BTF Comments – 28 March 2024

2

for the issues raised below, we accept the applicant’s other BNG 4.0 inputs.

1. We calculate that the area of the baseline onsite Urban Individual Trees habitat is 0.7655

hectares, not 0.47 hectares as the applicant suggests (we are unclear how this figure was

calculated). Our calculations are based on the Applicant’s Arboricultural Impact

Assessment4 as set out at Appendix B. 0.1419 hectares of this baseline habitat will be lost,

with the balance being retained.

2. Urban Individual Trees habitat has High strategic significance under the local plan, because

trees are specifically identified in core policy BCS9 and SADMP DM17.

3. On the basis that this habitat is, as the applicant indicates, in Moderate condition, we

calculate that it is worth 7.04 Habitat Units (HUs), of which 5.74 HUs will be lost.

4. Both BNG 4.0 and the Statutory Metric trading rules require that losses of habitat of

Moderate distinctiveness (such as Urban Individual trees habitat) ‘must be replaced by

area habitat units of either medium band habitats within the same broad habitat type or,

any habitat from a higher band from any broad habitat type.’5 This means that Urban

Individual Trees habitat can only be replaced with Individual trees habitat or with habitats

with a higher distinctiveness.

5. As the trading rules apply only up to the point of no net loss, we calculate that, if the

habitat is replaced like for like, then 401 Statutory Metric ‘small’ category trees will need

to be planted in order to comply with the obligation.

6. The applicant proposes planting 142 new trees on site so, assuming that none of these will

be planted in private gardens (this will need to be verified), a further 259 Statutory Metric

‘small’ category trees will need to be planted elsewhere, off site. The applicant has made

no proposals for this and will need to do so whilst still complying with the Biodiversity

Mitigation Hierarchy.6

7. We note in passing that the applicant suggests that the 142 trees to be planted onsite will

be ‘medium’ category trees (under BNG 4.0). However, the guidance makes it clear that

‘post-development size class is determined by the size of the tree at site-planting’ so that

users should ‘record newly planted individual trees as ‘small’, unless ‘medium’ size or

above at the time of site-planting.’7 No nursery-supplied trees are greater than ‘small’ size

category at the time of planting.

8. We also note that the applicant has classified some trees as a linear Line of Tree habitat

0.097 kilometres long. This is incorrect. These trees fall within the Statutory Metric

definition of Individual Trees habitat:

‘Use the broad habitat type ‘Individual trees’ to record: ... lines, blocks or groups of

4 23_03104_P-ARBORICULTURAL_IMPACT_ASSESSMENT-3510249. 5 https://assets.publishing.service.gov.uk/media/65c60e0514b83c000ca715f3/The_Statutory_Biodiversity_Metric_-_User_Guide_.pdf - page 13. 6 https://www.legislation.gov.uk/uksi/2024/50/made - regulation 37A 7 https://assets.publishing.service.gov.uk/media/65c60e0514b83c000ca715f3/The_Statutory_Biodiversity_Metric_-_User_Guide_.pdf - page 55.

BTF Comments – 28 March 2024

3

trees found within and around the perimeter of urban land.’8

9. The removal of this habitat increases the Hedgerow Units net gain to 306.38%.

10. If no offsite habitat is created, not only will the application be in breach of the trading

rules, but it will also fail to achieve the 10% biodiversity gain the applicant aspires to and

only achieve a net gain of 6.11%. If the trading rules are complied with just to break even,

the gain will be 58.76%.

It is clear from the above that the BTRS and the Biodiversity Gain calculations, both adopted

policies, are inconsistent. We have made proposals to align these but our proposals have not

been taken up - Why we need a new Bristol Tree Replacement Standard. In the meantime, we

suggest, the obligation of the NPPF and Biodiversity gain must take precedence.

8 https://assets.publishing.service.gov.uk/media/65c60e0514b83c000ca715f3/The_Statutory_Biodiversity_Metric_-_User_Guide_.pdf - page 52.

