The Carriageworks Action Group has today submitted an objection to the planning application to build 28 1 and 2 bedroom flats on the site currently proposed for eight 3 and 4 bedroom houses. This hasn’t been an easy objection to make as we support the broad priniciple of more social and affordable housing on the site. However, the quality of the proposals is so far below acceptable standards we feel we have to object. The content of the objection is below.
Objection to 21-00577-F
In December 2011 the Carriageworks Action Group produced its Community Vision for the future of the Carriageworks. This built on extensive public debate and consultation and was later adopted by Bristol City Council. Excerpts from the Community Vision that are relevant to this application are as follows:
“We want to see a true mix of housing types for sale and for rent including private and social housing, both low and high cost; a range of sizes should be provided to suit a mix of needs, from single people to families“.
“We want the new development to be designed to a high quality with good environmental standards. We want to see full use being made of roofs to provide opportunities for biodiversity and the creation of gardens, perhaps for growing food“.
The statement of community involvement that has been submitted by PG Group as part of the application rightly notes that CAG and others in the community have always wanted more social and affordable housing on the site than provided for in the approved 2015 scheme. When PG Group suggested, confidentially, to members of the Liaison Group* that this could be achieved by changing blocks E and F, in principle support was voiced.
On 14th December 2020 Liaison Group members were sent some plans for changes to Blocks E and F. We had substantial concerns, not least unit sizes below the national standards, and sent these to PG Group on 22 December. There was no further contact until after the planning application was submitted at the end of January. Neither did PG Group do anything to consult more widely with the local community about their proposed application.
CAG held a community meeting, via Zoom and attended by 18 people from CAG, on 25 February to discuss the application. PG’s architect presented the proposals and two other members of the PG team were able to provide answers to some of the questions posed.
Our objections to the proposals have, at their root, the divergence from the Community Vision in terms of unit size, occupation types and quality. While we remain committed to seeing more social and affordable units on the site this planning application fails on so many levels that we cannot support it. In particular:
- The quality of residential space, in particular natural lighting of the interior and solar gain, is potentially below acceptable standards especially on the ground and lower ground floors. This is due to the lower ground levels, the presence of retaining walls and the height of the surrounding buildings. This will not only have an impact on the health of residents but will also put increased dependence upon artificial lighting and heating. A daylight assessment in accordance with BRE guidelines should be submitted
- The proposals further consolidate a narrow mix of unit size on the site with the addition of more one bedroom units and the removal of larger units
- The choice of external finish and material colours is depressing and more fitting to brutalist housing development in the Eastern Bloc. A more appropriate solution should be found that fits better with the local context
- The lack of natural surveillance in the sunken courtyard gives us concerns about community safety. The advice of secure by design specialists should be sought
- The increased height, the removal of the gap between Blocks E and F, the changed roof configuration, the placement of windows (in habitable rooms and corridors) and the materials used lead us to believe that there will be an increased impact on the amenity of neighbouring residential properties especially through the loss of natural light and overlooking. A daylight assessment and shadow path should be submitted along with sections showing the proposed building in the context of properties on the neighbouring streets
- The impact of the increased height and depth of the building, compared to the permissioned Blocks E and F, is not justified by any benefit to the quality of design and the mix of unit size as aspired to by the Community Vision
- Conflicting descriptions of the tenure mix have been provided. Most recently, at the February community meeting, we have even been told that the mix is unknown. It is impossible to support this application without knowing whether the scheme is for social rent, affordable rent or shared ownership occupiers
- During site construction there has been almost constant Sunday working and working outside of permitted hours Mon-Sat, to the great detriment of local residents. If, as and when planning permission is granted there should be an absolute condition to prevent out of hours and Sunday working
- The loss of green space, replaced in part by a dark subterranean courtyard
- The amended parking layout needs a swept path analysis to demonstrate it is workable
- The Energy and Sustainability Study states that PV panels cannot be installed because “the roof space for Block E is proposed to accommodate a green roof in the interest of biodiversity” (page 21). However, no green roof appears in the planning application drawings. There should either be PVs or a green roof.
In conclusion, the proposed development is unacceptable and would provide housing units that are unliveable. To refer back to a quote from a member of the planning committee when the first 2015 application was submitted: “Only its mother could love this”. Since 2015 we have come a long way but we are in danger of the scheme sliding backwards little by little, justified by challenging circumstances and the smoke and mirrors of viability. A mixture of unit sizes and occupation along with high quality design and environments is essential for this development to be a success. As they stand the fundamentals of this proposal are sub-standard and no amount of change to the exterior design will compensate. This is an important gateway site with a facade of historical importance both locally and nationally. From a potential silk purse PG have made a sow’s ear. These proposals should be referred back for improvement.
* The CAG Liaison Group comprises six people involved in CAG who engage at a detailed level with the developer and the Council to champion the Community Vision. They report back to the broader CAG community.