Having read the comments of Traffic Development Management and Bristol WalkingAlliance, TRESA would like to support the concerns raised about the impact of this planningapplication on sustainable transport routes.The Mead Street Development Brief prioritises the safety of pedestrians and cyclists but thecurrent proposal undermines this.The proposed bell-mouth access would impede pedestrian movement along the footway.The pavement at the junction of Mead Street and St Lukes Road is too narrow.Other surrounding footway widths are obstructed by proposed seating, planting, trees, Sheffieldstands, and loading bays which is unacceptable and potentially unsafe.Some of the doors appear to open over the pavement which is unsafe for passing pedestrians.The current proposal should not prejudice the future public transport route and associatedwalking/cycling routes.

2

Public Transport Route

The Development Brief includes safeguarding space on Mead Street for a 6.4m widecarriageway/public transport route and 3m wide segregated cycle path. The importance ofsafeguarding this space is strengthened by the recent West of England Combined Authority decisionto develop an Outline Business Case for options, without significant tunnelling, shortlisted inFuture4WESTs Strategic Outline Case. Option SWC11 incorporates Mead Street. The currentdevelopment proposal should not prejudice this important public transport route and associatedpedestrian environment.

Bristol Walking Alliance27 August 2024

I object to the height of the buildings proposed. The fact that the view of Totterdown will beobstructed is extremely concerning. I am also very concerned about the increased traffic in rushhour as this road gets extremely busy.

I am in favour of new housing on the Barts Spices site. However, I am concerned aboutthese proposals for the following reasons as they would affect the people who would live there.Firstly, there appears to be fire safety concerns. Secondly, there is a high proportion of singleaspect dwellings. Finally there has been a reduction in the amount of affordable housing from 30%to 20% - Bristol is in desperate need of affordable housing and this needs to be a priority.

I strongly object to this application for the following reasons:

The impact on environment - The area is already overcrowded with an extortionate number ofdevelopments which will have a detrimental effect on what is being referred to as 'Clean Air' - theaddition of this construction will impact the environment both during the construction and thereafterbecause of the increase in the number of cars such a vast development will bring - this is an areathat suffers with gridlock on a daily basis (as a sufferer of asthma the impact on walking locally isalready felt)This is an area that does not have the infrastructure capability to cope with the impact of anotherlarge-scale development. It is naive to take the view that the residents will walk/cycle into the citycentre when no doubt the residents of this development will have visitors to their homes and willalso have ambitions to travel beyond the local area to other parts of Bristol and the UK in whichthey will need a vehicle beyond the provision of public transport - the number of parking spacesare not sufficient enough to cater for all residents and visitors without further impacting a denselypopulated area. Such a development will therefore put strain on an area that is struggling withresidents searching for parking.The local infrastructure does not have the capacity to cope with the impact on schools, NHSprovisions such as GP's Dentist etc - this is already a very highly populated areaSuch a sizeable construction will impact the historic Totterdown skyline which is an importantfeature of Bristol, the continual desire by developers to build high-rise to achieve the highestnumber of occupants and profits with a disregard to Bristol's history is already prevalent in this

area.

I am not objecting to the increase/need of additional properties, however at least keep them to theoriginal/historical local vernacular and look to build houses rather than a monstrous high-risebuilding.It would appear that the developer is showing an absolute disregard to the planning system andthe concerns of the residents and are looking to introduce where possible and as close to theiroriginal submitted plan with the hope of what feels like a bullying and grinding down approachputting their profit over everything and I hope that the Bristol City Development Control ACommittee do not consider their need for such profit to affect the decision over the need of uscouncil tax paying residents.

This application shows clearly that applicant doesn't work with the community at all -everyone in the neighborhood voicing objections about height over and over again as that is ahistorical place and is one of the most important places in Bristol - first thing that meets touristsand instead of nice colourful rows of totterdown they will see massive tall buildings. Not only thatbut instead of bringing infrastructure to the community it takes off it - south Bristol is in crisis ofhospitals and schools anyway and on top of it it doesn't have parking in place which might be avision for the future but how many of the residents will go towards neighbouring areas to park?

The applicant doesn't make any substantial changes with every application and just trying tominimise community involvement by making deadline for objections over school holidays - all in allapplicant doesn't work with community but against it and should be rejected until they finally act oncommunity concerns

This development is absolutely the wrong type of building to put on this plot for thefollowing reasons:

The buildings are far too high and bulky in mass.Terrible living accommodation for potential residents.Ruining an iconic Bristol landscape.Lack of Parking.Single aspect windows.Fire safety for residents.Not enough facilities already in this area, i,e, doctors, pharmacy, dentists. Over subscribed schoolplaces.Beautiful trees have been decimated and new ones will be put in planters. (These trees will thendie in 12 months).Come on Bristol, we can do far better than throw these awful buildings up.

