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21/11/2011 Re: 11/00034/P - Response to the Dove Lane Outline Application Dear Mr Butler, St Pauls Unlimited (SPU) has proactively worked with Places for People on the Dove Lane Development for over three years. We have committed such a significant amount of time to this work because we believed we could influence the development of this site. SPU agreed with Places for People that we would assess any application based on the 13 principles identified in the Dove Lane Area Regeneration Strategy section of the St Pauls Neighbourhood Plan. The Coordinating Body have had the opportunity to review the outline application Places for People have submitted and it is with regret that we feel it necessary to object to this application. Our objections are listed below and are organised by the 13 principles mentioned previously. 1. Mixed use, with employment and other uses diversified across a broad social and economic scale. a. The outline application does not address this principle. This is an employment site that should deliver an employment-led scheme with some residential use as proposed in the Neighbourhood Plan. We do not accept that ‘mixed use’ means a residential-led scheme. The Neighbourhood Plan firmly states the need to enhance and protect employment uses in the area. The loss of employment uses in the area over recent years makes it even more important that an appropriate mix of employment uses of different social and economic scale is delivered on this site. b. The Dove Lane Development site is designated as an industrial and warehouse use area. This designation has not been changed. The Core Strategy may make a broad provision for the consideration of a change of use but it also reflects SPD10 and the aspirations laid out in the St Pauls Neighbourhood Plan, which clearly supports a mixed use, employment led site. We would like to see a range of employment uses supported on this site, including workshops and a range of uses, which support the existing businesses in the area. The Neighbourhood Plan clearly identifies the community’s aspirations to retain this site as an 1


employment and enterprise led site and this outline application completely overlooks these community aspirations. c. The strategy in the Neighbourhood Plan for Dove Lane seeks to enhance and build on the existing employment activity on Newfoundland Rd. We would like to see the Dove Lane development do the same. We feel the proposed outline application marginalises the types of uses along Newfoundland Way and therefore puts them at risk in any future development on the grounds they will be ‘out of character’. We appreciate that the revised outline application has rearranged its layout to accommodate the concerns around industrial noise from the Hammonds workshop on Wilson Place. However, we are concerned that if Hammonds decides to sell their site, the Dove Lane site will then legally be allowed to revert back to it’s previous preference of having residential units at the end of Wilson Place. Once these units are put in place the Hammonds site will no longer be able to site a similar (noisy) business. This will open a clear path for the owner to apply for and easily gain permission to change the use of this site. This action would then completely eliminate the industrial and warehouse uses site from the community. d. Retail was not identified in the Neighbourhood Plan as an area for growth. The Neighbourhood Plan recognises the importance of the existing retail in the area (Grosvenor Rd & Sussex Place) and specifically Stokes Croft. We are particularly concerned that new retail will compete with and therefore undermine Stokes Croft. We are not able to comment further on the retail premises without understanding what the retail offer will be and how this is likely to impact on existing businesses. 2. Increase & enhancement of employment opportunities – creating accessible employment for local people. a. St Pauls suffers from chronic unemployment. To combat this challenge, the community needs a range of employment opportunities that are accessible to the local community. This outline application is full of B1 (offices) uses and a few A2 (shops). There is no provision for spaces that would cater to, increase or enhance locally relevant employment opportunities. B2, B8 and workshop space uses should be integrated in the site to take into consideration the existing community. 2


b. We would like a firm commitment from the developers to help train up and employ local people in the building of this site. This application offers no reassurances this is being considered. 3. Street and scale that has its foundation in history, and a future in principles of human scale, legibility and place making. a. We do concede that the scale of buildings has been reduced over the course of Places for People’s consultation, but we believe the overall scale of the site is still far too large. The majority of buildings are far too high and out of keeping with the area of St Pauls and St Agnes (an area of terraced town houses). b. We appreciate that site E is the one site in the application in keeping with other residential accommodation and that block D steps up towards New Ervine Terrace, thereby making an effort to not completely overshadow properties on Halston Drive. c. We are very concerned about the overall scale of block C. The Sports Centre will be dwarfed by the new building and the addition of the small triangular building that will directly overlook Cabot Primary School is particularly concerning. We are also concerned that the terrace of houses on St Nicholas Road will be overlooked by block C. 4. Creation of opportunities for local enterprise, in particular start-up and growth. There is no mention of a provision for an enterprise centre, as [reviously discussed with Places for People, in this application. 5. Safe, and crime-free environment, self-policing through design and use (avoiding fortress-mentality.) a. At the moment children/families can get to and from the St Pauls Gardens estate and the school without crossing a road. The proposed road layout will mean crossing a proposed primary route through the site. b. Without the detailed plans of the street layout it is not possible for us to assess how safe we feel the streets will be. However, we are clear that active street frontages and natural surveillance are key 3