BTF Comments – 28 March 2024

4

Appendix A – DM17 / BTRS Calculation

Totals 53 42 152

Tree ID Tree

Category Tree Count

Trees Removed

DBH (cm)

Trees Replacements

Required

T1 C 2 1 0 30 0

T2 A 2 1 0 109 0

T3 C 2 1 0 26 0

T4 B 2 1 0 40 0

T5 B 2 1 0 31 0

H6 C 2 0 0 8 0

T7 C 2 1 1 40 4

G8 C 2 35 35 40 140

T9 C 1 1 1 32 3

G10 C 2 3 3 15 3

T11 C 1 1 1 15 1

T12 C 2 1 1 15 1

G13 C 2 6 0 10 0

G14 B 2 0 0 52 0

BTF Comments – 28 March 2024

5

Appendix B – Statutory Metric Individual trees habitat area calculation

Tree ID

Tree Count

Trees Removed DBH

(cm)

Statutory Metric

Category

Baseline Habitat

Habitat Retained

(ha)

Habitat removed

(ha)

Totals 0.7655 0.1419 0.6236

53 42

T1 1 0 30 Small 0.0041 0.0041 0.0000

T2 1 0 109 V. Large 0.0765 0.0765 0.0000

T3 1 0 26 Small 0.0041 0.0041 0.0000

T4 1 0 40 Medium 0.0163 0.0163 0.0000

T5 1 0 31 Medium 0.0163 0.0163 0.0000

T7 1 1 40 Medium 0.0163 0.0000 0.0163

G8 35 35 40 Medium 0.5705 0.0000 0.5705

T9 1 1 32 Medium 0.0163 0.0000 0.0163

G10 3 3 15 Small 0.0123 0.0000 0.0123

T11 1 1 15 Small 0.0041 0.0000 0.0041

T12 1 1 15 Small 0.0041 0.0000 0.0041

G13 6 0 10 Small 0.0246 0.0246 0.0000

G14 0 0 52 Medium 0.0000 0.0000 0.0000

BTF Comments – 28 March 2024

2

Assessment4 as set out at Appendix A. 0.1419 hectares of this baseline habitat will be lost,

with the balance being retained.

2. Urban Individual Trees habitat has High strategic significance under the local plan, because

trees are specifically identified in core policy BCS9 and SADMP DM17.

3. On the basis that this habitat is, as the applicant indicates, in Moderate condition, we

calculate that it is worth 7.04 Habitat Units (HUs), of which 5.74 HUs will be lost.

4. Both BNG 4.0 and the Statutory Metric trading rules require that losses of habitat of

Moderate distinctiveness (such as Urban Individual trees habitat) ‘must be replaced by

area habitat units of either medium band habitats within the same broad habitat type or,

any habitat from a higher band from any broad habitat type.’5 This means that Urban

Individual Trees habitat can only be replaced with Individual trees habitat or with habitats

with a higher distinctiveness.

5. As the trading rules apply only up to the point of no net loss, we calculate that, if the

habitat is replaced like for like, then 401 Statutory Metric ‘small’ category trees will need

to be planted in order to comply with the obligation.

6. The applicant proposes planting 142 new trees on site so, assuming that none of these will

be planted in private gardens (this will need to be verified), a further 259 Statutory Metric

‘small’ category trees will need to be planted elsewhere, off site. The applicant has made

no proposals for this and will need to do so whilst still complying with the Biodiversity

Mitigation Hierarchy.6

7. We note in passing that the applicant suggests that the 142 trees to be planted onsite will

be ‘medium’ category trees (under BNG 4.0). However, the guidance makes it clear that

‘post-development size class is determined by the size of the tree at site-planting’ so that

users should ‘record newly planted individual trees as ‘small’, unless ‘medium’ size or

above at the time of site-planting.’7 No nursery-supplied trees are greater than ‘small’ size

category at the time of planting.

8. We also note that the applicant has classified some trees as a linear Line of Tree habitat

0.097 kilometres long. This is incorrect. These trees fall within the Statutory Metric

definition of Individual Trees habitat:

‘Use the broad habitat type ‘Individual trees’ to record: ... lines, blocks or groups of

trees found within and around the perimeter of urban land.’8

9. If no offsite habitat is created, not only will the application be in breach of the trading

rules, but it will also fail to achieve the 10% biodiversity gain the applicant aspires to and

4 23_03104_P-ARBORICULTURAL_IMPACT_ASSESSMENT-3510249. 5 https://assets.publishing.service.gov.uk/media/65c60e0514b83c000ca715f3/The_Statutory_Biodiversity_Metric_-_User_Guide_.pdf - page 13. 6 https://www.legislation.gov.uk/uksi/2024/50/made - regulation 37A 7 https://assets.publishing.service.gov.uk/media/65c60e0514b83c000ca715f3/The_Statutory_Biodiversity_Metric_-_User_Guide_.pdf - page 55. 8 https://assets.publishing.service.gov.uk/media/65c60e0514b83c000ca715f3/The_Statutory_Biodiversity_Metric_-_User_Guide_.pdf - page 52.