I object to the updated application.The applicant indicates that two changes are proposed to the scheme that was consented in 2022:- The addition of external walkways to the eastern elevation of Block C to achieve fire regulationcompliance; and- The reduction of the Affordable Housing provision from 30% to 20% to reflect the scheme beinga Build-to-Rent development.EXTERNAL WALKWAYSThe Health and Safety Executive (HSE) has not considered the application since July 2022 i.e.more than two years ago. It is important that the HSE is consulted and provides an opinion on firesafety, particularly for Block C. At the moment there is only a fire safety report commissioned bythe developer which states: "The latest updates to the submission introduce an alternative escapefor all apartments by means of an external escape gantry/balcony connecting the two cores.Levels 02 to 10 are served by the external balcony."When this was incorrectly proposed as a 'non-material amendment' for a previous application,objections were submitted about the design and safety of the external walkways and theimplications for residents. It is not clear how use of the walkways can be restricted to emergenciesonly. The temptation will be to use the walkways as 'balconies', for informal storage, or aswalkways in non-emergency settings. This would not only present a fire hazard, but also invadethe privacy of residents whose windows face the walkways.The potential for inappropriate use is clearly known by the developer who has proposed wordingfor a New Condition 51: "Prior to the occupation of the development, a Fire Escape Management

Plan shall be submitted to the Local Planning Authority and approved in writing. The Fire EscapeManagement Plan shall confirm the locations of all fire escapes within the proposed developmentand provide details of the measures that will be implemented to ensure that these doors are notopened outside of an emergency scenario, except for maintenance or other official purpose."Government guidance (Fire_Safety_in_Purpose_Built_Blocks_of_Flats_Guide-update.pdf(publishing.service.gov.uk)), indicates: "Escape routes from flats in some older blocks may involveforms of alternative exit, such as linking balconies and pass doors, that are no longerrecommended."We reiterate our concern that the original application was approved without due consideration tofire safety. This has led to subsequent questionable attempts to address the existing design faultswithout due consideration to the quality of life and safety of residents.It is imperative that the proposal for external walkways as a fire safety measure be considered bythe HSE. It is not something that should be approved through informal discussion between thedeveloper and a senior planning officer (as was suggested in the covering letter from thedeveloper's agent).REDUCTION IN AFFORDABLE HOUSINGA key reason why the consented scheme was approved, against the recommendation of theplanning officer, was because it provided 30% affordable housing. The officer's report indicated:"The applicant has confirmed that 30% of the dwellings would be offered as Affordable PrivateRent as part of a wholly Build to Rent scheme. The policy requirement of 30% affordable housingwould be secured by s106 agreement. This application can only consider the policy compliantoffer, and any planning consent would be able to secure the policy compliant offer only."When the application was approved by Development Control Committee A in 2022, on conditionthat fire safety issues would be addressed, there was no suggestion that this should be achievedby reducing the percentage of affordable housing.OFFICER'S RECOMMENDATION TO REFUSE THE ORIGINAL APPLICATIONI share the following concerns raised by the planning officer who recommended in 2022 that theapplication be refused:(1) 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 approvedcouncil 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.(2) The excessive height, bulk and massing would result in less than substantial harm to thesetting of the adjacent Bedminster conservation area, and this harm would not be outweighed byany public 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 Development

Management Policies 2014.(3) 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.(4) 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.

Dear Councillors and Planning Officers, It is tragic that the developer of this site is stillable to submit low quality housing for the less well off in society and is now even reducing theamount of that 'affordable' housing with the latest amended submission, to maintain and evenboost their profit margin.I hope the Councillors of Bristol will vote with me in objecting to this application, for all the reasonsI have given before and in addition the following:1. The reduction of Affordable Housing from 30% to 20%. I live in Totterdown where 4 secondhomes in view of my front door are let on Airbnb, denying people homes to rent and pushing theprice of rents higher than many can afford. These flats, in their prime position for tourists and theexpanded university campus nearby will be available to private landlords to buy then to let tostudents or on a weekly basis on Airbnb or similar, exasperating the availability of housing stillfurther.It is criminal to allow the developer to reduce the affordable percentage against BCC policy.2. The addition of external walkways added to satisfy the emergency evacuation of residents justgoes to show the inadequacies of the design councillors approved. The walkways will obviously bea security risk and not be able to be monitored or supervised sufficiently to stop casual use byresidents and visitors wanted or otherwise.My previous objections remain and should be read in conjunction with this objection, they include;A. Height of blocks interupts the city views of the Richmond Street escarpment and row ofcolourful houses, an iconic part of Bristol's aesthetic and genius locii, as important as thecrescents in Clifton.

B. The mass of the blocks and design layout and the very poor landscaping provision has anegative impact on the city's conservation area nearby and the 'crowds' and narrows the RiverAvon, further reducung wildlife corridors between the railway and river banks.C. The design of the flats gives tenants inadequate storage , inadequate natural light andinadequate private outdooropen space, creating the slums of the future.D.The impact on highway safety in view of the need for servicing and the commercial units atground level is dangerous and could be avoided by a better design layout.E.The additional cars owned by the households will cause parking chaos in the area and affectnegatively air quality.F. The development of this corner site should be considered only when the whole of the MeadStreet area has had an overall design for open space set out and the density of housing for thewhole Mead St site considered..this should not set a precedent for the levels of housing density orheight and mass of blocks for Mead Street.