c. We are concerned that the plot of land between block C and the Sports Centre will provide a sheltered and/or neglected area of land that may attract anti social behaviour. d. We are concerned about parking, which we know is a controversial issue. Without any further information on the application we do not feel there is enough detail to support the request of basement parking occupying the entire space under blocks A, B, C, and D. We recognise the need to provide some parking in these spaces but we have fought against gated communities, which this level of basement parking could easily create. We feel that the parking solutions suggested in this outline application are symptoms of over development. Street level parking is part of streets being alive, which we will not achieve with underground and gated communities. 6. New gateway into St Pauls (while avoiding inappropriate traffic movement), permeability through ground level links, welcoming to pedestrian and cycle movement. The outline application does not address this principle. a. There is excessive traffic movement in this small area, which also encourages rat runs from the M32 to the north of the city. b. The current suggestion for opening New Windsor Terrace into a two way street will put a primary route directly across a major footpath for children and families accessing Cabot Primary school. c. New Windsor Terrace also cuts straight through the Green Route (a green pedestrian route from town) identified in the Neighbourhood Plan. The Neighbourhood Plan proposes pedestrian priority roads/streets and ‘home zones’, which serve to reduce vehicle speeds and aid permeability. These principles (including those promoted in Colin Buchanan’s 2006 ‘St Paul’s Traffic & Streetscape Study’) must not be ignored. d. The proposed road layout will dramatically increase traffic in the area of the St Pauls Nursery. At present the road running next to the Nursery is only used by local traffic. This outline proposal will turn this road into a main route into and out of the development site. 4


e. The Neighbourhood Plan proposes a solution more caring of the local area and places greater emphasis on people using pavements and cycle routes safely than on cars. f. The existing community would like to see a development that looks and feels like part of the existing community. The proposed layout of buildings and roads appears to be a completely separate neighbourhood. There is no connectivity via Dove Lane (street) to Halston Drive and residents and businesses can access and leave the site without ever interacting with the rest of the St Pauls community. g. With the opening of the junctions at Drummond Road and Ashley Road, and Drummond Road and City Road, the current plan introduces a very clear potential rat run via Prince’s Street through New Windsor Terrace, New Ervine Terrace and via Dove Lane out to the motorway. 7. All new development designed and built to sustainable construction principles. We are unable to comment because we do not have the information we need. 8. Adaptable, through flexibility of built form to ensure appropriateness for the long-term. We are unable to comment because we do not know enough about the detail – i.e. how the area will work. We would note however, town houses stand the test of time as they can be made into flats and they can be made larger or smaller. Flatted developments are not so adaptable. In the Neighbourhood Plan we actively promote “Lifetime Homes” that can be used during various stages of life as well as encouraging and welcoming older people back to the area. 9. Environmental enhancement – contributing to the improvement of air quality, ‘greening’ and natural environmental diversity. a. There is no evidence of environmental enhancement – the development appears to be similar to recent city centre developments and could be anywhere. b. The outline application makes absolutely no provision for public realm or green space and will greatly increase pressure on the limited green 5


spaces in St Pauls. It is baffling to us that Bristol City Council could invest so extensively in the Area Green Spaces strategy which specifically identifies St Pauls as an area with insufficient amounts of green space and yet the developers and Bristol City Council’s own planning department have completely ignored the advice in this strategy. c. The proposed development does not build on St Pauls Park as an asset; it does not increase the natural surveillance of the park and does not enhance the green route. d. We do not want to see section 106 contributions made at the expense of green space provision in this application. 10. Respect for the residential and social community of St Paul’s. We feel the outline application is suggesting building an entirely separate community. St Pauls Unlimited has long reinforced that we want this new development to become part of the existing community. The suggested road layout creates a new community, the lack of social housing integration in the development excludes the majority of St Pauls residents and the employment space does not meet the needs of the existing community. From these plans, we cannot identify provisions for play equipment or garden spaces. The over subscription to existing green spaces in St Pauls is already a challenge. Adding to this problem by increasing the population but not increasing the provision for green/communal areas disrespects the community. It creates more intense competition for limited community space. 11. Creativity and innovation. The outline application does not address this. A Public Arts strategy is included but it offers no firm commitment to any particular element of creativity, nor does it commit the developer to seriously consider or give preference to the wants and needs of the local community. 12. Multi cultural. There is no evidence that the outline application reflects the multicultural nature of the area. 6


13. Utilise building form and enhancement to the natural environment that creates a protective barrier between the traffic of M32 / Newfoundland Road and the existing and any new residential areas proposed. We are pleased to see that the proposed envelopes of the buildings indicate the building will step increase in size closer to the motorway, instead of having their tallest point overlooking the existing residential areas in St Pauls. We would like to reiterate though, that we still believe the overall scale of the site to be too large. Housing Housing is not one of the 13 principles in the Neighbourhood Plan, but it is an issue we have discussed at length with the developers. Our views on the housing proposed as part of this outline application are: a. We reiterate that this scheme should be for a mixed-use employment led site. It should not be residential led. b. We have accepted that some housing in the area should be offered to keep it from becoming a “dead zone� after hours. We have always encouraged that the housing provision should be for families with a range of market and reduced rent options. There is not a single unit offered in this plan for reduced rent or social housing. This appears to be another effort to keep the existing community of St Pauls completely separate from this new development. c. We have approximated that around 15% of residential units are onebedroom apartments. St Pauls already suffers from an over concentration of this type of accommodation. We therefore believe this percentage is too high and should be reduced. Section 106 We are concerned that the community is not being invited to input into the Section 106 heads of terms. We would like to formally request the opportunity to input on all Section 106 contribution recommendations. Reserved Matters We are concerned about the lack of detail in this application. We would therefore like to formally request that we are consulted on all reserved matters in the future. 7


In conclusion: We are disappointed that we have spent so many years actively engaging and consulting with the developers to now be presented with an outline application that appears to disregard so many of the aspirations of the community. This outline application seems to offer only a few small concessions to the community. Otherwise it looks and feels like an attempt to keep the existing community separate from this development. Kind Regards, Maryanne Kempf St Pauls Unlimited Chair

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SPU Response to Dove Lane outline application 2011