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KCG’s Objection to City Centre Planning Application

Planning Application  23/04490/F  Proposal to demolish former Debenhams building and build a mixed use development with 28 storey tower.

The Kingsdown Conservation Group strongly objects to this application. The proposal significantly fails to meet the standards of good design set out in the National Planning Policy Framework and the government’s National Design Guide. Due to its bulk, scale and height, the proposal shows a complete disregard for the surrounding context, resulting in a building that is not grounded in its locality. It fails to acknowledge the existing coherent pattern of development that runs along The Horsefair, consisting of a string of buildings from Cabot Circus to Primark, all of which are relatively consistent in height.

The development is also significantly over what is deemed an acceptable number of homes per hectare. Although the “Urban Living SPD” does not specifically define a maximum number of homes per hectare, it does refer to the report “Superdensity 2015” for guidance.  This report was written in response to concerns that “we are sleepwalking into hyperdense development without proper regard for the long-term consequences”.  The report recommended the adoption of “mid-rise development to meet London housing needs: apartment blocks of between five to eight storeys” and to “resist hyperdensity” with a “presumption against hyperdense  development over 350 houses per hectare (hph)”. The point is that anything over this density makes sustainable housing communities difficult to achieve and encourages housing types alien to our cities. This proposal, however, proposes a massive 715 hph, more than double the maximum recommended (according to the Planning Statement, which gives a site area of 0.72 hectares) or possibly even 1120hph if the site area is only 0.46 hectares as stated in the Application Form. This surely has to be unacceptable and likely to cause problems in the future

The SPD also discourages single aspect dwellings and recommends avoiding any that are North facing, yet over half (55%) of the proposed homes would be single aspect, of which 9% are North facing, a fact that becomes particularly important as they would overlook an extremely busy road.

In terms of the impact of this development on heritage assets, listed buildings and conservation areas, the visualisations make abundantly clear how significant this would be. The impact on the setting of St James’s Priory, John Wesley’s New Room and Portland Square, all Grade 1, would have a highly negative impact on their setting   The effect upon adjacent Conservation Areas would be no less. The Kingsdown Conservation Area Appraisal states that “spectacular citywide views enjoyed from Kingsdown are fundamental to its special interest”,  and that to the “South Kingsdown’s streets and precipitous lanes give unique views of the city and beyond. The preservation of Kingsdown’s views is vital in protecting the areas, character and special interest”. The applicant’s own Heritage Statement gives Kingsdown a rating of a designated heritage asset of high significance. Yet the view down Montague hill shows views across the city would be completely obliterated by the enormous bulk of the proposed development.

Nor is the proposed development sustainable. Tall buildings are known to have a far higher level of embodied carbon when compared to buildings ten storeys or less. If Bristol is serious about its net-zero targets it should not be supporting tall buildings. Instead it should be encouraging the reuse of buildings wherever possible. We would prefer this were the case with the Debenhams building which is an asset to the area.

The recreation of Barr’s Street, while superficially appealing, is, in our opinion, neither necessary nor desirable.  Opening up Broadmead to an extremely busy roundabout just when it is proposed to make Broadmead traffic-free seems counterproductive. The public realm created would not be of high value, being taken up completely by steps and ramps. It would also have the effect of pushing up the height of the adjacent blocks. Far better to lose the height of the tower by infilling between the blocks and creating a covered arcade, echoing the arcade that at one time ran to the side of this site. Better still, a direct link from the Bearpit to Broadmead would negate any need for steps and help rejuvenate the Bearpit.

In terms of design it is important that any building of such impact should be well designed and contribute positively to its urban setting. Sadly this is not the case. The detailing is generic and uninspired, too few flats are given balconies and the impact at street level is wholly negative.

We should make it clear that we fully accept that there is a need for new homes in Bristol but do not believe this is the solution. The Superdense 2015 report shows that high density housing schemes are possible without sacrificing the integrity of a city’s urban fabric. Given the environmental crisis facing the world, Bristol has a chance to encourage more sustainable housing solutions.  Please refuse this application

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