My apologies, for some reason I overlooked this document - 23_03791_F-APPENDIX_B_-_STATUTORY_BIODIVERSITY_METRIC-3752787.xlsm - published on 2 September last.

However, this only shows 0.1833 ha of baseline Individual trees habitat with 0.0666 ha retained. The next entry is blank, though the user comments suggest it relates to trees.

I see that the breach of the trading rules in their calculation is caused by a shortfall of 0.11 HU of heathland and scrub habitat.

I have input my tree habitat areas into my annotated version - attached. I have also only allowed for small category trees to be used to create new habitat (as per the SM Guidance).

I have also set the strategic significance of the Individual trees habitat to High - given the express protections given to them in the Local Plan - BCS9, SADMP DM 17 & the BTRS SPD.

I have factored in the inevitable delay between the removal of the habitats and their post-development creation (I see there is no habitat enhancement proposed), at a notional two years, but you may consider that insufficient given what is proposed.

This results in a net loss of area habitat of 32.23% which is 2.00 HU short of the 10% net gain target. There is also a breach of the trading rules caused by shortfalls of 0.11 HU of Heathland and scrub habitat and 1.49 HUs of Individual trees habitat.

I have not analyzed the hedgerow habitats.

Dear Development Management - Please publish this email and the attachment on the Planning Portal.

RegardsMark

Mark CD AshdownFor Bristol Tree Forum

Looking at the comments and objections, maybe we should just leave it as a nursinghome? We have an aging population and a very challenging care system. A portion of the landcould be used for giving free housing to the nursing home staff, as we know it's very difficult,underpaid work. It could be a blueprint for future care of the old and infirm.

None of this will work under a capitalist/profit driven/market system. But nothing works anyway, sowhy not try something radical?

As residents of Greenway Bush Lane, we object to the current proposed plans as theyare insufficiently thought out and fail to demonstrate how the new homes will be properlysupported with appropriate soft infrastructure.

The lack of car parking is of serious concern. Rather than reducing the use of cars, this will simplypush cars onto already busy surrounding roads, creating a gridlock and further difficulty for thosewho already struggle to park in the area. Considering the pressure on parking on match days dueto the stadium, on Sundays due to the tobacco factory market and due cultural events andfestivals such as Upfest there is already an influx of people to the area which already makesparking a huge problem for existing residents. It is a huge oversight that no visitor parking forthese hundreds of new homes has been addressed. Any development on this site should includemultiple parking spaces per home to accommodate for families that own multiple cars or will behaving visitors.

The proposal also suggests very tall and imposing 3/4 storey town houses which are not inkeeping with the local area. A more sympathetic design should have been prioritised over thecramming in of houses to such a small space. The same goes for the large building flats: this istall, imposing, and will ruin the street scape. It's also concerning that it's going to overlook so manyproperties and even the local primary school. It will block a huge amount of light across theneighbouring streets due to such an overdevelopment of such a small space.

We're also incredibly surprised that we were not notified of the plans when they were submitted.Considering that there would be a significant impact to our road we think it's hugely remiss that we

did not receive a letter notifying us of what had been submitted. We are confident that many morelocal residents and neighbours would have much to say on the plans should they have beenappropriately notified.

Whilst we are not against the building and development of new homes, we do think it's reasonableto expect that they are considerate of the local area that is already in existence. There have beenno appropriate plans put in place to appropriately support such an influx of people in the area.

Why no health impact assessment made and/or any provisions for health mitigationrelated to this development?With the high concentration of housing it's questionable the development will have a positiveimpact on health.Imposing height of blocks D & E obstructing light for those residents on Raleigh Road andGreenway Bush Lane. Also windows overlooking school playground and properties on RaleighRoad and Greenway Bush Lane.Concern that the two new thoroughfares will create danger at entrance/exits. Despite having NoThrough Road signs will they actually be blocked?As the development is on Private and the road unadopted how will parking and No through roadsbe policed? Without the roads will be abused and become "Rat Runs" and parking will overspillonto the public roads.The site entrances/exits will create danger points if they are projecting onto the pavement andnarrowing the roads which are NOT "Main Roads" as highlighted in the Submission Pack. Theyare Side Roads. Furthermore, I see "No Entry" signs at the exits on both Raleigh Road. One isdirectly opposite another Car park entrance/exit. Totally unsuitable and dangerous. Both exitsshould be changed to entrances with exits at Greenway Bush (which is far less busier thanRaleigh).

The extra 250+ residents will add huge pressure to already over stretched Health Care, DentalCare, Social Care and Nursery/Early year Child CareThe loss of parking space will also have (as above) a detrimental effect on local society. BCC triedand failed not to issue RPZ parking permits on a nearby new re-development.

