Planning Statement
West Car Park of Bristol Zoo Gardens College Road, Clifton
Bristol, Clifton & West of England Zoological Society
March 2021
30418/A5/GN February 2021
Planning Statement
West Car Park of Bristol Zoo Gardens
College Road, Clifton
On behalf of Bristol, Clifton and West of England Zoological Society
Project Ref: 30418/A5/GN Status: Draft Rev: P1 Prepared by: Georgina Nelson Checked by: Simon Prescott Authorised by:
Barton Willmore LLP 101 Victoria Street Bristol BS1 6PU
Tel:0117 929 9677 Ref: 30418/A5/GN/bc
Email: [email protected] Date: March 2021
COPYRIGHT
The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP.
All Barton Willmore printed stationery is produced using recycled or FSC paper and vegetable oil-based inks.
CONTENTS PAGE
1. Introduction 1
2. Background on Bristol Zoological Society 3
3. The Site – Car Park to the West of Bristol Zoo Gardens 5
4. Development Proposal 9
5. Consultation 10
6. Planning Policy 18
7. Assessment of Proposals Against Planning Policy 30
8. Planning Obligations Statement 44
9. Conclusion 45
West Car Park of Bristol Zoo Gardens Introduction
1.0 INTRODUCTION
1.1 On behalf of the Bristol, Clifton & West of England Zoological Society, this Planning Statement accompanies an application for planning permission for residential development at the car park to the west of Bristol Zoo Gardens. The description of development is:
Erection of 65 dwellings, associated parking, new vehicular access and associated infrastructure and landscaping.
1.2 The site is located to the west of Bristol Zoo Gardens in Clifton, Bristol. The site is brownfield as it currently is a car park and provides ancillary storage. The site is within the Clifton and Hotwells Conservation Area.
1.3 To safeguard the future of Bristol Zoological Society (the Society), it is necessary to relocate the Society’s operation from the Clifton Bristol Zoo Gardens site to its existing Wild Place Project Site in Blackhorse Hill, Bristol (Junction 17 of the M5 Motorway). The aim is to create a world-class Zoo for Bristol and the West of England. This application should be determined on its own merits and not linked to the future proposals for the main Bristol Zoo Gardens site, and this is addressed in other sections of this Statement.
1.4 This planning application is supported by the following documents and reports:
Document Consultant Planning Application Form and Certificates Barton Willmore CIL Additional Information Form (CIL) Barton Willmore Planning Statement – including: Barton Willmore - Affordable Housing Statement Planning Obligations Statement Design and Access Statement Barton Willmore Architectural Drawings Barton Willmore - Site location plan - Site layout plan Existing and Proposed drawings Landscape Drawings Barton Willmore Transport Statement – including Travel Plan PEP Heritage Assessment Cotswold Archaeology Public Art/Cultural Contribution Strategy within DAS Barton Willmore
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Document Consultant Assessment of impacts of neighbouring amenity within DAS Barton Willmore Energy and Sustainability Statement Hydrock Daylight and Sunlight Assessment Hydrock External Lighting Assessment Hydrock Waste Management and Servicing Strategy Hydrock Acoustic Assessment Hydrock Air Quality Assessment Hydrock Utilities Statement (including Broadband Connectivity Hydrock Statement) Sustainable Drainage System Strategy Hydrock Contaminated Land Statement Hydrock Tree Survey Silverback Arboricultural Consultancy Ltd Ecological Assessment Wessex Ecological Consultancy Statement of Community Involvement JBP Construction Management Plan Bristol Zoological Society
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2.0 BACKGROUND ON BRISTOL ZOOLOGICAL SOCIETY
2.1 Bristol, Clifton & West of England Zoological Society Ltd (‘the Society’) is a conservation and education charity which currently operates Bristol Zoo Gardens in Clifton and Wild Place Project in South Gloucestershire. The Society’s mission is saving wildlife together and their vision is for wildlife to be a part of everyone’s lives and for people to want to, and be enabled to, prot ect wildlife now and for the future. They have five objectives:
1. Saving wildlife 2. Engaging our public 3. Creating conservationists 4. Sustaining our environment 5. Sustaining our future
By 2035 Bristol Zoological Society will:
• Grow the proportion of species at our zoo with targeted conservation action to more than 90%.
• Engage and connect with more than 800,000 visitors and members per annum.
• Engage and inspire over 90,000 schoolchildren and students per annum – the conservationists of the future.
• Become a carbon-neutral organisation.
• Develop the new Bristol Zoo through a major programme of capital investment.
2.2 The Society is a charity and receives no council funding. Therefore, it must maintain ways to operate as a viable and sustainable business in order to generate profit to achieve its charitable objects.
2.3 Visitor numbers to Bristol Zoo Gardens have reduced in recent years and consequently overall income growth has slowed. This is a direct result of a lack of new exhibits at Bristol Zoo Gar dens and under-investment over the last 20 years.
2.4 As a result, the Society’s means of generating sufficient profit to reinvest in Bristol Zoo Gardens and Wild Place Project has diminished, with the Society recording operating losses in four of the last six years. Using reserves to cover this deficit is financially unsustainable for the Society.
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2.5 This situation is now further exacerbated by the coronavirus pandemic. Whilst the Society has sufficient funding in place via additional bank borrowing to operate in the short to medium-term, the long-term future appears even less certain than up until this point.
2.6 To safeguard the future of the Bristol Zoological Society, the decision has been announced to relocate Bristol Zoo to its Wild Place Project site. Significant capital income must be raised in order to deliver a bold new vision and masterplan for the new Zoo that will increase visitor numbers and as a result profits that can in turn be re-invested into the new Bristol Zoo (at the Wild Place site).
2.7 The optimum use of their land and property assets alongside a more compelling and engaging capital fundraising campaign will ensure that the Society can create the capacity for investment over the next five years and beyond. The Society is bringing forward this application to raise funds to safeguard the future of the Society. As a charity the Trustees are legally required to obtain maximum value from the charity’s assets to reinvest in its charitable objectives.
2.8 The Society recognises these challenges as an opportunity – the Society must make substantial investment to rejuvenate exhibits and facilities at Wild Place. Charitable donations, bank funding and doing what they can to boost visitors can only take them so far. Radical, innovative thinki ng is needed to transform and invest in their other site.
2.9 The Society has been exploring the potential to release part of their land holding at Bristol Zoo Gardens for residential development to fund investment in the future of the Society. The West Car Park is identified as having the most obvious potential for this and is a potential asset which could be developed in order to release the vital funds to initiate the first phase of the development at the new Bristol Zoo. The intention is that the Society would release value of the West Car Park site by securing planning permission for residential development and invest the proceeds from the sale back into the Society’s charitable objectives.
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3.0 THE SITE – CAR PARK TO THE WEST OF BRISTOL ZOO GARDENS
3.1 The West Car Park (the application site) which serves the Bristol Zoo Gardens main site, is not part of the main Zoo site and is separated by College Road.
3.2 The application site is brownfield, previously developed land, as it is a car park located to the west of Bristol Zoo Gardens, and is within the administrative boundary of Bristol City Council. The site lies within the Clifton area of Bristol and is within the Clifton and Hotwells Conservation Area. College Road is to the North East and Cecil Road borders the site to the South East. The main Zoo site is opposite the application site on College Road and the other prevailing land uses surrounding the site are residential.
3.3 The site is in a sustainable location, in accessible walking and cycling distances to essential retail shops, facilities and services in Clifton. It is only 1.5 miles from the centre of the city. There is a frequent bus service (service 8 and 505) and bus stops can be found on Clifton Down (70 metres to the north of the site) and 40 metres to the north east for the northbound stop.
3.4 The site measures 0.51 ha in size. It is currently used primarily as parking for Bristol Zoo colleagues and ancillary storage. It also serves as overflow parking for zoo visitors, mainly in holidays and peak periods. The car park is managed by the Society and currently provides 160 car parking spaces.
3.5 A portion of the site is also used by Bristol Zoo Gardens for greenhouses and auxiliary buildings and a gardener’s yard.
3.6 Pedestrian and vehicle access to the site is from College Road and vehicle access to the Gardener’s yard is via Cecil Road.