BTF Comments – 28 March 2024

3

only achieve a net gain of 6.11%. If the trading rules are complied with just to break even,

the gain will be 58.76%.

It is clear from the above that the BTRS and the Biodiversity Gain calculations, both adopted

policies, are inconsistent. We have made proposals to align these but our proposals have not

been taken up - Why we need a new Bristol Tree Replacement Standard. In the meantime, we

suggest, the obligation of the NPPF and Biodiversity gain must take precedence.

BTF Comments – 28 March 2024

4

Appendix A – Statutory Metric Individual trees habitat area calculations

Tree

ID

Tree

Count

Trees

Removed

Statutory

Metric

Category

Baseline

Habitat

Habitat

Retained

(ha)

Habitat

removed

(ha)

Totals 0.7655 0.1419 0.6236

53 42

T1 1 0 Small 0.0041 0.0041 0.0000

T2 1 0 V. Large 0.0765 0.0765 0.0000

T3 1 0 Small 0.0041 0.0041 0.0000

T4 1 0 Medium 0.0163 0.0163 0.0000

T5 1 0 Medium 0.0163 0.0163 0.0000

T7 1 1 Medium 0.0163 0.0000 0.0163

G8 35 35 Medium 0.5705 0.0000 0.5705

T9 1 1 Medium 0.0163 0.0000 0.0163

G10 3 3 Small 0.0123 0.0000 0.0123

T11 1 1 Small 0.0041 0.0000 0.0041

T12 1 1 Small 0.0041 0.0000 0.0041

G13 6 0 Small 0.0246 0.0246 0.0000

G14 0 0 Medium 0.0000 0.0000 0.0000

I support the whole projects because i support affordable housing.

will see

1. Our current site no longer meets our needs and has been restricting our growth formany years;2. Moving to Yate will create more jobs and greater opportunities for our whole team;3. We need the money from the sale of the Filwood Road site to invest in new jobs and growth;4. The current site is next to a residential area and primary school - not the ideal location for abusiness with lots of HGVs moving in and out of the site;5. There's a housing crisis in Bristol - we are proposing 255 new homes in what is a mainlyresidential area already;6. Most of the homes we are proposing are houses which will fit in well with the homes onneighbouring streets; there are some apartment buildings but these are limited to four storeys andwould sit mainly on Goodneston Road, away from the existing houses;7. The scheme includes much-needed affordable homes, and all homes would meet the highestenergy efficiency standards.

The scheme includes much-needed affordable homes, and all homes would meet thehighest energy efficiency standards.

The scheme includes much-needed affordable homes, and all homes would meet thehighest energy efficiency standards.

Grew up in the area pleased for development of this site.

more affordable housing is needed in Bristol build with modern systems energyefficiency.

GPI employees and company has a future in Yate site. better for progression anddevelopment in general.Affordable housing.

this move offers job security for the younger generation, the all site at fishponds wasvery old and very high maintenance, it also gives the opportunity for the development of affordablehousing

I am a employee of GPI vacating the site and believe the development of the oldmanufacturing site into houses will benefit the area and and increase the availability of housing ina city that sees a shortage of new houses.

Moving to Yate will create more jobs and greater opportunities for our whole team. Thecurrent site is next to a residential area and primary school - not the ideal location for a businesswith lots of HGVs moving in and out of the site

Moving to Yate will create more jobs and greater opportunities for our whole team;There's a housing crisis in Bristol - we are proposing 255 new homes in what is a mainlyresidential area already;

The scheme includes much-needed affordable homes, and all homes would meet thehighest energy efficiency standards.

The current site is next to a residential area and primary school - not the ideal locationfor a business with lots of HGVs moving in and out of the site;

Moving to Yate will create more jobs and greater opportunities for our whole team;

Comments

I object to this on the flowing grounds

- I was told about the "consultation" in March this is year via a letter but was not told this planningapplication had gone in.

