TRESA has drafted a long list of objections to the development at 122 Bath Road (see below). If you agree with any or all of these points, please object to the proposal. You can do so by clicking on ‘make a comment’ on the Bristol City Council website Redevelopment of the former car wash site to provide 54 self contained residential flats, with associated car and cycle parking. landscaping and access (major). – 122 Bath Road Totterdown Bristol BS4 3ED
If you have already made a comment, and would like to add further concerns, don’t worry – you can simply add another comment.
Other ways to make your views known (the planning website sometimes has problems!) are here:
- email development.management@bristol.gov.uk
- write to Development Management, City Hall, Bristol City Council, PO Box 3399, Bristol, BS1 9NE
- contact your local councillor and send your comment through them
The proposal is for large blocks (54 flats) on the current carwash site near the Thunderbolt.
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TRESA strongly objects to this proposed development at 122 Bath Road for the following reasons.
Overdevelopment of the site
The proposed development of 54 homes far exceeds Bristol City Council’s own guidance on the density of homes per hectare. For context: planning permission was granted in 2011 to provide 11 dwellings, and before the Urban Living supplementary planning document (SPD) was accepted policy, the Council had identified this site as having an indicative capacity of 22 dwellings.
The Urban Living SPD shows this area as ‘Inner Urban Area’ with an optimum density of 120 units per hectare, but the proposed development equates to 540 dwellings per hectare. Using the council website Pinpoint, the area appears to be 0.11 hectares, so optimum density would be 12 units. This application is for 54 units, which is 4.5 times (450% over) the current target density.
Negative Effect on Local Character, Appearance and Context
The proposed design and construction of this development would be detrimental to character and appearance of the Totterdown district. The building design itself does not share any design features or characteristics with the surrounding area. It is of no architectural merit and does not appear to meet the criteria or intent of the following policies:
– National Planning Policy Framework (NPPF), July 2021, Section 12, Paragraph 130, being neither visually attractive nor sympathetic to local character and history
– Policy DM26 of the Site Allocations and Development Management Policies states that development proposals will be expected to contribute towards local character and distinctiveness by retaining, enhancing and creating important views into, out of and through the site as well as making appropriate use of landmarks and focal features, and preserving or enhancing the setting of existing landmarks and focal features.
– Bristol Development Framework Core Strategy (adopted 2011) Policy BCS21
2.26.3 Policy BCS21 of the Core Strategy states that development should contribute positively to an area’s character and identity, creating or reinforcing local distinctiveness. This policy expands upon this requirement by setting out the criteria against which a development’s response to local character and distinctiveness will be assessed. The design of development proposals will be expected to contribute towards local character and distinctiveness by: i. Responding appropriately to and incorporating existing land forms, green infrastructure assets and historic assets and features; and ii. Respecting, building upon or restoring the local pattern and grain of development, including the historical development of the area; and iii. Responding appropriately to local patterns of movement and the scale, character and function of streets and public spaces; and iv. Retaining, enhancing and creating important views into, out of and through the site; and v. Making appropriate use of landmarks and focal features, and preserving or enhancing the setting of existing landmarks and focal features; and vi. Responding appropriately to the height, scale, massing, shape, form and proportion of existing buildings, building lines and set-backs from the street, skylines and roofscapes; and vii. Reflecting locally characteristic architectural styles, rhythms, patterns, features and themes taking account of their scale and proportion; and viii. Reflecting the predominant materials, colours, textures, landscape treatments and boundary treatments in the area. Development will not be permitted where it would be harmful to local character and distinctiveness or where it would fail to take the opportunities available to improve the character and quality of the area and the way it functions.
2.26.5 To respond effectively to local character and distinctiveness development should not, for example, have a detrimental impact on existing important views by reason of its siting or design, or fail to conserve green infrastructure and heritage assets that could, if retained and integrated into the design, provide a better relationship between the proposed new development and the historic environment.
– Bristol City Council Urban Living SPD (adopted November 2018): Q1.1 Has the scheme adopted an approach to urban intensification which is broadly consistent with its setting? Q1.3 Does the scheme respond positively to either the existing context, or in areas undergoing significant change, an emerging context?
Objections:
The proposed development is not ‘entirely consistent’ (as the submitted Design and Access statement suggests) or even ‘broadly consistent’ with the setting on Bath Road in which it would be situated and does not respond positively to the existing context or the emerging context.
The proposed development site is on the side of Bath Road that is characterised by the Grade II listed Three Lamps junction signpost, the New Walls housing estate comprising low-rise flats and 2-storey houses with gardens, the Grade II listed Thunderbolt (Turnpike Inn), and a 3-storey Victorian terrace along the Bath Road, with Totterdown’s colourful Victorian terraces rising up the hill to form iconic views including the Grade II listed tower of Holy Nativity church.