3.7 Some immediate neighbours have rights of way on the site, which are retained as part of the development proposal. These are: • Glenavon has a right of way across the site and the right to park 6 cars, currently located at the rear of their garden. • Cliftonbank House (which is also called Llanfoist House on some plans) shares an access with Avonbank (sometimes called The Blue House) which requires access through the site to access garages. West Car Park of Bristol Zoo Gardens Bristol Zoo Gardens and the West car park
The West Car Park, unlike Bristol Zoo Gardens which is designated as a Local Historic Park and Garden, is within the Clifton and Hotwells Conservation Area. It is not considered a defined landmark. It is outside of the curtilage of the Zoo and therefore is not curtilage listed to the Zoo’s three listed buildings. There are no listed buildings on the West Car Park site.
Planning History
3.8 Planning history at the site is summarised below:
Reference Description of development Status 00/00725/LA Alterations to boundary walls including Granted 17 Jul 2000 provision of vehicular access and associated landscaping. 0/00686/F Use of land currently used for greenhouses, Granted 17 Jul 2000 storage and garaging for car parking, as extension to existing car park, to include alterations to boundary wall, vehicular access and associated landscaping.
00/00729/LC Demolition of greenhouses Granted 17 Jul 2000
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4.0 DEVELOPMENT PROPOSAL
4.1 The application seeks planning permission for the redevelopment of the existing car park and gardener’s yard to the west of the Zoo for residential development, and proposes the following:
• Provision of 65 residential dwellings, mix to include 1,2 and 3-bed apartments and 3-4 bed mews houses; • 20% affordable housing is proposed (13 dwellings); • 45 Parking spaces for residential use (approx. 0.7 spaces per dwelling); • Private garden or balcony space for the majority of dwellings; • Access from the existing entrance point off Cecil Road, via an improved vehicle junction; • Redevelopment of site to residential use whilst retaining access to existing constraints as required (e.g. substation, covenants), this includes the 6 additional car parking spaces retained for use by a neighbouring property; and • All proposed dwellings meet nationally described space standards. The apartments will be designed to facilitate flexible use of space and generous ceiling heights will be proposed for all main living spaces.
4.2 The proposals include two blocks of apartments and two areas of mews houses as below: • Block A: the main block comprising 44 apartments; • Block B: comprising 14 apartments; • Mews A: 5 no. 4 bed mews houses; and • Mews B: 2 no. 4 bed mews houses.
4.3 Detailed design information can be found within the supporting Design and Access Statement prepared by Barton Willmore.
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5.0 CONSULTATION
5.1 A formal submission for pre-application request was made to Bristol City Council in March 2020. The proposed development submitted for pre-application comment related to a scheme for 78 dwellings (no affordable housing provision and a proposed density of 153 dph) and the buildings proposed ranged from 2-4.5 storey plus semi basement parking.
5.2 The response from Bristol City Council dated 16 th July 2020 confirmed that there are not any designations, policies or constraints that mean the principle of residential development is unacceptable. However, the pre-application response listed a number of matters to address within a future application for planning permission. The Council’s response dated July 2020 was prepared prior to the Zoo announcing closure of the Clifton site. The closure of the Bristol Zoo Gardens site in 2022, means that a number of issues stated within the Council’s response are no longer of relevance. However, the following remain matters to address as part of this application:
• Provision of 20% affordable housing should be considered; • The proposal was a storey too high; • The removal of car parking does not create unacceptable pressure on on-street parking or other car parks; • The site is within a sensitive heritage setting and needs a considered heritage-led response; • Height, scale, massing and density needs to be considered; • The lack of outdoor amenity space to serve dwellings; • Protecting the amenity of neighbouring properties; • A Sustainability Statement is required setting out response to policies; and • The Protection of existing trees, replanting and ecology.
5.3 The pre-application comments received from the Council have been considered in full and the content of the application is in accordance with the validation requirements and addresses each matter, as detailed in subsequent sections.
5.4 Regular review meetings with the planning officers have been held during the design and consultation process on the evolving development, highways and conservation heritage.
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Public Consultation
5.5 An extensive public consultation programme has been undertaken as part of the pre -application process. The Society and its consultant’s JBP, have consulted individuals, occupiers of neighbouring properties, key stakeholders and public groups as part of the continued consultation. Further detail can be found in the supporting Statement of Community Involvement. The comments received have helped to inform and guide the proposal. The groups consulted include:
• Neighbours • Community Forum • Bristol Civic Society • Clifton and Hotwells Improvement Society
5.6 The following means of consultation have been undertaken:
• Letters sent to 54 immediate near neighbour addresses in Clifton Down, College Road, Cecil Road, advising the occupants of the pending consultation and offering virtual meetings or telephone conversations to discuss the proposal in advance of the wider public consultation; • Community Forum meetings, where representatives of key stakeholder groups, including resident associations, have been able to view the work in progress proposal and make comments and ask the design team and Society questions at regular intervals; • Online digital exhibition to replace the pre-COVID standard public exhibition. This was publically available to view via the Bristol Zoological Society website and provided an opportunity to make comment, but to also read further information. • A consultation pack, including a copy of the exhibition material was delivered to over 200 addresses. This also included a questionnaire, with space for comments, and a freepost reply envelope; • The proposal, consultation process, and opportunities to engage, was widely advertised by the Society in Clifton via a geo-targeted Facebook Ad campaign, with a reach of more than 6,000; • It was promoted through the Society’s subscriber and Member enewsletters; • The consultation was covered by Bristol Post, BBC Online and ITV Westcountry; and • Separate meetings have been held with neighbours, Bristol Civic Society, and other key stakeholders.
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5.7 The table below (reproduced from the Statement of Community Involvement summarises the comments received during the consultation process and how the design has considered them :
People told us… The Society’s response
Sustainability
‘Sustainability should be a high priority The Society agrees, and has made sustainability a core factor in for the site’ the design process. Our sustainability consultants have been working with the design team in bringing forward a design that includes a fabric first approach to construction, the inclusion of energy- efficient Air Source Heating, which becomes ‘plug and play’ ready for further decarbonisation of the national grid.
In addition, the design of the building fabric seeks to provide a 30-40% carbon reduction above the baseline Part L requirement for reducing heat loss and air permeability.
The scheme has also been considered and designed against the Home Quality Mark for wellbeing, design and comfort of future inhabitants. Types of Homes
‘There should be a mix of differently- The application includes a mix of differently-sized homes from sized homes’ 1, 2 and 3-bed apartments to 3/4-bedroom mews houses. Brownfield sites
‘Brownfield sites should be developed’ This is a brownfield site in an urban area which is already developed as a car park. The Society is proposing the redevelopment of the car park to deliver much needed housing on a brownfield site in a central location in line with principles of the NPPF and local planning policy. The proposed use will deliver more social and economic benefits than the current use of the site as a car park.
Design
Some were ‘concerned about the During, and following the consultation process, Block A has gone height, scale and massing of Block A through a process of refinement with the massing and elevation (on College Road) and its effects on design to break up the visual scale of the building. neighbouring properties’. The massing and height has been considered against the existing neighbouring properties, and discussed in detail with the heritage consultant to further articulate the façade, and design to ensure that there is no adverse impact on the character of the surrounding area, and the development is appropriate in scale to the area.
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The ridge height is approximately 2.3m (less than a storey) above the existing height of the adjacent terraces. This is considered acceptable in the Urban Living SPD which defines this as modestly higher than prevailing building heights (can be up to 1.5x height).
The ridge height is approximately 1.2m above the existing height of the Pavilion building opposite. Our heritage consultant has considered the new development against the Pavilion, and the impact on the heritage and significance of the Pavilion Building.
The design has been carefully considered with the upper floor within the mansard roof space to ensure efficient use of the building envelope, a common feature of buildings in the Clifton area.
A daylight/sunlight assessment of the impact of Block A on surrounding properties and their amenity space shows that they are in line with acceptable BRE standards.
Heritage consultants have informed the proposal and undertaken a Conservation Area assessment. Their findings are that ‘although in general proximity to other historic buildings the site’s location does give sufficient space to ensure that the new structures will not dominate them’.
‘Plans were good - thoughtful, It is important that the design strikes a balance between balanced, and efficient’ maximising the potential of the site within an efficient and appropriate building form whilst being responsive and considerate to its context.
The elevation style and façade design contemporary yet sensitive to the heritage area. It would not be considered appropriate to pastiche replication of existing building styles, and a modern contemporary style would not be in keeping with the area. The proposed style sensitively responds to the surrounding area in a contemporary manner.
The design has been developed in collaboration with consultants to ensure it is appropriate to neighbouring properties and the character of the Conservation Area.