- There is no discussion around healthcare, dental services and schools

- There is a discussion around cycle paths, but no mention of how cars from an extra 250households will be managed on the already congested roada. Fishponds is already congested, theair quality is bad and public transport is not up to standard. Cycling in Bristol is not viable forfamilies. The roads are too narrow and there is not enough space for segrated cycle paths. Alsothree kids under seven are not easy to get around by bike.

- The two brick chimney stacks are used by birds of prey, they should be listed and kept.

- How will the council and Wessex water manage the already oversubscribed sewage network?

This development is part of a much larger development and needs to be viewed assuch.The development needs to offer a much higher provision of affordable housing - 15% is way shortof what is needed and just exacerbates a problem. This part of Fishponds also needs a newschool - the existing provision cannot accommodate the numbers that will be required when AtlasPlace has been completed. We also need useable amenity space and investment into communityinfrastructure e.g. an endowment scheme set up with Quarter Community Foundation to securelong-term funding for important community services such as youth work and community centres.We can't allow this opportunity to be missed - developments of this size must also deliver socialvalue to ensure we maintain a sustainable neighbourhood.

1.Concern re provision of contractor parking during construction.I feel it is important to ensure that there is adequate on site parking for construction staff, siteoperatives and associated plant. This should be provided within the site boundary for the durationof the phased construction to minimise disruption to local residents and avoid traffic congestion.

Traffic management on the bridge section of Filwood Road will be essential.

2.Provision of on site public/ green space.There appears to be very little provision which is a concern particularly given the provision offamily homes with children.

Object on the basis of lack of detail of street frontage, character of streets and the useof courtyard parking due to its association with crime. The council should push developers to setout character guidelines for future reserved matters applications within this outline application.This is to avoid the site lacking a holistic strategy once the outline is consented. Rear courtyardparking should be avoid to ensure these new communities aren't targets for anti social behaviour.Density of the site should align with the local plan. Stronger cycle path links would be welcome.

The pictures of green space look very nice but who will carry out any upkeep?

I have concerns on the development of such a high number of properties with regards tothe impact on existing infrastructure in the local area.This - and other (recently completed, and recently proposed) local developments will put additionalstrain on local services: schools, doctors, dentists etc.With no provision for additional (or expansion to existing) services - the service(s) they provide willinevitably decline.I do recognise the need to build social/non-social housing.

I would expect BCC to handle the highways impact of this development application - to take intoconsideration the need to promote cycling, walking and public transport as a means to service thisarea. if they don't they will have failed the local community in my opinion.

Comments from the Fishponds Community Planning Group

The Fishponds Community Planning Group was established at the end of July. Our role is to actas a conduit of information between developers and members the community in the centralFishponds area, about major developments that are proposed in our area. We seek to- Engage constructively with residents, local businesses and developers.- Collate the views of residents and local businesses, about major planning applications in ourarea, and ensure that these views are considered.- Encourage development that will be positive for the local community, both current and futureresidents.

The Fishponds Community Planning Group held its first Committee Meeting on 7th September.Due to limited time constraints over the summer holiday period, we have not been able to carry outa detailed community consultation about the above Application for Outline Planning. We will beseeking community views over the coming months. However, in order to meet the timetable forresponses to the current application, we will make the comments specifically and only about theGPI application: Application Number: 23/03104/P.Comments regarding Atlas Place as a whole will be forthcoming following fuller communityengagement.

We were pleased to see that the application to develop the GPI site proposes low rise, mixedstyles of housing, including family homes and low rise apartment blocks, and there has been

consideration for car parking and outside spaces. We were also pleased that GPI has shown agenuine interest in community opinion, and that communication channels between FishpondsCommunity Planning Group and GPI representatives have been established. However, fromdiscussion among members of the Fishponds Community Planning Group and a review ofcomments against the application and on the Fishponds Community Planning Group Facebookpage, we would make the following comments.

1. This application covers only one part of the proposed Atlas Place scheme, and this is thesmallest of three elements of the site. It is not realistic to comment on one element only, withoutseeing the impact of all three schemes on each other, and on the wider area.

This point has been made by several of the people who have commented on the OutlineApplication on the Planning Portal to date, and their concerns are shared by members of theFishponds Community Planning Group.

2. We are aware that the GPI application is an Outline Planning Application that it likely to change.There is a significant local concern that the heights of the development on the GPI site couldincrease, subject to approvals on the adjacent sites.

