A couple of weeks ago we met with PG to talk about the Cultural Plan. While there we took a few snaps.
CAG has submitted a follow-on objection (pasted below) addressing PG Groups’s proposed alterations to their planning application for 28 flats in place of Blocks E & F. You can view the full application on the Council’s planning portal or a summary of their proposed changes on our page.
We are writing in response to the alterations submitted by PG Group on 11 May 2021 to the proposals for Blocks E & F at the Carriageworks site.
On 5 March 2021 we lodged an objection to the original application. In summary our objections were:
- The design suggests that natural lighting to the residential units is very limited. A daylight assessment has not been provided to give any reassurance on this matter
- The mix of unit size is adding more small units and removing larger units, thus consolidating a narrow mix across the site as a whole
- Material colours are depressing
- Lack of natural surveillance in the sunken courtyard. Secure by design principles should be applied
- Loss of natural light and increased overlooking of neighbouring properties will reduce their amenity
- Increased height and depth of the building is not justified by any commensurate increase in design quality or mix of unit size
- Lack of any clarity on unit tenure
- Loss of green space
- Lack of a swept path analysis to show that revised parking layout is workable
- Contradictions within the application which says there will both be and will not be a green roof. The lack of PV panels is excused by reference to a green roof, but the design shows a flat hard surfaced roof.
PG’s alterations propose the following:
- Reconfiguration of internal layouts, mainly to move bicycle store indoors with the loss of one flat
- Changes to configuration of windows
- Grey brick replaced with red and buff brick
There is no written explanation to support the submitted drawings or to explain how the grounds for objection submitted by many parties (including the Crime Reduction Unit, the Conservation Advisory Panel, Montpelier Conservation Group, Bristol Civic Society and many local residents) are being addressed.
The proposed alterations seem to address our concern about the depressing colour of the building and there is a slight change in unit size mix with a preference to two bed units as opposed to one bed, but our other grounds for objection are not addressed and therefore stand.
The proposed alterations also show that the new 42 space bicycle store will now be accessed through two sets of doors (external double door of c.1.2m and internal door of c.0.7m width) with a c.1.5m wide joining corridor. This does not comply with good design standards (e.g. London Cycling Design Standards) and will be very awkward to use, if not impossible for users with non-standard sized bicycles.
Unless the above concerns are addressed we believe that this application should be refused planning permission.
Despite numerous and widespread objections, planning permission was granted in September 2021. The main reason appears to be Bristol failing to meet its housing targets which means that all other policy considerations are of insufficient importance to justify refusing permission.
The owners of the site on Hepburn Road that includes 86-102 Stokes Croft have made proposals for the redevelopment of the backland and renovation of the street front properties. CAG have looked at these and has the following comments to make:
Development and improvement of the site is supported in principle
2. Construction Site Access
Concern about how this will be achieved.
- Access via Stokes Croft onto Hepburn Rd is impossible due to width of the lane
- Only alternative route is via City Road or Ashley Road, then Brigstock Road and finally the length of the narrow residential Hepburn Road. Very difficult to safely achieve this given its narrow width and parking both sides. Even if they seek to close the road to any parking (which would be very controversial) the 90deg turn from Brigstock Rd may be impossible for larger transporters
- Alternatively everything has to be craned off lorries parked on Stokes Croft – seems to be the only realistic option – but huge disruption on Stokes Croft (aka A38) itself and may not be permitted by Highways
- If Carriageworks development is underway there will already be a considerable amount of construction traffic in the vicinity
- Important that works on Hepburn Road site do not unduly impact Carriageworks construction works
- Combined impact of multiple construction sites on local residents, especially those on Hepburn Road, must be born in mind and appropriate controls and mitigation measures put in place
3. Proposed Use
The scheme design was completed in January, before COVID. We question the demand for student housing post-COVID. If there is a fall in student numbers and demand for student accommodation, what adaptation will there be to other residential uses? Is the scheme sufficiently resilient and flexible to enable it to change to alternative types of residential use? Conversion to HMOs would be detrimental to the area.
Numbers 92, 96 and 98 do not appear to have been granted change of use for residential use. Ground floor units fronting Stokes Croft should all be retail or business use – not residential. This should be a benefit of the scheme for the wider community, will avoid breaking the street frontage, and will better complement the Carriageworks scheme.
