BTF Further Comments - 05 March 2024

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In light of this, these trees will be the responsibility of the Bristol City Council as the Highway

Authority to plant and maintain, and so fall to be compensated under the Bristol Tree

Replacement Standard (BTRS) so that only 20 of the 38 trees proposed will be the responsibility

of the applicant to plant.

Given the conditions, and assuming that it is even possible to plant eight of these proposed

trees on a National Highway - the A370 - all 18 trees will have to be planted in tree pits in hard

standing. Under BTRS, trees planted in hard standing are charged at £3,318.88 per tree. On this

basis, the cost will be £59,739.84. However, this figure is indexed to the date of payment using

this formula:

BTF Further Comments - 05 March 2024

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As of today’s date, this would be £91,870.06 at £5.103.89 per tree, where ‘B’ in the above

formula is taken from the ONS RPI All Items Index (Jan 1987=100).3 However, this value is likely

to change between now and any payment being made.

The obligation to plant these trees as proposed and to make this payment under BTRS needs to

be made a condition of any grant should this application be approved.

3 https://www.ons.gov.uk/economy/inflationandpriceindices/timeseries/chaw/mm23

BTF Comments - 04 March 2024

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under the recently mandated biodiversity gain requirements,5 then their value would be

significantly greater than when we last commented in August 2022.

Applying the Statutory Metric,6 these 11 trees formed an Urban Individual trees habitat covering

an area of 0.1630 hectares. The habitat was in Poor condition but had a High strategic

significance. This table sets out our calculation, which is based on the original arboricultural

survey:7

Taking into account the 38 trees which are proposed to be planted on site (though, as 18 are

outside the redline boundary and will be, in fact, street trees on the public highway, they are

offsite habitat), we calculate that a further 25 ‘Small’ category Individual trees would need to

be planted elsewhere in order to comply with Rule 1 of the Statutory Metric - the trading rules

of this biodiversity metric must be followed. This states that lost medium distinctiveness

habitats, such as Individual trees, must be replaced with the same broad habitat or any higher

distinctiveness habitat. We have assumed that all the trees being planted will be achieve

moderate condition and have high strategic significance, and that they will be planted in Bristol

four years after the original trees were removed and have habitat area of 0.2547 hectares after

30+ years. We have left the other habitat designations and parameters unchanged.

As the trading rules only apply up to the point of no net loss (of that habitat), once the trading

rules have been met, biodiversity gain requirements may be met by the creation and/or

enhancement of any other habitat, provided it is within the relevant module – area or linear

habitats.

Even on this basis, the proposals still only achieve a total area net gain of 0.80%, which is well

below the 10% minimum now required under the recently mandated biodiversity gain

requirements.

5 https://www.gov.uk/guidance/biodiversity-net-gain. This came into force on 12 February 2024. 6 https://assets.publishing.service.gov.uk/media/65c60e0514b83c000ca715f3/The_Statutory_Biodiversity_Metric_-_User_Guide_.pdf 7 21_06878_F-TREE_SURVEY-3117556

Six of the street trees that formed part of the compensation for trees felled during thehasty site demolition/clearance have been removed from the resubmitted landscape drawings.Two have been removed from the York Road frontage and four are now omitted from the MeadStreet frontage.There is no explanation that I have been able to see for the removal from the proposed of thesetrees nor where the compensation value they could have contributed will be made elsewhere.As such the claims for the required BNG enhancement are invalid.

TRESA has serious concerns about the recently available Affordable Housing Mixreport which states: "The preferred strategy of the Applicant is that Block C would be transferred toa Registered Provider. This is dependent on the overall funding strategy of the development andthe potential occupier. Block C contains 69 dwellings. 44 of these dwellings (20% of the total 221dwellings) would be secured as affordable housing within the Section 106 (following theagreement of the proposed changes sought via the Deed of Variation). It is anticipated that theremaining 25 dwellings would be let by the Registered Provider as 'additional' affordable homes,which are not secured by the Section 106 (as amended by the Deed of Variation) or by planningcondition."AFFORDABLE HOUSING PROVISION. The percentage of secured affordable housing (20%) hasreduced significantly from what was agreed in the previously consented scheme (30%). Theprovision of affordable housing was a key factor influencing councillors to approve the previousscheme despite the officer's recommendation for refusal on numerous grounds. This reduction inaffordable housing is unacceptable.The applicant proposes that Block C would be transferred to a registered provider and that all theaffordable housing would be within Block C.Block C was problematic when the previous scheme was approved, including serious concernsabout fire safety. Fire safety has improved, but it is noticeable that the design of Block C continuesto be inferior to Blocks A and B. In separating Block C from Blocks A and B, there will beghettoisation of the affordable housing residents who will be living in the 'inferior' block.

AMENITY SPACE. The applicant states: "All units will have access to a private balcony, internalcommunal private amenity space and communal outdoor amenity space." As far as we can tell,this is not true.We can find no "internal communal private amenity space" for Block C, although there are two"private internal community spaces" either side of the entrance foyer for Blocks A and B.Residents in Blocks A and B will have access to a roof garden. There is no roof garden forresidents in Block C.Residents in Blocks A and B will have access to a ground floor, enclosed private courtyard. BlockC residents will not have access to any private ground floor open space, but will have access tothe public open space, which has been reduced in size (with the potential for increased windchannelling), will be a thoroughfare for the general public, and into which the majority of thecommercial and residential bin stores open (all of the bins for Block B and Block C).It is also worth noting that 44 (64%) of the flats in Block C are proposed to be 2-bedroomed flatsfor 3 people, which may well be flats in which children live. These children will not have access togood quality, safe amenity space within the development.

The initial application was unsuitable & should have been refused, but this one is evenworse - horrendous lack of affordability & what happened to the 'community building' - oh, youknow, just drop 3 bed flats, we'll make more off 1 bed ones. Simply dreadful and, as before, notsomething that will properly benefit the locality or the wider city.YOU DO NOT NEED TO BE BEHOLDEN TO PROFIT FOCUSED DEVELEOPERS - DOBETTER!

BRISTOL CIVIC SOCIETY'S RESPONSE TO THE S73 APPLICATION FOR MEADSTREET.

23/04650/X | Application for variation of Condition Nos. 39 (Landscaping (Tree Planting) works),45 (Use Class Restriction) and 50 (List of approved plans) following grant of planning permission21/06878/F Mixed-use redevelopment including 221 residential (C3) units and 651 sq.m. ofcommercial floorspace (Class E) on ground floor, together with a new vehicular access off MeadStreet, cycle and car parking provision, private amenity space, servicing arrangements,landscaping, public realm, and associated works. | Land At Corner Of York Road And St LukesRoad Bedminster Bristol BS3 4AD

Summary.

Bristol Civic Society objects strongly to this application. The Society objected to the application21/06878/F which was approved despite the officers' recommendation for refusal. Our objections(appended below) related to the height and massing of the proposal, the impact of these onimportant views particularly those towards the Totterdown escarpment and quality of life issues.We consider that the changes proposed would have a more adverse effect on the quality of lifewithout reducing the adverse impact on views. Affordable housing provision was part of thebalance of considerations in the approval of the last application. The Society supported this aspect

of the proposal, notwithstanding our overall objection, in the event that the Council approved it.We, therefore, object to the reduction of the proportion of affordable housing from 30% to 20% ofthe total units. We note also the increase in the number of one and two bedroom flats and thedeletion of most of the three bedroom flats which diminishes the residential offer and the potentialfor community building. In view of these changes to the original application together withfloorspace changes and changes in the footprint of the development, the Society requests thatofficers carefully consider whether the application is a valid s.73 application. In any case, if theapplication proceeds, it should be considered by Members at a Development ManagementCommittee so that all the issues raised by the proposal can be considered transparently. Thiswould help reassure the local community that their concerns have been taken seriously.

Main changes to the proposal arising from 23/04650/X.

There have been a number of changes to the footprint of the development as follows:

The footprint of blocks A and B was 1,685sqm now proposed 1,853sqm, an increase of 168sqm or9.97%.The footprint of blocks C was 769sqm now proposed 806sqm, an increase of 37sqm or 4.81%.Combined footprints of blocks A, B and C was 2,454sqm now proposed 2,659sqm, an increase of205sqm or 8.35%.