Inadequate provision for electric vehicle charging.Insufficient on site vehicle parking especially now as spaces reduced on house sites.Too many trees removed and not replaced appropriately and the overall effect on wildlife. The roofsurface of the large blocks will create areas which gulls will use creating noise etc.The effect of light pollution and noise from heat pumps.Concerns re emergency vehicle access on Sundays when Raleigh Road is closed to vehicles.What provision will be made for local residents with regards to pollution (noise, dust etc) whendemolition takes place?Concern also the effect on Sewage and water supply systems.Some of the documents on the portal are not viewable whilst S278 GA will not enlarge

I object to this planning application, we still haven't found out why no letters were sent toneighbours re this application as the lack of comments show there has not been enoughinformation to the community apart from the one day consultation at the tobacco factory a yearago, June 2023 though it is interesting to not there are more objections to the plans than those infavour . if the plans had been more widely available I'm sure there would have been a publicoutcry as to the loss of trees and shrubs especially in this area of Bristol known to be the leasttreed.

It is very difficult for a lay person to for through 5o odd revised documents to see what thechanges to the plans are especially in such a short timescale having only received a notice of thechanges on June 5th & the deadline is June 12th

I signed up to email updates from the developer nut have received nothing.

Revised plans of the side of block E on to Raleigh Road show a metal door (19) opening on toRaleigh Road but no explanation as to what it is for.

Trees.... developers have a get out clause where they can mitigate for the loss of trees in adevelopment by planting somewhere else, this doesn't seem right when at least 40 plus trees and380m of hedging will be lost on this site, made up of forsythia, Budleia, Cotoneaster, & Viburnum,all important for butterflies and bees as well as providing food for birds in the winter and nestingsites in the summer, blackbirds, dunnocks, collared doves, magpies etc all nesting at the moment.I fail to understand how the developers can state that this development will increase biodiversity

At present properties on Raleigh and Greenway bush lane look out onto trees and shrubs and willinstead look out on to the sides of 4 & 5 storey building towering over their 2 storey house and withwindows looking straight into their bedrooms and taking away daylight, sunset and for some viewsof Clifton & the suspension bridge.

Both roads have become very busy with coronation road being in the CAZ, people use Southvilleas a cut through, the shrubs etc help absorb this extra pollution and enhance and soften thestreetscape.The plans suggest land opposite 89-99 Raleigh Road is all hedging but there are 2 mature limetress not on th plans & by my eye the 2nd largest on the site.

Light pollution, will effect surrounding streets, with illuminated signs at the end off the new roads &street lighting in the development .

Parking.... due to 2 roads crossing the site the roads plus build outs will reduce parking on Raleighand greenway bush by approx 10 cars on each road. Reducing parking provision on site will makethis worse especially as RPZ only runs from 9-5 Monday to Saturday, so cars from the new estatecan park after work even if they have no permit .

The plans show access on to Raleigh Road from the estate will be right turn only, the junction ofRaleigh Road and North street is already a very difficult, dangerous and busy junction & access isrestricted on Sunday due to the market.

It is sad to see how a once prestigious Bristol architectural practice has declined to alevel that they now produce this rubbish. It would be nice if they came up with a sensitive designthat responds to the local context, rather than lazily repeat the design of Wapping Wharf on everyproject.

It is clear that the approach taken by the architects was based on their own arrogant belief thatthey know best, with no regard for those who actually live in the area and will have to live with theconsequences of their actions.

I don't believe the design and access statement is a genuine record of the design process. It is asham. Had a proper process of site analysis (such as evaluating constraints and opportunities,consulting local residents etc) been followed, the proposed through road site layout would nothave emerged. The design and access statement was clearly cobbled together at the last minuteto post rationalise decisions already made by the pompous architect. It's disappointing that theother consultants have enabled this arrogant approach and sold out by trying to justify such a poordesign.

There is no excuse for removing so many existing trees and failing to meet the biodiversity netgain and tree replacement requirements. Had the architects cared, they could have embraced theexisting greenery and incorporated the existing trees, rather than plow through existing habitatswith new roads that nobody wants.

Likewise, the proposed works to highways are the kind of interventions you'd expect to see where

access to existing streets needs to be managed due to changing circumstances. To include suchmeasures on a brand new project, which is essentially a clean slate, is a joke. The architectsshould be embarrassed that they have created a problem which the traffic consultant has to thenfix with ugly build outs and signage. I fail to see any convincing justification for the two newthrough roads to counter such strong local objection. Presumably the justification is profit?

I can't see any evidence that the architects have any respect for the comments received fromresidents and consultees and they have stubbornly refused to accept other views may be valid.They have barely changed the design through the whole process. For example, the request fordual aspect bookend houses fronting Raleigh Road has been ignored. I'd urge to case officer toreview exactly how the design has evolved in response to comments before making a decision. Idon't believe it has.