The below statement is provided by the Windmill Hill and Malago Planning Group in response tothe above application. It is understood that this application is specifically to amend certain aspectsof the design with regard to the reduction of affordable homes and the introduction of externalwalkways.

It was the opinion of the group that the introduction of the walkways missed several opportunitiesto alleviate issues with the design as a whole.

1. HeightThe applicant has chosen to not reduce the height of the building within their amendment, whichmay have had an impact on the fire strategy. As it is the building is still too tall for the area, and byvirtue of its height, it will obscure the Totterdown escarpment behind it, this is in contravention ofthe supplementary planning document on Urban Living.

2. It still has a lot of single aspect accommodationMany of the flats are single aspect accommodation, these have not changed, and the introductionof the external balconies has not altered this. This is advised against in the supplementaryplanning document on Urban Living.

3. There will still likely be an overheating problem

Even with the introduction of the external walkways, single aspect flats will still be at risk ofoverheating due to the tall windows which are not adequately shaded, have only small openingwindows and will be difficult to purge vent if there is only one side with opening windows.

4. The design is still sheer walls leading to possible future problems with windThe design has not used the introduction of walkways and balustrades to reduce the instances offlat walls and the channelling of wind currents between the flat surfaces of the buildings on thesite. These effects are advised against in the supplementary planning document on Urban Living.

5. The design does little for biodiversity and improving the green infrastructure, and makes noacknowledgement they cut down several trees on the site trees on site prior to the first applicationbeing submitted.

6. The proposed reduction of affordable homes seems to run counter to the applicants desire toassist with housing need and seems to be a further reduction from the initial consultationdocuments on this scheme where 100% affordable was initially promised.

The applicants are seeking two changes:

1. Addition of external walkways to the eastern elevation of Block C to achieve fire regulationcompliance;2. Reduction of affordable housing provision from 30% to 20% to reflect the scheme being a build-to-rent scheme.

Bristol Civic Society is not commenting on the first proposed change but we object to the proposedreduction in the proportion of affordable housing. 21/06878/F was granted by members against therecommendation of refusal from officers. In their deliberations, the policy compliant provision ofaffordable housing was a significant factor and it was noted that 30% provision was extremely rareand almost a miracle. The Society objected to the application on a number of grounds includingheight, massing, impact on views and quality of the living environment. The provision of theproposed quantum of supportable housing was, however, a feature we supported. The Society,therefore, feels strongly that any reduction in the affordable housing provision, which Councillorsconsidered and welcomed when deciding to approve the application, should be resisted. Thiswould dilute one of the few mitigating elements of, in the Society's view, an otherwise harmfuldevelopment.

The principal reason why this scheme was originally approved in the first place againstthe recommendation of the planning officer, was because it provided 30% affordable housing. Ifthis is no longer on offer, it calls into question the whole scheme particularly as the scheme hadmany problems outlined by the planning officer...

The original application's flaws included

- Being too tall- Providing poor quality living accommodation with inadequate private amenity space- Risks of overheating- Sheer walls leading to potential problems with wind- Not adding to the biodiversity of the area - and of course even before the application wassubmitted mature trees and all vegetation was removed from the site. And this is an area of Bristolwith poor tree cover and in need of increased canopy cover and green areas.. Problematic parking provision

- Parking issues

The proposed building are too high and will obstruct the view of the iconic Totterdownescarpment.

The density is too high and many of the flats will have a poor outlook and poor light.

Bristol should be building communities with adequate services and space for a families to live intheir home long term.

I have concerns about traffic and parking in Totterdown and Victoria Park which doesn't currentlyhave a residents parking scheme.

I object to this on the following grounds -

- Echoing what other commentators have said, the reduction from 30% affordable housing to 20%affordable housing is pointless and puts increased pressure on Bristol's housing crisis. We are indire need of homes and pushing things further out of everyone's reach is only going to exacerbatethe situation.

- The tower block itself is far too high and will obscure one of Bristol's most iconic views - again,this has been raised in previous objections.

- The apartments themselves have an issue with a lack of suitable light, and the walkways willinevitably be used day-to-day rather than for emergencies.

- There are far too many apartments being built in the block, putting pressure on neighbourhoodservices such as surgeries, schools etc.

In light of the above this application should be refused.

It is unacceptable that the new plan has reduced the proportion of social housing. Thiswas a

significant factor which influenced the acceptance of the original plan, against the advice of theplanning officers. Either it should revert to the original 30% or be reconsidered for approval.

The developer did not make it clear, in their original submissions, how tall these buildings will be.Many of the gardens/houses in the Richmond Road terrace will now be overlooked by the topfloors of these buildings, which will be a loss of privacy. However, this does not seem to havebeen considered.

Objections against this development remain. The single aspect windows will be claustrophobic forresidents. The buildings are too high, bulky and oppressive. They will detract from the iconicBristol landscape of the colourful houses on the escarpment. It is a charming, idiosyncratic area,but this development is packing too much into too small a space. If it is allowed to go through, itdoes not bode well for the other proposed developments around it.