It may be that an ‘emerging context’ on the opposite side of the Bath Road dual carriageway will include high blocks of flats. But, unless there is an intention to demolish Totterdown’s existing homes and historical landmarks, any development at 122 Bath Road should respond positively to the existing homes and landmarks within which it is located.
Views of the Totterdown escarpment, with its colourful domestic-scale terraces, comprise a valued south-Bristol landscape asset. These views will be obscured from several viewpoints. It is insulting to suggest “the scheme also takes its cues from Totterdown behind” and “Its form follows the topography of the land behind, stepping and rising up just like the terraces on the hill behind it.” The proposed development will block views of those terraces, dominate and overlook existing homes, and negatively impact on the existing context. Totterdown should not be considered “behind” the development – the development should be part of Totterdown and enhance the escarpment.
Heritage
Section 66 of the 1990 Act states that “in considering whether to grant planning permission for development which affects a listed building or its setting, the local planning authority…shall have special regard to the desirability of preserving the building or its setting or any features of architectural or historic interest which it possesses”. Subsequent case law has emphasised that there is a need for local planning authorities, while carrying out the planning balance, to apply “considerable importance and weight” to the statutory presumption in favour of preservation or enhancement of listed buildings and their settings.
Objections:
The proposed development will dwarf the Grade II-listed Thunderbolt pub. The developer’s own assessment concludes that “implementation of the development proposals within the application is likely to result in a moderate adverse effect to important elements of the setting of the inn.”
Furthermore, there is no reference to harm caused by the proposed development to views of the Grade II listed Holy Nativity church tower. Neither is any mention made of the proximity to the Grade II listed Three Lamps signpost which is part of the streetscape of the proposed development, or views of the Totterdown escarpment which are also considered to be a historical and landscape asset.
Overshadowing and Loss of Privacy
The Urban Living SPD indicates: “Tall buildings will generally be discouraged on physically constrained sites within existing built up areas, where a tall building is likely to have a negative impact on the daylight and sunlight penetration into the habitable rooms of existing buildings.”
Bristol Local Plan – Site Allocations and Development Management Policies; DM27: Layout and Form states “The height, scale and massing of development should be appropriate to the immediate context, site constraints, character of adjoining streets and spaces, the setting, public function and/or importance of the proposed development and the location within the townscape.”
The developers concede this is a constrained site in an existing area. The Daylight, Sunlight and Overshadowing report indicates that a number of surrounding properties will be adversely affected but goes on to suggest this will be minor because the affected rooms are non-habitable. Unfortunately, the quality of the report is questioned when it is admitted that desk-top assumptions have been made about the layout of surrounding homes, and there are some inaccuracies in the addresses of affected properties. TRESA remains concerned about the impact on daylight and sunlight resulting from this dense and overbearing proposal.
It is indicated that “to ensure the safe use of the roof terraces, the solid masonry wall is raised up to form a solid parapet wall in accordance with current building regulations”. It is unclear whether this additional height, and hence additional overshadowing, is taken into consideration when describing the height of the buildings and the impact on existing residential properties.
The height of the proposed development, the “generous” balconies to all flats at the rear of the building, and the roof terraces will result in overlooking and significant loss of privacy for all residents of nearby properties.
The Design and Access statement indicates: “The proposed scheme takes full advantage of its location and offers three large communal roof terraces to allow residents to all take full advantage of full sunlight and far reaching views over the river and Bristol beyond.” This statement is insulting to existing residents who will have their views completely obscured by a tall block of flats overlooking and overshadowing their homes.
Traffic Generation and access
TRESA supports the promotion of sustainable transport. However, with a development of this size it is important to consider the impact on local roads and parking, especially as this area is known for rat running.
Having a single vehicle entrance on County Street to a development of 54 flats (the majority of which are 2-bedroomed) will inevitably increase local traffic on a road that already has access issues due to the number of cars parked kerbside combined with increasing volumes of traffic cutting through the rat-run through Angers Road to County Street and up Stanley Hill.
Parking provision is already considered inadequate by local residents, and a proposal for 54 flats with only 22 parking spaces will increase pressure on the parking in surrounding streets where local residents and businesses rely on the limited number of non-allocated spaces for visitors, deliveries and trades.
Potential Safety Hazards
TRESA echoes the concerns included in another comment on this proposal. The ground investigation report shows unacceptably high levels of: Arsenic, Lead, Benzo(b)fluoranthene, Benzo(a)pyrene, Dibenzo(ah)anthracene. Elevated concentration of these heavy metals and PAHs represents a health risk. There is insufficient data or content on steps that will be taken to ensure these will be dealt with and not become a risk to local residents during the construction phase or to the residents living there.