1. From looking at the different plans the access road to blocks D and E appears to benot quite opposite the car park for some of the homes on the opposite side of Raleigh Road. Isthere research to show that a staggered entrance/exit on both sides of the road is safer or moredangerous than directly opposite?2. Again from looking at the Masterplan Strategy diagram it is difficult to ascertain how many/which of the onsite trees are being saved. Where block E is being sited there are several maturetrees which would soften the impact block E will make on local residents. Design strategy 2.2 onlyappears to only save trees on the north side of the development. Those shown on the south sideappear to be on Aldi's land.3. Block E is much nearer Raleigh Rd than Block D to Greenway Bush due to the children'splayground area. Is there really enough land between Block E and Raleigh Rd for hedging andtrees to be able to grow healthily?4. The revised plans have not addressed the pressure of 106 new homes and the impact onparking locally. There is too little provision for vehicle parking onsite. Both Greenway Bush andRaleigh Rd will lose parking spaces with the formation of the new roads. It was suggested thatBCC would not offer on street parking permits. What guarantee is there that this will happen? Yousay 'not envisaged' 2.10 but that is not good enough. It needs to be precise and clear when peopleare buying or renting.5. The illustrations in the documentation show a variety of Southville and Chessel streets includingthe larger and taller homes of Greville and Stackpool Roads but not the small 2 storey homes thatare on Raleigh Road that will be facing these taller homes and blocks.Design 2, 2.7 illustration shows large windows overlooking Raleigh Rd ('Block E to Raleigh Road,10 windows some paired and full storey in height'). Are such large windows fair on residents living

opposite in private 2 storey homes?6. Vehicle Access 2.9. When did Vectos undertake their survey?A road survey van was taking a survey in Raleigh Road the morning of 04/04/2024. This was theEaster holidays, therefore no school traffic with cars pulling in to let children out. Less peoplegoing to work or working locally as people/families away on holiday. Generally, a particularly quietday!7. Have you considered the impact of the new street lights, apartment lights (from the largewindows) on the homes facing the new development? Or the impact of cars exiting/entering thedevelopment at night, throughout the winter on existing residents opposite the new roads? Whatwill the impact of all this extra light have on the birds, bats and other wildlife locally?

It is not clear what has changed in the revised plans. The concerns I have seen fromother objections appear to remain, namely...

1) the imposing height of blocks d and e overlooking the school playground and obstructing viewsand light for neighbours on raleigh and lime road

2) the significant risk of two new through roads in a busy school area that will encourage drivers tocut through, in particular where cars are turning out onto greenway bush lane and Raleigh road atpick up and drop off times

3) the pressure the additional 106 homes and estimated 250 extra residents will have on thealready stretched local parking and also impact on primary healthcare as noted by the recentlyposted nhs comment

I note the cover letter from Savills to BCC was dated 23/05/24 with the UpdatedSubmission Pack. The submissions within were on the Planning Application Documents web pagethe next day (24/05/24).However the letter to local residents alerting us to the comments deadline (12/06/24) was dated29/05/24 and physically received on 05/06/24.Upon looking at the list of all new documents there are FIFTY TWO.Developers first local residents way way down the bottom of the pile.

Although the decision is still pending and the revised plans were submitted onlyrecently, it seems that demolition preparations have already begun. Various types of demolitionequipment are being delivered to the premises regularly.

This application was discussed at the groups meeting on 16/4.

We are objecting to this application on the following grounds.

- The flats will overlook and block out the light from the school playground. This could beconsidered a safeguarding issue for the children as they can be overlooked and observed. Andmay also be considered as a loss of amenity, given that the shading effect will make theplayground unusable when there is a frost, as ice will remain covering the ground well into theschool hours.

- Too little provision for electric vehicle charging to reduce pollution via petrol/diesel engines.

- Too little provision for vehicle parking, given the nature of the properties proposed. Whilst webelieve it is laudable to attempt to reduce traffic this will not happen until other provision is in placeand we cannot see this being the case, indeed our local public transport system is getting worse.

- Removal of well developed trees is being proposed and these are not being replaced with similarsized trees or in the required x3 quantities. We would like the developer to redraft the plans toavoid removing the trees and damaging the local biodiversity.

- Sustainability issues relating to materials used do not seem to be featured in the application. Thismust be considered.

As a Bristolian looking to buy her first home and a long term resident in BS3 fed up ofpaying a sickening anount of rent to greedy landlords, these new homes look great and Ipersonally would love to live in and own one of them.

Can this area cope with another development of this intensity? Can Raleigh Road copewith 2 new roads opening onto it? Drivers often pay no heed to 20mph as they see the road isclear ahead! 2 new roads will also create a loss of available parking on Raleigh Road forresidents, workers at the Tobacco Factory and other local businesses who have parking permits,putting pressure on other streets. There is very little parking available most of the time and once acar is moved a few minutes later a new one arrives. Interesting to note that when the consultationat the Tobacco Factory took place The Hill team parked in Amerind presumably as parking wastight. Although in a RPZ the street is used after 5pm by people attending theatre, restaurants andbars. With every good will most people love their cars. They may travel on fine days on foot,scooter or bus but will have a car for inclement and weekend trips away. There is not enoughparking available for residents and visitors on this site. What guarantee is there that residents inthis complex will not be offered RPZ permits? BCC broke this promise before when another sitewas developed.Many families walk from home or Aldi car park down Raleigh Road to drop/pick up their children atthe local school. The density of this site will increase hazards as Raleigh Road becomes evenbusier.On waste days the vehicle queue can back up in both directions with vehicles attempting to cut upthe side roads.The plan is of course to make money and be cost effective. Such a shame that the new homes arenot facing the homes already on Raleigh Road and Greenway Bush Lane which would be inkeeping with the area. Also that one area was not developed for sheltered housing for seniors toprovide a diverse community.The two large blocks appear to have flat roofs from the meetings attended. We have a gull and

pigeon population who will love these roofs. They already nest and breed on available spaces.What will be done to combat this problem?One block will overshadow the school playground. Both will look down on homes.The mature trees and the habitat they provide will be lost when they are cut down and dug up forease of building. Even with replanting the biodiversity of the site will take time to re-establish in anarea lacking hedges and trees.