The lack of parking will cause awful issues in surrounding streets. The development, as it stands,will not prove an asset but an eyesore. Make the flats more liveable in, reduce the height and re-consider parking allocations.

The timing of this consultation, over the summer school holidays, is unsatisfactory. More time is

needed, to ensure people have a proper chance to comment.

I object to this planning proposal on the following grounds:- inappropriate height destroying the view of the very attractive Totterdown escarpment- inappropriate height making it difficult to establish communities (see social effects of tower blocksin the 1950s)- single aspect windows - no cross ventilation

I can't really see much difference from the original plans that were recommended forrejection but waived through by the Tory led Planning Committee. The tower slabs are ugly andview blocking. Would prefer a design like the flats built at the over end of York Road/BedminsterBridge. I would hate to live in a block this size, having to use lifts and artificial light all day. Nocross flow of air and all this when the climate change is kicking in. Bristol deserves much betterthan the rubbish being allowed.

I object to changing from 30 per cent to 20 per cent social housing.

Bristol has a policy of min 30 per cent social housing in development. The developers knew thiswhen asking for original permission. Bristol has a housing crisis where people are struggling topay to rent homes. Some having to leave the city, breaking up communities and family units. Iobject to change from 30 per cent to 20 as we are in desperate need of social housing.

The height of the buildings is too high and is not in proportion to surrounding buildings. It will feeloppressive, will block light and won't feel safe in terms of human proportion.

Single aspect windows is poor design.

Two previous applications relating to this site, and submitted by the same agent, are notcurrently linked as related cases (Reference 23/03279/NMA and 23/04650/X). Both should belisted as related cases for the history of this current application.One of these applications (23/04650/X) was also described as an 'application for variation ofconditions' and was refused on two important grounds that remain relevant to this currentapplication: affordable housing need including homes suitable for families, and; the developmentof a socially sustainable neighbourhood.THE NEED FOR AFFORDABLE FAMILY HOMESThe officer's report indicated that affordable, family sized homes are a priority for the area:"The applicant's agent has alluded to the fact that that there is a substantial number of family sizedunits in the wider Southville Ward area... However, the synopsis given by the agent does not lookat the localised picture of the LSOA, where, as stated above, there is a shortage of family sizedunits.""Policy BCS18 within the adopted Local Plan is being retained within the Local Plan review, assuch, this policy carries weight in the consideration of this application. This policy requires all newresidential development to maintain, provide or contribute to a mix of housing tenures, types andsizes to help support the creation of mixed, balanced and inclusive communities. To achieve anappropriate tenure, type and size mix the development should aim to:- Address affordable housing need and housing demand;- Contribute to the diversity of housing in the local area and help to redress any housing imbalancethat exists"

A SOCIALLY SUSTAINABLE NEIGHBOURHOODThe officer's report indicated:"The Mead Street Development Brief was approved in 2022. One of the aims of this document isto "Create a socially sustainable neighbourhood with mix of homes, employment, communityspace and access to open green spaces" (p66).""It has been relayed to officers during the course of the application that BTR [Build to Rent] is seenas a product where tenants typically chose not to remain for any length of time. However, theNPPG guidance on Build to Rent is clear that 'Individual schemes should meet any relevant localand national planning policy requirements.' (para. 011)"

I am concerned that the weight of a new tall, massive building on York Road so close toan unstable riverbank - as we now know The Cut to be in this area - poses a new risk of provokingthe collapse of the riverbank, potentially taking the A370 with it. Have appropriate tests beencarried out since the Council became aware of the current riverbank issues? If not, this buildingdevelopment could prove disastrous.

It is not clear how the new walkways in the scheme will be restricted to emergencies only. Thewalkways will probably be used as 'balconies', for storage due to the lack of external space or aswalkways in non-emergency settings. This would not only present a fire hazard, but also invadethe privacy of residents whose windows face onto the walkways.

The City council policy requirement is for 30% affordable housing. This scheme is only offering20%

The design quality of the scheme is poor - there is a high proportion of single aspect dwellingswhich would have poor ventilation.

The excessive height, bulk and massing would result in less than substantial harm to the setting ofthe adjacent Bedminster conservation area, and this harm would not be outweighed by any publicbenefits. In view of the over development of the site the overall design quality is compromised, andthe proposal fails to integrate itself positively into the city streetscape and skyline. The view of theTotterdown escarpment would be impeded.

The development would have an unacceptable impact on highway safety in view of therequirements for servicing and reduced footway widths.

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.

Lack of parking in the new scheme will have an affect on neighbouring areas.

Overall the scheme would have a detrimental effect on the area and its surrounding landmarks.The location of the new school practically opposite the site would also be affected by noisedisturbance from building noise.