3. There are serious local concerns about the impact of this scheme, as well as the wider AtlasPlace development, on the highway infrastructure. Without seeing the proposed traffic scheme forAtlas Place as a whole, it is impossible to make fully informed comments. However, currently,concerns raised include:a. Traffic impacts of 255 new dwellings on already narrow and congested roads.b. Serious concerns about road safety, based on residents' experience. Residents are particularlyconcerned about safety around local schools, with the additional traffic that the scheme willgenerate, especially the crossing points between Chester Park Infants School, the Spotted CowPub and Goodneston Road - an accident blackspot at the moment.c. Concerns about the additional parking that the scheme will generate and the impact this willhave on already congested neighbouring streets, particularly Enfield Road and Filwood Road.d. The impact and suitability of the access points that are current suggested in the outline plancannot be assessed without an overall transport plan for Atlas Place.

4. Residents and businesses are concerned about the existing amount of traffic in the centralFishponds area, the absence of any traffic plan for the Fishponds area, and the fact thatFishponds is not (at the present time) included in Bristol's Strategic Transport Plan. At the sametime, residents' experiences are that the local bus services are less reliable than they have been inthe past. We recognise that this is not a planning issue, and that it is a city wide issue. However,there is concern that, following development at Atlas Place, many more people will be usingalready congested local buses.We believe that it will be vital to develop a coordinated travel plan for the area, based on the plansof the three sites that make up Atlas Place and the needs of the local community. This should be

developed with residents and businesses who are deeply aware of the current local issues.

5. Residents have raised concerns about the impact of the GPI scheme, as well as the whole ofthe Atlas Place development, on local services, especially health - both GPs and Dentistry - andon local schools, many of which are already oversubscribed. We are aware that this is not a directplanning issue, but it is one that should be considered when looking at the impact of thesedevelopments on the local area. The Fishponds Community Planning Group would not bereflecting local views if we did not raise these issues.

6. There is a desperate need for truly affordable housing, and for social housing for rent, in theFishponds area. There must be a minimum amount set, ideally in line with Council policy as thisinitial site will set the standard for Atlas Place as a whole. The community wants to see socialhousing spread across the whole development, not in segregated blocks; and a consistentstandard of housing of all tenures on the whole development.

7. There are concerns about the density of the proposals, particularly in relation to the Atlas Placedevelopment as a whole.

8. As this is outline planning, we are unable to assess the green credentials of the site, but we willlook at this carefully when information becomes available.

9. We will need to see the detailed designs to be able to assess impacts such as overlooking,overshadowing and loss of light for individual properties around the site, design, and local amenity.

The Civic Society is concerned regarding the loss of employment land and loss ofemployment opportunities in this part of Bristol. In our view there needs to be a significant amountof commercial space on the Graphic Packaging site.

Provided that this fundamental concern is addressed satisfactorily the Society has the followingpoints to make about the current proposals:

It would be ideal if the three adjacent sites (sites considered within the Atlas Place StrategicFramework) are considered at the same time, enabling a comprehensive approach to successfulplace making. In this way issues such as transport planning, permeability, building heights and theprovision of services could be properly assessed in a co-ordinated way.

We understand that the current draft proposals for the three sites show a significant disparity ofdensities between them. In our view these should all be closer to the 120 dph stated in thecouncil's urban living spd for urban areas.The Civil Society considers that the application for the Graphic Packaging site should not bedetermined until the Atlas Place Strategic Framework is drafted, consulted on, and adopted by thecouncil and becomes a material consideration in the determination. We are aware of proposals toprogress a joint approach and wonder what has happened to these proposals.https://atlasplacefishpondsfuture.com/

Although the proposed building heights are appropriate to the south of the site the Society

suggests that the scheme could readily accommodate more housing at a higher density in thenorthern section, towards the junction of Goodneston Road and Filwood Road. Development atthis location might be higher, ideally designed in an appropriate relationship with the proposals forthe two adjacent development sites.

At ground level in this corner of the site there might be scope to include other uses such asemployment floorspace and services?

In conclusion we consider that this application is premature pending the finalisation of the AtlasPlace Framework. This will need to involve a comprehensive public consultation exercise. Themaster plan needs to include a significant amount of employment floorspace.

I am in principle in support of this development as more affordable houses are neededin Bristol however has enough thought been put into the local infrastructure? The neighbouringroads are extremely tricky to navigate at peak times already and many of them don't allow for2cars passing at the same time. Local schools are already experiencing extremely highapplications which are increasing year on year and good luck if you need a dentist! The GP seemsto be coping, but try and get an appointment.