ObjectionFirstly, lack of planning notices locally and no communications with residents (ie leaflets thru'doors). Documents "unavailable for viewing at this time" on BCC Planning app website doesn'texactly help either.Blocks overlooking school and St John are too high and the prospect of windows looking onto aplayground are questionable. Five storey townhouses are not appropriate for the location.I'm concerned about the air quality/noise and parking issues whilst the work is intended to becarried out.Parking for local residents within the RPZ in Greenway Bush and Raleigh Roads WILL be affecteddespite what the ridiculous so called survey suggested: that was complete nonsense as anyoneactually living in the area will confirm. There will be loads more than the 100 cars mooted. Newinner city projects should be looking at non car owners not increasing them.The roads through the development must not connect but be blocked stopping so called Rat Runs.Ideally blocked at the Raleigh Road side (not Greenway) as Raleigh is narrower and much busier.They should be maintained by BCC and not become Private Roads as in effect this will bring aGated Community to the area.The loss of trees/hedging will have a serious effect on wildlife. Imperative the retention &enhancement of boundary vegetation is accomplished as Southville has the fewest amount oftrees in any area of Bristol.The whole aspect of the disposal of this land by the previous owners was questionably devious. Isincerely hope this vein is not extended.

Firstly, despite public consultation from the developer in 2023, many in the communityare not aware of the deadline for comments on this application is March 20th due to lack ofnotices, there are 2, one on Raleigh Road and one on Greenway Bush Lane, neither of which arevery visible to the passer by. There were no letters to local residents, but if this is not a councilpolicy anymore more ,then there should be more notices on lampposts.

Streetscape. I object to the loss of 61 mature trees and 380m of mixed hedging. The number oftrees on the developers plans is inaccurate, there are 2 mature lime trees opposite 93-99 RaleighRoad, this H6 on the plans is said to be solely hedgerow, but along with the 2 lime trees there are31 leylandii trees with substantial trunks which sustain many birds, housing nests for dunnocks,blackbirds and collared doves. The tree report carried out in March 2023 and the ArboriculturalImpact Statement suggests the hedgerows are made up of, Viburnum, Cotoneaster, Budleia andforsythia, these are all important plants for butterflies, bees and birds and yet the hedging is notconsidered to meet the Habitat of Principal importance and can therefore be removed. Thedeveloper states that they would 'retain and enhance boundary vegetation where possible', how isthis so if they are removing 380m of hedging. With the current climate crisis and pollution due tothe number of cars using both Raleigh Road and Greenway Bush Lane, the removal seems abackward step.The height of blocks D&E are to high and dense, they will overbear the school playground makingit very dark and shady and balconies will directly overlook the playground. AT present house no's89-99 Raleigh Road look out on trees and sky, with the development they will be looking at a 5storey nearly blank wall.This development does not enhance the streetscape having end walls of buildings on to both

roads. Why not enhance the roads by carrying on the current terrace housing like that on theopposite side of the road and have the taller building behind.Parking will be sorely compromised with this development. Although it is preferable for people notto have cars, for some it is essential so car ownership needs to be taken in to account. It is apolicy for the council to reduce parking allocation where possible on new developments and I seethe developer has now done so but in this situation it will be detrimental to the current residentswho already have problems parking despite the RPZ. The problems are worse after the RPZ cutoff of 5pm , this is fuelled by residents in the overcrowded streets as well as people using theTobacco Factory theatre, local amenities and parking for Ashton Gatefootball ground. Although the new houses may not be given residents permits with the 9-5 cut offthey will still be able to use their cars for work and come home in the evening and try to park. Theaccess roads to the site will result in the loss of quite a few parking spaces on both roads too.

My main objection is that the creation of 2 new roads will come at the expense ofparking spaces on both Raleigh Road and Greenway bush lane in an area where the pressure onparking is imense.The RPZ 5pm cut off is ridiculous and should be re thought if this development is given the goahead as visitors to the new residents will be fighting for spaces with local residents, football fans,theatre goers, North Street shoppers, Sunday market visitors and store holders etc.

The new roads will also create a rat run via the new road and Walter Street for people to avoid thehectic Raleigh Road/North Street junction.

I also object to the 4 storey end houses as they're too tall and the loss of trees.