Width across courtyard was 18m now proposed 16.9m.Width between blocks B and C was 18.0m now proposed 16.2m.

York Road pavement width reduced by 0.4m in front of blocks A and B.York Road pavement width reduced by 0.6m in front of block C.

The effect of this is to reduce the amount of ground level open space between the buildings and inthe three-sided courtyard area. Overlooking from one flat to another would also be exacerbated.The Society feels that these factors would reduce the quality of life for residents.

Although the footprint of the building has changed, the impact of the height and massing on viewshas not. The views from the north towards the Totterdown escarpment, a key city view, arecompromised by the intrusion of the tall blocks. A reduction of two or three storeys would greatlyreduce this adverse impact. The Society considers it imperative that officers require verified viewsdemonstrating the impact of the development on important views affecting the Totterdownescarpment, conservation areas and open space. Such verified views must include the full heightof the buildings.

The offer of accommodation has changed:

The proportion of one and two bed apartments has increased at the expense of most three bed

apartments.The proportion of affordable units has been reduced from 30% of the total to 20% ie. from 66 unitsto 44.The remainder of the accommodation is for private rental.

In the Society's view this will lead to a more transient group of occupants and diminish theprospects for community development. The affordable housing offer in the approved schemefeatured in the balance of considerations leading to the grant of permission.

Design changes arising from a change to a modern method of construction, using a SIBS modularsystem could adversely affect the appearance of the proposed development. It is a yet to beproven that this type of construction can avoid creating very simple aesthetics, with no depth orgrain to the elevations thus making them look flat. Bristol has a history of elegant, finely detailedbuildings with elevations of depth and character. These new buildings designs will createelevations that are bland, flat and cheap in appearance. A good example is the reduced size of thewindows in the new application and thus the poor proportion of solid to void shown on theelevations plus the horizontal jointing at each floor level makes it look like a stacked set ofportacabins. We realise that there is a cost of living crisis but this should in no way reduce theneed for good quality and characterful architecture. The National Planning Policy Framework isvery clear (paragraph 131) that the "creation of high quality, beautiful and sustainable buildingsand places is fundamental to what the planning and development process should achieve."

There is still a preponderance of single aspect flats. This would adversely affect thequality of life as would the juxtaposition and overlooking between flats, especially between livingrooms and bedrooms.

The introduction of more active uses at ground level could, depending on their nature, bebeneficial.

Although the Society does not wish to encourage car use in central Bristol the reduction of parkingprovision to just 5 disabled persons' spaces raises a number of issues. The absence of parkingspaces would discourage if not preclude people whose work is dependent on having a car such astaxi drivers and peripatetic care workers from moving to the development. This could increase thetransient nature of residents living there and exacerbate the difficulties of community developmentwe have already identified arising from the offer of accommodation. The disabled persons spacesprovided are also very inconveniently located for M4(3) flats for which they are intended. Theseissues should be resolved and could be by the reinstatement of the basement car park.

Conclusions.

The Society objects to the proposal because of the harm, set out above, that would result,particularly on the quality of life of residents and on important views. In view of the fundamental

changes proposed in the application, we ask the officers to consider carefully whether thisapplication is consistent with the requirements of a s73 application. Whether this applicationproceeds or whether it becomes an application for planning permission for a revised scheme, theSociety feels strongly that it should be considered by members at a Development ManagementCommittee to enable full public discussion of the issues it raises.

APPENDIX - The Society's submission on 21/06878/F.SummaryBristol Civic Society objects strongly to this application. The Society considers that proposals forthe loss of commercial premises should not be considered in the absence of a masterplan for thearea providing for a balanced redevelopment of the area from Bath Road to Bedminster Green.Such a plan should be adopted by the Council after full consultation with residents and otherstakeholders. The proposal itself raises a number of concerns relating to its height, the resultantquality of life for residents and its impact on views, particularly those towards the Totterdownescarpment.

Change of Use.The Society is increasingly concerned that employment generating floorspace in the St Philips andBedminster areas is being redeveloped for residential purposes in the absence of overallstrategies for these areas aiming to achieve a balance of new uses. We agree that the areas areripe for redevelopment but feel strongly that strategies to steer it should be formulated in fullconsultation with residents and other stakeholders before they are adopted by the Council. In themeantime, the Society cannot support the loss of employment generating uses on land defined inthe Local Plan as a Principal Industrial and Warehouse Area.

Height, Massing and Impact on Views.The proposed development comprises an eight storey block adjoining St Lukes Road with twoparallel eleven storey blocks. The block next to St Lukes Road is attached to the parallelEleven storey block with a five storey development. The easternmost block is free standingseparated from its neighbour by an area of public space. The Society is concerned that blocks ofthis height and mass will be harmful to views toward Richmond Street, with its colourful terracedhouses, atop the Totterdown escarpment. This is one of Bristol's important, landmark views.Equally important are views toward the Grade I Listed buildings at Temple Meads Station and thespire of St Mary Redcliffe. A full analysis of the proposals impact on views agreed with the Councilis essential before the application is considered. We are not convinced that the Visual ImpactAssessment adequately addresses these concerns.

Quality of Living Environment.The Society has a number of concerns regarding the potential living environment which wouldresult from this application. Air quality could be compromised by its location at the junction of StLukes Road and the heavily used York Road. The preponderance of single aspect flats is also a

concern. The provision of outdoor amenity space is very sparse for a development of 244dwellings. It is not clear what facilities will result from the development on-site and the site itself isnot convenient for day-to-day shopping requirements and other services. The impact of thisdevelopment on school places in the area also needs to be considered.

Affordable Housing.Notwithstanding our overall objections to this proposal, the Society is supportive of the Council'spush for affordable housing and so we would welcome 100% provision should the Council approvethis application.

here is still a preponderance of single aspect flats. This would adversely affect thequality of life as would the juxtaposition and overlooking between flats, especially between livingrooms and bedrooms.

HERITAGE, TOWNSCAPE AND VISUAL ASSESSMENT STATEMENT OFCONFORMITYThe developer does not make any effort to address issues of concern relating to heritage,townscape and visual assessment arising as a result of the proposed changes to the approvedscheme.While admitting that the proposed changes will have heritage impacts, the footprints of the blockshave increased, the blocks are wider, and the elevational treatment is revised, these are alldismissed as minor. No visualisations are provided to justify such assertions.The developer also asserts that the amended proposed development 'continues to adhere withnational and local planning policy with regard to heritage and townscape'. This statementmisrepresents issues raised in the Officer's Report objecting to the approved proposal, whichindicated that it did not adhere to national and local planning policy with regard to heritage andlandscape.BEDMINSTER CONSERVATION AREAVerified views are not provided with the current application but the increased mass of the buildingswill exacerbate breaches to national and local planning policy.Grade II listed buildings 138-142 (even) York Road are statutorily protected for their architecturaland historic character. They contribute to a long and consistent curving terrace of regular scale,character, and profile stretching along most of the length of the left bank of the New Cut.Viewpoints 'Clarence Road looking east' and 'York Road looking north-east' for the previous

scheme identified a degree of visual impact due to the height and scale of the proposeddevelopment. The increased scale and massing would appear behind the listed buildings resultingin harm to their setting.The proposed development would result in a loss of consistency of scale and character of thebroad sweep of frontages along York Road, the strength of character of York Road would beundermined by development which does not sustain the proportions and traditional grain within itssetting, and the development would be a jarring transitionThe current proposed change to a modern method of construction, using a SIBS modular system,has resulted in a significant change to the elevations of the blocks which will exacerbate theseproblems. The reduced size of the windows, the poor proportion of solid to void, and the horizontaljointing at each floor level are in sharp contrast to the character of the existing York Road terrace.TOTTERDOWN ESCARPMENT AND VIEWSThe Totterdown escarpment is identified as a key view and landmark in this character area and isa skyline feature in views east along York Road specifically. What makes this feature special is thecombination of raised topography with a line of highly characteristic terraces above and the bandof green vegetation below. Its linear quality and visibility as one moves through the city betweenTemple Meads and the Floating Harbour is a key part of its interest.The proposed development adopts a scale and building form that will block the continuity of thisview. Previous Views Analysis demonstrate it would significantly interrupt key views, in particular,the Totterdown escarpment.The Mead Street Development Brief notes the local landmark of Pylle Hill/Totterdown escarpment,with the coloured terrace of houses running along it, as a feature which adds to the local characterof the area and contributes to wayfinding and legibility in the city.The Urban Living SPD advises that a tall building should not be located where it hides or masksthe topography of the city. It is also noted that the flats score poorly against Urban living SPD,which would undermine any public benefit arising from the provision of housing, and the currentapplication significantly reduces the amount of affordable housing provided.

