TRESA objection to 15 storey Tower for Totterdown Bridge

Hadley Property Group purchased the empty plot next to Totterdown Bridge (The old Esso garage/car wash).  They then suggested a 12 storey tower (above road level), and despite objections the plans have become worse with the tower growing to 14 storeys, and now 15 storey above road level.  Additional blocks 6 – 8 storeys are also included along the Bath Road (From the bridge towards the Paintworks).   Plans, application and commentary available here.

This site is currently very ugly and needs development but TRESA does not support any development at any cost.  Whilst many aspects of this application are good, the sheer size and height are excessive.  Previous zoning and planning for the area suggested development of 2-4 storeys.  We would even accept up to 6 storey, but 15 is too much.

Below is the objection that TRESA has submitted to the council.  We encourage others to review the plans and comment.  Feel free to reuse any of our points.

Objection to Hadley Group planning application 18/04620/F

The Totterdown residents association (TRESA) wish to object to the application submitted by Hadley Group for 160 units along Bath Road, Totterdown (Ref: 18/04620/F). Whilst there are many elements of this application we support, we believe the proposed design is significantly detrimental to the area due to the 17 storey tower and the ugly, “could be anywhere” design.

Elements we support
We are supportive of development on this site and agree that the current view is poor. However that does not justify any development at any cost to the urban environment. We believe the shorter buildings (7 storeys) are tall, yet may be suitable for this site.
The planned improvements to public realm are also appreciated. They offer good design with active frontage and a mix of residential and commercial.
The public access with a riverside walk is also a valuable asset if the extension through to the paintworks can be guaranteed.

Contravenes Local Plan
The city wide Local Plan and site allocation detail this site as being suitable for approximately 40 units. This application is for 160 which is clearly not the intention if the plan. We do not believe that “approximately” equals 400% increase.
The plan is currently being reviewed, but until it is published, the existing document sets the precedent. However we also believe that revised plan does not suggest tall buildings at this location.
We would also draw attention to paragraph 11, section “c” of the NPPF that suggests consent be given when development proposals accord with an up-to-date development plan. Clearly this is not the case.
What is the purpose of a well-researched local plan if it can be discarded so readily just to increase profit for a developer?

Contravenes Spatial Framework (2016)
The city wide spatial framework for the Avon Riverside area clearly shows this site as having a low rise development form of 1-4 storeys (see section 3, fig 2). The spatial plan even shows a map clearly indicating where taller buildings could be developed.
The scenario testing for avon riverside also shows this site being low to mid rise (section 4, fig 30).
What is the purpose of a well-researched spatial plan if it can be discarded so readily just to increase profit for a developer?

Excessive Height
The height of the tower is our main concern – if this block were similar height to the other blocks, TRESA would recognise the overall benefits of this development
The tower building is simply too tall. It is imposing and domineering over the site and immediate neighbours. It’s singular height against the backdrop of the historic and distinctive Totterdown will create a jarring element to the scene.
The proposed tower (15 storeys above road level) meets the definition of a tall building in both the existing SPD, and the current revision which is open for consultation. Using either document, this design fails to meet the requirements for a tall building. Both SPDs state that tall buildings will be considered for the city centre. This site is not in the city centre, and there are no local precedents for a building like this.
Both SPDs and also BCS21 state that tall buildings must be of exceptional design – This does not meet that criteria. The developer claims the tower is “slender” yet that does not match any definition of that word. It is clearly bulky, blocky and ugly.
Paragraph 8 of the NPPF state that developments should “support strong, vibrant and healthy communities”. Evidence suggests that tall towers do not do this, and instead create poorly connected groups of people who feel alienated from their surroundings.
Finally, the draft SPD for tall buildings suggests reasonable density figures for areas of Bristol. The site falls within the “Urban setting” with an optimum density of 120 units per hectare. This development has 160 units per 0.5ha = 320 units per hectare. This is over 2.5 times the optimum level.

Visual Appearance
The proposed design for the tower is not suitable. It is too industrial in appearance. We have heard people say it looks like a prison! Other comments are that it looks like the East London blocks erected in the late 1960s. It does not reflect the local character of the victorian buildings opposite or the undulating nature of the site. This contravenes both SPD – tall buildings, BCS 21, and the NPPF. Paragraph 131 of the NPPF says “In determining applications, great weight should be given to outstanding or innovative designs […], so long as they fit in with the overall form and layout of their surroundings.” This design fails to do this.
The Bristol Civic Society also commented on designs during the pre app consultation and concurred by saying: “The tall building design is not good enough to satisfy Policy BCS21 – Quality Urban Design or acceptability criteria set out in SPD1 – Tall Buildings.”

Route through to Paintworks
The designs state that a future route could developed through the site into the Paintworks. During pre app consultation it was stated that this was would be included as part of the development – not simply a future aspiration.

Affordability criteria
The application offers 20% affordable housing, rather than the expected target of 30%. Hadley suggests this is due to the site being unviable so they shouldn’t really provide any affordable units. Their own cost estimates state that the large development costs are due to the excessive height. The cost analysis also shows a profit of £8m and 15% return. Although less than common practice, it is still a sizeable profit.
Hadley speculated in purchasing the site and has since found it will get less profit for a reasonable development – they are therefore trying to cram in more units to reach an arbitrary profit level. The local community should not have to accept poor quality design to offset private profits!

Poor quality consultation
The planning support statement provided by Hadley suggests that response to the designs was favourable. This is not the case and the detailed document on community consultation dances around the fact that most respondents were against the height and the style.
One of the documents from Hadley group also stated this was a “community led” design. This is factually wrong. Hadley group have treated consultations as “tick-box” exercises. There has been no serious consideration of community feedback around excessive height and the design has become progressively taller at each stage.

So in summary, we believe this design conflicts with the Local Plan, the Spatial Plan, the Site Allocations, BCS21 and the SPD- Tall Building (Current & Draft versions). The height of this development is simply not suitable for this area and will significantly change the character of the area.
We urge the planning department in BCC to reject this application due to the height. We hope the planners encourage Hadley group to think about the long term impacts of their design, and retain the positive elements yet review the need for the an excessive, incongruent tower.