This scheme was awful from the first version of the first application and remains so, withno attempt with this application to mitigate the many documented failings. The one aspect thatswayed the committee decision was the level of affordable accommodation offered. With a 33%reduction in this offer there is now nothing to commend it.The application 21/06878/F as Savills cover letter says, did not comply with the BNG requirementsof the 2021 Environment Act as that did not come into force until this year. But there is now nojustification for those BNG requirements to be avoided by this amended planning application. Assuch this application should be fully compliant with current planning legislation.Neither did the granted scheme comply with the Bristol Tree Replacement Standard which didapply at that time. Many of the trees shown were located in planters and so effectively pot plantswhich could never reach maturity. Others were shown planted within the highways pavement forwhich there was no indication of approval for.

It is really disappointing that this scheme has been approved for 221 residential unitsagainst local support when there is such strain on the local public amenities in the area (doctorssurgeries, NHS dentists, school spaces, parking spaces), and that it was approved at the heightwhere two of the blocks obstruct the iconic view of the colourful Totterdown houses, when bothconcerns could have been mitigated to some extent by reducing the size of the development.

It is more concerning still to see that following approval they are looking to reduce the percentageof affordable housing (from 30% to 20%), given the cost of living crisis, the desperate need foraffordable housing in Bristol and that having 30% as affordable housing seemed to be a conditionof approval despite neighbours and local resident group concerns. I second the concerns raisedby TRESA.

I objected to the application submitted in 2022 and I object to this later application. Thisapplication indicates two proposed changes to the scheme submitted in 2022. This scheme wasconsented against the advice of the planning officer at the time who recommended the applicationbe refused. And with good reason.

- The addition of external walkways to the eastern elevation of Block C to achieve fire regulationcompliance; and- The reduction of the Affordable Housing provision from 30% to 20% to reflect the scheme beinga Build-to-Rent development.

EXTERNAL WALKWAYS:The Health and Safety Executive (HSE) has not considered the application since July 2022. Thisis DEEPLY CONCERNING given the fire risk in tall buildings and the consequences we have seenin Bristol already as well as other parts of the UK. It is crucially important that the HSE is consultedand provides an opinion on fire safety, particularly for Block C. At the moment there is only a firesafety report commissioned by the developer which states: "The latest updates to the submissionintroduce an alternative escape for all apartments by means of an external escape gantry/balconyconnecting the two cores. Levels 02 to 10 are served by the external balcony." I believe it showsnegligence not to request HSE involvement in considering this amended application.

When this was incorrectly proposed as a 'non-material amendment' for a previous application,

objections were submitted about the design and safety of the external walkways and theimplications for residents. It is not clear how use of the walkways can be restricted to emergenciesonly - just look at anecdotal evidence from other tall buildings with walkways. Being cooped up insmall confined spaces, particularly in hot weather, the temptation will be to use the walkways as'balconies' and possible areas to engage and converse with near neighbours. Areas are likely tobe used for informal storage, or as walkways in non-emergency settings. This would not onlypresent a fire hazard, but also invade the privacy of residents whose windows face the walkways.

The potential for inappropriate use is clearly known by the developer who has proposed wordingfor a New Condition 51: "Prior to the occupation of the development, a Fire Escape ManagementPlan shall be submitted to the Local Planning Authority and approved in writing. The Fire EscapeManagement Plan shall confirm the locations of all fire escapes within the proposed developmentand provide details of the measures that will be implemented to ensure that these doors are notopened outside of an emergency scenario, except for maintenance or other official purpose."

Government guidance :(Fire_Safety_in_Purpose_Built_Blocks_of_Flats_Guide-update.pdf(publishing.service.gov.uk)), indicates: "Escape routes from flats in some older blocks may involveforms of alternative exit, such as linking balconies and pass doors, that are no longerrecommended."

The original application was approved without due consideration to fire safety - this must nothappen again! This has led to subsequent questionable attempts to address the existing designfaults without due consideration to the quality of life and safety of residents.

It is imperative that the proposal for external walkways as a fire safety measure be considered bythe HSE. It is not MOST CERTAINLY NOT something that should be approved through informaldiscussion between the developer and a senior planning officer (as was suggested in the coveringletter from the developer's agent).

REDUCTION IN AFFORDABLE HOUSING:A key reason why the consented scheme was approved, against the recommendation of theplanning officer, was because it provided 30% affordable housing. The officer's report indicated:"The applicant has confirmed that 30% of the dwellings would be offered as Affordable PrivateRent as part of a wholly Build to Rent scheme. The policy requirement of 30% affordable housingwould be secured by s106 agreement. This application can only consider the policy compliantoffer, and any planning consent would be able to secure the policy compliant offer only."

When the application was approved by Development Control Committee A in 2022, on conditionthat fire safety issues would be addressed, there was no suggestion that this should be achievedby reducing the percentage of affordable housing.

OFFICER'S RECOMMENDATION TO REFUSE THE ORIGINAL APPLICATION

I think it is important to reiterate the concerns raised by the planning officer who recommended in2022 that the application be refused:(1) 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 living environment for its occupiers and would fail to meet liveabilitycriteria sought by recently approved council guidance, which seeks to achieve a liveableenvironment for future occupiers when developing at higher densities, and as a result fail to meetthe requirements of the NPPF, policy BCS21 of the Core Strategy 2011, and policies DM26 andDM29 of the Site Allocations and Development Management Policies 2014.