I wish to object to this planning application for several reasons.

1. This is submitted as amendments to a previos plan yet large parts of the plan have changed sothis should be rejected and submitted as a new application.Changes include: reduction in parking, reduction in affordable units, footprint of buildings, spacebetween building, materials used, constructio0n method, composition of flats, and light levels.

2. Scale and density - This development does not meet the local plan (either current or newversion). The density per hectare is over that specified in the plan. This density is out of characterwith the local area and the immediate street scape.

3. Low quality of living space. These are not nice places to live. Units are small and single aspect.There is insufficient light entering the flats, and the buildings are now only 13m apart whichadversely affects privacy.

4. No mixed community - This proposal is only for 1 and 2 bedroom units which does not lead tohealthy mixed communities and will likely become rental units for students.

5.Lack of affordable units. The number of affordable units has dropped below the BCC target. Thisalone shouldbe enough to reject this proposal.

Finally the original plan was rejected by planjning officers, the fire brigade, local community andeveryone else apart from the planning committee who approved it solely for the affordable units.With these affordable units beoig removed, there is no benefit to the commnity for thisdevelpoment so it should be rejected.

I am a local resident with a particular interest in this development as it is near where Ilive so I am very familiar with the location of the old Barts Spices site.

The proposed development is much too high density for this relatively small site which is boundedby two busy roads (York Road and St Lukes Road) and a currently quiet street that will struggle tocope with the associated traffic of the developments proposed for this site and others on MeadStreet.

The blocks are too high for the surrounding area and will not be pleasant places to live with thehigh levels of traffic noise and air pollution and a lot of south-facing flats that will be intolerably hotin the future hot weather predicted by climate change.

The changes to the plans that reduce the size of most flats will lead to transient tenants with nofamilies, leading to a lack of community with no sense of identity and belonging. There is a highprobability, because of the central location and nearness to Temple Meads station, that many ofthe properties will end up as Airbnb lets, with all the known problems these bring to urban areas.

The flats further along York Road (built in the latter decades of the 20th century) are a moreappropriate type of development that would fit better onto this site and would be more attractive tofamilies.

In addition, having read TRESA's detailed objections to the proposal, I am in complete agreementwith the points they make. These flats will not help to solve Bristol's housing problems and arelikely to become the slums of the future. The city of Bristol deserves better than this so I stronglyobject to this proposal.

The development has inadequate parking provision and this will lead to pressure onsurrounding streets..

There are simply too many units densely packed together with no supporting infrastructure toaccommodate the influx of residents. And there is inadequate outdoor space for them.

There is a lack of affordable housing units. The flats planned are not providing well lit or suitablydistanced private accommodation. The density and size of the flats does not promote communitybut will mean an itinerant population.

The buildings are too high and block off the view of the surrounding area and are out of characterwith the area.

I have read TRESA's detailed submission and I agree with it.

Objection.I have read TRESA's objection to the proposal and I am in complete agreement withevery point it makes. I would add that the proposed amendments seem to be setting thedevelopment up as a magnet for Air BnB investors as opposed to affordable community housingwhich is what everybody agrees is needed. The proposal even advertises the fact that it is 'for rent'and for short term living.The parking provision is not serious - 5 spaces for 221 flats. It is a deliberate pretence to suggestthat because of the proximity to the city centre, 5 spaces will somehow be adequate parking for221 flats.I object strongly to the amended proposal.

I totally understand the acute need for housing in Bristol. The development of this sitefor housing is vital. My objection is that this is poor quality housing that will fail to create a newcommunity. It is ill-thought out, poorly designed and hastily developed.

Bristol deserves better.

Specifically:

* There is very little outdoor space for residents of the development.

*The revised plans have a larger amount of flats that are now single aspect and so would have apoor outlook, receive limited light levels and require higher energy consumption. This arises fromthe overdevelopment of the site.

*Such a poor living environment for any occupiers would fail to meet liveability criteria sought byrecently approved council guidance, which seeks to achieve a liveable environment for futureoccupiers when developing at higher densities, and as a result fail to meet the requirements of theNPPF, policy BCS21 of the Core Strategy 2011, and policies DM26 and DM29 of the SiteAllocations and Development Management Policies 2014.

*The proportion of affordable housing for this proposed development is 20%. The City CouncilsPolicy BCS17: Affordable Housing Provision suggests 30% for city centre locations. This isunacceptable given that the provision of affordable housing was a key factor in the decision toignore the officer recommendation and approve the previous scheme.

*All of the 3-bedroom flats have been removed and the number of 2-bedroom flats has beenreduced. The new mix is 149 x 1-bedroom and 72 x 2-bedroom. The applicant states: "theproposed mix is more appropriate for the proposed tenure, being 'Build to Rent', where occupantswould generally live for shorter periods." This undermines the Mead Street development briefwhich aims to promote and support a new neighbourhood community.

*Limited light levels were identified as a problem with the consented scheme. Given that thecurrent scheme presented has smaller windows, and the tower blocks are closer together, this willinevitably exacerbate the problems with daylight... yet no Internal Daylighting Assessment reporthas been provided.

*The proposed buildings are bulkier and the distance between blocks has been reduced to lessthan 17 metres for single aspect flats looking directly into one another (the fire strategy documentplaces the midway boundary at 8.13 metres, giving a distance of 16.26 metres).

* In the current application, all but 5 of the car parking spaces in the basement have beenremoved. This means there is no parking allocation for the overwhelming majority of residents andvisitors, or for staff and visitors of the commercial units.

* The developers have reduced the amount of refuse area despite the same number of residentialand commercial units. The private courtyard is dominated by service entrances to bin and cyclestorage. Far from being a restful area, illustrated by developer with people on sunloungers ,thespace will be disturbed by refuse depositors and collectors, cyclists , aroma from bin storage, andfor most of the day be in heavy shade from shadowing from the high buildings and escarpment.

The councillors approved the application last time disregarding a 5000 signature petition against it,against Planning Officers recommendations, against the Police concerns of safety and securityagainst concerns of the Fire Service and the application contradicting BCC's own Local Plan andthe National Planning Policy Framework recommendations for building quality, density and livingconditions.

Here is an opportunity for the Councillors to take a breath and reevaluate.

Do not be the people that are building the slums of the future.

Instead, build new communities.

Bristol deserves better than this proposal.

I totally understand the acute need for housing in Bristol. The development of this site for housingis vital. My objection is that this is poor quality housing that will fail to create a new community. It isill-thought out, poorly designed and hastily developed.

Bristol deserves better.

Specifically:

* There is very little outdoor space for residents of the development.

*The revised plans have a larger number of flats that are now single aspect and so, would have apoor outlook, receive limited light levels and require higher energy consumption. This arises fromthe overdevelopment of the site.

*Such a poor living environment for any occupiers would fail to meet liveability criteria sought byrecently approved council guidance, which seeks to achieve a liveable environment for futureoccupiers when developing at higher densities, and as a result fail to meet the requirements of theNPPF, policy BCS21 of the Core Strategy 2011, and policies DM26 and DM29 of the SiteAllocations and Development Management Policies 2014.

*The proportion of affordable housing for this proposed development is now only 20%. The CityCouncils Policy BCS17: Affordable Housing Provision suggests 30% for city centre locations. Thisis unacceptable given that the provision of affordable housing was a key factor in the decision toignore the officer recommendation and approve the previous scheme.

*Limited light levels were identified as a problem with the consented scheme. Given that thecurrent scheme presented has smaller windows, and the tower blocks are closer together, this willinevitably exacerbate the problems with daylight... yet no Internal Daylighting Assessment reporthas been provided.

*The proposed buildings are bulkier and the distance between blocks has been reduced to lessthan 17 metres for single aspect flats looking directly into one another (the fire strategy documentplaces the midway boundary at 8.13 metres, giving a distance of 16.26 metres).