The addition of all the these homes will have a significant impact on these numbers.

My objection is related to the lack of infrastructure in the area. Any development relatingto housing should follow improvements to roads, doctor surgeries and schools - not housing first.

The road layout around the Graphic Packaging is congested and busy with many bottle necks andmajor junctions. What is in place to improve this?

Local surgeries are already busy like in other areas. Additional housing will only compound thisproblem.

Schools are already full. What happens when more spaces are needed?

Also, if this development is part of the wider 'Atlas Place' why aren't all the developers presentingtogether, at once to give one full picture of how the area will be changed. Instead of individualapplications which will probably not work together.

If the area is set to gain so many new homes, it will need a bigger preschool. CurrentlySt josephs preschool is oversubscribed and looking for a bigger venue to support the families inthe area and to feed on to both Chester park and St josephs schools. I think that a preschoolbuilding should be built on the Filwood road site to support the community.

I have serious concerns about the impact the proposed development will have on thelocal area due to the number of proposed dwellings.

There have already been so many housing developments in the Fishponds area in recent years.

It is likely each dwelling will have at least one car, and most likely two (I have witnessed this on mystreet, and this pattern appears to be common to the area). I don't see how the local road systemcan absorb such an increase of cars on the roads.

I agree with other comments regarding lack of infrastructure in the locals area to cope - nurseries,schools, GPs, dentists.

I also have a serious concern about the lack of resources to manage anti-social behaviour (oftenrelated to how people drive their cars). How will this be factored in to the cost of the development,and what the development will give to the local community?

Another comment highlights there are to be three separate developments, so I question why thesedon't come in on one planning application. There is a serious lack of transparency on the part ofthe developers, and their intentions. I am of the view the council does have a responsibility tosupport and uphold the quality of life for residents already living in the area (and already feels overcrowded).

I agree the site should be used for housing but the density of this proposal is too high. 3and 4 story buildings are not in keeping with the area, particularly at the Enfield Road junction.Please let us not have a monstrosity like the Totterdown Bridge buildings which stick out like asore thumb for miles around. No matter how 'green' the plans, the reality is that most householdsown more than one car & developments need to start recognising this. The proposed number ofparking spaces will be catastrophic for surrounding roads where parking is already an issue. I'malso concerned about traffic congestion on the surrounding roads, particularly Filwood road -access to the site should be considered very carefully & whilst the obvious choice might be tomake the main access via Goodneston road planners also need to consider the proximity ofChester Park Infant school as the 4-way junction by the Spotted Cow is already hazardous & Ibelieve they lost funding for a second lolly pop lady on that side some years ago. Facilities in thelocal area such as doctors and dentists are already well oversubscribed & unless proper provisionfor this is included in the plans - ie new surgeries actually built and set up- existing services will notcope & long term or lifelong residents of Fishponds will suffer

Firstly, I understand the need for affordable housing and this site is in a prime locationand a Brownfield site. However the whole Atlas Place development would have a profoundlynegative effect on Fishponds. The development, including this application, is simply too large forthe local infrastructure to absorb.

Approach:Plans for the 3 sites should surely be combined into one planning application. Plans considered inisolation mean that the overall impact of the development cannot be understood. The one by oneplanning approach seems a way of getting approval in an underhand fashion.

Traffic impact:I am very concerned about the impact this proposed development will have on the traffic in thelocal area. Fishponds road is already congested, especially at rush hours, with drivers usingsurrounding roads as cut throughs and driving over the speed limits.

On Ridgeway Road within the last few months there has been an accident at the bridge andmultiple incidents of residents parked cars being driven into and written off. At peak times trying topull out at the junction on Ridgeway Road/Lodge Causeway is difficult. Chester Park InfantsSchool sits right on this junction increased traffic as a result of this development would be aconcern for child safety. I am pleased to see an "improvement scheme" would be recommendedfor this junction as part of the Transport Statement.More information on this is needed - what is theimprovement scheme to be and how will this help with the issues at hand? Traffic calming

measures for affected adjacent roads, such as Ridgeway Road, should be put in place.

