaws in the applicant’s justification for provision of 65 spaces

This section details why the information provided in the Transport Statement is flawed and does not

support their assertion that 65 spaces will be sufficient to avoid parking overspill on to surrounding roads.

Firstly it should be noted that the TDM response (dated 1st August 2022) to the initial application

specifically stated that “A clear breakdown of all staff split between care, administrative, domestic and

ancillary must be provided. This needs to take into consideration the 24 hour site provision and the fact

that public transport may not be operational when staff changes over, such as late at night or early in the

morning. This will require staff to depend on the use of motorised forms of transport.”

This applicant has provided neither this, nor evidence to support any proposed ratio of cars to residents.

Instead they have continued to rely on comparison with parking provided at non-comparable – and

non-existent! – sites, rather than identifying the actual likely needs for this particular site.

1.2.1 Inappropriate reliance on Bristol City Council Parking Standards for Care Homes

During the consultation process, the applicant referred to the on-site parking capacity being restricted by BCC

parking standards. In this application (eg Transport Statement 6.8 and 6.33) they have repeatedly stated that they

are providing more spaces than would be allowed by the BCC parking standards. This is misleading, due to their use

of C2 parking standards, which relate to residential care homes, and have significantly different needs to an Extra

Care scheme.

Transport Statement 6.6 states “Car parking is set as the following for ‘Hospitals/Nursing Homes and Residential

Care Homes’, with ‘Convalescent and residential car homes’ having the following standard.

C2 1 space per 2 Full time staff

1 space per 6 bed space”

This paragraph omits to mention that the allowance of “1 space per 6 bed space” is set for visitors, not for residents,

who presumably are assumed (in a care home) not to be able to drive. The C2 parking standards are clearly not

intended, or appropriate, for a scheme in which many residents will be capable of driving, and which will be

marketed as having rentable on-site parking spaces.

It should be noted that the BCC C3 parking standards allow for the following:

One bed house/flat: one space per dwelling

Two bed house/flat: 1.25 spaces per dwelling

Transport Statement 6.7 states that there will be 105 two-bed and 11 one-bed apartments, so C3

planning standards would allow for 142 car parking spaces.

It is understood that the Extra Care development does not easily fit into either a C2 or C3 category – in

particular, there will be a need for residents’ parking spaces, which are not allowed under C2, while there

will be an additional need for staff parking, which is not recognised under C3. In fact, BCC’s TDM response

to the first version of this application (dated 1st August 2022), states:

‘Application Design Principles for Extra Care Housing (3rd edition) June 2020 sets out that “Parking

standards will need to be negotiated with the planning/highways authority as there are often no

defined standards for ‘housing with care’”. TDM agrees with this statement.’

It appears that the applicant has ignored this.

1.2.2 Meaningless comparison with provision at dissimilar schemes

Most of the applicant’s case seems to rely on a suggestion (Transport Statement 6.19) that “The parking,

when checked against other examples in TRICS, local examples and national examples, shows the

provision is in line with other schemes”. However, the amount of parking provided at these other sites is

not relevant in determining the actual parking needs of this site.

• Firstly, the amount of parking provided at any other site does not indicate this is sufficient to meet

the actual demand; there may well be overspill at these other sites, or usable public parking close-

by. For some, the location of the site (eg out of town) actually prohibits overspill – which is not

the case at the St Christophers Square location, being surrounded by residential streets with

unrestricted parking which residents, staff and visitors will seek to use if they cannot park on site.

• Secondly, the sites referred to are not sufficiently similar in nature, location or demographics, to

be comparable to St Christophers Square for the reasons explained in the sections below. Several

of the referenced sites have not even been built!

