be an important element of approved outline planning permission 21/02141/P and must be implemented as it will become the direct route between the University academic sites and student accommodation on both sides of the river as well as linking the wider Silverthorne Lane development area with the new south entrance to Temple Meads station. We applaud the ground floor uses and its orientation opening-up the views and space to the floating harbour. The design could be improved at this level by swapping the cycle store and sub-stations to allow a better and more active street frontage onto Avon Street. The access required for the sub-stations could be given through the accessway adjacent to the TQEC phase 2 building without too much difficulty. We would also suggest the windows on the ground floor to the floating harbour could be substantially larger and even increase the ground floor height to help daylighting and help enhance the design by opening-up views of the floating harbour, bringing the outside in. The building is split into distinct parts defined by setbacks and changes in height which we consider can be used to enliven the building’s elevations by applying different architectural treatments to each distinct element. More emphasis could be given to the external architectural treatment of the common area rooms on the corners of blocks. We note the architect’s intent to reference the historic use of the site (a Vitriol Works - creating brightly coloured chemicals) by use of coloured glazed bricks in key areas of the building, however, the extent is so minimal that bland grey brickwork predominates and presents a colourless and uninspiring building with no relationship to the Bristol red brick and stone vernacular. There is a lost opportunity with the landscaping proposals. There seems to be too much hard landscaping and not enough trees, rain garden areas and soft landscaping. The idea of fencing off the courtyard is wrong; the public should be allowed to venture into this space from the harbourside walkway to encourage the mixing of students and the local population. It is good that sustainability is a major factor in the design proposals, and we will be keen to see and read about the actual sustainability proposal in due course, especially the whole life carbon analysis and the sound /noise surveys. Further comments, January 2025 The context elevations and views shown in the TVIA show that the building proposed is bland, too high and overbearing in some views, which confirms our earlier comment that the scheme is poor aesthetically and does not relate to the history of the site, particularly disappointing as the site is in the Silverthorne Lane Conservation Area and adjacent to the listed Marble Works. We agree with Historic England that ‘there is little architectural texture in the articulation of the proposed elevations, as these appear as a flat veneer with no depth to framed banks of fenestration or accentuation of the string courses and pilasters’ and that the design approach to the elevations ‘should be significantly revised, to provide a meaningful and clearer response to the character and appearance of the Conservation Area…..through greater horizontal emphasis and articulation of the blocks and a more contextual material palette.’ We note that in the Statement of Community Involvement three (of four) responses to the public consultation take issue with the appearance of the proposed buildings. 1. the grey exterior looks so dull. Your previous developments (e.g. Wilder Street & New Bridewell) look a lot nicer. 2. the facade treatment and external design is extremely bland and dated. The current massing seems

sensible, stepping down towards Motion, but desperately needs some more inspiring materiality/facade treatment. 3. Thomas Heatherwick‘s book called ‘Humanise’ outlines how so many buildings these days are dull and boring. Your design fits into this category. Consider adding detailing to the facade to give it more character. Make it less uniform. It looks like a prison, or an excel spreadsheet. Those small little windows look quite depressing. We agree with these observations that confirm our earlier comments that reconsideration of the design of the elevations is imperative. It should be noted that the scheme in Wilder Street was the recipient of a Bristol Civic Society Design Award in 2022. The award panel citation applauds the varied facade treatments of the scheme and advocates it as a model for future student accommodation developments. We have reviewed the Noise Impact Assessment and noted the introduction of wintergardens to student bedrooms on the north-eastern elevation as an acoustic device to counter the noise from Motion Nightclub. We are surprised that the wintergarden space is counted as part of the room area, which is bizarre as it appears to be only 0.7m wide and unusable. We consider that the inner wall should be the solid wall and the outer wall the glazed wall, which would then be expressed externally as a different architectural treatment, so enliven the building’s elevations. We have reviewed the daylight and sunlight report and note that a good level of daylight is achieved in most rooms, however, the inclusion of the future building on the site on the opposite side of the path to the proposed footbridge over the river has a significant negative effect on daylight in the rooms facing the path. This negative effect could be overcome by enlarging the windows, which would also enliven the building’s elevations. We consider that there must be a fundamental rethink of the elevational treatment of this building to respond to the character and appearance of the Conservation Area. There needs to be greater horizontal emphasis with a more clearly defined base, middle and top to the elevations and different architectural treatments applied to distinct parts of the elevations as defined by setbacks and changes in height. The dull grey brickwork needs to be replaced by a more contextual material palette reflecting the Bristol red brick and stone vernacular. www.bristolcivicsociety.org.uk Registered charity No. 244414