The building line follows existing adjacent terraces, creating a positive presence and active street frontage. The primary elevation on to College Road will sit behind the existing boundary wall (reduced in height) and planting. This is common to the area and in keeping with the character of the Conservation Area.
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‘High-quality materials’ were High-quality local materials such as natural stone (both rubble important stone/ smooth faced) are proposed which are in keeping with that of the surrounding buildings. ‘Being in keeping with the character of Heritage consultants have informed the development of the the conservation area’ was important. proposal and undertaken an assessment of the proposal in Some asked if ‘there would be an relation to the Conservation Area. impact on nearby heritage assets (such as Grade II listed buildings)?’ Their findings are that the proposal does not dominate heritage features: ‘Although in general proximity to other historic buildings, the site’s location does give sufficient space to ensure that the new structures will not dominate them’.
A detailed heritage analysis of both designated (Listed) and non- designated heritage assets, including the impact of the proposed development on the character area is detailed in the Historic Environment Impact assessment report.
Density / housing numbers
Some respondents felt that ‘The density There is a responsibility for the Society, the consultant team proposed was too high’ and Bristol City Council (BCC) to ensure an appropriate and efficient development of a brownfield site in a sustainable location.
As a charity the Trustees are legally required to obtain maximum value from the charity’s assets to reinvest in its charitable objectives.
BCC’s Urban Living Supplementary Planning Document encourages increased densities of housing where appropriate, particularly on a site which is well-served by public transport and within walking distance of centres including Clifton Village and Whiteladies Road.
The level of density proposed has been interrogated to ensure that the following features can comfortably be incorporated within the site alongside the proposed density: • A good range and mixture of residential accommodation provided across the site, ranging from 1-3 bed apartments and 4 bed houses. This has been led by market intelligence to ensure the exact mix is appropriate to the local context; • An appropriate level of parking relative to dwellings; • All homes are generous in sizing (compliant with National Space Standards); • Majority have private outdoor amenity space (balcony, terrace or gardens).
Traffic / access / parking
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‘Why was a single access point off Cecil A number of options were considered for access, including the Road proposed? Wouldn’t it be better existing point on College Road. The existing access off College to retain the access point on College Road is not of suitable design for a residential development Road?’ because of restricted width and visibility from the adjacent boundary walls.
The proposed access arrangement will result in less traffic through the Cecil Road/College Road junction during the peak hours and a very limited increase at other times, whilst the Zoo is still open. There is no record of road safety issues at the junction.
A single access point from Cecil Road is sufficient for the size and number of dwellings proposed.
‘Wouldn’t there be an increase in traffic We have undertaken surveys with expert transport consultants and an impact on air quality?’ Peter Evans Partnership (PEP) over several years. This has allowed us to gain an insight into parking need and availability in the local area. PEP has calculated that the new scheme will generate less traffic than the current site’s use. Once the Bristol Zoo Gardens (BZG) site closes, there will no longer be traffic generated by visitors.
The assessment by PEP has identified hourly traffic flows through the College Road/Cecil Road during the day as a result of the development would be around six vehicles. This equates to one vehicle every 10 minutes which would also not be a material increase. The increase in traffic identified above would also only be temporary until Bristol Zoo Gardens closes in late 2022.
The proposed redevelopment Annual Average Daily Traffic (AADT) is predicted to be 159. The existing trip generation, for when the site was operating as a car park, was 206 AADT. Traffic flows are therefore predicted to decrease.
Comments relating to car parking The accessibility of this location makes not owning a car a provision included: realistic option for residents, and so the policy is different. • ‘There were not enough There is pressure from Government/locally to make such parking spaces for the number changes for new homes. of homes proposed’ Sustainability is core to everything the Society does, and its • ‘There might be increased ambitions for this site and its future. demand on local on-street permit parking’ Bristol City Council’s (BCC) highways team has advised us that they will seek this development to be designated as ‘low-car’. • ‘The development should be This means that the development would be put on the list of car-free and car use actively developments that are prohibited from obtaining RPZ permits. discouraged’
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A BCC mapping tool records this information and is used when a request for a parking permit is made. The team has said that they will seek a condition or obligation to the planning permission that this advice is passed to owners/tenants.
In line with the NPPF and local planning policy when determining car parking provision, consideration should be given to site accessibility, availability of public transport, car ownership levels, and mix of development.
The site is within walking distance of employment opportunities, education and a range of shops and services. Direct bus access is also possible to retail and commercial areas, both in Clifton and beyond in Bristol city centre. Therefore, in this location it would not be a necessity to own a car. The level of car parking proposed is therefore designed on this basis.
The Bristol Zoo Gardens site
‘The West Car Park proposal should be The application for the West Car Park is necessary to be able to considered alongside the forthcoming begin the first phase in our development of the new Bristol Zoo, redevelopment plans for Bristol Zoo and will provide the vital funds needed to initiate this Gardens’ development and sustain Bristol Zoological Society over the next 3 years during this transition period. This phased approach ensures we have sufficient capital and security ahead of the redevelopment plans for the Bristol Zoo Gardens.
The Executive Board and Trustees of Bristol Zoological Society will be leading a separate planning permission process for the future of the Bristol Zoo Gardens site. It is intended to include an ‘urban conservation hub’ in the Zoo’s iconic main entrance building to ensure the heritage and story of the Zoo will continue to be told. This could also become the base of the Avon Gorge and Downs Wildlife Project community and conservation programmes, an exhibition of Bristol Zoo Gardens’ heritage and a café. Affordable housing
There was a mixed response on Twenty per cent of the housing is proposed to be affordable. affordable housing, with most concerns This is in line with Bristol City Council’s Core Strategy Policy regarding affordability of housing for BCS17, and the requirements set out in the Affordable Housing first time buyers. Practice Note 2018 for proposals in the ‘inner west’ part of the city, responding to the significant need in Bristol.
Outdoor space
Many felt that ‘private outdoor amenity The need for outdoor space is recognised as especially important space was important‘ following the COVID-19 pandemic. The site is within a two- minute walk of Clifton Down, providing residents with an
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opportunity for enjoyment of expansive shared outdoor space. 77 per cent of the proposed dwellings have a private amenity space in the form of a private garden or generous balcony exceeding 1.5m in width and depth.
Sufficient outdoor amenity space is also provided in line with the Quality Home Mark for sustainable homes
A number of respondents stated that There are a number of good quality mature trees on the site ‘trees, including additional trees and that are to be retained, as they are both ecologically important, the conservation of fine existing trees, and add to the distinctive character of the area. were important’ Any smaller trees that are required to be replaced within the car park will be better integrated into the development’s design layout in line with Bristol City Council’s Tree Replacement Standard and enhance the ecological value of the site.
The inclusion of green roofs and living walls further support wildlife, and integrate the tree planting with other spaces for wildlife to nest, forage and shelter.
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6.0 PLANNING POLICY
Introduction
6.1 This section of the Planning Statement summarises the relevant planning policy context for the planning application.
6.2 Section 38(b) of the Planning and Compulsory Purchase Act 2004 states that determination of a planning application must be made in accordance with the Development Plan unless material considerations indicate otherwise.
6.3 The Development Plan for the application site comprises: • The Bristol Core Strategy (2011); • Site Allocations and Development Management Policies Local Plan 2014; • Bristol Central Area Action Plan 2015; and • West of England Joint Waste Core Strategy 2011.
6.4 Relevant material planning considerations include Bristol’s Urban Living Supplementary Planning Document (SPD 2018) and the Government’s overarching policies contained within the National Planning Policy Framework (NPPF), which establish a presumption in favour of sustainable development, encourages economic growth and seeks to boost the supply of housing.
National Planning Policy Framework
6.5 The National Planning Policy Framework (NPPF) sets out the Government’s planning policies and how they are expected to be applied. The relevant sections of the NPPF are outlined as below.
Delivering a sufficient supply of homes
6.6 Paragraph 65 and 66 set an expectation for strategic policy-making authorities to establish a housing requirement figure for their whole area, including a set housing requirement for the individual neighbourhood areas reflected in the strategy. If it is not possible to provide an accurate figure for a neighbourhood area, an indicative figure should be provided, if requested by the neighbourhood planning body. The indicative housing requirement figure should be based on up - to-date evidence.
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Determining Applications
6.7 In determining applications, Paragraph 49 states that arguments that an application is premature are not likely to justify refusal. It may be considered more likely in the limited cases where the emerging plan is not yet adopted and the proposal or impact deriving from the development would be significant, whereas granting permission would undermine the plan-making process.