(2) The excessive height, bulk and massing would result in harm to the setting of the adjacentBedminster conservation area, and this harm would not be outweighed by any public benefits. Inview of the over development of the site the overall design quality is compromised, and theproposal 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.

(3) 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.

(4) 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.

THIS APPLICATION IS ILL CONSIDERED AND POORLY PRESENTED.... And submitted duringschool holidays!!!! Many of those wishing to respond to this application by registering theirthoughts with BCC will be on holiday. Questionable timing. I hope that full consideration will begiven this time to the application rather than a cursory glance and a tick to meet targets.

Planning Application at York Road & Mead Street, refs. 24/02678/X & 21/06878/F

I understand that revised proposals have been made for this application.

Revised ProposalsWhen this proposal came before the Planning Committee, the recommendation was for refusal,and none of the reasons for refusal have been addressed in the revised application. Thisapplication should therefore be refused.

The committee gave as the sole mitigating factor in its decision that the proposal included 30%affordable housing provision. The revised proposal reduces that number of units to 20%, thereforeremoving any possible justification for granting planning permission.

There were also concerns expressed at the time about the means of escape in case of fire whichwere yet to be resolved at the time of the meeting. The proposed method of alternative means ofescape via exposed raised walkways. These passages are subject to direct exposure from fireboth from within existing flats and adjoining buildings. They are intended not to be used except incase of fire and are also reliant on management procedure to keep them clear of obstruction andin a useable state.

Urban Living SPDThe proposal still falls short of guidance in Bristol city Council's Urban Living SPD: Makingsuccessful places at higher densities in a number of key areas:

The scheme is contrary to density recommendations in the SPD resulting in excessive andoppressive density likely yo lead to poor living conditions.

The proposal is contrary to the SPD which states that a tall building should not be located where ithides or masks the topography of the city

Calculations using the BCC child yield calculator and available outdoor play space indicate thescheme falls well below the minimum required.

The design is still poorThe proposals are over-large and over-heightThe proposed housing density is too highInsufficient weight has been given to noise, air quality, community or environmental concernsWhat little social merit there may have been in the scheme has now been removed

Further objections are noted below - the following are observations based on submittedinformation:

Designthe towers still loom over the street and their surroundings in an overbearing way. Almost all publicrealm has been given over to very tall buildings too close to the boundaries. The overallappearance is blocky and grim and does little to ease the sense of oppression on nearbybuildings, all of which are lower and some of which are Listed.

The statement on Daylight states that light levels within apartments will be improved over thosepreviously indicated by changing the paint reflectance. This is not a legitimate improvement.

Single Aspect - Impact on OccupantsSingle aspect flats face each other in vast walls only 18m apart but 34m high leaving no privacyfor the prospective residents, particularly as their balconies would be only 15m apart. Internally,the flats are served by dark narrow corridors 30m long with a single window at one end andwindowless lift shafts at the other. A statement claims that only 47% of the flats are now singleaspect. However, many of the flats claimed to be dual aspect have a single small window facingsideways onto a recessed balcony as their only claim to this, and several have as their secondaspect the well created on the Northeast side facing the Royal Mail sorting depot which may be

reformed into a similar well in due course, and it is a condition of approval that these flats haveobscure glazing to that elevation, therefore having no second aspect.

Building Height and Affect on Surrounding areaThe enormous height of the proposals would dominate the local landscape and obscure one of themost famous and iconic views in Bristol. The submitted view from Temple Meads Approachillustrates this starkly. Other views, although chosen to show the buildings in their best light, clearlyillustrate the damaging and overbearing affect on this part of the City, and the removal of views ofthe iconic escarpment.

Although submitted drawings do not indicate it, the upper floors would look down upon nearbyhouses which are currently on top of the escarpment as well as those surrounding at lower levels.The buildings would likewise blight the surrounding area and plots of land on Mead Street andYork Road. There is a pointed irony in the use of a large view of the escarpment in the Design andAccess Statement.

On the West side, the building is still 1.5m from the boundary apart from the introduced well.Assuming the adjacent site were to be developed in a similar fashion, flats would be touchingdistance apart across a man-made crevasse. This is an unacceptable approach, blighting nearbylandowners.

Design statements and elevations seek to draw comparisons in height with existing flats acrossthe river but fail to acknowledge the location of those buildings which are set back from roads in arelatively open landscape rather than being immediately adjacent to major roads.

The design has completely failed to acknowledge the unique position adjacent to the river, a majorroad and pedestrian route as well as the nearby topography.

Planning StrategyThe height and bulk of the development is contrary to the Mead Street Development Brief which isintended eventually to be the guide for planning this area.

DensityThe proposed density would be over 500 dwellings per Hectare, plus commercial and servicingareas.

The Bristol Urban Living SPD - Making Successful Places at higher densities indicates that anupper limit of about 120 units/Ha would be appropriate in this 'Inner Urban Area' and is in excessof the 200 units/Ha for city centre settings. The scheme is contrary to the SPD resulting inexcessive and oppressive density.

