Key issues for Totterdown, in Active Travel England’s comments relating to L&G’s proposals for Temple Island, are set out in the extracts below.
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Notice is hereby given that Active Travel England (ATE)’s formal recommendation is as follows:
Deferral: ATE is not currently in a position to support this application and requests further assessment, evidence, revisions and/or dialogue as set out in this response.
Background
Active Travel England (ATE) welcomes the opportunity to provide recommendations on the above proposals which comprise a significant opportunity to regenerate a former brownfield site while contributing towards improved accessibility for the area and insodoing delivering sustainable development where active and sustainable forms of travel become the natural first choice for journeys to and from the site.
In total, the proposals seek outline consent for eight buildings comprising just under 45,000sqm of office space across two blocks, a 163-bedroom hotel / conference building, the provision of flexible commercial uses including retail, food and drink, and four residential blocks accommodating 520 apartments. One of the office buildings is submitted for full (detailed) planning permission.
On the basis of the above quantum of development, it would be reasonable to expect the development to provide living accommodation for a new residential community of around 1,000 people in addition to the site providing jobs for a stated 2,400 employees in addition to visitors to the hotel, conference and other facilities on site.
Summary
ATE has reviewed the proposals and summarises its response below:
- Transport Assessment – The trip generation analyses presented within the Transport Assessment (TA) is incomplete. The quantum of movements by walking, and cycling has not been assigned to the local network any farther than the immediate access points and therefore fails to convey wider movement demands.
- Surrounding area – While the applicant has undertaken a reasonable assessment of the quality of local environment, the numerous deficiencies highlighted in the TA and Design and Access Statement (DAS) cannot substantiate the assertions made that a) the accessibility of the local area is ‘excellent’, and that b) the development is likely to be acceptable “without any additional physical transport infrastructure”. This is not a credible position and is considered out of step with the updated National Planning Policy Framework (NPPF) paragraphs 96 and 115 and the policy expectation to deliver safe, inclusive and accessible infrastructure to serve the development, given the 8,000 additional daily walking and cycling movements the development will generate.
- Off-site Infrastructure the application appears to rely heavily on infrastructure to be delivered or partially funded by neighbouring projects and planning applications while offering no specific financial or physical contributions of its own, other than within the site itself. Whilst the internal benefits are recognised, no attention has been paid to addressing the deficiencies highlighted in the submitted DAS and TA.
- Relationship / access to the A4 Bath Road – the limited detail around the site’s interface and relationship with Bath Road does not sufficiently demonstrate how the development will compliment, contribute to and benefit from emerging proposals to improve what is currently an extremely poor environment. Information on the proposed lift and stepped access to Bath Road is absent and fails to provide the necessary comfort that the site will be accessible and inclusive.
- Trip Generation and Assignment – Critical Issue
The submitted Transport Assessment (TA) provides a detailed numerical analysis of the movement demands of the site, relative to each use and each mode of travel but fails to illustrate or assign these flows to the local network in sufficient detail as to provide an evidence base upon which to assess the quality of local routes.
The applicant is required to provide daily and peak hour two-way assignment plots for walking, cycling and public transport movements that illustrate the distribution of trips associated with the development, as has been usefully provided by other similar developments, examples of which ATE is happy to share.
The application proposals are forecast to generate 7,102 walking (including public transport) and 1,204 cycle trips, compared with 714 trips associated with car or taxi travel, emphasising the site’s location and reflecting the low availability of parking.
While the above is positive, the TA only briefly refers to the direction of these movements in Figures 7.5 and 7.7 which fails to convey the extent of impact upon local routes, presenting the figures in pedestrians/cyclists per minute (presumably limited to the peak hours) while only considering the broad exit points of Cattle Market Road, Feeder Road and Temple Meads Station.
Off-site infrastructure – Critical Issue
While the development aims to provide a high-quality public realm within the red line boundary, the same cannot currently be said for much of the area that surrounds it, warranting the need for a qualitative assessment of the key routes set out below as agreed with ATE during pre-application discussions.
The TA includes an Active Travel Zone Assessment (ATZ) which is included within the appendices alongside further commentary at TA sections 3.3.19 – 3.3.23. TA Figure 3.9 confirms the scope of the route assessment agreed with ATE relative to a number of off-site destinations including schools, parks, colleges, bus stops and leisure facilities. This assessment is crucial given the movement demands created by the development that currently do not exist.
The ATZ confirms a number of locations where the quality of current infrastructure is largely unfit for purpose to serve the needs of up to 1,000 new residents as well as the 2,400 that will be employed within the development, and collectively accounting for over 8,000 new trips each day. Recurring themes involve safety and personal security, together with a lack of crossing facilities, segregation for cyclists and along some routes the volume and speed of traffic, which further negatively impacts the attractiveness of local infrastructure. Each of these factors serve to discourage people from travelling by active modes, but in locations where the opportunities to move around the local environment to access open/green space are limited, this also gives rise to social isolation and mental /physical health concerns.
