TRESA supports the objections raised by a Totterdown resident (set out below) in relation to the inadequately ‘revised’ development proposal on the old Bart Spices site at the corner of St Lukes Road and York Road. Please submit objections (‘make a comment’) here: 21/06878/F | Mixed-use redevelopment including 221 residential (C3) units and 651 sq.m. of commercial floorspace (Class E) on ground floor, together with a new vehicular access off Mead Street, cycle and car parking provision, private amenity space, servicing arrangements, landscaping, public realm, and associated works. | Land At Corner Of York Road And St Lukes Road Bedminster Bristol BS3 4AD
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Planning Application at York Road, ref. 21/06878/F
I understand that revised proposals have been made for this application. Having had a look at the proposals, I am disappointed to see that there have been very few substantive changes and I wish to continue to object to this proposal:
The design is still poor
The proposals are over-large and over-height
The proposed housing density is too high
Insufficient weight has been given to noise, air quality, community or environmental concerns
Alterations in Design
Although there has been a slight reduction in the number of units, from 244 to 221, this has resulted mainly from reducing the height of ‘Block A’ nearest to St Lukes Road by a single storey, and by removing a few flats from the opposite boundary, which would never have been viable in the first place.
Sadly, the towers still loom over the street and their surroundings in an overbearing way. Almost all public realm has been given over to very tall buildings too close to the boundaries. The overall appearance is blocky and grim. Removing the dark grey metallic cladding by changing it to matching brick only serves to emphasise the monolithic nature of the blocks.
The reduction in height of one block by one storey represents a marginal improvement on a scheme which is fundamentally flawed and does little to ease the sense of oppression on nearby buildings, all of which are lower and some of which are Listed. The remainder of the blocks remain over-tall.
The revised statement on Daylight states that light levels within apartments will be improved over those previously indicated by changing the paint reflectance. This is not a legitimate improvement.
Impact on Occupants
Single aspect flats face each other in vast walls only 18m apart but 34m high leaving no privacy for 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 and windowless lift shafts at the other. A revised statement claims that only 47% of the flats are now single aspect. However, many of the flats claimed to be dual aspect have a single small window facing sideways onto a recessed balcony as their only claim to this, and several have as their second aspect the unfortunate blank well created on the north-east side facing the Royal Mail sorting depot.
I note that design change of introducing this well has also prevented the flats in this block having access to an alternative means of escape, which is undesirable. Single stairs should not be shown without additional lobbies as these are, or continuing into the basement floor unchecked as this is contrary to government guidance and a likely fire hazard.
Building Height and Affect on Surrounding area
The enormous height of the proposals would dominate the local landscape and obscure one of the most famous and iconic views in Bristol. The submitted view from Temple Meads Approach illustrates this starkly. Other views, although chosen to show the buildings in their best light, clearly illustrate the damaging and overbearing effect on this part of the City, and the obscuration of views of the iconic escarpment.
Although submitted drawings do not indicate it, the upper floors would look down upon nearby houses 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 and York Road.
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 touching distance apart across a man-made crevasse. This is an unacceptable approach, blighting nearby landowners.
Design statements and elevations seek to draw comparisons in height with existing flats across the river but fail to acknowledge the location of those buildings which are set back from roads in a relatively 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 major road and pedestrian route as well as the nearby topography. It is bland and anonymous and appears to have been designed in isolation from the City altogether.
Planning Strategy
The City Council is developing a planning strategy for this area in conjunction with the Whitehouse Street area, which would hopefully establish some relevant guidelines in consultation with local residents and businesses. Presumably the current scheme is designed to jump the gun on this and should certainly be refused until a proper strategy for re-development is established.
The Whitehouse Street area has an emerging strategy which includes recommendations on heights of buildings, and there is every reason why the Mead Street planning strategy should do the same, being a more sensitive site.
Density & Urban Living SPD
The proposed density according to numbers submitted with the application would still be over 500 dwellings per Hectare, not including the extensive commercial and servicing areas on lower floors.
The Bristol Urban Living SPD – Making Successful Places at Higher Densities indicates that an upper limit of about 120 units/Ha would be appropriate in this ‘Inner Urban Area’ and makes no mention of commercial activities. According to BCS20, the Totterdown escarpment, one of the highest density urban areas in Bristol contains 120 dpH. The proposal for more than 4x this would clearly be excessive with overcrowding and poor social outcomes resulting.
The Urban Living SPD also states that ‘a poorly designed tall building can have a detrimental impact on the historic townscape of a city like Bristol’ and ‘ the topography and skyline of a city like Bristol.’ This proposal would do all of that if permitted to proceed.
Light Levels
The Internal Daylight Assessment indicates that many of the apartments will be miserably dark with those on the lower levels having low light levels and almost no view of the sky, yet concludes this would be acceptable. There is also an assumption that the remainder of the site would remain undeveloped, and relies on having surrounds which are single storey to achieve the results that it does, something that is mostly unlikely to remain, and which is referred to in the Design and Access Statement.