4. Impact on Carriageworks Block D
The pre-app states that their Block A “is single aspect with the rear back to back to the blank boundary wall of the carriage works proposals” i.e. Block D of Carriageworks. This needs correction. The rear wall of Block D is not blank – instead it contains six small windows, two of which provide light to kitchens and the remainder of which provide light to hallways. On the ground floor there is a doorway providing access to the narrow service area. The building previously on the site of Block D had windows looking over Croft Dale, so rights to light are established. Clearly Block A of the pre-app scheme could not be built without blocking the windows in Carriagework’s Block D.
The microclimate in the narrow service area between Carriageworks Block D and pre-app Block A, with three storey buildings surrounding it, will be awful. Furthermore, building to the boundary will mean there is no ability to service the rear wall of Block A. A larger space between the buildings would be beneficial.
Block D is a three storey building. Block A is four storeys. There is a difference in ground levels (Block D ground floor is 25.5m above datum), but is it enough for an entire extra storey to be built in Block A so that the roofs of the two buildings are flush, as indicated in the drawings? Assael drawings for Carriageworks suggest there is not enough difference. Proposals to increase Carriageworks Block D above three storey height were previously resisted due to the impact on the immediate neighbourhood. The ground level may have to be lowered to accommodate four storeys.
The residential units in Block D will be sold as 10 affordable housing units. The pre-app proposal is for a 27 unit student housing block immediately adjacent. Is this appropriate, especially if Block A has any rear windows?
5. Stokes Croft Frontage
Currently the parapet wall of 102 Stokes Croft adjoins the Carriageworks below second floor level, thereby creating a significant step-down from the listed building to 102 and the adjoining terrace (note that step-down from adjoining buildings was also a significant issue on the Ashley Road frontage between the unlisted Tucketts Building and neighbouring new-build). The proposal is to increase the height of 102 with a mansard roof, although the drawings are not sufficiently detailed to know how high this will be. Nevertheless. the impact of the step down will be reduced, to the possible detriment of the prominence of the Grade II* listed Carriageworks building.
Furthermore, the band of bluestone on the Carriageworks close to the top of 102’s front wall must not be obscured by any works to No. 102.
Being adjacent to an important listed building the materials used should be of a high quality and meet conservation standards. Windows should be timber, not PVCU.
6. Gated Developments
The pre-app scheme is for a gated development. CAG has been adamant that this is not suitable for the Carriageworks scheme or indeed for anywhere on Stokes Croft. We are concerned that if Hepburn Road scheme is gated it will set a precedent that might in time be used to gate other sites in the area.
CAG has long argued for major development in the area to contribute to the wider social, environmental and economic character and vitality of the area. The mix of space and uses at the Carriageworks helps achieve this and the emerging Cultural Plan will define in more detail how this it will happen. The Hepburn Road scheme, as one of the larger development sites on Stokes Croft, should be encouraged to do likewise and complement other existing uses and investment in the area.
20 people came to the meeting including three representatives of PG Group.
The meeting opened remembering Pete Bullard who died at the end of October. A Just Giving page has been set up to collect for two nut trees and a greengage tree in Brunswick Sq. in Pete’s memory. Pete would have wanted trees that give fruit / nuts freely to the local community. We miss him.
Revised Revisions to the Planning Permission: Comments
The aim of the Community Meeting was to seek community views about the revised amendments submitted to the Planning Authority as a S.73 application. The comments in this paper will combine the views expressed at the meeting with those expressed to members of the CAG Liaison Group by people who were not able to attend the Community Meeting. CAG’s role is to convey all the different views to make the community’s input as transparent as possible. It was noted that in the initial consultation about the development of the site, in 2011, 96% of 1600 people said that their priority was to “see something done” to address the dereliction of the site through building out a scheme.
PG Explanation of Proposed Amendments
PG submitted their S.73 scheme last summer after having priced up the permissioned scheme. Costs were proving higher than previously forecast. This was tackled by simplifying some elements of design to speed up the build process, and reducing the complexity of the design which takes out some costs. The key change was to the Ashley Road façade by taking out ‘stepped in’ juliet balconies (expensive to build) and adding floors to the frontage to take it to the same height as the rest of Block A. There was some resistance to that. The amended proposals pulled back the fifth floor from Ashley Road. The designs also addressed the ‘flat face’ to the façade architecture to make it less bland and add some additional horizontality to the design. There was further community feedback in October so PG then added more features to the elevation to add horizontality and pulled back the fifth floor even further with loss of one unit. Note that pulling the fifth floor back still further would reduce number of units which would be defeat the objective of the additional floor. We lose eight units without the changes.