Route 4 – Avon Riverside path (to Paintworks)
ATZ summary: lack of personal security, dark, lack of places to stop, unwelcoming - The TA references the West of England Local Cycling and Walking Infrastructure Plan (LCWIP)’s stated intention to improve this route, on the assumption that this would be funded by the later redevelopment of St. Phillip’s. However, this would have been written a considerable time before the proposals were emerging for Temple Island. The opportunity this route provides for access to the proposed development should therefore not be overlooked, particularly given the access this provides to the areas of Paintworks and further into Brislington, in avoidance of Bath Road, and the barriers to cycling including the proposed lift and steps, the steep ‘corkscrew’ access or the circuitous route via Cattle Market Road.
- The wider St Phillip’s development is some time away and the LCWIP assumption is not considered sufficient grounds to absolve this route from consideration for funding from the current development where there are identified issues of personal security that will deter walking and cycling, with particular attention to the safety of women and girls. There are clear opportunities for an improved, fully lit and widened / surfaced path where achievable between the site and Sandy Park using this route.
- Route 5 – As route 4, then via Albert Road (to Paintworks)
feels unsafe, no resting points, T-junction difficult for active travel, traffic volumes - In addition to the riverside path, attention should be applied to Albert Road between the development and its junction with Bath Road at Totterdown Bridge. The outcome of the ATZ assessment in respect of this route does not substantiate the claim (TA parag 10.1.2) that the development is “highly accessible by all sustainable modes”. No proposals are put forward to address these deficiencies.
- Route 6 – Wells Road via Park St / School Rd to Totterdown / Knowle
steepness of route, lack of step-free access, poor quality benches / resting places, physically challenging - The route assessed here is steep in places and will present a barrier to a number of users, but not all. While existing gradients are not something that can be easily addressed, a number of helpful interventions are however referred to within the assessment including street lighting, the provision of new benches and revised parking arrangements that would make this route more tolerable for the sizeable community to the south-east of the site that would rely on this route.
- Elsewhere, connectivity to the city centre along the A4, and as acknowledged by DAS p27 “is dominated by cars” and provides a “…poor pedestrian and cycling connection to Bristol” (DAS p61). Further consideration is required here, and similar to concerns raised later how the site interfaces to the A4 (and connects to any improvements) is at the moment yet to be demonstrated.
- Route 7 – Wells Road to St John’s Lane
crossings do no meet desire lines, unwelcoming environment, high traffic volumes, cycles sharing with buses - Route 8 – York Road / St Luke’s Road to Victoria Park
inability to cross, unpleasant tunnel experience, poor lighting and drainage - The ATZ highlights a number of deficiencies along both of these routes. It is therefore for the applicant to demonstrate, either how a) any wider strategic proposals are likely to either address these deficiencies or b) provide its own strategy for improving access, given the application will result in considerable movement demands from the directions of Wells Road, York Road and St John’s Lane to reach the residential areas of Windmill Hill, Knowle, Totterdown and beyond, in particular view of the difficulties of access identified along Route 6.
- These routes represent the most likely opportunity for residents of the development to access sizeable green space and play facilities (as illustrated in the DAS p51 53). Access to green space is widely accepted as of key benefit to maintaining positive physical and mental health outcomes, as highlighted in the recent Government Chief Medical Officers Report entitled: Health in Cities of December 2024 where recommendation 7 reads: “Making walking and cycling more practical and safer, and access to green space easier and more equitable, would go a long way toward removing barriers to improving physical activity levels and could significantly improve the health of England’s increasingly urban population”
- Improving access to such areas should therefore not be considered an optional extra or a low priority, but in view of the findings within the National Travel Survey (2023), where the number of leisure-related movements far outweigh those of commuting, improving the quality of linkages along this route should not be overlooked.
In summary, and while the above analysis provides only a partial summary of the worst areas of infrastructure, it provides a flavour of significant areas of surrounding public realm that is either secluded, unsafe, unattractive and inaccessible for the vast majority of users due to issues of gradient, seclusion, lack of surveillance or absence of separation (or protection) from motorised traffic.
In the spirit of the commitment made within the DAS p63 to “creating accessible and inclusive places that encourage sustainable travel choices giving priority to pedestrians and then bicycles”, this should not only apply to the areas within the red line boundary but must also consider (and enhance) surrounding routes given the significant additional movement demands that will be generated by the development. Far greater consideration and dialogue is required of the routes surveyed relative to the two-way demands created by the development throughout the day.