A) Comparison with TRICS assisted living schemes

Firstly, Transport Statement 6.11 & 6.12 state the applicant has considered six such schemes in the

“assisted living” category of TRICS, with an average of 0.412 spaces per dwelling. These TRICS sites are not

comparable with St Christophers Square for the following reasons:

• primarily because they are for standard “assisted living” meaning that they do not require the

same degree of parking for staff and carers (except for AC-03-P-01 and LE-03-P-01 which appear

to be care homes, where residents do not have cars)

• four of them (AD-03-P-01, NF-03-P-01, NY-03-P-01 and TY-03-P-01) provide rented social care

accommodation, which is a significantly different demographic from the St Christophers Square

target market

• three of them (AD-03-P-01, NF-03-P-02 and TB-03-P-01) are intended for single occupancy, with

solely 1-bedroom flats and studios. This clearly reduces the ratio of cars per dwelling, compared

to St Christophers where most flats are designed for double occupancy

• one of them (TW-03-P-01) is restricted to residents aged over 70, unlike St Christophers which

limits one resident per dwelling to be over 65

• most of them (such as the Edge of Town ones AC-03-P-01, LE-03-P-01, TB-03-P-01, TY-03-P-01)

have no uncontrolled on-street parking close by, which prevents overspill, unlike the location of

St Christophers.

It is also worth noting that the TRICS extracts in Appendix H do not show the number of car parking spaces

per scheme, and the applicant has provided no information to enable their figures to be validated.

Clearly this data does not provide any reliable justification that this ratio of spaces per dwelling will be

sufficient for a scheme of the nature and location of St Christophers.

(For the purposes of the above, Appendix H Page 99 identifies the sites by road name and town, which

enables them to be identified as the following assisted living schemes or care homes:

AC-03-P-01 Daneside Court, Chester Way, Northwich

AD-03-P-01 Bede House Court, St Machar Drive, Aberdeen

LE-03-P-01 Jasmine Court, Nottingham Road, Loughborough

NF-03-P-02 Harriet Court, Lakenfields, Norwich

NY-03-P-01 Sunnyfield Lodge, Fennell Grove, Ripon

TB-03-P-01 Abbeyfield Park House, Garfield Road, Paignton

TW-03-P-01 Kenton Lodge, Kenton Road, Newcastle Upon Tyne

TY-03-P-01 Sperrin Court, Limekiln Lane, Tyrone)

B) Comparison with “other integrated retirement living schemes”

Transport Statement 6.15 and 6.16 refer to parking provision at the site covered by Bristol Application 17/06914/F

in Bishopsworth, which was approved with 22 spaces for 62 units.

However, the demographic of residents of this scheme (Brunelcare Waverley Gardens) is entirely different from that

proposed for St Christophers Square. The majority of the units are single-bedroomed, and the site provides 100%

affordable housing to applicants on Bristol City Council’s health and social care waiting list1. This is totally different

from the private ownership of largely 2-bedroomed flats in St Christophers Square. Neither does the scheme provide

the proposed additional community facilities, with the associated additional staff and visitors of St Christophers

Square.

Furthermore, the amount of parking provision at this site does not prove that it is sufficient for all parking

requirements or that there is no overspill. In fact, the Bishopsworth application shows that the applicant based their

own parking estimates on comparison date (from TRICS) for residential care homes2, which do not allow for parking

spaces for residents. While there may have been a reason why this was seen as valid in the case of Waverley Gardens

(eg to cater purely for the additional staff requirements), this does not make it comparable to St Christophers Square,

which is being marketed with available residents’ parking. In fact, BCC commented on the application that “there

must be measures in place to maintain this low level of parking demand and prevent an increase, which if overspilled

onto the surrounding highway could create congestion”. None of this is comparable with St Christophers Square.

It is notable that the applicant has avoided comparison with the two far more similar local sites:

• The Vincent is less than a mile away and provides 66 car parking spaces for 65 retirement

apartments.

• Westbury Fields Sommerville Retirement Village two miles away, which provides private

retirement accommodation. This is one of Bristol City Council’s approved Extra Care Housing

sites3 and is registered by the CQC to “provide care and support to people living in specialist ‘extra

care’ housing”4. This development also provides more than one parking space per dwelling.