*All of the 3-bedroom flats have been removed and the number of 2-bedroom flats has beenreduced. The new mix is 149 x 1-bedroom and 72 x 2-bedroom. The applicant states: "theproposed mix is more appropriate for the proposed tenure, being 'Build to Rent', where occupantswould generally live for shorter periods." This undermines the Mead Street development briefwhich aims to promote and support a new neighbourhood community.

* In the current application, all but 5 of the car parking spaces in the basement have beenremoved. This means there is no parking allocation for the overwhelming majority of residents andvisitors, or for staff and visitors of the commercial units. Parking is already an issue in Totterdown,this revised plans' lack of parking will make the challenges far more difficult for new residents andput unacceptable, additional pressure of already limited parking.

* The developers have reduced the amount of refuse area despite the same number of residentialand commercial units. The private courtyard is dominated by service entrances to bin and cyclestorage. Far from being a restful area, illustrated by developer with people on sunloungers ,thespace will be disturbed by refuse depositors and collectors, cyclists , aroma from bin storage, andfor most of the day be in heavy shade from shadowing from the high buildings and escarpment.

The councillors approved the application last time disregarding a 5000 signature petition against it,against Planning Officers recommendations, against the Police concerns of safety and securityagainst concerns of the Fire Service and the application contradicting BCC's own Local Plan andthe National Planning Policy Framework recommendations for building quality, density and livingconditions.

Here is an opportunity for the Councillors to take a breath and reevaluate.

Do not be the people that are building the slums of the future.

Instead, build new communities.

Bristol deserves better than this proposal.

Lack of affordable housing - reduction to 20% instead of 30%

There is no parking available at all in revised plan which will cause huge issues for thesurrounding area which already lacks parking opportunities.

I strongly object to this development proposal.for the following reasons;

There is very little outdoor space for residents of the development.

*The revised plans have a larger amount of flats that are now single aspect and so would have apoor outlook, receive limited light levels and require higher energy consumption. This arises fromthe overdevelopment of the site.

*Such a poor living environment for any occupiers would fail to meet liveability criteria sought byrecently approved council guidance, which seeks to achieve a liveable environment for futureoccupiers when developing at higher densities, and as a result fail to meet the requirements of theNPPF, policy BCS21 of the Core Strategy 2011, and policies DM26 and DM29 of the SiteAllocations and Development Management Policies 2014.

*The proportion of affordable housing for this proposed development is 20%. The City CouncilsPolicy BCS17: Affordable Housing Provision suggests 30% for city centre locations. This isunacceptable given that the provision of affordable housing was a key factor in the decision toignore the officer recommendation and approve the previous scheme.

*All of the 3-bedroom flats have been removed and the number of 2-bedroom flats has been

reduced. The new mix is 149 x 1-bedroom and 72 x 2-bedroom. The applicant states: "theproposed mix is more appropriate for the proposed tenure, being 'Build to Rent', where occupantswould generally live for shorter periods." This undermines the Mead Street development briefwhich aims to promote and support a new neighbourhood community.

*Limited light levels were identified as a problem with the consented scheme. Given that thecurrent scheme presented has smaller windows, and the tower blocks are closer together, this willinevitably exacerbate the problems with daylight... yet no Internal Daylighting Assessment reporthas been provided.

*The proposed buildings are bulkier and the distance between blocks has been reduced to lessthan 17 metres for single aspect flats looking directly into one another (the fire strategy documentplaces the midway boundary at 8.13 metres, giving a distance of 16.26 metres).

* In the current application, all but 5 of the car parking spaces in the basement have beenremoved. This means there is no parking allocation for the overwhelming majority of residents andvisitors, or for staff and visitors of the commercial units.

The lack of a reasonable amount of car parking will inevitably have a detrimental impact upon theresidential streets in the area, making an already congested neighbourhood become even morechoked with vehicles.

* The developers have reduced the amount of refuse area despite the same number of residentialand commercial units. The private courtyard is dominated by service entrances to bin and cyclestorage. Far from being a restful area, illustrated by developer with people on sunloungers ,thespace will be disturbed by refuse depositors and collectors, cyclists , aroma from bin storage, andfor most of the day be in heavy shade from shadowing from the high buildings and escarpment.

There are inadequate facilities and infrastructure to support the density of housing in this area, alack of GP surgeries, transport links, car parking, schools and retail.

The councillors approved the application last time disregarding a 5000 signature petition against it,against Planning Officers recommendations, against the Police concerns of safety and securityagainst concerns of the Fire Service and the application contradicting BCC's own Local Plan andthe National Planning Policy Framework recommendations for building quality, density and livingconditions.

Here is an opportunity for the Councillors to take a breath and reevaluate. Do not be the peoplethat are building the slums of the future.Instead, build new communities.

Bristol deserves better than this proposal.

In regards to this development, I would like to quote remarks made by Michael Gove,the then Housing Secretary, on Wednesday 11th May 2022. Mr Gove was speaking in relation tothe UK's housing shortage.

Mr Gove said: "I think it is critically important that even as we seek to improve housing supply, youalso seek to build communities that people love and are proud of."It is no kind of success if, simply to hit a target, the homes that are built are shoddy, in the wrongplace, don't have the infrastructure required and are not contributing to beautiful communities."

The proposed development as it stands will be neither a community nor beautiful. No one will loveit nor be proud of it, least of all those living there.This development is about hitting a target and nothing else.Bristol, a self-proclaimed green city building developments like this? Proud? We should be utterlyashamed.

I object to the updated proposal as it increases the disbenefits to locals and eventualblock residents for the sole benefit of the developer.1. The reduction in outdoor communal space is accompanied by the removal of balconies,reducing access to the outdoors.2. The decrease in affordable housing from 30% to 20% has no justification in the current housecrisis.3. The increased focus on 1 and 2 bedroom accommodation is explicitly driven by a desire toincrease transient occupation, which will undermine the community.4. The reduction of car parking spaces from 43 to 5 will exacerbate an already acute parking andcongestion problem in the area.

These objections sit alongside my concern around the existence of the development in the firstplace, increasing the population of the area with no extra provision in services to care for thosepeople; developments that, aesthetically, diminish the area, throwing up more towerblocks; anddevelopments that do nothing to truly address the housing crisis we are in.

My comments re this development remain the same as those I submitted for the originalproposal for this site in 2022.In brief: the iconic view of Totterdown escarpment will be obstructed (eg from Temple MeadsStation, Redcliffe Hill and other public places in the city.The new plans look very similar and out of keeping with the rest of the area. Windtunnel effectbetween the blocks remains an issue.The new plans have no parking provision (the original plans show scant parking, alreadyinsufficient) which will affect delivery and maintenance of essential services & commercialdeliveries to the flats in the development.There are fewer dwellings in the new plan but the density continues to be very high and, as before,many flats have only 1 window.Even less affordable housing (in terms of numbers as well as %)

I am not opposed to new home being built on this land however I have three majorconcerns regarding the recent proposed changesto this application:

1) Almost all parking has been removed. This is absurd - most flats are likely to have 1 car, onaverage - so where will the 200+ additional cars park in the day & overnight?2 the number of "affordable" homes is being cut from 66 to 44 - this is a usual developer trick and Isuspect was their intension from the outset. If the change to modular construction, proposed in thechanges to this application will make it cheaper, then why would you need to reduce the affordableelement.3 reduction to public / green space - again ditto above, usual developer trick & likely their initialintension from the outset.

The council needs to show a backbone with these flagrant profit enhancing amendments to thisapplication and throw them out.

