TRESA has submitted a strong objection to the latest application for the former Bart Spices factory site. The statement is reproduced in full below.
The application is here (comments can be submitted by clicking on ‘Make a comment’): 23/04650/X | Application for variation of Condition Nos. 39 (Landscaping (Tree Planting) works), 45 (Use Class Restriction) and 50 (List of approved plans) following grant of planning permission 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
________________________________________________________________________________________________________________
TRESA strongly objects to this application, for the following reasons.
1] A NEW APPLICATION
The application is presented as a series of variations to conditions 39, 45 and 50 (with 50 being the drawings). However, conditions 27, 28, 29, 30, 31 and 40 are also affected. Given the substantial differences from the consented scheme, this is a new application and should be treated as such.
At the point of submitting this objection, important documents are missing from the application including:
- Ecological Assessment and BNG Assessment
- Heritage Statement of Conformity
- Internal Daylighting Assessment
- Wind Assessment report
- Waste storage and collection plan
2] HISTORY OF THE APPLICATION
The officer report relating to the previously approved scheme recommended REFUSAL for the following reasons, which also apply to the current application:
- 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.
- 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.
- 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.
- 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.
Despite these reasons for refusal, and serious concerns about fire safety, the Development Control Committee were persuaded to approve the previous scheme because of the need for affordable housing.
The requirement to address fire safety concerns resulted in the submission of a poor-quality revised scheme in the guise of a ‘non-material amendment’. This was not accepted by the planning officer and the developer was advised that an application which reduced the quality of the scheme was unlikely to be approved.
Nevertheless, the developer has chosen to present a scheme, inaccurately described as ‘variations to conditions’, which exacerbates many of the problems of the approved scheme and reduces the proportion of affordable housing.
3] OBJECTIONS TO THE CURRENT APPLICATION
REDUCTION IN AFFORDABLE HOUSING: The proportion of affordable housing has reduced from 30% to 20%. This is unacceptable because the provision of affordable housing was a key factor in the decision to ignore the officer recommendation and approve the previous scheme.
ACCOMMODATION MIX: The total number of flats (221) is the same as the approved scheme. However, the mix has changed. The approved scheme was for 121 x 1-bedroom, 77 x 2-bedroom and 23 x 3-bedroom. All of the 3-bedroom flats have been removed and the number of 2-bedroom flats has been reduced. The new mix is 149 x 1-bedroom and 72 x 2-bedroom. The applicant states: “the proposed mix is more appropriate for the proposed tenure, being Build to Rent, where occupants would generally live for shorter periods.” This undermines the Mead Street development brief which aims to promote and support a new neighbourhood community.
ACCESSIBILITY: The consented scheme indicated 98% of the dwellings will be delivered as M4(2) dwellings, and 2% of the dwellings will be delivered as M4(3) dwellings; the current application retains the required 2% M4(3) dwellings but does not include any reference to M4(2) dwellings. The consented scheme included 14 parking spaces for disabled use only; the current proposal provides 5 parking spaces for disabled residents only.
DAYLIGHT: Limited light levels were identified as a problem with the consented scheme. The current scheme has smaller windows, and the tower blocks are closer together. This is likely to exacerbate the problems with daylight. However, no Internal Daylighting Assessment report has been provided.
POOR LIVING ENVIRONMENT: 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.
BULK AND MASSING: The proposed buildings are bulkier and the distance between blocks has been reduced to less than 17 metres for single aspect flats looking directly into one another (the fire strategy document places the midway boundary at 8.13 metres, giving a distance of 16.26 metres). Balconies are less than 13 metres apart which severely compromises privacy. The resulting canyon between Blocks B and C is about twice as tall as it is wide. No wind speed report has been provided.
HEIGHT AND TOPOGRAPHY: The Urban Living supplementary planning (SPD) advises that tall buildings should not hide or mask the topography of the city. The Mead Street Development Brief notes the local landmark of the Pylle Hill escarpment, with the coloured terrace of houses running along it, as an important feature which adds to the local character of the area and contributes to wayfinding and legibility in the city. The proposed height of both the approved and the current applications will mask the topography. A new application provides an opportunity to reduce the height, enabling this important landmark to continue to be visible from key vantage points.
LACK OF PARKING: The approved scheme included 43 car parking spaces in the basement of the development, which was significantly lower provision than the maximum permitted under the Council’s Parking Standard. In the current application, all but 5 of these spaces have been removed. This means there is no parking allocation for the overwhelming majority of residents and visitors, or for staff and visitors of the commercial units.
IMPACT ON HIGHWAY SAFETY: The increased bulk of the buildings has further reduced the pavement width along York Road, which is already considered insufficient. Together with the proposed trees, this will cause problems for pedestrian movements.
WASTE STORAGE AND COLLECTION: Arrangements for waste storage and collection have changed. The width of the path for moving refuse bins appears to be narrower than the one previously deemed inadequate, and the collection area is smaller. A new waste storage and collection plan is required to indicate how these issues will be addressed.
FIRE SAFETY AND ESCAPE ROUTES. The required two staircases per building are, at last, included in the plans. However, the location of the bin stores at ground level on either side of the canyon is problematic when buildings are so close together. A fire in one of these stores would cause a lot of damage and probably spread up both blocks very swiftly. Given the history of the application, including the approval of an unsafe design subject to conditions, the fire safety proposals should be carefully examined.
PLANS AND MATERIALS: There is no scale comparison on the drawings, contrary to Bristol City Council submission policy. The roof profile and upper floors differ from the approved designs. It is proposed that the intermediate floors will be of modular construction, but there is insufficient information about the appearance. The applicant states that final selection of material finishes to be approved on site. There are amendments that change the external appearance of the buildings and, to comply with Policies BCS22 (Conservation and the Historic Environment) and DM31 (Heritage Assets), the potential effects on the setting of the Conservation Area should be assessed. No Statement of Conformity is currently available for scrutiny.