The end town houses are too high and do not need to have the extra storey. They willbe imposing and add further to the 20% VSC reduction that has already been noted for my home.This reduction is described as 'minor' as it would be by someone who doesn't actually live hereand will not be affected.There are too few parking spaces for the number of dwellings. The snapshot of half an hour onone evening does not properly represent the problems we already have trying to park around here.As an example, I had to drive round the streets yesterday evening at 20.45pm for a parking space(a Wednesday with no event on at the Stadium) and at 11.30 today I had to park a couple of roadsaway. This is typical and the additional cars of new residents and their visitors will make thesituation even worse.

I'm Stunned this application is in extension of time [EOT]and no Neighbour Notification has been made (to the neighbours) as at the end of January 2024.

The bungalows on the site are under thirty years old and of a type now hard to find in this city... I'mnot convinced demolishing them is sustainable behaviour, so object.

I'm for the terraced housing in principle, and they should all have electric car chargers at the front,and 3-phase power supply to the houses from the outset whilst it's a cheap-to-install to all, not asan individual afterthought. Electric car charging is changing and needs some future-proofing now.Cars arriving here as family support vehicles rather than commuters, may well not be new andmay have legacy charging systems within them.

The statement of community involvement has clearly been completely ignored. It's very obviousfrom the D&A statement that the only significant influence is Design West, and that done in anenvironment out of local context. The confidential letter printed out so prominently does not betraylocal understanding. Just a big planning application team with only one architect present.

Blocks D& E have grown taller than in some earlier consultation exercises, are set up on a cliffrelative to the car parking for school and ambulance station, and will clearly overshadow theschool playground in winter and spring terms or terms one to four of the six-part academic year.This is at a direct cost to the primary school students in play therefore and may prevent frost orsnow clearing on cold days. I object to blocks D&E.

Cynically using the BRE daylight & Sunlight method without any shadow casts comes as normalwith these planning consultants who typically dont include the required actual shadow casts inBristol Applications.The approach Apparently seeks to bury this issue of colder or darker open space in numbers thatthe public and Planning Committees cannot relate to. Then it can be discursively dismissed. Thereis supposedly no light issue in the class-room. End of concern. Except there is a concern, theplaygrounds are well used, and that's the playground being in shade when it matters.

Blocks D & E are too tall and I'd take a row of lower houses in preference here. Other solutionsmight be possible but height needs reducing.

The transport assessment is very long and says many over-optimistic things about walking timeisochrones and similar shorter cycling times from the site. Yet it includes bridges across theharbour that do not exist and completely ignores the matter of topography in Clifton. So no you arenot going to get to Clifton Village in those times from here because there's the matter of crossingwater, major roads and Climbing 100m each journey and a good chunk of the population justcannot do that either rapidly or at all as active travel.

One of the key SCI concerns is loss of on street parking for locals. That's already under aseparate threat emanating from the schools own safeguarding concerns. But this applicationcynically throws in a little late night summer survey of one half hour on one day to imply that thereisn't a parking issue, when there clearly is at many other times. Shame on you !

Paras 3.60 and 3.61 refer."On Street Parking3.60 A site visit was undertaken on Wednesday 19 July to understand the car parking positionalong Greenway Bush Lane and Raleigh Road. An informal parking survey was undertakenbetween 2130 and 2200 to understand the demand for on street parking.3.61 The survey confirmed that there was 223m of formal parking bays which were vacant. Thisequates to spare capacity for around 38 vehicles to park. The position on Raleigh Road showedaround 18m of vacant parking spaces which equates to spare capacity of around 3 vehicles."ENDS

These results display no such "understanding" !. Very obviously these straw-pole "survey results"do not address the issue with any comprehension of the local night economy such as parking for asell-out at the tobacco factory theatre, or any knowledge of match day afternoons or evenings forRugby and Football half a mile from Ashton Gate Stadium.It's either very naïve or deliberately misleading.The demand for on street parking by locals will lead to them trying to secure a place as the SE-zone parking restriction ends at 5pm. Waves of outsiders then may well park-up, filling all theplaces before seven pm. Once saturated, spaces may later appear after a match starts assomeone not involved in that but using a local restaurant or whatever moves off and so a Raleigh

road resident may gain that place or the parking may indeed become vacant for the remainder ofthe evening. But the fact is that locals can't take these spaces on once they have had a drink orgone to bed.

Saying the survey is informal and yet concluding that there is general spare capacity in the districtis knowingly Untrue. The survey is its own little piece of unrepresentative data which may becorrect at the Summer holiday day and time of night taken. The conclusion is howeverinappropriate to the whole year and all the days within it. Perhaps it's a client pleaser insertedagainst normal better judgement.

The FACT is that there's an RPZ here , and that was installed because there was a residentsparking Problem with weekday commuters mode-shifting here, . And that did not solve theSaturday men's football issue. So the days covered were increased. But the Stadium countered bygrowing in capacity and running new evening Rugby and new Women's matches and so on. TheRPZ issue is increasing not diminishing.Rather the report shows new dangers may appear in Greenway bush lane such as refuse trucksturning through children walking between the twinned school campuses.

To conclude , I've been interested in the terraced housing solution from the outset but the twonorth-end blocks of flats are too big, and in places that prejudice the school environment. There isan issue with under provision of onsite parking spilling over into conflict with the neighbours.The travel assessment may include a lot of truths but in practice mislead on several fronts.Taking up road space for new entrances is going to create issues.