Traffic and parking issuesThere are no parking spaces for this development and there is no residential parking schemes inTotterdown and Victoria Park so this will have a huge impact on local neighbourhood parkingspaces. This is an already busy junction and the impact of new housing with cars anddeliveries/services to the properties will create more congestion and therefore pollution.DesignThe design, scale and massing of this development is not in keeping with the character of thesurrounding area. The other houses on York road are four stories high so it does not create asmooth line or continuation of the York Road frontage.It is an over-bearing, out-of-scale and out of character design in terms of its appearance comparedwith existing development in the vicinity. There has been no attempt in the design to match orblend with existing buildings in the area.There is very little outdoor space for residents of the development.Appearance of the developmentThis is an ugly design and is far too dense. It looks like the developer is over-developing the sitefor purposes of making money and not adding to the character or charm of the area.Loss of a view from a public viewpointThe view of the coloured houses on the escarpment can be seen from many public view pointsacross Bristol. The public view as you cross Langton Street Bridge (the banana bridge) is awelcoming site for Totterdown residents and Bristolians alike. This view has not been considered

by the developer in their 'Visual impact assessment' to highlight the effect of this development onthe visual amenity of the area.Single Aspect FlatsIn Bristol City Councils Urban Living SPD, adopted by the council in 2018 it states thatdevelopments should:Maximise opportunities to provide dual aspect units, which improve access to natural light, choiceof views and cross ventilation through units providing greater capacity to address overheating.Adopt building typologies which minimise single aspect units, such as well-designed deck-accessor mansion block typologies.The revised plans have a larger amount of flats that are now single aspect.Lack of Affordable HousingThe proportion of affordable housing for this proposed development is 20%. The City CouncilsPolicy BCS17: Affordable Housing Provision suggests 30% for city centre locations.To summarise, I think this proposed development is over dense and too high and would thereforedetract from the amenity of the local area. The view of the Totterdown Escarpment is a well-lovedfeature of this area and as such should be preserved for futures generations to enjoy.

MEAD STREET DEVELOPMENT APPLICATION OBJECTIONSThere has been considerable concern expressed regarding this proposed development throughoutthe pre-application process, and this most recent 'application' adds further to the overwhelmingconcern of many living locally that the application is ill-thought-out, poorly designed and totallyinappropriate in scale and mass for the site.

I also object and would like to raise concerns that this application references 'a series of variationsto conditions 39, 45 and 50' (list of approved plans/drawings) of the consented scheme. However,it is clear that conditions 27, 28, 29, 30, 31 and 40 are also affected, and given the substantialdifferences from the (highly contested and against officer recommendation) consented scheme,this should therefore be considered and treated as a new application.

The application submitted does not include the following important documents:- Ecological Assessment and BNG Assessment- Heritage Statement of Conformity- Internal Daylighting Assessment- Wind Assessment report- Waste storage and collection plan

HISTORY OF THE APPLICATION TO DATE

The officer report relating to the previously approved scheme recommended REFUSAL for anumber of reasons:- Poor design quality of the scheme. A high proportion of single aspect dwellings which wouldhave a poor outlook, receive limited light levels and require higher energy consumption, whicharises from the overdevelopment of the site. Such a poor living environment for any occupierswould fail to meet liveability criteria sought by recently approved council guidance, which seeks toachieve a liveable environment for future occupiers when developing at higher densities, and as aresult fail to meet the requirements of the NPPF, policy BCS21 of the Core Strategy 2011, andpolicies DM26 and DM29 of the Site Allocations and Development Management Policies 2014. Idoubt any of the developers or their families live in such 'dwellings'.- Excessive height, bulk and massing - harm to the setting of the adjacent Bedminsterconservation area, and this harm would most certainly not be outweighed by any proposed 'publicbenefits'. In view of the over development of the site the overall design quality is compromised,and the proposal fails to integrate itself positively into the city streetscape and skyline. As such theproposal fails to comply with the NPPF, policies BCS21 and BCS22 of the Core Strategy 2011 andDM26, DM27, DM28 and DM31 of Site Allocations and Development Management Policies 2014.- Unacceptable impact on highway safety given the requirements for servicing and reducedfootway widths that would be required around the site to accommodate the development. Thiswould prejudice pedestrian safety, introduce unappealing and unsafe circulation and movementfunction, contrary to the NPPF, BCS10 of the Core Strategy 2012 and DM23, DM27 and DM28 ofSite Allocations and Development Management Policies 2014.- The development would fail to mitigate its impact through contributions towards site specifichighways improvements that would benefit the growth of the city, and as such would be contrary tothe NPPF and policy BCS11 of the Core Strategy 2012.- Despite these reasons for refusal, and serious concerns in particular with regard to fire safety,the Development Control Committee were persuaded to approve the previous scheme because ofthe need for affordable housing which seems to be driving this ill thought out, hasty developmentproposal.- The requirement to address fire safety concerns resulted in the submission of a poor-qualityrevised scheme in the guise of a 'non-material amendment'. This was not accepted by theplanning officer and the developer was advised that an application which reduced the quality of thescheme was unlikely to be approved.

I cannot understand, therefore, why the developer has chosen to present a scheme, inaccuratelydescribed as 'variations to conditions', which exacerbates many of the problems of the approvedscheme in addition to reducing from 30% to 20% the proportion of affordable housing...supposedlythe reason why the previous scheme was granted approval. I view this as highly arrogant andunacceptable.

MAIN OBJECTIONS TO THE CURRENT APPLICATION- REDUCTION IN AFFORDABLE HOUSING: Reduced from 30% to 20%. This is unacceptablegiven that the provision of affordable housing was a key factor in the decision to ignore the officer

recommendation and approve the previous scheme.- ACCOMMODATION MIX: Whilst the total number of flats (221) is the same as the approvedscheme, the mix has changed. All of the 3-bedroom flats have been removed and the number of2-bedroom flats has been reduced. The new mix is 149 x 1-bedroom and 72 x 2-bedroom. Theapplicant states: "the proposed mix is more appropriate for the proposed tenure, being 'Build toRent', where occupants would generally live for shorter periods." This undermines the Mead Streetdevelopment brief which aims to promote and support a new neighbourhood community.- ACCESSIBILITY: The consented scheme indicated 98% of the dwellings will be delivered asM4(2) dwellings, and 2% of the dwellings will be delivered as M4(3) dwellings; the currentapplication retains the required 2% M4(3) dwellings but does not include any reference to M4(2)dwellings. The consented scheme included 14 parking spaces for disabled use only; the currentproposal proposes just 5 parking spaces for disabled residents only.- DAYLIGHT: Limited light levels were identified as a problem with the consented scheme. Giventhat the current scheme presented has smaller windows, and the tower blocks are closer together,this will inevitably exacerbate the problems with daylight... yet no Internal Daylighting Assessmentreport has been provided. Is there a reason for that?- POOR LIVING ENVIRONMENT: there is a high proportion of single aspect dwellings whichwould have a poor outlook, receive limited light levels and require higher energy consumption,which arises from the overdevelopment of the site.- BULK AND MASSING: The proposed buildings are bulkier and the distance between blocks hasbeen reduced to less than 17 metres for single aspect flats looking directly into one another (thefire strategy document places the midway boundary at 8.13 metres, giving a distance of 16.26metres). Balconies are less than 13 metres apart which severely compromises privacy. Theresulting canyon between Blocks B and C is about twice as tall as it is wide. Interesting again, thatno Wind Speed report has been provided. Is no-one aware of the storm damage to property,accidents and deaths occurring due to high winds this past year.- HEIGHT AND TOPOGRAPHY: As has been pointed out throughout the history of thisdevelopment proposal applications, the Urban Living supplementary planning (SPD) advises thattall buildings should not hide or mask the topography of the city. The Mead Street DevelopmentBrief notes the local landmark of the Pylle Hill escarpment, with the coloured terrace of housesrunning along it, as an important feature which adds to the local character of the area andcontributes to wayfinding and legibility in the city. The proposed height of both the approved andthe current applications will mask the topography. A new application provides an opportunity toreduce the height, enabling this important landmark to continue to be visible from key vantagepoints.- LACK OF PARKING: The approved scheme included 43 car parking spaces in the basement ofthe development - actually significantly lower provision than the maximum permitted under theCouncil's Parking Standard. In the current application, all but 5 of these spaces have beenremoved. This means there is no parking allocation for the overwhelming majority of residents andvisitors, or for staff and visitors of the commercial units.- IMPACT ON HIGHWAY SAFETY: The increased bulk of the buildings has further reduced thepavement width along York Road, which is already considered insufficient. Together with the

proposed trees, this will cause problems for pedestrian movements.- WASTE STORAGE AND COLLECTION: Arrangements for waste storage and collection havechanged. The width of the path for moving refuse bins appears to be narrower than the onepreviously deemed inadequate, and the collection area is smaller. A new waste storage andcollection plan is required to indicate how these issues will be addressed.- FIRE SAFETY AND ESCAPE ROUTES. The required two staircases per building are, at last,included in the plans. However, the location of the bin stores at ground level on either side of thecanyon is problematic when buildings are so close together. A fire in one of these stores wouldcause a lot of damage and probably spread up both blocks very swiftly. Given the history of theapplication, including the approval of an unsafe design subject to conditions, the fire safetyproposals should be carefully examined.- PLANS AND MATERIALS: There is no scale comparison on the drawings, contrary to Bristol CityCouncil submission policy. The roof profile and upper floors differ from the approved designs. It isproposed that the intermediate floors will be of modular construction, but there is insufficientinformation about the appearance. The applicant states that final selection of material finishes tobe approved on site (!!!!!). There are amendments that change the external appearance of thebuildings and, to comply with Policies BCS22 (Conservation and the Historic Environment) andDM31 (Heritage Assets), the potential effects on the setting of the Conservation Area should beassessed. No Statement of Conformity is currently available for scrutiny.