Achieving appropriate densities
6.8 Within paragraph 123 of the NPPF it is stressed that planning policies and decisions avoid homes being built at low densities and ensure optimal use of a site where there is an existing or expected shortage of land to meet housing requirements. The use of minimum density standards should be considered in these cases and where appropriate a range of densities applied for the different areas.
Achieving well-designed places
6.9 The NPPF considers good design a key aspect of sustainable development and states that the creation of high-quality buildings and places is a fundamental goal of the planning and development process. Paragraph 124 states that the Government considers effective engagement between stakeholders, including applicants, communities and local planning authorities as essential throughout the process.
6.10 The Design and Access Statement which supports the planning application sets out how the scheme follows the principles of good design to create a sustainable development, entirely in keeping with its local context.
Local Planning Policy
6.11 The Development Plan for Bristol comprises the following:
• Core Strategy 2011; • Site Allocations and Development Management Policies Local Plan 2014; • Bristol Central Area Action Plan 2015; and • West of England Joint Waste Core Strategy 2011.
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6.12 The application site is within the Clifton and Hotwells Conservation Area (Policy BCS22). Bristol Core Strategy Policy BCS22 and Development Management Policies Local Plan Policy DM31 requires development proposals to safeguard or enhance heritage assets.
6.13 The development proposals will be assessed against the policies within the Development Plan and relevant local guidance including the Bristol Urban Living SPD. The proposal is in accordance with all relevant policies, but of importance is the following Policies which are considered in detail in later sections of this Statement:
• Affordable Housing BCS17 • Housing Mix BCS18 • Sustainable Travel – BCS10 • Climate Change – BCS13 • Sustainable Energy – BCS14 • Sustainable Design – BCS15 • Density – BCS20 • Transport – DM23 • Amenity Space – DM27 • Green Roofs – DM29
6.14 We provide a summary below of the key policies in relation the site and the proposed development. The Bristol Urban Living SPD is an important consideration and this is addressed fully in the submitted Design and Access Statement.
Heritage
6.15 The site is in the Clifton and Hotwells Conservation Area, and has four Listed buildings on the western boundary, where the following policies apply:
• The National Planning Policy Framework sets out that when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation, irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance.
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• Core Strategy Policy BCS21 sets out that development in Bristol will be expected to contribute positively to an area’s character and identity, creating or reinforcing local distinctiveness.
• Core Strategy Policy BCS22 requires development proposals to safeguard or enhance heritage assets and the character and setting of areas of acknowledged importance including:
o Scheduled ancient monuments; o Historic buildings both nationally and locally listed; o Historic parks and gardens both nationally and locally listed; o Conservation areas; and o Archaeological remains.
• Site Allocations and Development Management Policies Local Plan Policy DM31 expects development that has an impact upon a heritage asset to conserve and, where appropriate, enhance the asset or its setting.
Density
6.16 The Local Plan seeks a minimum indicative net density of 50 dwellings per hectare. Residential densities below this figure should only occur where it is essential to safeguard the special interest and character of the area. Core Strategy Policy BCS20 sets out that new development will maximise opportunities to re-use previously developed land – for residential development a minimum indicative net density of 50 dph will be sought. Net densities below 50 dph should only occur where it is essential to safeguard the special interest and character of the area. The appropriate density for any individual site will be informed by:
• Characteristics of site; • Local context; • Current and future level of accessibility to a range of employment, services and facilities; • Opportunity for mix of uses across site; • Need to provide appropriate mix of housing for community’s needs; and • Need to achieve high quality environments.
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6.17 In the emerging Draft Policies and Development Allocations document the site is located within the inner urban (more intensive) zone, where the minimum density is 120 dph (Policy UL2 Urban Densities). Similarly, the adopted Urban Living SPD (2019) identifies a density within urban settings of 120 dph. 6.18 Draft Policy UL1 in the emerging Draft Policies and Development Allocations document requires land to be used efficiently within the city with average site density of residential completions being around 100 dph, and that optimum density for new development is the density which balances the efficient use of land with liveability considerations.
6.19 Bristol City Council’s Urban Living SPD 2018 sets out a commitment to make the most of the development land available in the city to support the significant increase in new -and-affordable homes and infrastructure we desperately need. The SPD includes a commitment to making the most of the development land available in the city to support the significant increase in new -and- affordable homes and infrastructure the City so desperately needs. This is in recognition of the dramatic shift with people returning to live in or close to the city centre in the last 20 years. This urban renaissance has led to apartment living being commonplace in Bristol. The more successful schemes combine homes with cafes, shops, community uses and workplaces to create vibrant spaces with a high quality public realm.
Affordable Housing and Mix
6.20 Core Strategy Policy BCS17 requires the provision of 40% affordable housing. However, Bristol City Council’s Affordable Housing Practice Note (April 2018) includes, for an interim period, a ‘Threshold’ approach to policy BCS17 where planning applications (in Bristol Inner West and East zones) are meeting and exceeding 20% affordable housing could follow a ‘Fast Tra ck’ route. The site is within the Inner West Zone, where on the basis of the threshold approach the affordable housing requirement is 20%.
6.21 Policy BCS18 and BCAP3 require a mix of housing tenures, types and sizes as well as amenity space.
Car and Cycle Parking Standards
6.22 Site Allocations and Development Management Policy DM23 requires new develop to provide parking for pedestrians and cyclists including, where appropriate, enhancing the pedestrian and cycle network and, for major non-residential schemes, providing adequate changing, shower,
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storage and drying facilities for cyclists. In accordance with the adopted standards, development proposals will be expected to: • Provide an appropriate level of safe, secure, accessible and usable parking provis ion having regard to the parking standards, the parking management regime and the level of accessibility by walking, cycling and public transport; and • Provide appropriate servicing and loading facilities.
Accessible Homes
6.23 Site Allocations and Development Management Plan Policy DM4 requires 2% of new housing within residential developments of 50 dwellings or more to be designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users.
6.24 Emerging policy in the Local Plan Review (Draft Policy H9) requires residential development to include at least 10% of new build housing in proposals of 50 dwellings or more designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users (compliant with Building Regulations M4(3) Category 3: Wheelchair user dwellings). All new build housing designed to be accessible and adaptable (compliant with Building Regulations M4(2) Category 2: Accessible and adaptable dwellings) except for those dwellings that are designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users.
Amenity / Outdoor Space
6.25 Core Strategy Policy BCS21 requires development to contribute positively to an area’s character and identity, creating or reinforcing local distinctiveness and safeguard the amenity of existing development and create a high-quality environment for future occupiers by:
• Delivering a coherently structured, integrated and efficient built form that clearly defines public and private space; • Provide diversity and choice through the delivery of a balanced mix of compatible buildings and uses; • Create buildings and spaces that are adaptable to changing social, technological, economic and environmental conditions; • Promote diversity and choice through the delivery of a balanced mix of compatible buildings and uses.
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6.26 Site Allocations and Development Management Policy DM2 seeks the provision of a good standard of accommodation for future occupiers. Consideration should be given to layo ut, internal living space, external amenity space, outlook, privacy, adaptability, security, cycle and car parking and refuse and recycling storage. Policy DM27 provides further detail, and sets out that development will be expected to:
• Enable the provision of adequate appropriate and usable private or communal amenity space, defensible space, parking and servicing where necessary; • Achieve continuity of development edge that encloses and clearly define the public realm whilst physically; • Create distinct public fronts and private backs with clear and obvious ownership and responsibility for external spaces provided; • Enable active frontages to the public realm and natural surveillance over all publicly accessible spaces; • Enable existing and proposed development to achieve appropriate levels of privacy, outlook and daylight; • Be flexible to accommodate alternative but appropriate building types, plot types and uses which could adapt or change independently over time, taking into account the possibility for future extension.
6.27 Site Allocations and Development Management Policy DM16 requires new development to ensure that open space for recreation, to meet the minimum quality, access and quantity standards set out below:
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6.28 Site Allocations and Development Management Plan Policy DM29 requires new buildings to be designed to a high standard of quality by providing appropriate surveillance of all external spaces; ensure that existing and proposed development achieves appropriate levels of privacy, outlook and daylight; and to incorporate active frontages and clearly defined main entrances facing the public realm that emphasis corners and reinforce the most prominent frontages.