Light LevelsThe Internal Daylight Assessment indicates that many of the apartments will be miserably darkwith those on the lower levels having low light levels and almost no view of the sky, yet concludesthis would be acceptable. There is also an assumption that the remainder of the site would remainundeveloped, and relies on having surrounds which are single storey to achieve the results that itdoes, something that is mostly unlikely to remain, and which is referred to in the Design andAccess Statement.

The report on overshadowing nearby properties indicates that the new development wouldcompletely blight and overshadow the closest buildings which are within the BedminsterConservation Area, as well as blocking winter sunlight from existing flats across the river, yetagain concludes this will be acceptable.

PollutionThe Health Impact Assessment submitted with the application completely fails to identify an airpollution strategy or address problems beyond identifying that there may be one, despite the sitebeing directly on a busy road within the Air Quality Management Area. The size and bulk of thebuilding would contribute to trapping polluted air within close proximity, exposing pedestrians, roadusers and residents to unacceptable levels of pollutants.

It also concludes that residents at first floor level would be subject to dangerous levels ofatmospheric pollution, and makes no mention of the occupants and visitors to the ground floorcommercial spaces who would also be exposed, including those shown as sitting outside by theside of some of the most heavily polluted roads in the city.

Wind SpeedThe Wind Desktop Appraisal acknowledges that no wind tunnel or CFD study has been done. Itspeculatively uses data from a site 7km away and reduces predicted wind speeds by over 50%.This generic approach is unlikely to produce a correct result as it completely fails to recognise theunique topography of the area and the river valley. The conclusions that there would be littleadverse impact of wind funneling on the surrounding roads, paved areas and residents arelaughable to anyone familiar with the locality.

The revised appraisal indicates that it will be necessary to keep the existing trees to mitigate windspeeds to near-acceptable levels. It does not state if this refers to the trees already removed fromthe site.

TreesThe Tree Survey locates and classes all existing trees on the site and recommends that all exceptone should be kept, preferably with the surrounding green space. However the proposed schemeremoves every single one so the buildings can be larger. Indeed all trees and other vegetation on

the site have already been removed.

The proposed replacements are not likely to fare well, sited in hard landscaping 2m away from the11 storey cliff faces of the buildings. Claims in the Ecological Assessment that landscaping andbiodiversity would increase by removing all trace of existing trees , shrubs and greenery are notcredible. No mention is made of bats which are known by residents to inhabit the area and use theriver and escarpment for feeding and as a travel corridor. The proposals are very likely to interferewith current bat transit and roosting.

NoiseThe Noise Assessment Report submitted examines little except the impact of existing noise,mostly traffic, on the new residents, and concludes that many of the flats should have theirwindows sealed shut, with artificial ventilation, though no proposals are made as to how this wouldbe done. This type of design is generally considered unacceptable by current standards. There isno consideration of the considerable impact the residents would have on each other, or othernearby residents, facing a wall of other flats a short distance away with open balconies likely togive rise to considerable disturbance. This type of design is deeply flawed and known to give riseto many complaints. The proposed adjacent seating and café areas are only likely to make mattersworse.

TownscapeThe Heritage Townscape and Visual Impact Assessment praises its own scheme yet somehowmanages to miss the evidence of its own carefully selected and presented photomontages - thatthe scheme represents an awful blot on the landscape viewed from almost any angle and lurksover the nearby city in a threatening manner, blocking or spoiling views of the famous escarpmentfrom almost all angles, and sitting uncomfortably beside the Listed structure of the foot bridge.

SustainabilityThe Sustainability Statement claims great things in terms of energy saving, yet fails to mentionthat buildings above 6 storeys are known to become progressively less efficient and more energyintensive the higher they go while introducing long term maintenance problems.

ParkingThe Transport documents and Design and Access Statements do little to address the parkingproblem thrown up by the development, other than stating that little parking would be required. 14disability standard spaces are allocated to flats leaving 29 spaces for the remaining 207 flats aswell as the commercial spaces. This level is generally considered adequate for visitors to the flats,never mind the residents and staff. Expectations that they would not have motor vehicles areunrealistic and there is no nearby on-street parking at all. The only proposed solution is foroverflow parking on the Totterdown escarpment, which local residents will be able to identify as

ridiculous due to the non-existence of available spaces.

Waste DisposalThe Operational Waste Strategy is unsatisfactory, requiring tenants to take their segregated wasteup to 10 floors away and relying on building management to place all of the bins in collectionareas. The Strategy is also in direct conflict with the Landscape design as it shows the main binarea collection site exactly on the site of a large raised planter. This anomaly has not beencorrected.

InfrastructureThere is no mention of any infrastructure beyond the immediate site being provided, despite theadditional 221 homes proposed, which are also part of bigger plan for the Mead Street site thatcould see more than 1500 new homes. Figures produced with the application show that thedevelopers expects very few children to be present in the flats, although it is claimed the privatecourtyard would provide play facilities. The Bristol City calculator indicates that there wouldprobably be between 26 and 87 children living in the development. Details also state that there area number of schools within a radius of a few km, but all the closest ones have no spare capacity,and this development is only likely to make matters worse.