A poorly presented application, missing key reports and documentation, and inexcusably poordevelopment design creating a depressing environment for those unfortunate enough to besquashed into one of the Build to Rent properties that are not fit for purpose.

The amended proposal looks worse than the initial application and still has no provisionfor local infrastructure, support etc.

My previous comments on this application still apply and should be accepted asopposition to this amended version as a summary these include :- Inappropriate scale of building mass and height in relation to neighbouring terraces and industrialunits.- Over development of site in density and inadequate provision of useable, quality outside space.- Creation of single aspect units with insufficient natural light, demanding high energy use andneed for reflective paint.- Interruption of citywide views of an iconic landmark of the green escarpment and terracedhousesIn addition the developer has:Reduced the percentage of affordable units by one third is counter to the councillor's previousargument of support for the development. The developer 's claim of looking for 'unsecuredaffordable housing providers' carries no merit... . They are reneging on their commitment, thedevelopment should be refused permission and the council insist on 30% affordable housing aspreviously offered.

Reduced the amount of refuse area despite the same number of residential and commercial unitsReduced cycle storage in blocks A&B is not mitigated by an increase in block C.Cyclists in A&B have no internal access to storage facility, which is only accessible from outside.The omission of a basement and parking spaces on the Traffic Planner's instruction to "provide as

little as possible (parking) given the accessibility of the site by non -car modes and controlledparking in the area" ignores the pressures on the surrounding areas. Lack of parking provisiondoes not equate to reduced car ownership, car parking will be sought in surrounding streetsalready experiencing distress from commuter parking. The £221000 and £5693 payable to BCC tomitigate any impact from the low level car parking provision within the scheme is insufficient toalleviate impact .The private courtyard is dominated by service entrances to bin and cycle storage. Far from being arestful area, illustrated by developer with people on sunloungers ,the space will be disturbed byrefuse depositors and collectors, cyclists , aroma from bin storage, and for most of the day be inheavy shade from shadowing from the high buildings and escarpment .

The councillors approved the application last time disregarding a 5000 signature petition against it,against Planning Officers recommendations,against the Police concerns of safety and securityagainst concerns of the Fire Serviceand the application contradicting BCC's own Local Plan and the National Planning PolicyFramework recommendations for building quality, density and living conditions.The amended version has not addressed the concerns and objections made previously.This is the Councillors opportunity to demand Better for Bristol, to give people in desperate needfor housing somewhere they can feel proud to live and to invest in their futures.Instead of accepting a development that helps less people to afford rents, provides poor livingstandards, is a blot on the landscape, and which destroys citywide views of an ionic landmark, andsets a precedent for more anonymous, blocks of over dense housing and in between spaceslacking human scale, the councillors should refuse this application in its entirety and demandbetter .

Amenity of the AreaThe view of the coloured houses on the hill in Totterdown add to the amenity of the area. Byblocking this view and creating a wall of bricks this feature of the area will be lost forever. Thecoloured houses of Totterdown are what gives the area its charm and uniqueness.

Traffic and parking issuesThere are no parking spaces for this development and there is no residential parking schemes inTotterdown and Victoria Park so this will have a huge impact on local neighbourhood parkingspaces. This is an already busy junction and the impact of new housing with cars anddeliveries/services to the properties will create more congestion and therefore pollution.

DesignThe design, scale and massing of this development is not in keeping with the character of thesurrounding area. The other houses on York road are four stories high so it does not create asmooth line or continuation of the York Road frontage.

It is an over-bearing, out-of-scale and out of character design in terms of its appearance comparedwith existing development in the vicinity. There has been no attempt in the design to match orblend with existing buildings in the area.

There is very little outdoor space for residents of the development.

Appearance of the developmentThis is an ugly design and is far too dense. It looks like the developer is over-developing the sitefor purposes of making money and not adding to the character or charm of the area.

Loss of a view from a public viewpointThe view of the coloured houses on the escarpment can be seen from many public view pointsacross Bristol. The public view as you cross Langton Street Bridge (the banana bridge) is awelcoming site for Totterdown residents and Bristolians alike. This view has not been consideredby the developer in their 'Visual impact assessment' to highlight the effect of this development onthe visual amenity of the area.

Single Aspect FlatsIn Bristol City Councils Urban Living SPD, adopted by the council in 2018 it states thatdevelopments should:

Maximise opportunities to provide dual aspect units, which improve access to natural light, choiceof views and cross ventilation through units providing greater capacity to address overheating.Adopt building typologies which minimise single aspect units, such as well-designed deck-accessor mansion block typologies.

The revised plans have a larger amount of flats that are now single aspect.

Lack of Affordable HousingThe proportion of affordable housing for this proposed development is 20%. The City CouncilsPolicy BCS17: Affordable Housing Provision suggests 30% for city centre locations.

To summarise, I think this proposed development is over dense and too high and would thereforedetract from the amenity of the local area. The view of the Totterdown Escarpment is a well-lovedfeature of this area and as such should be preserved for futures generations to enjoy.

I objected to this development when it was first proposed on the grounds that it was tootall; too ugly; wholly out of keeping with its surroundings; add to already severe pressures of localamenities and services, esp GP surgeries and parking and that by interrupting the view ofTotterdown's coloured houses would mar an iconic part of the Bristol skyline. The same objectionsapply to this new bid for variations. In addition, the new proposal is made even more intolerable bythe removal of proper parking provision and the reduction in the % of affordable homes. The latterpoint is particularly irksome as modular builds are supposedly 15% or so cheaper than traditionalmethods so if anything there should be more homes at affordable prices, not fewer.

I object to the reduction of affordable private rented homes and especially to thereduction in parking spaces from 43 to 5 spaces. The 43 parking spaces were already inadequatefor the number of proposed flats, despite the aims of the associated transport strategy. It will placeso much more pressure on parking in Totterdown. I agree with the comments expressed byanother respondent as quoted below....:I objected to this development when it was first proposed on the grounds that it was tootall; too ugly; wholly out of keeping with its surroundings; add to already severe pressures of localamenities and services, esp GP surgeries and parking and that by interrupting the view ofTotterdown's coloured houses would mar an iconic part of the Bristol skyline. The same objectionsapply to this new bid for variations.

I have read TRESA's objection to the proposal and I am in complete agreement withevery point it makes. I would add that the proposed amendments seem to be setting thedevelopment up as a magnet for Air BnB investors as opposed to affordable community housingwhich is what everybody agrees is needed. The proposal even advertises the fact that it is 'for rent'and for short term living.The parking provision is not serious - 5 spaces for 221 flats. It is a deliberate pretence to suggestthat because of the proximity to the city centre, 5 spaces will somehow be adequate parking for221 flats.I object strongly to the amended proposal.

I object to the reduction in affordable rental flats and especially to the reduction in theavailable parking spaces. If this developer is granted this concession, it will set a precedent for theother developments planned in the Mead St development area. There is already virtually noavailable street parking in Totterdown. Agreeing the reduction in car parking spaces would make abad situation into a intolerable situation.

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:Dear Planning Department,

10 floors?! This sounds very unwise if the anticipated occupants are to be university students.

Also, the local residents will have their view seriously marred and the iconic view of Totterdown

will be marred for the foreseeable future.

The planned dwelling units themselves look like boxes of accommodation, rather than somewhere

to study safely and quietly.

If young couples are also the targeted market, how would they raise any offspring in such cramped

conditions?

There are no local shops and the nearest supermarket is some distance away.

The local GP service (Bridge View Medical) is oversubscribed as it is and getting a routine

appointment there is already very difficult.