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Trees and Green Infrastructure
6.29 Site Allocations and Development Management Plan Policy DM17 requires new development involving existing green infrastructure to integrate important existing trees. Where tree loss or damage is essential to allow for appropriate development, replacement trees of an appropriate species should be provided.
6.30 Core Strategy Policy BCS9 sets out that green infrastructure assets include open spaces, gardens, allotments street trees and planting. Development should incorporate new and/or enhanced green infrastructure of an appropriate type, standard and size. Where on-site provision of green infrastructure is not possible, contributions will be sought to make appropriate provision for green infrastructure off site.
6.31 Site Allocations and Development Management Plan Policy DM15 sets out that the provision of additional and/or improved management of existing trees will be expected as part of the landscape treatment of new development. The design, size, species and placement of trees provided as part of the landscape treatment will be expected to take practicable opportunities to:
• Connect the development site to the Strategic Green Infrastructure Network/Bristol Wildlife Network; • Assist in reducing/mitigating run-off and flood risk on the development site; • Assist in providing shade and shelter to address urban cooling; and • Create strong framework of street trees to enclose or mitigate the visual impact of a development.
6.32 The Urban Living SPD recommends that schemes incorporate existing trees into the overall design and layout, setting building back sufficiently to allow for growth, so that it responds positively to the existing/emerging context. It recommends that schemes plant deciduous trees along a south facing elevation to provide shading in the summer whilst permitting sun to penetrate at low winte r angles. In creating attractive, well designed/maintained outdoor spaces, the SPD recommends planting trees directly in the ground where communal private space is provided on a deck above a parking podium.
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Sustainability
6.33 Core Strategy BCS13 sets out that development should contribute to mitigating climate change through measures including:
• High standards of energy efficiency including optimal levels of thermal insulation, passive ventilation and cooling, passive solar design, and the efficient use of natural resources in new buildings; • Use of decentralised, renewable and low-carbon energy supply systems; and • Patterns of development that encourage walking, cycling, use of public transport.
6.34 Development should adapt to climate change through measures including:
• Site layouts and approaches to design and construction which provide resilience to climate change; • Measure to conserve water supplies and minimise the risk/impact of flooding; • Use of green infrastructure to minimise/mitigate the heating of the urban environment; and • Avoiding responses to climate impacts which lead to increases in energy use and carbon dioxide emissions.
6.35 Core Strategy Policy BCS14 sets out that development should minimise its energy requirements and incorporate renewable and low-carbon energy supplies to reduces its carbon dioxide emissions.
6.36 Core Strategy Policy BCS15 seeks to ensure that new developments are designed and constructed to minimise their environmental impact and contribute to meeting targets for reductions in carbon dioxide emissions.
6.37 The Urban Living SPD states that, in order for schemes to create a healthy environment for future occupants, Thermal Comfort Assessments should be prepared to demonstrate that the building will not overheat in current/future climate change scenarios, accounting for the urban heat island effect where relevant.
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Recycling and Refuse in New Development
6.38 Core Strategy Policy BCS15 and BCS21, and Site Allocations and Development Management Plan Policy DM32 requires flatted development to provide, as a minimum shared recycling facilities and refuse bins of sufficient capacity to serve the proposed development.
6.39 The location and design of recycling and refuse provision should be integral to the design of the proposed development. In assessing recycling and refuse provision, regard will be had to the following considerations:
i. The level and type of provision, having regard to the above requirements and relevant space standards; and ii. The location of the provision, having regard to the need to pro vide and maintain safe and convenient access for occupants, while also providing satisfactory access for collection vehicles and operatives; and iii. The impact of the provision on visual amenity, having regard to the need to minimise the prominence of the facilities and screen any external provision; iv. The impact of the provision on the health and amenity of neighbouring development and the proposed development; and v. The security of the provision against scavenging pests, vandalism and unauthorised use. Recycling and refuse storage should be separate from cycle storage, car parking and key circulation areas.
6.40 Development will not be permitted if recycling and refuse provision that meets the above capacity, design and access requirements cannot feasibly or practicably be provided.
Urban Living SPD
6.41 With regards to supplementary guidance, Bristol City Council’s Urban Living SPD 2018 is relevant and sets out a commitment to make the most of the development land available in the city to support the significant increase in new and affordable homes and infrastructure we desperately need.
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Emerging Local Plan
6.42 Bristol City Council is currently undertaking a Local Plan Review which will set out how Bristol will develop over the next 20 years, and the first round of consultation was undertaken in 2018. The most recent consultation was the Bristol Local Plan Review Draft Policies and Development – publication is set for 2022. The Plan is anticipated for adoption at the end of 2023.
6.43 The new plan should seek to include the Standard Method approach to housing requirements. The Standard Method suggests for Bristol a difference of 38,000 homes over a 20-year period. To accommodate this housing growth, there is a need to prioritise the development of brownfield sites to help reduce the pressure for the development of green belt sites.
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7.0 ASSESSMENT OF PROPOSALS AGAINST PLANNING POLICY
7.1 Based on an assessment of the proposals against national and local planning policy we provide what we consider to be the key planning considerations below.
Principle of Development on brownfield land
7.2 The site is considered brownfield due to its existing car park use and the Zoo’s ancillary buildings. There is not National or Local Policy to protect car parks. The site is brownfield previously developed land and is not subject to any national designations. The redevelopment of the car park to much-needed housing on a brownfield site in a central location is in line with principles of the NPPF and local planning policy. The proposed use will deliver more social and economic benefits than the current use of the site as a car park.
7.3 The principle of development of this brownfield site was supported in the Council’s formal pre- application response. This states that the Council do not consider that there are any designations, policies or constraints that means the principle of residential development is unacceptable.
7.4 A key objective of the Bristol Urban Living SPD (October 2018) is the efficient and effective use of land. It sets out that we need to make the best use of the city’s limited land supply in order to meet the need for new homes, jobs and infrastructure required by the City’s growing population. The highest densities should be located at the most accessible and sustainable locations. All developments should look to optimise their development footprint; accommodating access, servicing and parking in the most efficient ways possible. Where possible, different land uses should be mixed together; residential above businesses and community uses should become common place.
7.5 In the Urban Living SPD, Bristol Zoo Gardens is identified as being within the ‘inner urban area’. In relation to this area, the Urban Living SPD sets out that there is a common misconception that higher density development equates to poorer quality homes and neighbourhoods. So me of Bristol’s most desirable neighbourhoods, such as Clifton and Southville, are actually some of the most densely developed areas. Typical gross densities in Clifton are over 90dph, compared with gross densities of around 65dph on post-war high-rise estates. Whilst it is envisaged that the established residential areas will remain largely unchanged, there are opportunities to optimise densities in the transition areas in between the established character areas. From the emerging
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local plan context in Bristol and the region, it is clear that housing need is significant and that this relies on urban intensification and the delivery of brownfield, sustainable sites within Bristol.
7.6 On this basis, the principle of residential development at the West Car Park is considered to be acceptable, subject to the design being sensitive to the heritage setting (considered below). The West Car Park site provides a key opportunity to provide much-needed quality housing on a brownfield site in a sustainable location in Bristol.
Housing Mix
7.7 In line with local adopted and emerging planning policy on housing mix (BCS18 of the Core Strategy and Draft Policy H4 of the Draft Policies and Development Allocations), the proposals provide a mix, with a combination of one, two, and three-bedroom apartments and mews houses, contributing to diversity of housing in the area and redressing housing imbalances, and respond to changing population requirements. The proposed housing mix is:
Size of units No. % 1 bed (2 person) 13 20 2 bed (3 person) 5 8 2 bed (4 person) 34 52 3 bed 6 9 4 bed 7 11 Total 65 100
7.8 The pre-application advice received suggested that the proposed mix included some houses of at least 3 bedrooms and this has been considered and incorporated into the design proposal.
Affordable Housing Statement
7.9 The application provides 20% affordable housing, providing a ‘Threshold’ com pliant scheme under Route 2 of the Affordable Housing Practice Note 2018. This is in accordance with the guidance within Policy BCS17 and the Affordable Housing Practice Note. The site is within the ‘inner west’ part of the City and the proposed housing responds to the significant need in Bristol. The affordable housing will be delivered without public subsidy.
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7.10 The proposed 13 affordable dwellings will be located within Block B and comprise of the following mix: • 4no. 1b2p flats (min 50sqm.) • 5no. 2b3p flats (min 61sqm.) • 4no. 2b4p flats (min 70sqm.)