Relationship with A4 Bath Road
While it is welcomed that the application upholds the values of providing active frontage within the site and a number of the ideas and suggestions within the Active Frontage Strategy (DAS p163-172) are supported, what is less clear is the relationship between the development and the A4 Bath Road and how these proposals compliment, enable or contribute towards (either physically or financially) the emerging proposals to improve what all would agree represents an incredibly poor environment for all users. - Mention is made of the strategic expectation to provide cantilevered path alongside the A4 to widen/improve the environment in this location with reference made to the development not precluding its delivery (TA parag 4.2.3). However, no details are shown of how the application masterplan, and the lift and staircase facility has been designed to successfully coalesce with the emerging proposals for the A4 to
deliver a safe and accessible and attractive environment, other than to say that the buildings will be ‘set back’ from the road to enable the A4 works to take place. - Consequently, and as a result of these questions remaining unanswered, the potential resultant outcome, as illustrated on DAS p93 remains particularly bleak and unwelcoming for employees, visitors and residents of the development who would rely on this infrastructure.
- As yet, and potentially due to the absence of drawings/proposals being made available, it is difficult for this development to demonstrate in this instance how it will deliver an effective new gateway to the area, but more widely how this fulfils the pledge made within the DAS p60 for the site to “become a catalyst for the ambitious transformation planned across St.Philip’s Marsh”.
- In the interests of assessing the proposals against wider infrastructure strategies and the ability to demonstrate cohesion between projects, ATE would expect to see at the very least a composite plan of how the proposed development will interact with the A4 and form strong and attractive linkage to the wider area as is promised, and not, as referenced below treating this opportunity as a highway mitigation scheme that is not necessary to make the development acceptable.
Lift / Stepped access to Bath Road
As above, and while considered a key gateway to the site, detail on this aspect of the design of this is scant and largely absent from the proposal. For instance, the application neglects to demonstrate how the lift and accompanying steps meet the circulatory street layout (DAS p125 / TA Figures 6.8, 6.9 and 6.11), nor how the landings, gradient or steps comply with requirements for inclusivity. This could potentially be a symptom of the outline application being submitted with ‘all matters reserved’ but also in advance of further information on a scheme for the A4. - Further to the above, it is rather odd and of potential concern how TA parag 6.5.4, in consideration of a link that promises such a vital connection to the south and west of the site to view this facility as “not required to mitigate the impacts of the development in transport terms” and therefore asserting this linkage as an optional masterplanning extra rather than a necessity to promote permeable and inclusive access to a major development from / to the south and west. Some comfort is therefore required as to the applicant’s ambition here.
- It would also be helpful at this point if examples were provided of where similar lift /steps arrangements have been successful. In the absence of an ability to use the lift (either through poor maintenance, vandalism, neglect or malfunction) this will not deliver an inclusive and accessible environment. This will represent a barrier from the south and west for wheelchair and mobility scooter users in addition to those
pushing buggies, and therefore excluding several sections of the community from the site. The ability to use the opposite footway to access the corkscrew access is inconvenient at best given the gradients that exist. - Given the importance of providing an inclusive and accessible environment in line with the requirements of the Equalities Act, Inclusive Mobility, and the Public Sector Equality Duty (PSED), it is considered that these matters require further consideration and should not be left to the consideration of a separate and isolated reserved matters submission.
Travel Planning and Parking Impacts – Concern
Subject to creating the correct conditions in and around the site in way that prioritise walking, cycling and public transport as the most, safe and attractive option for travel, the proposals stand a reasonable chance of exhibiting a high reliance on sustainable forms of transport as per the aims of the Travel Plan. The mode share baseline figures identified within the Travel Plan are supported in principle but are only likely to occur as a result of investment in local infrastructure together with the necessary parking restraint measures in the local area.
ATE understands that financial contributions have been sought from neighbouring developments towards restrictive parking measures in the surrounding area but seeks greater information on the progress of these initiatives, given the potential for uncontrolled overspill parking from the site during all times of the day to result in footway parking, the hindrance of visibility, obstruction to crossings / accesses and a level of car reliance and increased congestion beyond what has been forecast within the TA. This is an increasingly likely outcome should the site become occupied in the absence of the necessary measures in the surrounding area, undermining the sustainability credentials of the site.
Next Steps
It is requested that these comments are forwarded to the planning case officer and shared with the applicants and their agents. ATE is therefore happy to be involved in future discussions with the applicant in addition to planning / highway officers at BCC as necessary.
It is important that the package of infrastructure necessary to support an accessible, safe and inclusive new community is got right and suitably informs planning conditions /obligations with the correct timing and triggers. This will enable and continue the step change in the quality of local infrastructure that is required to support major sustainable development in this area, while aligning with wider strategic interventions and complimenting neighbouring contributions and works in a way that is both joined-up and holistic.