The nearby roads are very busy and dangerous already.

Please reconsider on behalf of the safety and health of the local community - and register my

objection.

Thank you

Comment on updated application 23/04650/X

Following the recent submission of the application for variations of conditions, WHaM hasprepared the following comments:We do not believe that the application submitted, should be viewed as an amendment, because itrepresents a completely new scheme.

The application should be refused for the following reasons:- The mix of flats within the scheme vary from the approved. Reducing the quantity of familyaccommodation in the scheme. This results in a net loss of 3 bed apartments from the scheme.- The affordable housing has been reduced within the scheme, from 30% to 20%, as this was oneof the key measures noted in the case for approval of the current scheme.

Each of these changes to the scheme constitutes a larger change to the application than wouldtypically be covered by the provisions of a such a variation. The scheme should be required to goback to committee as the terms of the approval have been significantly changed.

The proposal also increased the built footprint of the building, which in turn makes less space forcritical green infrastructure in this area. It has already suffered the loss of the trees prior to theapplication being submitted, this proposal in turn allows less replacement green infrastructure to

be installed on site.

This loss of:- opportunity for green infrastructure,- Loss of affordable housing, and;- Loss of medium size family accommodation,Has resulted in a poorer quality scheme that does not serve the needs of the local community.

WHaM objects to this application for an amendment, and re iterates that the submitted documentsrepresent and entirely new application.

This application is supposedly limited to varying conditions 39, 45 and 50 (the latterbeing the drawings).

But the number and significance of the changes means that in reality it is a new application.

Furthermore, other conditions are affected and should have been , addressed explicitly (e.g. 27,28, 29, 30, 31, 40).

I 'd like to draw attention to the change in mix of 1, 2 and 3 bedroom apartments. This alonemakes it a completely different proposition which should be rejected. The developers werefortunate to get permission for the original proposal - they should be encouraged to 'take the win',and not push their luck.

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:This seems like a poorly thought out and overall negative high-rise in the middle of 2-3

story family homes.

There are a few key issues with the proposed development:

- The distinct lack of car parking

- The unnecessarily tall high-rise blocking the historical Totterdown houses.

- The cramped conditions of the flats do not fit into the surrounding neighbourhood.

The proposed complete absence of car parking is very short sighted and will turn all the

surrounding neighbourhoods into a nightmare for car parking. The application has not considered

any of the communities in Totterdown directly behind the towers. BCCs own documentation puts

Bristol car ownership at 1.04 due to the abysmal excuse for public transport around Bristol. The

applicants will need cars to traverse the city and its surrounding area due to lack of realistic

alternatives.

The height of the towers is completely unnecessary and will block all direct views of the

picturesque Totterdown skyline, a key image of Bristol. This application would never be accepted if

it was being built in Clifton blocking views of the suspension bridge, so why here?

The small cramped low-quality flats will bring down the overall area whilst providing little benefit to

any Bristol citizen struggling to find housing. These will be used almost exclusively for student

accommodation which will detract from the majority family homes in the surrounding area. There is

a school being built right next to the development, but no family units provisioned in the plans. This

seems very shortsighted.

Please register my strong opposition to this proposal.

Thank you,

TRESA strongly objects to this application, for the following reasons.1] A NEW APPLICATIONThe application is presented as a series of variations to conditions 39, 45 and 50 (with 50 beingthe drawings). However, conditions 27, 28, 29, 30, 31 and 40 are also affected. Given thesubstantial differences from the consented scheme, this is a new application and should betreated as such.At the point of submitting this objection, important documents are missing from the applicationincluding:- Ecological Assessment and BNG Assessment- Heritage Statement of Conformity- Internal Daylighting Assessment- Wind Assessment report- Waste storage and collection plan2] HISTORY OF THE APPLICATIONThe officer report relating to the previously approved scheme recommended REFUSAL for thefollowing reasons, which also apply to the current application:- The design quality of the scheme is poor - there is a high proportion of single aspect dwellingswhich would have a poor outlook, receive limited light levels and require higher energyconsumption, which arises from the overdevelopment of the site. This would result in a poor livingenvironment for its occupiers and would fail to meet liveability criteria sought by recently approved

council guidance, which seeks to achieve a liveable environment for future occupiers whendeveloping at higher densities, and as a result fail to meet the requirements of the NPPF, policyBCS21 of the Core Strategy 2011, and policies DM26 and DM29 of the Site Allocations andDevelopment Management Policies 2014.- The excessive height, bulk and massing would result in less than substantial harm to the settingof the adjacent Bedminster conservation area, and this harm would not be outweighed by anypublic benefits. In view of the over development of the site the overall design quality iscompromised, and the proposal fails to integrate itself positively into the city streetscape andskyline. As such the proposal fails to comply with the NPPF, policies BCS21 and BCS22 of theCore Strategy 2011 and DM26, DM27, DM28 and DM31 of Site Allocations and DevelopmentManagement Policies 2014.- The development would have an unacceptable impact on highway safety in view of therequirements for servicing and reduced footway widths that would be required around the site toaccommodate the development. This would prejudice pedestrian safety, introduce unappealingand unsafe circulation and movement function, contrary to the NPPF, BCS10 of the Core Strategy2012 and DM23, DM27 and DM28 of Site Allocations and Development Management Policies2014.- The development would fail to mitigate its impact through contributions towards site specifichighways improvements that would benefit the growth of the city, and as such would be contrary tothe NPPF and policy BCS11 of the Core Strategy 2012.Despite these reasons for refusal, and serious concerns about fire safety, the DevelopmentControl Committee were persuaded to approve the previous scheme because of the need foraffordable housing.The requirement to address fire safety concerns resulted in the submission of a poor-qualityrevised scheme in the guise of a 'non-material amendment'. This was not accepted by theplanning officer and the developer was advised that an application which reduced the quality of thescheme was unlikely to be approved.Nevertheless, the developer has chosen to present a scheme, inaccurately described as'variations to conditions', which exacerbates many of the problems of the approved scheme andreduces the proportion of affordable housing.3] OBJECTIONS TO THE CURRENT APPLICATIONREDUCTION IN AFFORDABLE HOUSING: The proportion of affordable housing has reducedfrom 30% to 20%. This is unacceptable because the provision of affordable housing was a keyfactor in the decision to ignore the officer recommendation and approve the previous scheme.ACCOMMODATION MIX: The total number of flats (221) is the same as the approved scheme.However, the mix has changed. The approved scheme was for 121 x 1-bedroom, 77 x 2-bedroomand 23 x 3-bedroom. All of the 3-bedroom flats have been removed and the number of 2-bedroomflats has been reduced. The new mix is 149 x 1-bedroom and 72 x 2-bedroom. The applicantstates: "the proposed mix is more appropriate for the proposed tenure, being Build to Rent, whereoccupants would generally live for shorter periods." This undermines the Mead Streetdevelopment brief which aims to promote and support a new neighbourhood community.ACCESSIBILITY: The consented scheme indicated 98% of the dwellings will be delivered as