Changing the chosen paint type in the revised Assessment is unlikely to lead to any real-life improvements.
The report on overshadowing nearby properties indicates that the new development would completely blight and overshadow the closest buildings which are within the Bedminster Conservation Area, as well as blocking winter sunlight from existing flats across the river, yet again concluding that this will be acceptable.
Pollution
The Health Impact Assessment submitted with the application completely fails to identify an air pollution strategy or address problems beyond identifying that there may be one, despite the site being directly on a busy road within the Air Quality Management Area. The size and bulk of the building would contribute to trapping polluted air within close proximity, exposing pedestrians, road users and residents to unacceptable levels of pollutants.
It also concludes that residents at first floor level would be subject to dangerous levels of atmospheric pollution, and makes no mention of the occupants and visitors to the ground floor commercial spaces who would also be exposed, including those shown as sitting outside by the side of some of the most heavily polluted roads in the city.
Wind Speed
The Wind Desktop Appraisal acknowledges that no wind tunnel or CFD study has been done. It speculatively 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 the unique topography of the area and the river valley. The conclusions that there would be little adverse impact of wind funnelling on the surrounding roads, paved areas and residents are laughable to anyone familiar with the locality.
The revised appraisal indicates that it will be necessary to keep the existing trees to mitigate wind speeds to near-acceptable levels. It does not state if this refers to the trees already removed from the site.
Trees
The Tree Survey locates and classes all existing trees on the site and recommends that all except one should be kept, preferably with the surrounding green space. However the proposed scheme removes 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 the 11-storey cliff faces of the buildings. Claims in the Ecological Assessment that landscaping and biodiversity would increase by removing all trace of existing trees , shrubs and greenery are not credible. No mention is made of bats which are known by residents to inhabit the area and use the river and escarpment for feeding and as a travel corridor. The proposals are very likely to interfere with current bat transit and roosting.
Noise
The 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 their windows sealed shut, with artificial ventilation, though no proposals are made as to how this would be done. This type of design is generally considered unacceptable by current standards. There is no consideration of the considerable impact the residents would have on each other, or other nearby residents, facing a wall of other flats a short distance away with open balconies likely to give rise to considerable disturbance. This type of design is deeply flawed and known to give rise to many complaints. The proposed adjacent seating and café areas are only likely to make matters worse.
Townscape
The Heritage Townscape and Visual Impact Assessment praises its own scheme yet somehow manages to miss the evidence of its own carefully selected and presented photomontages – that the scheme represents an awful blot on the landscape viewed from almost any angle and lurks over the nearby city in a threatening manner, blocking or spoiling views of the famous escarpment from almost all angles, and sitting uncomfortably beside the listed structure of the foot bridge.
Sustainability
The Sustainability Statement claims great things in terms of energy saving, yet fails to mention that buildings above six storeys are known to become progressively less efficient and more energy intensive the higher they go while introducing long term maintenance problems.
Parking
The Transport documents and Design and Access Statements do little to address the parking problem thrown up by the development, other than stating that little parking would be required. 14 disability standard spaces are allocated to flats leaving 29 spaces for the remaining 207 flats as well as the commercial spaces. Expectations that residents, visitors and staff would not have motor vehicles are unrealistic and there is no nearby on-street parking at all. The only proposed solution is for overflow parking on the Totterdown escarpment, which local residents will be able to identify as ridiculous due to the non-existence of available spaces.
Waste Disposal
The Operational Waste Strategy is unsatisfactory, requiring tenants to take their segregated waste up to 10 floors away and relying on building management to place all of the bins in collection areas. The Strategy is also in direct conflict with the Landscape design as it shows the main bin area collection site exactly on the site of a large raised planter. This anomaly has not been corrected in the revised design.
Infrastructure
There is no mention of any infrastructure beyond the immediate site being provided, despite the additional 221 homes proposed, which are also part of bigger plan for the Mead Street site that could see more than 1200 new homes. Figures produced with the application show that the developers expects very few children to be present in the flats, although it is claimed the private courtyard would provide play facilities. The Bristol City calculator indicates that there would probably be between 26 and 87 children living in the development. Details also state that there are a 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 Involvement
Sadly, the Statement of Community Involvement is just that – little more than a statement. It quotes percentages of answers to leading questions designed to elicit apparently positive responses, while making little of any negative concerns expressed. This is not community consultation, and does not reach the standards of the City Council guidance.
Conclusions
Conclusions of many of the documents submitted with the proposal amount to little more than the applicant marking their own homework and have produced hopelessly optimistic outcomes based on little evidence.
The scheme as presented is so deeply flawed in all respects that planning permission should not be granted under any circumstances. It would lead to poor health, social, visual , urban and civic problems and would also be a 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.