The following has been submitted to Bristol City Council planning department, arguing that an environmental impact assessment is needed for the current proposals (including a 2+19 storey tower) at Princess Street, Bedminster. This tower will be an overbearing addition to numerous views from Totterdown, Victoria Park and surrounding areas.
_____
25/10173/SCR Princess Street Bedminster Bristol BS3 4AG
Demolition of existing buildings and redevelopment to provide up to 460 dwellings, up to 420 purpose-built student accommodation bedspaces, up to 1,400 sqm of Commercial, Business and Service floorspace (Use Class E), amenity spaces, parking, servicing, landscaping, open space, play space, and associated works. Buildings will range in height from 6 to 19 storeys
Totterdown Residents Environmental & Social Action (TRESA) has read the EIA Screening Opinion Request, which we consider to have been written to persuade the reader that an Environmental Impact Assessment is not required. We strongly disagree for the following reasons.
The proposed ’19-storey’ tower is actually ground + mezzanine + 19 floors i.e. 21 storeys. This is entirely out of proportion to other buildings in the area, and is likely to harm the townscape and existing views.
Below, sections of the EIA Screening Opinion Request are considered which identify potential problems with the current proposed development. We believe these should be subject to an independent Environmental Impact Assessment.
Are there any areas or features on or around the location which are protected for their landscape and scenic value, and/or any non designated / non-classified areas or features of high landscape or scenic value on or around the location which could be affected by the project? Where designated indicate level of designation (international, national, regional or local).
The applicant has indicated “Yes. The Whitehouse Street Regeneration Framework… identifies a number of views to be considered when preparing development proposals. This includes a pedestrian view across the site from a plaque located within Victoria Park as well as a number of views from roads and bridges along the River Avon. Victoria Park is a well-used recreational resource within the local area.”
Is a Significant Effect Likely?
The applicant has indicated “No” and goes on to say “The height, scale and massing of the scheme has been developed to reduce its visual impact on the townscape. Effects on landscape and visual receptors can be reduced through the integration of appropriate urban design principles underpinning the site wide masterplan, and high-quality design proposals for mixed-use development. While it is acknowledged that the Proposed Development would represent a change in the height/scale/massing in the buildings at the Site, this increased height is supported by the Regeneration Framework and will be assessed as part of the Application. Given the urban setting, it is considered that the Proposed Development can be accommodated within the local townscape with appropriate design and massing measures. Townscape and visual impacts will be assessed within that TVIA that will accompany the Application, but based on the above, the potential effects are not considered to be of a significant level that would warrant EIA.”
We strongly disagree that the effect is NOT likely to be significant. Height and massing was one of the key issues when the Whitehouse Street Regeneration Framework was developed. A building of up to 10 storeys was a possibility; 21storeys is grossly out of proportion and will have a significant effect.
Is the project in a location where it is likely to be highly visible to many people? (If so, from where, what direction, and what distance?)
The applicant has indicated “Yes. The proposal will be visible from a range of visual receptors within Bristol. Those locations considered of relevance for which to prepare Visually Verified Montages or wireframes for inclusion within the Townscape and Visual Impact Assessment include: • Victoria Park plaque • Bath Bridge Roundabout • Bedminster Bridge Roundabout • Bedminster Station • From the southern edge of Perrett • View from the corner of Redcatch Road and Stockwood Crescent • View from the western edge of Victoria Park close to Somerset Terrace • View from the top of Park Street • View from St Michael’s Hill adjacent the Robin Hood Pub • View from the eastern side of Victoria Park.”
Is a Significant Effect Likely?
The applicant has indicated “No. While there will be visual changes to some receptors, effects on landscape and visual receptors have been reduced through the integration of appropriate urban design principles and a high quality design approach. Therefore, it is not considered likely that the Proposed Development would result in significant landscape or visual effects. A TVIA will be submitted as part of the Application, to allow townscape matters to be fully considered through the planning regime.”
We strongly disagree. The visual changes to some receptors will be significant. This need to be examined through an independent Environmental Impact Assessment and not left until a TVIA submitted as part of the Application.
Additional comments
In a recent public engagement activity TRESAcic submitted a response to the applicant, which included the following:
- Height: This is one of our biggest concerns and we note that it was a common concern of others who visited the ‘consultation’ event. It needs to be addressed. The 21-storey tower is totally unacceptable. It is massively over-sized for this area and will create an overbearing tower block that dominates the surroundings and adversely impact the skyline. During the consultation event the architect claimed that the Council’s Urban Living SPD was not relevant as the Whitehouse regeneration framework superseded it. This is not correct. The regeneration framework explicitly cites the SPD and in many places restates that the SPD is relevant. The framework and the SPD mention the prevailing height of this area as 3-4 storeys. So amplified height of 1.5x is 4-6 storeys. The framework mentions the possibility (not eventuality) of a contextual taller building at a particular site and suggests 10 storeys. Nowhere does the framework document mention a 21-storey tower. The framework also notes that citizens were concerned by excessive building height (page 32).
- VIEWS: The 21-storey tower will loom over the area. Although much was made in the ‘consultation’ about key views across the city from the viewing point in Victoria Park, there are numerous views that would be adversely punctuated by an ‘anywhere architecture’ oblong tower. It is worth remembering that Bedminster is a conservation area that has special character and appearance. The stated aim of Bristol City Council is to preserve or enhance them.
- DENSITY: The Urban Living SPD and the Whitehouse Regeneration Framework present optimum densities. This part of the city is clearly defined as an optimum density of 120 dwellings per hectare. This development appears to be about 850 dwellings (450+400 student units) across 1.6 ha. This is about 530 dph which is over 450% of the optimum density suggested. The SPD helpfully points out: “Recent research (Superdensity- HTA et al 2015) has shown that very high density can challenge positive response to context, successful placemaking and liveability aspirations, sometimes resulting in poor quality development.”
We, therefore, strongly object to the assertion from the applicant that an Environmental Impact Assessment is not required.
TRESAcic, www.tresa.org.uk
18 January 2025