The applicant then goes on to state in Transport Statement 6.17: “We have also looked nationally at

Integrated Retirement Living schemes” and refers to the average parking ratio of four such schemes.

This statement is highly disingenuous, because:

• None of these schemes actually exist; the data is provided from planning application forms but

none have been built, one was not approved, and one has been superseded.

• Where these have been approved, this was on the basis of defined site-specific circumstances

which would avoid parking over-spilling into residential areas, which demonstrably do not apply

to the St Christopher’s site.

Specifically:

• Epsom 19/01722 – application was rejected.

• BANES 20/00259 – application was approved on appeal (with 156 spaces, not 136 as shown by

the applicant), stating that: “Parking throughout the local area is also well controlled and the

nearest available on-street spaces are more than 500 metres from the site. As such, overspill

1 From Application 17/06914/F on the Bristol City Council Planning Portal: “Affordable Housing Statement” and “Housing Delivery Response” 2 From Application 17/06914/F on the Bristol City Council Planning Portal: “Trip Rate Calculation” 3 https://www.bristol.gov.uk/social-care-health/extra-care-housing - Section “Where you could live” 4 https://www.cqc.org.uk/location/1-126473607#accordion-1

parking is unlikely to occur.” This is fundamentally different from St Christophers, which is

surrounded by residential on-street spaces, which are known to already be under high demand.

• Elmbridge BC 2020/0832 – application was approved on appeal stating that: “There are also two

car parks within easy walking distance available for visitors and possibly staff to use… Ashley

Park Crescent and Avenue, beyond their gates, are private roads and it is clear from the signage

that this is the case and that there is to be no unauthorised parking with CCTV in place”. This is

fundamentally different from St Christophers, where there are no public car parks anywhere

nearby, and where the surrounding residential roads are not private and cannot restrict parking

to residents only.

• Cheshire West & Chester 17/03661 – application was not progressed and has now been fully

superseded by a new one (22/02075/S73) which is still under consideration.

Fundamentally, it should be obvious that planning applications for other sites, which have not even

been built, do nothing to demonstrate that the proposed parking at this site, in this location, will be

sufficient to avoid overspill.

C) Erroneous “parking accumulation” figures

In paragraphs 6.20 – 6.24 the applicant state that they have used TRICS figures to show parking

accumulation throughout the day, leading to projections of either 33 or 40 peak occupancy.

• These figures are actually incorrect; Appendix F shows that these projections are based on a

completely unjustified assumption, which is that at the beginning of the day the St Christophers’

car park will only be occupied by (respectively) 25 and 33 cars (out of 65 spaces). The

projections of peak occupancy are therefore unfounded and wrong.

• Furthermore, the comparison data is from the same assisted living schemes referred to in

Section B above, which are not valid comparators for the reasons given. In particular, they

provide no reliable comparison data about the number of care staff who will be arriving

throughout the day.

Overall, Section 6 provides limited data from non-comparable and non-existent schemes, and does

nothing to demonstrate why these could validly be extrapolated for the St Christophers scheme. It seems

highly unlikely that professional developers would actually base their own projections on such flaky

comparisons.

1.2.3 Meaningless comparison with occupation by guardians

The applicant states (Transport Statement 7.10) that “90 ‘guardians’ are currently living in the buildings, providing

round the clock live-in surveillance. Effectively this is the same as 90 separate residential units operating from the

site, and likely to have a higher impact on parking and traffic movements than the proposed use.”

This comparison is simply ridiculous, and is yet another subjective assertion with no evidence base or relevance.

• Firstly, this application can only be judged on the additional parking requirements from the previous

approved use – as a residential school for disabled children, where the only parking requirements were for

staff – rather than on a comparison to an unapproved interim situation. The applicant appears to be

implying that there has already been de facto approval for 90 residential units on the site – this is obviously

incorrect, and clearly should not be taken as an approved starting point for further increases.