Measures to ensure land is clear of contaminants can be expensive. We would not want to see the cost of this used as an excuse at a future date to reduce the level of affordable housing provided.
Urban Living SPD Responses
Q1.2 Does the scheme contribute towards creating a vibrant and equitable neighbourhood?
The description of the area in this proposal is disingenuous. For example, “A multitude of green open spaces are provided within a 10-minute walk of the site” is not true. Other than the Three Lamps estate green space currently managed by Places for People, access to green space is difficult especially for children or people with mobility issues. Access to some of the green spaces listed by the developer involves crossing the busy Bath Road dual carriageway and descending steep steps, or walking up a steep hill with narrow pavements that is a notorious rat-run, or negotiating the steep rat-run and then crossing the busy Wells Road.
Neither is there a “wide range of shops” on that part of Bath Road. Indeed, that part of Bath Road currently lacks any shops at all.
The developer suggests the site is “located within a walkable neighbourhood”. This is an aspiration but is not a reality, and there is no contribution in the design and layout of this proposal to make the neighbourhood more walkable.
It is argued that “The Ward based housing need identifies a real need for flats within this area given the predominance of terraced family housing.” However, it is important to note that Totterdown’s terraced houses are predominantly small, 2-bedroomed homes and families often move away if they have a second child as they need more bedrooms.
Q1.4 Does the scheme provide people-friendly streets and spaces?
Very little attempt is made to provide people-friendly streets and spaces in this development. There is no street level active frontage. At street level: “Deep angled louvres screen and ventilate the undercroft which houses the car parking, bin store, plant rooms and cycle storage required for the scheme.” This misses an opportunity to provide people-friendly active frontage at street level.
Vehicle access is via County Street which is a notorious rat-run for drivers seeking to avoid Three Lamps junction. This is acknowledged to be a problem by Bristol City Council and TRESA has been working with transport officers to try to resolve some of the issues. There is nothing in the current proposal to make County Street more ‘people friendly’ or to improve public space at the entrance to the development.
Q1.6 Has access, car parking and servicing been efficiently and creatively integrated into the scheme?
Car parking and servicing is at “undercroft level” and undermines the opportunity for active frontage at street level. Vehicle access is proposed through a single access from County Street, but no acknowledgment is made of the current problems with rat running on County Street that are likely to be exacerbated by the proposed overdevelopment of the site. It is argued that “the level of car parking is appropriate to the sustainable location of the site”. TRESA supports sustainable transport, but it is important to be realistic about the likely traffic implications of a development of 54 flats (the majority of which are 2-bedroomed). A proper assessment of available on-street parking is required, compared with the likely demand resulting from any new development including demand from new residents, visitors, delivery vans, service vehicles and traders.
Q2.3 Does the scheme provide sufficient outdoor space? Q2.4 Does the scheme create attractive, well designed and maintained outdoor spaces?
TRESA is concerned that the development relies entirely on balconies and roof terraces. There is no ground level public outdoor space, which is particularly difficult for families with children. The child yield is estimated to be 11-12. (Please see comments in relation to children’s play).
Q2.5 Does the scheme creatively integrate children’s play?
The scheme fails to integrate space for children’s play and makes the excuse that “due to the tight nature of this brownfield site the scheme is unable to deliver formal built in play facilities to meet these standards”. It is suggested that School Road Park and Perretts Park are within short walking distance. Both require negotiating steep rat runs and, in the case of Perrett’s Park, crossing the busy Wells Road. The green space managed by Places for People on Three Lamps estate may offer opportunities for nearby informal play, but the failure to integrate children’s play is the result of overdevelopment of the site and poor design. It is not acceptable that the only integrated outdoor play space is on balconies or roof terraces. Neither is it clear whether there is sufficient space for storing children’s play equipment, prams etc. within the development.
Q2.8 Does the scheme maximise opportunities for natural illumination of internal spaces; avoiding single aspect homes?
The scheme includes single aspect units and argues this is necessary to “make most efficient use of the space”. This suggests that the main motivation for single aspect units is to maximise profit rather than provide good quality accommodation.
SUMMARY
TRESA strongly objects to this proposal which contravenes several planning documents, represents gross over-development of the site, will overshadow and threaten the privacy of local residents, includes poor design (e.g. single aspect units, no integration of children’s play facilities) and undermines the local character and heritage of the area. TRESA would welcome and support a good quality design, no higher than 4-storeys, that contributes to people-friendly streets and spaces.