Dear Gemma,

I previously sent this to Nick Howell but I understand that this case is now with you.

I live near to the proposed development at and I would like to putforward some comments regarding the application.

I fully support the principle of residential development on the site and I am pleased tosee houses as the predominant building type.

I share the Civic Society's view that the development should 'face' Raleigh Road andnot sit sideways to it. The appearance of side/rear elevations will not contributepositively to the streetscape.

Increasing pedestrian routes between Raleigh Road and Greenway Bush Lane byallowing foot traffic through the development is welcomed, but I strongly feel thatvehicular access into the development should be from Greenway Bush Lane only (it is aquieter and wider road).

I have sketched both of these ideas onto the applicant's proposed site plan (seeattached).

Regards,

Summary

Bristol Civic Society supports the development of this site for housing and welcomes the proposalto include large houses in terraces, a form of development so characteristic of Southville. It isrefreshing that this is an application which is not just for a lot of small flats.

However, the density of the proposed development, 76dph, is much lower than would be expectedon an inner urban site. The proposed layout is focused on two new streets running betweenRaleigh Road and Greenway Bush Lane but fails to address these two existing streets. The 5-storey blocks of flats proposed along the northeastern side of the site are too high and too close tothe boundary; they have an adverse effect on the adjoining school playground and prejudicepotential development of both the school and neighbouring St Johns Ambulance sites.

We consider that it is possible to adjust the layout to overcome the above deficiencies by replacingthe two blocks of flats with a further terrace of houses and 'bookending' all the terraces of houseswith flats that turn the corners and face onto the existing streets, raising the density to 100dph andso complying with Bristol planning density policy and guidance.

ReviewWe are glad to see that the application is for residential dwellings (C3) and would emphasise thatany approval refers to the 'C3' designation so that the dwellings are kept as family accommodationand cannot be used as HMO's.

The application proposes 54 houses and 52 flats/maisonettes, a total of 106 dwellings on a 1.4hasite which produces a density of 76dph. 32 flats/maisonettes would be 'affordable', a ratio of30.2% of the total number of dwellings. BCC Core Strategy policy BCS20, Re-use of PreviouslyDeveloped Land, stipulates a minimum density of 50dph, the diagram on page 121 of the CoreStrategy document suggests that 85dph would be an appropriate density for Southville.Subsequent planning guidance set out in the Urban Living SPD suggests 100dph for outer urbanareas and 120dph for urban settings. Draft Local Plan policy UL2 suggests the minimum densityfor inner urban areas should be 100dph. Application of these density standards to this siteproduces figures of 1.4 x 85 = 119 dwellings, 1.4 x 100 = 140 dwellings and 1.4 x 120 = 168dwellings, all well above the 106 proposed in the application. The minimum number of proposeddwellings should be 140 to achieve a density of 100dph in conformance with policies BCS20 andUL2, and therefore use this brownfield site to its fullest potential and not be profligate in the use ofland.

Although the new tree lined streets, with dwellings each side, is supported, the proposed layoutfails to satisfactorily address both Raleigh Road and Greenway Bush Lane; there should be 'activefrontage' onto these two streets - houses and/or flats with front doors facing the street. The streetelevation drawings show virtually windowless 4--storey side walls of houses facing both streets.

The site section drawings do not show the 2m high retaining wall that runs along the northeastboundary. The retaining wall will make the two blocks of flats appear from the adjoining sites as sixstoreys high. It is a serious concern that these overbearing blocks will overshadow and overlookthe school playground. During school terms one to four, September through Christmas and on toEaster, when days are short and the sun low, the playground must be available for use. With nodirect sun, frost is less likely to clear from the ground-surfacing. The Daylight and Sunlight Studyacknowledges that overshadowing will cause a reduction in sunlight falling on the schoolplayground on 21 March but gives no indication of the effect that these blocks will have onmidwinter sunlight and what area of the playground could be in shade, covered in frost andtherefore unusable.The grey area drawn on the proposed site plan is misleading and makes the site look larger than itis. The grey area extends over the northeast boundary approximately 5m beyond the red line siteboundary. The two 5-storey blocks of flats, Blocks D and E, are 9m and 6m respectively from thesite boundary. There are windows/balconies/access decks directly overlooking the adjoining sites.These blocks are too close to the boundary and severely affect the potential of future developmenton the adjoining sites.The Statement of Community Involvement suggests that the greatest concern of local residents isparking. The Transport Assessment confirms that 13 existing on-street spaces on Raleigh Roadand Greenway Bush Lane would be lost as a result of the proposed development, which can onlyexacerbate the local resident's concerns.The application proposes the provision of 66 parking spaces for the houses and 20 for the flats,ratios of 1.22% and 0.38% respectively or 0.81% overall. In addition, the Transport Assessmentstates that future residents of the development would not be eligible for RPZ parking permits. A