Community InvolvementSadly, the Statement of Community Involvement is just that - little more than a statement. It quotespercentages of answers to leading questions designed to elicit apparently positive responses,while making little of any negative concerns expressed. This is not community consultation, anddoes not reach the standards of the City Council guidance.

ConclusionsMany of the documents submitted with the proposal amount to little more than the applicantmarking their own homework and have produced hopelessly optimistic outcomes based on littleevidence.

The scheme as presented is so deeply flawed in all respects that planning permission should notbe granted. It would lead to poor health, social, visual, urban and civic problems and would also bea fire hazard. It is clearly in breach of the Bristol Urban Living SPD as well as BCS1, BCS2,BCS15, BCS20 and BCS21 and should be refused.

SummaryThe original report to committee, while not comprehensive in coverage, summarized the mainproblems with this scheme and they still exist in addition to the unacceptable loss of affordablehousing.

I wish to object to the proposed changes to this development.I would give the same reasons as provided by the planning officer in 2022 who said the applicationshould be refused because:

(1) 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 approvedcouncil 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.

(2) The excessive height, bulk and massing would result in less than substantial harm to thesetting of the adjacent Bedminster conservation area, and this harm would not be outweighed byany public 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.

(3) 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.

(4) 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.

Ultimately, it is too big and bulky - and the reason it was previoulsy accepted was due to theprovision of 30% affordable units. This has now been removed and it appears to be the developerjust running rings around the planning system by agreeing things to get what they want, thensubmitting another application to remove that constraint.

TRESA objects to this application.The applicant indicates that two changes are proposed to the scheme that was consented in 2022:- The addition of external walkways to the eastern elevation of Block C to achieve fire regulationcompliance; and- The reduction of the Affordable Housing provision from 30% to 20% to reflect the scheme beinga Build-to-Rent development.EXTERNAL WALKWAYSThe Health and Safety Executive (HSE) has not considered the application since July 2022. It isimportant that the HSE is consulted and provides an opinion on fire safety, particularly for Block C.At the moment there is only a fire safety report commissioned by the developer which states: "Thelatest updates to the submission introduce an alternative escape for all apartments by means of anexternal escape gantry/balcony connecting the two cores. Levels 02 to 10 are served by theexternal balcony."When this was incorrectly proposed as a 'non-material amendment' for a previous application,objections were submitted about the design and safety of the external walkways and theimplications for residents. It is not clear how use of the walkways can be restricted to emergenciesonly. The temptation will be to use the walkways as 'balconies', for informal storage, or aswalkways in non-emergency settings. This would not only present a fire hazard, but also invadethe privacy of residents whose windows face the walkways.The potential for inappropriate use is clearly known by the developer who has proposed wordingfor a New Condition 51: "Prior to the occupation of the development, a Fire Escape Management

Plan shall be submitted to the Local Planning Authority and approved in writing. The Fire EscapeManagement Plan shall confirm the locations of all fire escapes within the proposed developmentand provide details of the measures that will be implemented to ensure that these doors are notopened outside of an emergency scenario, except for maintenance or other official purpose."Government guidance (Fire_Safety_in_Purpose_Built_Blocks_of_Flats_Guide-update.pdf(publishing.service.gov.uk)), indicates: "Escape routes from flats in some older blocks may involveforms of alternative exit, such as linking balconies and pass doors, that are no longerrecommended."We reiterate our concern that the original application was approved without due consideration tofire safety. This has led to subsequent questionable attempts to address the existing design faultswithout due consideration to the quality of life and safety of residents.It is imperative that the proposal for external walkways as a fire safety measure be considered bythe HSE. It is not something that should be approved through informal discussion between thedeveloper and a senior planning officer (as was suggested in the covering letter from thedeveloper's agent).REDUCTION IN AFFORDABLE HOUSINGA key reason why the consented scheme was approved, against the recommendation of theplanning officer, was because it provided 30% affordable housing. The officer's report indicated:"The applicant has confirmed that 30% of the dwellings would be offered as Affordable PrivateRent as part of a wholly Build to Rent scheme. The policy requirement of 30% affordable housingwould be secured by s106 agreement. This application can only consider the policy compliantoffer, and any planning consent would be able to secure the policy compliant offer only."When the application was approved by Development Control Committee A in 2022, on conditionthat fire safety and other issues would be addressed, there was no suggestion that this should beachieved by reducing the percentage of affordable housing.OFFICER'S RECOMMENDATION TO REFUSE THE ORIGINAL APPLICATIONWe continue to share the following concerns raised by the planning officer who recommended in2022 that the application be refused:(1) 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 approvedcouncil 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.(2) The excessive height, bulk and massing would result in less than substantial harm to thesetting of the adjacent Bedminster conservation area, and this harm would not be outweighed byany public 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 Development

Management Policies 2014.(3) 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.(4) 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.