M4(2) dwellings, and 2% of the dwellings will be delivered as M4(3) dwellings; the currentapplication retains the required 2% M4(3) dwellings but does not include any reference to M4(2)dwellings. The consented scheme included 14 parking spaces for disabled use only; the currentproposal provides 5 parking spaces for disabled residents only.DAYLIGHT: Limited light levels were identified as a problem with the consented scheme. Thecurrent scheme has smaller windows, and the tower blocks are closer together. This is likely toexacerbate the problems with daylight. However, no Internal Daylighting Assessment report hasbeen provided.POOR LIVING ENVIRONMENT: there is a high proportion of single aspect dwellings which wouldhave a poor outlook, receive limited light levels and require higher energy consumption, whicharises from the overdevelopment of the site.BULK AND MASSING: The proposed buildings are bulkier and the distance between blocks hasbeen reduced to less than 17 metres for single aspect flats looking directly into one another (thefire strategy document places the midway boundary at 8.13 metres, giving a distance of 16.26metres). Balconies are less than 13 metres apart which severely compromises privacy. Theresulting canyon between Blocks B and C is about twice as tall as it is wide. No wind speed reporthas been provided.HEIGHT AND TOPOGRAPHY: The Urban Living supplementary planning (SPD) advises that tallbuildings should not hide or mask the topography of the city. The Mead Street Development Briefnotes the local landmark ofthe Pylle Hill escarpment, with the coloured terrace of houses runningalong it, as an important feature which adds to the local character of the area and contributes towayfinding and legibility in the city. The proposed height of both the approved and the currentapplications will mask the topography. A new application provides an opportunity to reduce theheight, enabling this important landmark to continue to be visible from key vantage points.LACK OF PARKING: The approved scheme included 43 car parking spaces in the basement ofthe development, which was significantly lower provision than the maximum permitted under theCouncil's Parking Standard. In the current application, all but 5 of these spaces have beenremoved. This means there is no parking allocation for the overwhelming majority of residents andvisitors, or for staff and visitors of the commercial units.IMPACT ON HIGHWAY SAFETY: The increased bulk of the buildings has further reduced thepavement width along York Road, which is already considered insufficient. Together with theproposed trees, this will cause problems for pedestrian movements.WASTE STORAGE AND COLLECTION: Arrangements for waste storage and collection havechanged. The width of the path for moving refuse bins appears to be narrower than the onepreviously deemed inadequate, and the collection area is smaller. A new waste storage andcollection plan is required to indicate how these issues will be addressed.FIRE SAFETY AND ESCAPE ROUTES. The required two staircases per building are, at last,included in the plans. However, the location of the bin stores at ground level on either side of thecanyon is problematic when buildings are so close together. A fire in one of these stores wouldcause a lot of damage and probably spread up both blocks very swiftly. Given the history of theapplication, including the approval of an unsafe design subject to conditions, the fire safetyproposals should be carefully examined.

PLANS AND MATERIALS: There is no scale comparison on the drawings, contrary to Bristol CityCouncil submission policy. The roof profile and upper floors differ from the approved designs. It isproposed that the intermediate floors will be of modular construction, but there is insufficientinformation about the appearance. The applicant states that final selection of material finishes tobe approved on site. There are amendments that change the external appearance of the buildingsand, to comply with Policies BCS22 (Conservation and the Historic Environment) and DM31(Heritage Assets), the potential effects on the setting of the Conservation Area should beassessed. No Statement of Conformity is currently available for scrutiny.

Looking at the drawings I object to the height of the buildings. They will interfere with theview of the totterdown houses. An iconic view that can be seen for miles, a view that is first seenwhen arriving by train and a view that is printed and reproduced on many items that support Bristoland our tourism. A new build block would not be considered in front of the iconic row of houses inClifotn so why should it be in this case? Why ruin something that brings so much tourism andmoney to Bristol? I think the building should be a maximum of 6-7 stories if they were to go ahead.

This looks like a different scheme to the monster already approved. Its far to big andbulky for the location, so I am sure this will be waived through again.

I do find it strange about the 'Controlled parking comment' - Omission of Basement (1.2 -1.2.1)-the area next to the development , Totterdown and Victoria Park has no parking controls and isalready used as free carpark by commuters. So the statement is plainly untrue.

It is good to see that in the event of a fire residents will have another way to escape the building, Inever understood how just one way in and out was allowed (similar to the Tacky Towers shamblesleft half built on the Bath Road).

The pavement area around seems to have shrunk.

It will be interesting to see how having so many people crammed next to a dangerous St LukesRoad, with nothing in place to stop speeding motorists and the opening of the new school acrossthe road from the proposed development will work.

Overall its seems like as many tiny boxes have been crammed into even bigger slabs.

I would really like a lower, higher grade scheme on this site, that does not block the iconic view of

Totterdown.

I find the two building blocks of this development too high. Ten floors will at leastpartially block the iconic view of the Totterdown line of Victorian houses as seen from the Northand on arrival into Temple Meads railway station. The blocks both appear solid and rectilinear andnot at all pleasing on the eye. I am all for new accommodation and housing for the people ofBristol but this development appears brutal and not in keeping with a historical city.

Having another look at the drawings, further to my objection of 14.12.2023, I have a fewmore observations:

The eye is drawn to the strange diagonal balcony straps that were not previously a feature and thewindows which are all smaller than the approved designs..

The roof profile and upper floors are different to the approved designs.

Obvious other changes are the removal of basement and all parking - now only 5 disabled spacesfor all commercial and residential units. There is now a proper corridor in block C rather than thehanging balcony escape of the intermediate application and single stair of the original, althoughthe flat designs have been compromised as a result.

The depth of plan has increased i.e. the buildings have got bulkier including the link block. Thisdoes not just change the proportions. This is hard to make out, but most apparent in DesignAmendment Summary 1 (plans) and 4 (sections).

The statements do not make much mention of this, but crucially the distance between blocks hasbeen substantially reduced as a result. Also there is no scale comparison on the drawings,contrary to BCC submission policy.

It was about 19m which was inadequate - creating canyons between the blocks. This distance hasnow been reduced to less than 17m and these are single aspect flats looking directly into oneanother. Balconies are less than 13m apart which might be sociable but leaves no privacy at all -not the sort of thing that would normally be permitted with two storey houses and certainly shouldnot be allowed here - I think this is important as it contributes to the general sub-standardprovision. I note that the fire strategy document places the midway boundary at 8.13m making thedistance apart only 16.26m which is far too close for 11 storey buildings.

The resulting canyon between Blocks B & C is now about twice as tall as it is wide. Along with thesmaller windows this would also make the lower floors grim but there are no new daylight or windspeed statements.

The buildings have got closer to York Road, thus reducing the pavement width as well as makingthe wider part at the entrance smaller. The proposed trees there were already too closes to thebuilding to be properly viable and interfering with pedestrian movements. This will now be worse.

There is no refuse collection statement either although layout and storage has changed. The widthof path for moving bins through the canyon looks even narrower than the one previously deemedinadequate and if the old statement is to be relied on, the bins would still be gathered for collectionwhere there are trees and planting shown, although that area has got smaller.

The new mix is 149 1bed flats and 72 2bed flats - so nearly all one bed apartments. Combinedwith the sub-standard conditions, this does not bode well for a settled community. The applicationdoes not state, although I think we can hazard a guess which the limited affordable ones will be,thus adding to the poor social mix.The number of M4(3) i.e. disability accessible standard flats has been reduced to fit the 5 spacesnow proposed (previously 13) and all the others have been removed. There are the same totalnumber of flats at 221, but was 121 1B, 77 2B and 23 3B so quite a different mix. It does not saywhat the proportion of single aspect flats is, but it appears to have gone up in a furthercontravention of acceptable numbers.

BCC's own figures indicate a typical number of cars likely to be owned by residents it isconsiderably above zero, whatever the parking strategy may say. There is emphasis on the S106

contribution for traffic/parking being kept but now of course the situation will be that much worse,including for all local businesses and residents who will have to put up with the additional parkingform staff, residents and visitors.

It says that the intermediate floors of the new buildings will be of modular construction -presumably fabricated off site, but no detail as to what they would be made of or how put together.

The fire escape strategy thankfully now has two staircases per building. This is just as well as thelocation of the bin stores at ground level either side of the canyon is asking for trouble when thebuildings are so close together. A fire in one of these stores would cause a lot of damage andprobably spread up both blocks very swiftly.

The application purports to be one to vary conditions 39, 45 and 50, 50 being the drawings. This isin fact a completely new application and should be treated as such. In addition , other conditionsare affected and should have been listed, namely 27, 28, 29, 30, 31 and 40.

This application should therefore be ruled invalid and /or rejected.

At the time of writing this (16 December 2023) two documents, which are described assubmitted in the applicants covering letter, are missing from the list of documents available on theplanning portal. These are:- Ecological Assessment and BNG Assessment- Heritage Statement of ConformityTRESA intends to comment on the current proposal and it is important that these are available toenable a full assessment of this proposal.

I object to this application on the grounds that :

1 It is a completely new application masquerading as an application for variation of conditions anda new planning application is required. It is telling that these are the third architects to havesubmitted on behalf of the applicants, and the third different scheme.2 Crucial aspects of the already substandard proposals have been omitted e.g. car parking,affordable dwellings, amenity space3 It appears to be a completely new design with differing flats, commercial units, parking, layoutand external appearance.4 The loss of affordable housing is completely unacceptable, particularly as it was the onlymitigating factor quoted by Councillors in approving this unfortunate scheme in the first place,when it had been recommended for refusal.