Other changes have been to the windows on the Hepburn Rd frontage and to solar panels on roof.
We have grouped the views expressed into themes/key issues.
1. To what extent will the concerns be lessened if it goes to committee as opposed to being decided by the planning officer?
In favour of delegated decision making, some people were concerned about the depth of knowledge of the scheme amongst Councillors who may not be as aware of the detail as we (and the planning officer) are. However, it was noted that any committee decision would be based on an officer’s report highlighting the main issues.
In favour of a Committee decision, the balance of opinion in the room was that this would enable more transparency and would make the final decision “more like a normal planning application.”
There are concerns that the scheme contravenes planning issues especially relating to the privacy of tenants of Tucketts Buildings, and this mitigates in favour of committee decision making. Also, that the changes appear to be too significant not to be subjected to a proper planning process. A view was expressed, however, that some of the areas of contention might be better addressed through negotiation, rather than a binary decision at committee.
A representative of Montpelier Conservation Group (MCG), who have submitted an objection to the proposals, said that while a committee decision would make the process more accountable, there are concerns about the lack of supporting documents to justify the changes. The justification for the changes needs to be discussed at Committee, but this information is not available to form the basis of a discussion.
A particular concern is the lack of a viability statement. A representative from PG Group said that they had not been asked to provide a viability study as part of the S.73 application. Asked if they would provide one they said that that would have to be considered. In wider discussion about viability appraisals PG said that normally planning permission cannot be approved if a scheme is not viable.
The meeting discussed this issue. It was recognised that
- The viability of the scheme is very tight
- This is a very difficult time to be costing schemes – with enormous uncertainty and cost changes due to the political situation
- Viability statements are not normally released publicly. Rather, the planning authority will ask an independent party to verify the viability study and this assessment is made public.
CAG has heard conflicting views from people at the meeting, and others who were not able to attend:
- that even if the viability statement justified the need to make the proposed changes, they would still record objections
- that assessment of the viability statement would give a fair platform that would take account of the challenges of developing the site
- that the proposed changes involved compromises, just as the permissioned scheme involved compromises and what is most important is for the scheme to proceed and to be built.
Decision making timetable:
There was a concern about the need for swift decision making, before Purdah, so if the scheme goes to Committee, this needs to be very soon – by February at the latest. PG Group commented that they have had thisscheme priced up and they are now in a position to start on site quite quickly if they get planning approval. If there are too many further delays, their build contractor will review their commitment and either push up costs or may pull out.
A view was expressed that people in the community have been working on this for a long time. There is a need for decisions to be made to enable progress. “It would be such a shame to get this far and then put it back by another two years.”
2. Is the amended design acceptable?
A number of issues discussed
a) Additional floors on Block A facing Ashley Road; and design of the Ashley Road frontage:
The proposed addition of two floors at the Ashley Road end of Block A is contentious. Dominic Taylor said that this will result in a loss of light to Tucketts Buildings; and living room / bedroom windows which look into his building. It was noted that the windows overlooking could be easily addressed by design changes. Shadowing/impact on light is still a concern. Dominic said that a change in brick colour would make a fundamental difference.
MCG and the Conservation Advisory Panel are concerned about the size and scale of the building in a conservation area. There are also concerns about the design of the Ashley Road frontage, which has been described as “monolithic”, with no articulation. However, views have also been expressed that the new building will be alongside the Salvation Army Citadel which has a “far from perfect” frontage and which itself is not consistent with the aspirations of the conservation area.
There was a discussion about ways in which the design could help to address the concerns about the conservation area location, and the look of the frontage. For example:
- Further set back of the upper floors, recognising that the top floor flats would become smaller
- Design features to break up the monolithic flat frontage, creating more of a sense of a terrace (as in the permissioned scheme) would improve the proposals. Some creative solutions were suggested. A commitment from PG to have this conversation would help win support from some people in local communities.
- Can the depth of the Carriageworks part of the scheme be changed, to increase the number of units without changing the Ashley Road frontage? This would require a new, full planning application including addressing changes to a Grade II* listed building, so is not realistic.
- Could the setback at the front of Block A be reduced, allowing more space at lower, internal levels and so not requiring so much to be added on the upper floors? This would need a new full planning application, because it would change the footprint of the building. Also the increased set back aims to create more of a funnel effect into the alley going to the market square. Some people living close to the site also said that there will be a need for a wider pavement at that point, in interest of safety. A portico might offer a compromise solution, although could still require full planning permission.