better provision for the flats and maisonettes would be 0.5 spaces per dwelling so potentialresidents, such as taxi drivers and peripatetic care workers, who rely on cars for their employment,are not excluded from living in this development. Looking to the future we would suggest thatelectric vehicle charging points are incorporated into the bike/bin store in front of each house.To overcome the deficiencies set out above, we suggest that Blocks D and E are replaced by aterrace of houses along the north side of the northern street with flats and maisonettes attached ateach end, configured into L-shaped blocks facing Raleigh Road and Greenway Bush Lane.Similarly, houses at the end of the other three terraces would be replaced with L-shaped blocks offlats and maisonettes facing Raleigh Road and Greenway Bush Lane. The sizes and design of thehouses and their rear gardens would be identical to those illustrated in the application. Each L-shaped block of flats/maisonettes could include 4no. 1b/2p flats, 1no. 2b/3p flat, 3no. 2b/4p flats,1no. 3b/4p flat and 1no. 3b/5p flat, plus 1no. 3b/5p maisonette, all dual-aspect, arranged overthree floors plus an attic floor, with bin and bike stores at ground level. This reconfiguration of thesite layout would accommodate 52 houses and 88 flats/maisonettes, 140 dwellings in total, at adensity of 100dph, with 60 parking places for the houses and 45 parking spaces for theflats/maisonettes at ratios of 1.15% and 0.51% respectively or 0.75% overall. Four of the blocks offlats/maisonettes could be 'affordable', making the affordable provision 31.4%. The terrace on thenorth side of northern street would be 3/4 storeys high with windows 11m from the boundary,which would reduce the overshadowing and overlooking of the adjacent sites to an acceptablelevel and remove any adverse effect on potential development of these sites.

Dear OfficersAs residents of ** Exeter Road, Southville, we welcome the opportunity to comment on theemerging plans for residential development of 106 new dwellings at the former Amerind NursingHome site on Raleigh Road (Application Ref: 23/03791/F) .Firstly, we would like to put on record our support for residential development in this location. Thecontribution the proposals would make to the wider housing stock in Bristol is not insignificant andwould represent an effective re-use of previously developed land. We do though have 3 principleconcerns;- Impact on the local highway network, specifically existing residential parking- The height of the 5 storey town houses- The loss of treesTaking each one in turn;Impact on highway networkThe proposed development would provide a total of 86 off-street car parking spaces, which whenconsidered against the adopted parking standards set out in Appendix 2 of the adopted SiteAllocations and Development Management Policies SPD falls some way short of beingappropriate.It is acknowledged that the adopted parking standards are a maximum target, but when youconsider the following proposed unit typologies, the maximum target provision would be 143parking spaces;- 18no. 1 bedroom units; - 1 space per unit- 27no. 2 bedroom units; - 1.25 spaces per unit- 42no. 3 bedroom units; - 1.5 spaces per unit

- 13no. 4 bedroom units; - 1.5 spaces per unit- 6no. 5 bedroom units - 1.5 spaces per unitIn the context of residential development for up to 280 people of driving age, 86 off-street carparking spaces simply isn't enough. National and local planning policies rightly encourage a moveaway from the reliance on the private car but there needs to be an element of realism here andconsideration for the existing residents in the surrounding area. The shortfall of off-street parkingwill only serve to exacerbate what is already a very problematic parking situation in Southville,even with the introduction of Resident Parking Zones and access to more sustainable modes oftravel.We would like to understand more about what additional measures the applicant proposes tomitigate further on-street parking issues in Southville and request that these measures areconditioned to the grant of planning consent.Design (Height of proposed buildings)The design of the proposed development clearly takes its cues from the surrounding residentialcontext with a simplified form and material palette. That said, the plot sizes are generous which isa departure from the density of the existing urban fabric in Southville.This does leave the question whether the required number of units could be met without extendingup to 5 storeys in height. The proposed 5 storey townhouses are not appropriate to the locationand if the proposals really are to respond positively to the surrounding character and appearanceof the area then they should be reduced to four, and the unit numbers met by increasing thedensity of this brownfield site.The site is bound to the north by the 3 storey Ashton Gate Primary School and to the south by the4 storey Tobacco Factory building - neither of which are residential uses. The height of the 5storey townhouses would compete with these attractive landmark buildings when instead theyshould allow them to 'bookend' and frame the site.For the reasons above, it is our view that the 5 storey townhouses conflict with Policy BCS11(Quality Urban Design) which requires new proposals to 'contribute positively to an area'scharacter and identity, creating or reinforcing local distinctiveness'.Loss of TreesThe submitted Biodiversity Net Gain (BNG) statement confirms that the proposed developmentwould result in a net gain in biodiversity of 21.40%. This is well in excess of the 10% minimumexpectation and a real positive to the scheme.However it is disappointing to note that a significant number of trees will be lost to facilitate theproposed development and we question whether this is really necessary given the size of the siteand the layout of the scheme. The contribution that trees make to local biodiversity, the quality ofpublic realm and adapting to climate change should not be underestimated. Trees bring beauty,wildlife and a range of essential benefits to urban areas. They clean our air, shade our pavementsand improve our health and wellbeing.As previously developed land with little existing biodiversity on site, this does rather feel like anopportunity lost to incorporate existing green infrastructure into the design of the scheme. It will bedecades before the replacement trees reach maturity. The retention of existing trees would be afar better solution and would help retain a sense of place in a heavily urbanised environment.