7.11 The design of the affordable housing is indistinguishable in external appearance from the open market sale homes. The Applicant excepts a S106 legal agreement, which will set out the amount and location of the affordable units.
7.12 All affordable units comply with the Nationally Described Space Standards (NdSS) and a percentage of the affordable units will be fully wheelchair accessible.
Heritage Impact
7.13 Unlike Bristol Zoo Gardens, the car park (the application site) is not subject to the Local Historic Park and Garden designations (BCS22 and DM31) and Important Open Space (Policy BCS9 and DM17). There are not any Listed Buildings on site.
7.14 In line the NPPF, and Core Strategy Policy BCS21, BCS22, and Site Allocations and Development Management Policies Local Plan Policy DM31, the proposals conserve and enhance the setting of the adjacent Listed Buildings and Conservation Area. The current baseline analysis undertaken by Cotswold Archaeology has informed the proposal. As the application site is located within the Clifton and Hotwells Conservation Area and whilst there are no listed buildings or structures within the site boundary, there are a row of Grade II Listed properties which border the car park along the western boundary (Clifton Downs Villas). The proposals have been designed to be sensitive in its design response to the local heritage setting in response to the local heritage assets, in line with national and local planning policy.
7.15 Cotswold Archaeology has considered the existing outbuildings on the site (none are designated heritage assets) and two of the three buildings are considered to have no heritage significance. One of the buildings is considered to have ‘low’ heritage significance as it has potential to have been a coach house or gardener’s building and is approximately of the mid-Victorian era. Given the notable change in surroundings, the building is no longer readily ineligible as ancillary to the main villa and is of little real architectural interest and has a relatively high ‘capacity for change’.
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The proposal demolishes all the buildings on the site therefore the demolition of this building with ‘low’ heritage significance will need to be assessed against the need for new h ousing.
7.16 The boundary wall is a non-designated heritage asset and is not ‘curtilage listed’. Design proposals include partial removal of the wall to a certain height, retaining the boundary role in the local experience, along with key architectural features. There is a degree of ‘capacity for change’ in this regard that facilitates good place-making and in making smaller scale changes, retain the presence and intelligibility, facilitating better use of the site, and creating a more inviting, active frontage which communicates with the road in a more open and aesthetically pleasing way, whilst retaining its developed boundary role. The design proposals set to positively enhance the aesthetic on completion.
7.17 In respect of the impact on the Clifton and Hotwells Conservation Area it is considered that the proposed development facing College Road is an improvement compared to the existing car park. The car park is not a positive in the Conservation Area. The proposed buildings will not detract from the street scene and the proposed planting will have a positive effect.
7.18 The aspiration of the proposals is for a quality scheme which is sensitive to the heritage setting and representative of the wider city fabric. The elevation treatment and materiality has been primarily driven by its heritage setting and adjacent building and the proposals draw a contemporary yet sensitive reference from the local vernacular and heritage setting. The uppermost storey comprises of a mansard roof with dormer windows and this has been influenced by other buildings in the vicinity. The proposed materials will also integrate this contemporary take on traditional architecture into the existing setting.
7.19 The impact on existing Listed Buildings, Clifton Down Villas, has been considered and the Heritage report concludes that the changes as a result of the development, do not lead to a significant harm to the setting or significance of the Listed Buildings, but will lead to a small level of harm due to this change. This is overall considered to amount to a less than substantial harm (lower end) to the significance of the Villas. The same conclusion is reached for the Listed Pavilion building, set within Bristol Zoo Gardens, which is located opposite the application site. No instances of ‘substantial harm’ are recorded and the limited effects should be weighed against the benefits of the proposal.
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Access, proposed car parking and refuse
7.20 The application site will be accessed from Cecil Road for vehicles and pedestrians. A further pedestrian access point is provided off College Road to increase permeability of the site. The proposed layout makes provision for 45 car parking spaces (0.7 space per dwelling).
Parking No. Total number of parking spaces provided 45 (+6 retained for use by Glenavon) Number of residential parking spaces 45 (not including 6 retained for use by Glenavon) Number of parking spaces provided in garages 7 (one garage per mews house) Number of parking spaces provided in open 38 area of surface parking (to include 1 space for car club)
7.21 The location of the site means that education, employment, retail and services are all accessible from the site by foot, cycle and public transport in accordance with NPPF para 108 and Local Plan Policy DM23. The site and development is also in accordance with emerging Local Plan Policy T1 given the means of available alternative transport and by the provision of a car club car. The level of parking is appropriate considering the site’s proximity to local facilities and sustainable transport modes.
7.22 The Bristol City Council adopted car parking standards are maximum standards, and based on these standards a maximum of 83 car parking spaces could be provided for the proposed residential development. The provision of 45 car parking spaces is in accordance with these maximum standards. However, in line with NPPF and local planning policy when determining car parking provision consideration should be given to site accessibility, availability of public transport, car ownership levels, and mix of development. The site is within walking distance of employment, education, retail and services. Bus access is also possible to retail and commercial areas, both in Clifton and beyond in Bristol city centre. Therefore, in this location it would not be a necessity to own a car. The level of car parking proposed is therefore designed on this basis. The level of car parking proposed has also taken into consideration the type of housing proposed, anticipated car ownership levels, and also making efficient use of the land available, as suggested a t Local Plan policy DM23, in the Bristol Urban Living SPD, NPPF, and the emerging Local Plan policy T3.
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7.23 Sustainable transport modes will take priority over the private car; ample secure bike storage facilities (for 96 bikes for the apartments and 32 bikes in the south east building) will be provided at ground floor level across the site. Short stay outside cycle parking would also be provided by Sheffield stands meeting the requirement of one space per 10 dwellings. The amount of cycle parking exceeds the Bristol City Council minimum standards by 19 spaces.
7.24 A proportion of the surface level parking spaces will be provided with electric car charging facilities in addition to seven electric sockets allowing electric charging with the mews house garages (20% provision in accordance with emerging policy T5). The location will be discussed with BCC’s Highways Officer.
7.25 Refuse collection for the mews houses would take place from outside the property for those fronting the main access, and from a bin collection point at the back of the mews houses in the south east part of the site.
7.26 Refuse storage will be provided at ground level across the site within the apartment buildings. Access to these stores for refuse collectors would be adjacent to the highway from within the site.
7.27 In respect of the development and traffic impact, the traffic impact assessment undertaken has identified that in the long term there would be a net traffic benefit compared to the current usage of the site as a car park. However, in the short term during the period that the Zoo is still operational, the traffic impact of the residential development alone is not ‘severe’ and thus would not result in a road safety concern, in line with NPPF paragraph 109.
7.28 The accompanying Transport Assessment and Travel Plan prepared by PEP provides further information.
Loss of Car Parking
7.29 The Bristol Zoo Gardens West Car Park has a total of 160 car parking spaces. The car park is used by Bristol Zoo Gardens based colleagues (approximately 50 staff and volunteers park in the West Car Park each day), Bristol Zoological Society operational vehicles, visitors to Bristol Zoo Gardens (when required), and corporate/function guests to the Pavilion. Some of the residential properties to the west of the car park also have a right of access through the car park to the rear of their properties.
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7.30 As part of its decision to close the Clifton Zoo site at the end of August in late 2022, the Society requires the sale of the West Car Park to be able to invest in its long-term future in developing the new Bristol Zoo at Wild Place Project. There could therefore be a short period of time when the Zoo is open, but the West Car Park is not available for car parking.
7.31 It is proposed that non-operational staff will relocate from Bristol Zoo Gardens to existing office accommodation at Wild Place Project towards the end of 2021. This and other measures will negate the need for dedicated non-operational staff parking at Bristol Zoo Gardens. At this time, end of 2021, the West Car Park will also close to visitors. Therefore, there could be approximately an eight-month period in 2022 when displaced car parking could occur as a result of the closure of the car park.
7.32 At present the Society does make full use of its opportunity of purchasing on-street parking permits for its colleagues. It is anticipated that this would be sufficient to cater for the displaced colleague parking need.
7.33 As the visitor usage of West Car Park varies throughout the year, due to the nature of tourism, so would the level of displaced cars occurring as a result of the closure of West Car Park. On quieter days at BZG there would either be no, or very limited, displaced visitor car parking as a result of the loss of the West Car Park. On the busiest days at Bristol Zoo Gardens there would be up to around 150 cars displaced.
