Another application has been submitted for the former Bart Spices factory site.
TRESA’s objection is reproduced in full below.
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TRESA objects to this application.
The applicant indicates that two changes are proposed to the scheme that was consented in 2022:
- The addition of external walkways to the eastern elevation of Block C to achieve fire regulation compliance; and
- The reduction of the Affordable Housing provision from 30% to 20% to reflect the scheme being a Build-to-Rent development.
EXTERNAL WALKWAYS
The Health and Safety Executive (HSE) has not considered the application since July 2022 i.e. more than two years ago. It is important that the HSE is consulted and provides an opinion on fire safety, particularly for Block C. At the moment there is only a fire safety report commissioned by the developer which states: “The latest updates to the submission introduce an alternative escape for all apartments by means of an external escape gantry/balcony connecting the two cores. Levels 02 to 10 are served by the external balcony.”
When this was incorrectly proposed as a ‘non-material amendment’ for a previous application, objections were submitted about the design and safety of the external walkways and the implications for residents. It is not clear how use of the walkways can be restricted to emergencies only. The temptation will be to use the walkways as ‘balconies’, for informal storage, or as walkways in non-emergency settings. This would not only present a fire hazard, but also invade the privacy of residents whose windows face the walkways.
The potential for inappropriate use is clearly known by the developer who has proposed wording for a New Condition 51: “Prior to the occupation of the development, a Fire Escape Management Plan shall be submitted to the Local Planning Authority and approved in writing. The Fire Escape Management Plan shall confirm the locations of all fire escapes within the proposed development and provide details of the measures that will be implemented to ensure that these doors are not opened outside of an emergency scenario, except for maintenance or other official purpose.”
Government guidance (Fire_Safety_in_Purpose_Built_Blocks_of_Flats_Guide-update.pdf (publishing.service.gov.uk)), indicates: “Escape routes from flats in some older blocks may involve forms of alternative exit, such as linking balconies and pass doors, that are no longer recommended.”
We reiterate our concern that the original application was approved without due consideration to fire safety. This has led to subsequent questionable attempts to address the existing design faults without due consideration to the quality of life and safety of residents.
It is imperative that the proposal for external walkways as a fire safety measure be considered by the HSE. It is not something that should be approved through informal discussion between the developer and a senior planning officer (as was suggested in the covering letter from the developer’s agent).
REDUCTION IN AFFORDABLE HOUSING
A key reason why the consented scheme was approved, against the recommendation of the planning officer, was because it provided 30% affordable housing. The officer’s report indicated: “The applicant has confirmed that 30% of the dwellings would be offered as Affordable Private Rent as part of a wholly Build to Rent scheme. The policy requirement of 30% affordable housing would be secured by s106 agreement. This application can only consider the policy compliant offer, and any planning consent would be able to secure the policy compliant offer only.”
When the application was approved by Development Control Committee A in 2022, on condition that fire safety issues would be addressed, there was no suggestion that this should be achieved by reducing the percentage of affordable housing.
OFFICER’S RECOMMENDATION TO REFUSE THE ORIGINAL APPLICATION
We continue to share the following concerns raised by the planning officer who recommended in 2022 that the application be refused:
(1) The design quality of the scheme is poor – there is a high proportion of single aspect dwellings which would have a poor outlook, receive limited light levels and require higher energy consumption, which arises from the overdevelopment of the site. This would result in a poor living environment for its occupiers and would fail to meet liveability criteria sought by recently approved council guidance, which seeks to achieve a liveable environment for future occupiers when developing at higher densities, and as a result fail to meet the requirements of the NPPF, policy BCS21 of the Core Strategy 2011, and policies DM26 and DM29 of the Site Allocations and Development Management Policies 2014.
(2) The excessive height, bulk and massing would result in less than substantial harm to the setting of the adjacent Bedminster conservation area, and this harm would not be outweighed by any public benefits. In view of the over development of the site the overall design quality is compromised, and the proposal fails to integrate itself positively into the city streetscape and skyline. As such the proposal fails to comply with the NPPF, policies BCS21 and BCS22 of the Core Strategy 2011 and DM26, DM27, DM28 and DM31 of Site Allocations and Development Management Policies 2014.
(3) The development would have an unacceptable impact on highway safety in view of the requirements for servicing and reduced footway widths that would be required around the site to accommodate the development. This would prejudice pedestrian safety, introduce unappealing and unsafe circulation and movement function, contrary to the NPPF, BCS10 of the Core Strategy 2012 and DM23, DM27 and DM28 of Site Allocations and Development Management Policies 2014.
(4) The development would fail to mitigate its impact through contributions towards site specific highways improvements that would benefit the growth of the city, and as such would be contrary to the NPPF and policy BCS11 of the Core Strategy 2012.