• Secondly, the applicant provides no evidence or rationale to support their assertion that the new Extra Care

facility would have a lesser impact than the current use by guardians. We have been told by one of the

guardians that only about 10 of them have vehicles, which are able to be kept on-site, and rarely used apart

from to travel to festivals. There is in fact no comprehensible reason why 90 individual guardians – largely

young people, looking for cheap temporary accommodation – would require more parking than the

occupants of 116 primarily 2-bedroom apartments intended for relatively wealthy retired couples and

individuals, together with the supporting staff and visitors of an Extra Care facility.

1.2.4 Summary

Overall, it is clear that the applicant has provided no reliable evidence to indicate that 65 spaces will be

sufficient, for this scheme and location, to avoid parking overspill onto neighbouring roads.

1.3 Research-based estimate of likely parking requirements

As the applicant has not produced any actual estimates or evidence of the likely parking requirements for

the site, this section provides a basis for making a reasonable estimate of the parking needs for each

category of site user.

This results in a total estimated demand for parking for 115 vehicles. This number is explained in detail

below, together with references to the supporting research.

1.3.1 Residents’ parking requirements

The applicant justifies the low number of parking spaces by suggesting that “car ownership levels within an

integrated retirement community are far lower than an open market housing development5”. However, they do not

provide any evidence to justify or quantify this statement.

In the new document “Addendum Planning Statement” the applicant also suggests (Paragraph 4.48) that

“the parking proposals are considered in the context of the site location and the other transport

measures.” referring to the fact that “the site is in a sustainable location where walking, cycling, mobility

scooter use and public transport are viable options for journeys.”

However, it is clearly a fallacy to suggest that the viability of other options for short journeys directly leads

to low car ownership – at best it could indicate that not all journeys may need a car, but not that residents

will feel able to give up their cars altogether. For example, elderly residents are highly unlikely to choose

to take one or more buses (or cycle!!) while carrying heavy shopping, or rely on buses and trains to visit

family who live even a little distance away. It is far more likely that residents will wish to keep their existing

cars, especially if they believe they will be able to leave them at no cost in the surrounding streets, where

even if they are not regularly used they will reduce the already limited parking availability for residents of

those streets.

In fact, contrary to the applicant’s unevidenced assertions, all sources we have identified show there are

continued high levels of car ownership throughout retirement, as evidenced below. The data sources

referenced, and defined assumptions below, indicate a likely need of 73 parking spaces for residents.

Firstly, it should be noted that the applicant states that there will be “a minimum age of 65 for lead residents;

although experience confirms the average age of residents at the point of entry will be late 70’s and on a needs

basis.”6 Unfortunately, the applicant provides no sources to evidence the “experience” which supports this

assertion, which cannot therefore be treated as a reliable basis for estimates.

In fact, the proposed Heads of Terms7 confirms that the minimum age is 65 for lead residents, but also shows that

there is no minimum age or care requirement for a cohabitee (who may continue to live in their property following

the death of the lead resident). The applicant has promoted the development as being appropriate for couples where

one partner may be younger and more independent, while the other is starting to need some care.

There is no data to indicate that car ownership of this demographic will be low. As noted in the TDM response dated

1st August 2022: “as people are living longer they are not automatically switching to public transport, especially if

they remain fit and active”. In fact, a survey by Statista8 in 2017 states that “British people aged 60 years and older

were the age group with the highest share of car ownership”.

Furthermore, the ONS dataset entitled “Table A47 - Percentage of households with cars by income group, tenure

and household composition – UK, financial year ending 2018”9 shows a high percentage of car ownership amongst

retired adults. In particular, for retired couples who are not mainly dependent on state pension (the key likely

demographic for St Christophers Square), 89% of retired couples own one or more cars as shown in the following

extract:

5 Statement of Community Involvement Part 1 Page 50 (or Page 51 of PDF) 6 Planning Statement Page 14 Paragraph 4.2 (Page 17 of PDF) 7 Draft Heads of Terms Page 2 (Page 4 of PDF): Definition of “Qualifying Person” 8 https://www.statista.com/statistics/682596/consumers-who-own-a-motor-vehicle-in-the-united-kingdom-uk-by-age/ #:~:text=British%20people%20aged%2060%20years,were%20planning%20on%20purchasing%20one. 9https://www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances/expenditure/datasets/percentageofhouseholdswithcarsbyincomegrouptenureandhouseholdcompositionuktablea47