7.34 Anticipated visitor numbers have been modelled across the period of time when the Zoo Gardens will remain open, but the West Car Park is no longer available. A profile can be built of the number of days each month where the North Car Park and on-street parking would be insufficient to accommodate the likely Bristol Zoo Gardens visitor demand. This is estimated to be between nine and twenty-two days depending on how many colleague spaces are used.
7.35 The Society has use of an additional overflow parking facility situated off Ladies Mile. This provides 600 spaces for up to 28 days per year and therefore provides the additional visitor parking capacity that may be required.
7.36 The Society introduced timed visitor tickets in 2020 (as part of COVID adaptations) and this will be continued going forward. The introduction of timed tickets means the Society is able to ensure adequate parking is available relative to the number of visitors arriving at Bristol Zoo Gardens and the need for parking is more evenly spread throughout the day.
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7.37 In addition, a number of other transport options will be available:
• Colleagues and visitors will be encouraged to travel by alternative travel modes, walking, cycling, bus, or train; • Colleagues and visitors could travel by car and use the Long Ashton Park and Ride (Bus service 505 from Long Aston Park and Ride, stops immediately outside Bristol Zoo Gardens); • Colleagues could park on street, if eligible for a permit or park in five hour pay and display bays (free on the Downs); • Visitors could park on street in the five hour pay and display bays (free on the Downs and at weekends).
7.38 If planning permission for this application is granted it is proposed that construction of the development would commence during 2022 (the use of the car park will continue until December 2021 and sold in January 2022). Based on typical build programmes it is unlikely that the residential dwellings would be occupied prior to the closure of the Zoo. Therefore, there is not a time period that the Zoo would be operational and the residential dwellings occupied at the same time.
Design – Height, Scale and Massing
7.39 The proposals have been designed taking into consideration adopted policy within the Urban Living SPD (2018), the Site Allocations and Development Management Policies (2014), and emerging policy contained in the Bristol Local Plan Review Draft Policies and Development Allocations (March 2019). We provide comment below of how the proposals respond to the policies contained within these documents.
Density
7.40 Density: in the emerging Draft Policies and Development Allocations document the site is located within the inner urban (more intensive) zone, where the minimum density is 120 dph (Policy UL2 Urban Densities). Similarly, the adopted Urban Living SPD identifies a density within urban settings of 120 dph.
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7.41 The density of the proposed scheme is 127 dph. This is on the basis of the site being within the inner urban area of Bristol and dominant townscape character area and high intensity usage. It is also based on the site’s proximity to transport infrastructure, facilities and district centre. The site is within easy walking distance of the district centre of Clifton Village; the proposed increased density will therefore support the local services and facilities available. The conversion of many terraced houses and in the immediate context villas into smaller residential units demonstrates a precedent for densification, and an appetite for apartment units of this type. Policy UL1 (Effective and Efficient Use of Land) of the emerging Draft Policies and Development Allocations is clear that new development will be expected to reflect Bristol’s urban character by maximising opportunities to re-use previously developed land and delivering quality, well-designed environments at higher densities. Development proposals should develop land to its optimum density. Development will be encouraged to make efficient use of land by, where appropriate, developing under -used land and buildings and/or extending buildings upwards using the airspace above them. The proposal meets the objectives of the Urban Living SPD in respect of density.
Height
7.42 The proposed development proposes 65 residential units across four development blocks, ranging in height from two storeys up to four and half storeys (accommodation in the mansard roof space). The surrounding residential dwellings are predominantly large villas ranging from three to five storeys in height (accommodation in roof space), with some smaller scale two-storey mews and cottage dwellings to the north. Building heights range from three to five storeys in the surrounding area, therefore a proposed five-storey frontage onto College Road will be successful in reinforcing the block structure onto the road.
7.43 The proposed development does not constitute a tall building (over 30 metres) in respect of the Urban Living SPD. The proposed development is therefore not assessed against section 3 ‘Tall Building’ of the SPD.
7.44 When assessing the proposed height of the development against the SPD, it is apparent that the emerging context has been significantly examined (demonstrated within the Design and Access Statement), which has resulted in the proposal sitting comfortably within the surrounding prevailing building height. The questions set within the SPD have been fully answered within Appendix 1 of the accompanying Design and Access Statement.
7.45 The height of the proposed development was raised in the Council’s pre-application response, which incorporated a semi-basement parking solution. The height has been considered extensively
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since those comments were received and as a consequence the overall proposed height reduced. It is now considered that the proposed building fronting College Road suits the immediate context. Massing
7.46 The block structure and massing has been developed to ensure that no overshadowing of existing and proposed properties occurs. The apartments are arranged primarily on a north/south axis to ensure that the apartments benefit from easterly and westerly light and do not block daylight to any proposed or existing dwellings.
7.47 The buildings are primarily arranged on a north/south axis, to maximise the opportunity for direct light into habitable rooms. The majority of apartments will be dual aspect units benefitting from east and westerly light. Single aspect apartments will be carefully designed to ensure natural illumination and ventilation to all habitable rooms and kitchens. Many units will be provided with balconettes where balconies are not provided.
Open Space
7.48 In line with Core Strategy Policy BCS21, Site Allocations and Development Management Policy DM2, DM16, and DM29, the proposals contribute positively to the area’s character and identity, reinforcing local distinctiveness and safeguard the amenity of existing development, creating a high-quality environment for future occupiers.
Private outdoor space
7.49 The Urban Living SPD recommends providing a minimum of 5 sq m of private outdoor space for a 1-2 person dwelling and an extra 1 sq m for each additional occupant. In accordance with the SPD the proposal provides private gardens and balconies. The minimum depth and width of the balconies exceeds 1500mm as required by the SPD.
Children’s play space
7.50 Children’s play space is not provided on site, given access to a large area of public open space immediately to the North of the A4176 Clifton Down. Children’s play equipment is provided within an 11-minute walk of the site at Clifton Suspension Bridge Playground. Open green space to play on Clifton Down, as well as informal recreation and a number of sports clubs and activities is available within a 2-minute walk (150m).
Sustainability
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7.51 In accordance with Core Strategy Policy BCS13, BCS14, and BCS15 and the Urban Living SPD, the proposals seek to minimise its energy requirements and incorporate renewable and low - carbon energy supplies to reduces its carbon dioxide emissions. The applicant wholeheartedly supports Bristol City Council’s commitment to becoming carbon neutral and climate resilient by 2030. As a wildlife and conservation charity, it also wants to give a helping hand to local wildlife. The development proposals include: • Fabric-first approach for energy efficiency, with the potential to include high levels of thermal insulation and air tightness; • Mechanical ventilation and heat recovery, renewable materials and triple-glazed windows; • Electric car charging points and plentiful cycle parking provision; • Bird boxes, bat boxes/bricks and bee bricks to be integrated on site; • 30-40% carbon reduction from baseline using the current (Part L2013) carbon factors ; • Air Source Heat Pumps providing future proofing for future ‘plug in and play’ to future district heating networks; • Future proof electricity use against 2025 gas ban and provision of further reduction as the national grid becomes further decarbonised; • Development in line with Home Quality Mark 4 Star elements.
Amenity of future occupiers
7.52 The proposal seeks to achieve good levels of amenity for future occupiers. The development provides for adequate levels of light and outlook for future occupiers, plus provision of amenity space is included, following the feedback received at the pre-application stage.
7.53 The design of the dwellings fully complies with Nationally Described Space Standards and the requirements of the Urban Living SPD and meeting 4 Star Home Quality Mark targets for wellbeing and carbon footprint. The design proposal includes all dual aspect apartments to ensure sufficient natural light.
7.54 A Daylight and Sunlight Assessment report prepared by Hydrock accompanies the application and this concludes that the proposed apartments performance is deemed to be acceptable based on the density of the development and the context of the site. The daylight levels received will be well within acceptable tolerances for the majority of the building. The daylight performance is thus deemed to be acceptable, as the worst-case apartments have been modelled which represent a small percentage of the overall scheme. The development is performing well in terms of sunlight as both the rooms and the amenity spaces are passing sunlight criteria.
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7.55 A Daylight and Sunlight Assessment has been prepared in accordance with BRE Guidance to accompany the application. The assessment covers the proposed development and any adverse impact assessment on surrounding residential buildings. The development and impact have been assessed using the criteria set out in the Building Research Establishment’s (BRE) ‘Site layout planning for daylight and sunlight – a guide to good practice’ (BR 209) (Littlefair, 2011). Whilst the guide itself states that its guidelines are not mandatory, they are those predominantly referenced for daylight and sunlight standards in the UK.