Discussing ways to change the Ashley Road frontage so there is a better fit with the Conservation area, Dominic Taylor floated the idea of pastiche. This was discussed.
- A representative from PG said that planners have given a strong steer away from pastiche
- Quentin Alder commented that it would be virtually impossible to do these flats in pastiche style as their windows would all have to be the same size
- Generally, being creative with design features, materials and finishes was favoured over pastiche.
c) Reaching solutions
Overall, most of the people in the room thought that “we are not far from a solution” to the design issues, and there is agreement about process. This echoes views which have been expressed recently to members of the CAG Liaison Group by people unable to attend this meeting. There is a strong desire to see the development progress. The design of the permissioned scheme has always been a disappointment, but the blight of the long derelict site was far worse. One local resident summed this view up with the statement: “Is the design that important? We need the housing.”
d) St Pauls frontage (aka Back, or ‘Berlin’ Wall)
Usually described as the ‘back wall’, Lori Streich raised the issue of the St Pauls frontage. This is the wall that will face directly onto Hepburn Road, and will overlook St Pauls. A planning consideration has always been that the scheme must not turn its back on St Pauls. This wall will be significantly higher than the houses around it, and so will be seen across a very large area. Westmorland House could be seen from Brunswick Square. This wall will be widely visible across parts of the city. CAG Liaison Group members accept that it will be monolithic and has been likened to a ‘Berlin Wall’. How to mitigate this impact?
- PG Group have assured members of the CAG Liaison Group members that the windows will be as in the permissioned scheme. These have been designed so residents of the new housing will not be able to look into the gardens of Hepburn Road residents.
- A discussion about design, finish and materials needs to happen. It was noted that community engagement with this is a planning condition. CAG is aware that this dialogue will need to be managed so that it is realistic; but also needs to be ambitious and creative.
- A suggestion that some of the public art budget could be committed to that wall to mitigate the potentially negative impact it will have on St Pauls, and the wider cityscape, was met with enthusiasm. Lori said that we are looking for a constructive discussion that resolves the issues. PG Group said that there will be time to have this discussion, before that frontage is built.
Materials and finishes
If the S.73 application is approved, the discussion about materials and finished will happen soon after. This will be an issue for the Hepburn Road frontage; and materials could break up the Ashley Rd monolith and introduce some of the verticality. CAG can collate views and ideas, and work with PG Group to develop and run an effective process for this dialogue. PG Group is open to ideas.
This has not been forgotten! Liaison Group members are concerned that it will tie in with the commercial development of the Ground Floor; and will contribute to the developed site being a great place to live and a positive contribution to the local community. This is still on the agenda, and we will return to it. The infrastructure and design will need to address the needs that will be articulated in the Cultural Plan.
· Affordable housing: PG Group reported that they are looking in a positive way to increase the amount of affordable housing. Lori said that CAG will continue to press on this issue.
· Naming roads: Liaison Group members suggested that the lane into the site be called Bullard’s Way, in Pete’s memory. PG Group seem to be open to this. More discussion needed.
CAG will send notes of this meeting to the Planning Officer by the end of this week. PG Group will discuss timetable with the Planning Officer in the next few days.
There will be a Carriageworks community meeting on Tuesday 7th January, 6:30-8:30pm at St Pauls Learning Centre, Grosvenor Road, St Pauls.
The meeting will be to discuss the proposed amendments to the S.73 application submitted by PG and covered in our post of 15 November.
We are sad to report that Pete Bullard passed away on 31 October. Pete was an active member of CAG since our start in 2011, and an active campaigner for the redevelopment of the Carriageworks site for much longer.
Pete chaired the St Pauls Planning Group. Not a single major development or planning application in St Pauls has escaped his scrutiny. He also worked with others to ensure the restoration of St Pauls Park, and he was the person behind the planting of trees along Grosvenor Road. Over the years of his community activism, Pete was involved with more projects and environmental improvements in St Pauls than we can list.
Pete also produced beautiful pieces of stained glass and has taught many people to create their own works in this medium. Every Tuesday evening (in term time) saw him at St Pauls Learning Centre running his glass class. (So if you ever wondered why CAG Community meetings never happened on a Tuesday… that’s the answer.) He was also an enthusiastic photographer, and fisherman.