There is no reason why car ownership for the population living at St Christophers Square would be any less than

these figures demonstrate. In fact, Department of Transport data10 shows that while the number of “car trips as

driver” (NB – this refers to individual trips, not car ownership) may decrease with age, there is a corresponding

increase in “car trips as passenger”, indicating that as the care needs of one person increase, they become more

reliant on their partner (or carer) to be able to drive them, so are still likely to retain their cars.

The nature of the development (the applicant refers to it being aimed at retired people “who want to still live

independently”11, and their website claims that “The services will help residents to live independently for longer12”)

and its location, surrounded by residential streets with non-restricted parking, suggest that many potential buyers

would see it as a benefit that they can retain their cars, parked either on-site or very close by. (This is not the case

for out-of-town retirement schemes, where there is no viable alternative to parking on-site and car ownership is

limited to the actual on-site provision.)

Assuming that 50% of the 116 flats at St Christophers Place are occupied by two adults (although it may well be more

than this initially), and 50% by a single adult, and that all have income above state pension level (as is likely to be

necessary), the ONS figures indicate that an average of 70% of flats will have occupant(s) owning one or more car.

Even assuming that this would be limited to only one car per individual or couple (which may be reasonable, if not

enforceable), this would result in a potential 81 cars to be accommodated.

The applicant proposes the use of a car club (with 2 allocated spaces) to reduce car ownership, which is appreciated,

but there is no data to support the likely take-up of this. It is interesting that the applicant proposes (Transport

Statement 7.11) that Bristol City Council will be solely responsible for promoting this to residents – showing that the

applicant takes no responsibility for encouraging car ownership reduction through its usage. However, as an

estimating assumption only, if 10% of residents give up their cars due to the availability of 2 car club cars, this would

lead to a reduced estimate of 73 residents’ cars needing to be accommodated.

1.3.2 Staff parking Requirements

Travel Plan 1.1.1 and Transport Statement 6.6 refers to the site having between 15 and 20 staff on site at any one

time and apply BCC’s standard of “1 space per 2 Full time staff” to this figure (rather than to the 33 FTE shown in the

Application Form). However, there is no rationale or evidence to support either figure, which are at best unvalidated

and unenforceable.

In fact, 15 – 20 on-site staff is likely to be a significant under-estimate, particularly at peak hours. The following

analysis shows that an estimated 37 staff are likely to be on site during peak hours. A fairly optimistic estimate of

50% of staff travelling by car suggests the need for at least 19 car park spaces for staff.

The TDM response to the Application (dated 1st August 2022) specifically requested the applicant to

provide “A clear breakdown of all staff split between care, administrative, domestic and ancillary must be

provided. This needs to take into consideration the 24 hour site provision and the fact that public

transport may not be operational when staff changes over, such as late at night or early in the morning.

This will require staff to depend on the use of motorised forms of transport.”

Unfortunately, the applicant has not provided this, or indeed any supporting information to explain the

number of permanent staff on site, or to indicate the basis for estimating the likely number of carers who

10 NTS0601: Average number of trips (trip rates) by age, gender and main mode 11 Transport Statement Paragraph 5.2 12 https://www.stchristophersbristol.com/benefits-of-extra-care

will be required to support the residents. Therefore this section provides some research basis for likely

estimates of what staffing will be required.

The only information about levels of care provision is given on Page 14 of the original Planning Statement, where

paragraph 4.4 states that “residents must have a minimum package of 2 hours support per week”. There is no

maximum, and residents may ultimately receive 24-hour care, with paragraph 4.1 confirming that “residents may

also organise night service or care companions for episodic care of permanent appointments”.

It is surprising that the applicant has not conducted more detailed research into the amount of care they are likely

to be providing. Fortunately, there are a num