7.56 The outcome of the assessment shows that there would be ‘minor adverse’ effect on daylight and sunlight to some of the existing dwellings surrounding the site. Particular existing buildings to note that are minorly affected are terrace houses along College Road (40-48), which will be affected in terms of sunlight levels, and 50 College Road, which will be affected in terms of daylight levels. ‘Minor Adverse’ is deemed where loss of skylight only just meets guidelines or areas that fall outside of guidelines are not critical, as opposed to ‘Moderate Adverse’, where a loss of skylight is marginally outside the guidelines and large area of open space/windows are affected or ‘Major Adverse’, where a large number of open space/windows are affected and the loss of skylight is substantial. However, this is considered acceptable in accordance with BR 209.
7.57 A noise assessment prepared by Hydrock considers the impact of existing noise levels resulting from College Road and the potential noise source of the Zoo’s Clifton Pavilion on the proposed dwellings. The Pavilion is occasionally used for functions and weddings. Clifton Pavilion already has some mitigation in place to control noise break-out and the risk to the proposed dwellings is considered low. Nevertheless, should the local authority wish to impose a noise limit on the venue to provide assurance that the Policy DM35 music noise limit is met within the proposed dwelling, this can be accepted by the Applicant. In any event use of the Venue will cease 2022/2023.
7.58 In respect of noise levels arising from the existing urban environment, the noise levels are considered low and the proposed triple-glazed windows will provide a sufficient composite sound reduction to satisfy Policy DM35.
Amenity of neighbours
7.59 The design proposal has been founded on protecting the amenity of neighbouring properties. Extensive context analysis has been undertaken and to ensure that the Consultant Team were aware of the local concerns, meetings with occupiers of neighbouring properties have been held.
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The Design and Access Statement sets out in detail how the scheme has been designed to avoid negative impacts on the neighbouring properties, in terms of overshadowing, overlooking and loss of daylight and sunlight. Sections are included to demonstrate the suitable window – window distances of neighbouring properties.
7.60 A Daylight and Sunlight Assessment has been prepared in accordance with BRE Guidance to accompany the application. The assessment covers the proposed development and any adverse impact assessment on surrounding residential buildings. The development and impact have been assessed using the criteria set out in the Building Research Establishment’s (BRE) ‘Site layout planning for daylight and sunlight – a guide to good practice’ (BR 209) (Littlefair, 2011). Whilst the guide itself states that its guidelines are not mandatory, they are those predominantly referenced for daylight and sunlight standards in the UK.
7.61 The outcome of the assessment shows that there would be ‘minor adverse’ effect on daylight and sunlight to some of the existing dwellings surrounding the site as outlined in section 8.55.
7.62 The accompanying Noise Assessment has considered the impact on the existing properties as a result of the proposed building services plant. Air Source Heat Pumps are being considered and the nearest noise sensitive properties have been assessed. A plant noise limit of 5dB below the typical background sound level is typically required by Bristol City Council (BCC). However, a lower limit is proposed to the rear of existing dwellings and this is considered acceptable when compared against the standard BCC requirement.
7.63 In terms of air quality, an assessment has been prepared and submitted with the application. This sets out that during the construction phase the proposed development could give rise to emissions that create dust on adjacent uses. However, by appropriate mitigation measures to reduce the emissions and their potential impact it is not considered that there will be significant residual effects. The submitted Construction Management Plan seeks to limit dust emissions by water spraying.
Ecology
7.64 The Ecological Report prepared by Wessex Ecological Consultancy includes findings from the surveys which did not find signs of protected species on site and that development of the site would not have any significant ecological impact.
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7.65 The report makes recommendations for mitigation and this includes the replacement planting of native tree and shrub species. It also highlights that the redevelopment of the site brings opportunities for the enhancement of ecological value, the following is proposed as part of the landscape proposal: • Planting on the western margins of the site to include native shrub species and areas of wildflower lawn, which will be of value to a range of insect species and to priority bird species such as dunnock and song thrush. • Planting elsewhere on the site will include species that are of value for wildlife, including priority species. These will include berry-bearing trees and shrubs; trees that are either native or are closely related to native species (such as ornamental Malus and P yrus spp, which support most of the insects supported by native species; and nectar-rich herbaceous plants that are of value to pollinating insects such as bumblebees. • The Bristol population of swifts has declined substantially, in line with national decli nes, largely due to the loss of suitable nest sites as buildings have been improved. The provision of artificial nesting sites, in the form of boxes, bricks or tiles, has been shown to be effective in reversing this decline and will be provided on site as shown on the attached map within the Ecological Report. • Bird and bat boxes will also be fitted to trees on the site and provision for insects such as solitary bees will be made either by incorporating suitable crevices into walls or by providing insect hotels.
Trees and Green Infrastructure
7.66 In line with Core Strategy Policy BCS9, Site Allocations and Development Management Plan Policy DM15, DM17, and the Urban Living SPD the proposals incorporate new green infrastructure and retain some existing trees.
7.67 Given the site’s current car park use, subsequently the majority of the site is covered by existing hard surfacing. Existing trees are therefore predominately growing around the site boundaries or within planted strips between the parking spaces. The arboricultural survey identified twenty-four trees to be surveyed. Of the trees surveyed two trees were categorised A, fifteen trees were categorised B, one tree was categorised U, the remaining trees were categorised C (further information is within the submitted Arboricultural report).
7.68 Eight of the existing trees are to be retained, with replacement tree planting proposed to mitigate against the loss of the trees to be removed.
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8.0 PLANNING OBLIGATIONS STATEMENT 8.1 The Applicant accepts that a S106 agreement will be necessary to secure the 20% affordable housing (Policy BCS17) Route 2 of the Council’s Affordable Housing Practice Note.
8.2 The S106 will include the following information relevant to affordable housing: • RSL Payment. • Service Charges. • The location of the affordable units (Block B). • Specification (NdSS) and 2% Wheelchair accessible. • The date by which development will commence (18 months of the permission being granted).
8.3 A S106 could also include the following provisions: • Public art/Cultural Contribution.
• Residential Travel Plan.
8.4 The open market dwellings will attract a Community Infrastructure Levy (CIL) payment. The Council uses money raised from CIL towards: set up and admin costs; area committe es to spend on local schemes and strategic infrastructure projects to support the growth of Bristol.
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9.0 CONCLUSION
9.1 This application has been prepared on behalf of Bristol Zoological Society in support of the proposed development at the Bristol Zoo Gardens’ West Car Park for 65 homes. The application site is in a highly sustainable location for new homes, benefitting from the services and facilities in Clifton and the wider Bristol area.
9.2 The proposals make efficient use of a brownfield site in a central and sustainable location in Bristol, to provide much needed housing, in line with national and local planning policy.
9.3 The challenges that the Society has experienced in recent years means that the Society has made an operating loss in four of the last six years. It is therefore necessary to close the Bristol Zoo Gardens site in Clifton and relocate the Zoo the Wild Place Project site. Releasing value from the sale of the West Car Park site will provide funds to go back into creating a new world class Bristol Zoo, for the city and the West of England, which brings significant economic and social benefits to the City.
9.4 Extensive public engagement has been undertaken as part of the proposals with the community and Council. Including submission of a formal pre-application request for information, Community Forum meetings, digital exhibition, neighbour meetings, online Public Forum and over 200 addresses receiving consultation packs through the door. Through this process the Applicant has sought to shape the proposals in light of the comments received, ahead of the application submission.
9.5 The application proposal is supported by a suite of technical assessments and reports, which demonstrate how the proposed development can be adequately mitigated and delivered.
9.6 The application proposals meet both local and national planning policy. It is important to note that the NPPF reiterates the Government’s support for sustainable economic growth and that significant weight should be placed on the need to support growth and productivity. To this end, there are a substantial benefits that the application proposals would bring to the local area such as: • 13 new and much-needed affordable homes for local people; • Contributions to the Council’s Community Infrastructure Levy to fund infrastructure delivery in the local area; • The payment of S106 monies to benefit the community;
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• The creation of direct and indirect construction-related jobs over the lifetime of the construction of the development; and • A boost to the Council’s five year housing land supply position.
9.7 The application proposals will help Bristol City Council deliver sustainable development on a site that meets both national and local planning policy – to provide much-needed new homes for local people.
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