The Travel Plan included in the proposal shows a high amount of anticipated road travel byresidents of this development (Table 8.2). The impact on traffic should be shown across the AtlasPlace development as a whole, not just one of the three areas. Fishponds does not have theinfrastructure to cope with the additional traffic proposed for 255 dwellings in this application, letalone the 2500 proposed across all 3 sites. If the 875 additional car/van shown for the 255dwellings, are scaled up for the 2500 dwellings proposed across Atlas Place it comes out asaround 8700 additional journeys daily?! If these figures are true, Fishponds would be unliveable,constant gridlocked traffic and massively increased pollution from standstill cars.

I am also concerned about the impact of traffic from lorries and deliveries during the build process.Will the developers commit to not using Ridgeway road for their deliveries? The narrow bridgewould be unable to cope with such sustained lorry use. Ridgeway Road is not noted in Table 6.37on HGV Distribution.

The Transport Statement does not alleviate my concerns on traffic. The Statement uses 2011Census data as the basis for much of the analysis. I understand that for travel purposes 2021Census data may be unreliable due to COVID-19 however since 2011 travel habits have greatlychanged. The availability of public transport in the area has worsened. Even in the last year amultitude of services were cut from local buses. This results in an increased use of cars. Theanalysis and conclusions in the Transport Sattement are not based on reliable data. In addition,reference is made to the previously approved 2013 application and it is stated that the traffic willactually have decreased as the proposals are no longer for a mixed use site. It is also stated thatin comparison to current use of the site the proposed development will be less trips. However thetype of trip also needs to be considered. Deliveries are more likely to use larger roads, such asFishponds Road, whereas residential vehicles are more likely to cut through and speed around thesmaller neighbouring roads. In addition the previous application was approved 10 years ago andthe general traffic in the area has increased during this time. These comparisons are not fair and apreviously approved application should not form the basis of approval now.

The Transport Statement table 6.36 shows traffic distribution to the neighbouring roads. Theanticipated increase in traffic towards M32 via Fishponds Road would also have an impact onneighbouring roads such as Ridgeway Road, and Stonebridge Park where drivers cut through toavoid the traffic. The knock on impacts don't appear to have been fully considered.

The Transport Statement quotes a High Court Judgement (6.3) for the case of Hawkhurst ParishCouncil v Tunbridge Wells Borough Council and uses this as a basis to pre-emptively dismissconcerns around congestion as a result of this proposed development (6.4). This is incrediblytroubling and feels deceitful. The case quoted is not comparable to the current application or areain question. Firstly the size of the development, the 43 retirement apartments in the case are in noway similar to the 2500 dwellings proposed across Atlas Place, or even the 255 in this application.

The location is also vastly different. The case quoted was in a small village, whereas the AtlasPlace development is in one of the largest UK cities, with significant existing congestion it wasrated 5th most congested City in the UK in 2023 (StressFreeCarRental.com). Fishponds is wellconnected to the M32 and the J2 Junction could be severely affected by congestion resulting fromthe Atlas Place development. Not considering the cumulative impact of the Atlas Placedevelopment as a whole and any other developments in Fishponds could have disastrous effectsto East Bristol. Surely this case cannot be used to set a precedent for how traffic concerns shouldbe treated resulting from the proposals for this development.

Design:The dwellings in the surrounding area are maximum 2 or 3 stories high houses. The flats in theproposals are not in keeping with this and will reduce light to the existing properties whilst alsocreating an imposing landscape. The height should be limited to be in line with the propertiesalready built in the roads surrounding the proposed development. In addition, this is a large site sothe properties on the periphery of the site could also be set back further to infringe less on theexisting properties on the neighbouring roads.

Due to the unaffordable nature of houses in the UK 1 bed flats will often be occupied by 2 personsand grown up children are living with their parents for longer. This means that more car parkingspaces are needed than ever before. The spaces in the plans do not seem adequate. Car parkingon the surrounding roads is already an issue and inadequate parking spaces in this developmentwould exacerbate the problem.

Impact on local services:The local doctors and dentists are already unable to cope with the amount of patients. Nurseriesand schools are oversubscribed. There is nothing in the plans to state how this will be dealt with.Will additional funding be provided to local services to allow them to extend their offering? Will newservice providers be built? Doing nothing should not be an option.

Many of these issues have been previously raised by residents as part of the engagementexercise on the Atlas Place website. It is disappointing to see in the main, that these have notbeen addressed. I am actually more concerned having now read through the plans, particularly theTransport Statement.