Pete will be deeply missed in CAG and in St Pauls. His funeral will be on 2 December, with a service at Canford Crematorium at 11.15, followed by a
Celebration of Pete’s life at St Paul’s Learning Centre 12.30 for 1 til 5 pm on 2 December
Please drop in to the Learning Centre, Grosvenor Road, BS2
to share memories and stories and to see some of Pete’s glass work.
There will be a collection (no flowers please) to contribute towards the planting and maintenance of 3 fruit and nut trees in St Pauls Park as a lasting memorial.
We understand that PG have submitted new proposals to the planners, thereby amending their May 2019 S.73 application. PG tell us that these are the same as the proposals shown at the July community meeting, but we haven’t yet seen them. As soon as they are available we’ll let you know.
In the meantime PG have published a table analysing and responding to the public objections made to their May proposals.
On 16 May 2019 the PG Group submitted to Bristol City Council a Section 73 application to make material changes to the Carriageworks planning permission. These changes have attracted significant opposition.
At the CAG Community Meeting on 10 July PG introduced revisions to their proposed changes. These revisions have not yet been submitted to or registered by the planners. Comments made at the meeting included:
- Ongoing concern about the height of the Ashley Road frontage, increaesd shadowing from the increased height
- Lack of syntax to the retail frontage
- The replacement of triangular windows with bolt-on window louvres facing Hepburn Road (which, since the meeting, we now understand is being addressed). The St Pauls frontage is as important as any other and should not be subjected to cost-cutting of this nature. The Carriageworks must not turn its back on St Pauls.
- Whether a Section 73 application is appropriate given the scale of changes proposed
- The need to increase the amount of affordable housing
- Use of local labour and suppliers
- What are the archaeological findings?
As and when PG do revise their application any comments already submitted will potentially have reduced relevance. Equally the planners will need to be clear if comments submitted after the submission of any revisions by PG refer to the orginal or revised proposals. CAG would like to see any confusion avoided so that quick and effective decisions can be made by the planning authority.
The S.73 application, any revisions and all comments can be found at https://planningonline.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=summary&keyVal=PRLISBDNHHU00
As and when the revisions are submitted by PG we will post an update on this website.
Planning Condition #15 attached to the Carriageworks development states: “Prior to the commencement of any construction works for the development a Cultural Programme Delivery Plan shall be submitted to and approved in writing by the Local Planning Authority. This shall set out the details of the Cultural Programme Steering Group, co- ordinated by an appointed programme manager. This Delivery Plan shall set out clear principles for the delivery of cultural projects to be delivered within the site.”
In January 2018 local consultants Willis Newson were appointed to prepare both the cultural plan and a public art plan. They ran various events through the year to find out what local organisations thought and in September presented their ideas at a public meeting. Since then progress has slowed as the developer, PG Group, has focused on other not insignificant matters e.g. demolition.
The CAG Liaison Group has kept asking about progress and recently had a meeting with PG and Willis Newson but there’s still nothing to share that gives a sense of direction or costs.
CAG believes that the Cultural Plan should address the long term use of the site as a whole. To this end we have produced a discussion document which you can download (pdf) which will be discussed at the community meeting on 16 May.
PG have submitted a non material amendment application for Block D (the social housing block).
This is the summary they provide in the covering letter:
• Reducing the number of stair cores in the block from 2 to 1. This allows for a slight increase in the size of certain units and an improved layout;
• Reduction in the number of doors to the non-residential units at GF level;
• Introduction of new WC and storage room at the end of the bike store to serve market traders. This will result in a reduction in the number of cycle spaces in the store from 114 to 100, though this will be compensated for by a matching increase in cycle spaces in Block A (to come forward under a separate application);
• Some of the drawings approved under NMA ref 19/00408/NMA included a set of external steps adjacent to the cycle store. These were included in error and have now been removed;
• Removal of most doors to the south elevation. The small rear ‘yard’ area, which was previously subdivided and allocated to the commercial units and one of the apartments, will now only be accessible via the communal entrance lobby for maintenance purposes. This will reduce the potential for noise and disturbance to the apartments above and the adjacent buildings;
• Change to fenestration at ground, first and second floor level on the front and rear elevations;
• Termination of the stair core at 2nd floor level to remove roof access. It is anticipated that any Registered Provider would identify the roof terrace as difficult to maintain and manage. Removing the stair access to the roof also presents a more uniform roof profile and reduced the overall height of the building.