Whilst the proposed development provides an overall net gain in trees on site, this falls short of therequired replacement ratio of 2:1 set out by policy BCS9 (Green Infrastructure) of the local plan. Ifthe proposed tree loss really is necessary, we would ask the applicant to review additionalopportunities for tree planting to really enhance the public realm, improve health and wellbeing,and ultimately reduce the impacts of pollution.As a final point, we would like to put on record our thanks to the applicant and design team fortheir extensive community engagement to date. With that in mind, we hope that issues raisedabove are taken into account and we look forward to hearing how they will be addressed.

Dear Officers,As residents of Exeter Road, Southville, we welcome the opportunity to comment on the emergingplans for residential development of 106 new dwellings at the former Amerind Nursing Home siteon Raleigh Road (Application Ref: 23/03791/F) .

Firstly, we would like to put on record our support for residential development in this location. Thecontribution the proposals would make to the wider housing stock in Bristol is not insignificant andwould represent an effective re-use of previously developed land. We do though have 3 principleconcerns;- Impact on the local highway network, specifically existing residential parking- The height of the 5 storey town houses- The loss of treesTaking each one in turn;

Impact on highway networkThe proposed development would provide a total of 86 off-street car parking spaces, which whenconsidered against the adopted parking standards set out in Appendix 2 of the adopted SiteAllocations and Development Management Policies SPD falls some way short of beingappropriate.It is acknowledged that the adopted parking standards are a maximum target, but when youconsider the following proposed unit typologies, the maximum target provision would be 143parking spaces;

- 18no. 1 bedroom units; - 1 space per unit- 27no. 2 bedroom units; - 1.25 spaces per unit- 42no. 3 bedroom units; - 1.5 spaces per unit- 13no. 4 bedroom units; - 1.5 spaces per unit- 6no. 5 bedroom units - 1.5 spaces per unitIn the context of residential development for up to 280 people of driving age, 86 off-street carparking spaces simply isn't enough. National and local planning policies rightly encourage a moveaway from the reliance on the private car but there needs to be an element of realism here andconsideration for the existing residents in the surrounding area. The shortfall of off-street parkingwill only serve to exacerbate what is already a very problematic parking situation in Southville,even with the introduction of Resident Parking Zones and access to more sustainable modes oftravel.We would like to understand more about what additional measures the applicant proposes tomitigate further on-street parking issues in Southville and request that these measures areconditioned to the grant of planning consent.

Design (Height of proposed buildings)The design of the proposed development clearly takes its cues from the surrounding residentialcontext with a simplified form and material palette. That said, the plot sizes are generous which isa departure from the density of the existing urban fabric in Southville.This does leave the question whether the required number of units could be met without extendingup to 5 storeys in height. The proposed 5 storey townhouses are not appropriate to the locationand if the proposals really are to respond positively to the surrounding character and appearanceof the area then they should be reduced to four, and the unit numbers met by increasing thedensity of this brownfield site.The site is bound to the north by the 3 storey Ashton Gate Primary School and to the south by the4 storey Tobacco Factory building - neither of which are residential uses. The height of the 5storey townhouses would compete with these attractive landmark buildings when instead theyshould allow them to 'bookend' and frame the site.For the reasons above, it is our view that the 5 storey townhouses conflict with Policy BCS11(Quality Urban Design) which requires new proposals to 'contribute positively to an area'scharacter and identity, creating or reinforcing local distinctiveness'.

Loss of TreesThe submitted Biodiversity Net Gain (BNG) statement confirms that the proposed developmentwould result in a net gain in biodiversity of 21.40%. This is well in excess of the 10% minimumexpectation and a real positive to the scheme.However it is disappointing to note that a significant number of trees will be lost to facilitate theproposed development and we question whether this is really necessary given the size of the siteand the layout of the scheme. The contribution that trees make to local biodiversity, the quality of

public realm and adapting to climate change should not be underestimated. Trees bring beauty,wildlife and a range of essential benefits to urban areas. They clean our air, shade our pavementsand improve our health and wellbeing.As previously developed land with little existing biodiversity on site, this does rather feel like anopportunity lost to incorporate existing green infrastructure into the design of the scheme. It will bedecades before the replacement trees reach maturity. The retention of existing trees would be afar better solution and would help retain a sense of place in a heavily urbanised environment.Whilst the proposed development provides an overall net gain in trees on site, this falls short of therequired replacement ratio of 2:1 set out by policy BCS9 (Green Infrastructure) of the local plan. Ifthe proposed tree loss really is necessary, we would ask the applicant to review additionalopportunities for tree planting to really enhance the public realm, improve health and wellbeing,and ultimately reduce the impacts of pollution.As a final point, we would like to put on record our thanks to the applicant and design team fortheir extensive community engagement to date. With that in mind, we hope that issues raisedabove are taken into account and we look forward to hearing how they will be addressed.