I do still hope these home can stop some of the antisocial behaviour and driving. Thecut through s need to be sealed off and a separate access road built for these homes.

Totally understand the need for more housing but not 200 in the middle of alreadyknown rat runs with an example being ridgeway Road neighhood surveys demonstrating anoverwhelming concern with traffic from residents. If the whole area surrounding was to become 'liveable' then sounds great but if not this is jusy going to increase the already concerning trafficthat all local councillors are aware off and have attended public meetings concerning the issue.

I don't think any consideration has been given regarding existing residents adjacent tothe planned development. Thought has not been put towards access, parking or the impactinsufficient parking on site will affect existing roads. Bus routes are not as reliable as they oncewere due to driver shortages. Thought needs to be given to the height of new builds. There are nobuildings higher than 2-3 stories currently in the locality and anything higher will impede theprivacy of nearby housing. There is currently no plans for increased doctor, dentist, nursery orschool places. All of which are stretched to capacity for the current catchment area. No discussionhas been had regarding how building works will affect the local area or how local residents will beinformed of these

255 is too many to for the local services to cope with. You will have to properly deal withthe increased demand for doctors, dentist, roads, parking, busses etc. Even the 1 bed propertiesare likely to have more than 1 person living in them so you will have to factor for more than 400extra people.Why can't you keep the building heights the same as the current buildings? Blocking sunlight fromcurrent buildings will have an adverse affect on property. Place the taller buildings where there arealready some then no one will be put out.This is just one of the sites that will be developed.

You will also have to factor proper cycle parking. Any outdoor bike rack will be like supermarketsweep for bike thrives.

The roads will need to be re designed for the extra traffics. The roundabout outside myproperty already gets clogged up and is used as a rat run to get to Kingswood and staple hill. Theadded will cause more traffic build up and more idling outside residential properties. New stationroad is already used as a rat run with a small one way system from Lidl carpark which isconstantly misused. Hockey's lane will also become congested.

Parking should not even be a necessity in a city in this day and age yet with all of these extrapeople and public transport slashed it is only going to get worse.

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:You must not support any planning application which falls below the council's own 30%

threshold for "affordable" housing. These targets exist for a reason.

I understand and support the need for more housing but the surrounding infrastructureneeds to be improved too.

My concerns for this development are as follows:

Parking for current residents of Enfield Road - I am currently able to park outside my home most ofthe time, but that is only because there are no dwellings on the other side of the road so anyvisitors or houses with 2 cars can park over there. I don't expect to park outside my house but I doexpect to park in my road. The new houses will have their own parking spaces, but any additionalvehicles could end up being parked over the road on our side meaning we can't park. We onlyhave a single car but many houses now have 2 or more. Could we have the option to drop curband park on the front of our gardens? We will then have the ability to charge electric cars.

At one of the consultation meetings we met with a transport representative who basically said 'wellyou live in a city you don't need a car'. I think the council and their representatives need tounderstand the world as it is not as they would like it to be!

My second concern is local facilities such as Doctors and Dentists - the nearby surgeryBeachwood Medical Practice and Fishponds Family Practice are already over-subscribed andstruggling to keep up with demand. Nearby dentists already don't take NHS patents.

My third concern is the increase in traffic, the large lorries will no longer come past but if each

dwelling has one car (we know it will be more like 2) that is a minimum of 200 extra vehiclesmoving through the area. The Filwood Road junction at the roundabout near New Station Road toaccess Morrison's or Aldi is a bottle neck already and will need to be widened to allow 2 way trafficflow.

My fourth concern is noise and pollution during the demolition and building phases. I work fromhome so am here all day. But the dust will cause issues with the air and potentially damagevehicles.

Fifth - interruptions to water/gas/electricity supplies as well as WiFi because I work from home andam here all day.

Sixth - Litter - the road is cleaned every three weeks by a lovely council worker who is verydiligent. In between times, I go out and litter pick myself each week, the provision of bins on theroad would help the situation.

There will be to much disruption on these roads, as traffic is always building up mosttimes of the day, 255 homes are a lot of extra people living in a small area.

I understand the need for more housing in Bristol, especially affordable housing.My concern is that the area around the proposed development is already extremely busy andthere are regular accidents at the junction between Goodneston Road and Lodge Causeway. Withso many new houses, the congestion will inevitably become unmanageable. There are simply notenough resources in the area to sustain so many new residents especially when it comes to roadusage and road safety.