The Panel considered that the proposed development would not preserve or enhancethe character of the Conservation Area, and would lead to adverse impact to the setting of aGrade II listed building, the Marble Mosaic Works, due to its scale, massing and design. Thebuilding would be too tall, and the elevations need to be articulated to provide a clear bottom,middle and top. More weight needs to be provided to the comers of the building.There is no active frontage proposed, and the development does not meet any of the principles ofthe Urban Living SPD. The historic pier that is proposed to be retained at the edge of thepavement would have no context. The harm that would be caused to the Conservation Area is notoutweighed in the balance. The Panel objects.

BTF Comments – 04 December 2024

2

Broad Heathland and shrub habitats are identified in the UKHab as a category of h3 Dense

scrub, which is defined as ‘patches of shrubs that are <5 m in height with continuous (> 75%)

cover.’ h3h Mixed scrub is defined as ‘comprising a mixture of species without a single species

dominant or stands with dominant species not listed in h3a-h3k.’2

The applicant’s arboricultural evidence identifies three tree features growing along the edge

of the canal:3

Tree

Number

Tree

Count Tree Species Scientific Name

Height

(m)

Number

of Stems

Stem Ø

(cm)

T1 1 Goat willow Salix caprea 4.5 MS 21

T2 1 Goat willow Salix caprea 6 MS 83

G1 14 Dogwood, holm oak

and buddleia Various 5 MS 13

While tree T1 might be designated as Mixed scrub habitat, because it is only 4.5 metres high,

the applicant has chosen to designate it and T2 as Individual trees habitat.

However, the applicant has designated tree group G1 as Mixed scrub habitat. This is incorrect

because it does not meet the UKHab definition – it is not less than 5 metres high. It is Urban -

Individual trees habitat. On this basis these three trees have a habitat area of 0.0977 ha.

We have reduced the baseline Mixed scrub habitat area by 35% to 0.013845 ha in light of this,

though this causes a small mismatch between the combined ground-based pre and post-

development habitat area that will need to be adjusted.

Strategic Significance

Urban trees are given express protection under the local Plan – BCS9 and SADMP DM17. On this

basis we have assigned both these baseline and post-development habitats as having high

strategic significance.

Individual trees habitat creation

The applicant will plant ‘approximately’ small BNG category 26 trees in the post-development

phase. The arboricultural evidence states that 18 trees will be planted at ground level and a

further eight trees on the root terrace. We assume that these will be in some sort of planter.

Trees in planters should not be designated as Individual trees habitat. Instead, they should be

classified these as part of the Urban Ground level planters habitat though, of course, they

would not be on the ground. We have excluded these eight trees to be planted on the roof in

our Individual trees habitat calculation, though we accept they should be given some sort of

habitat value.

2 UKhab Ltd (2023). UK Habitat Classification version 2.0 - https://ukhab.org/. 3 24_04568_F-ARBORICULTURAL_IMPACT_ASSESSMENT_AND_TREE_PROTECTION_PLAN-3805204

BTF Comments – 04 December 2024

3

The post-development habitat creation delay

There is going to be a delay between the baseline habitats being removed – we assume in the

demolition phase – and the new habitats being created so have factored in a two-year delay for

habitat creation.

The net gain calculation

On the basis of the changes set out above, we calculate that there will be a net loss of area

biodiversity of 20.33%, with a shortfall of 0.31 habitats on the assumption that a 10% net gain

target has been used.

In addition, there is a breach of the trading rules caused by a shortfall of 0.66 habitat units of

Individual trees habitat. This will also need to be addressed.

BTRS

We calculate that 14 replacement trees will be required under SADMP DM17 and the Bristol

Tree Replacement Scheme SPD (BTRS) to replace the 14 trees that make up tree group G1.

However, as the applicant plans to plan more than 14 on site, no offsite compensation will be

necessary.