The Former St Christopher’s Site
The Original Proposal for the Development of the Site, March 2022
A planning application for the development of the St. Christopher's site was registered with Bristol City Council in mid March 2022.
Summary of the Proposals
The overall proposed is for an ‘Extra Care’ development for people over 70 who are basically fit and active but who need some on-site care and support each week. (NB. This is not ‘Sheltered Housing’ nor is it a ‘Care Home’; it fits between these, and Westbury Park does not currently have an Extra Care facility.)
The main components of the project were:
- 122 apartments – 11 one bedroom, 111 two bedroom.
- Shared facilities: café/bar/dining, art room, activity room, hydro pool, gym, exercise studio (some availability to local community).
- Offices, etc. for staff.
- Parking for residents, visitors, staff, pool cars/minibus.
- Gardens (some open to the community).
- Rooms for community and school use.
The Development Masterplan showed :-
- The five lodges on Westbury Park converted to 25 apartments.
- 86 apartments in four ‘villas’ and eleven 2 bedroom, two storey ‘cottages’ behind. The apartment buildings range from three to six storeys
- The listed Grace House converted for facilities and staff (with added pool).
- North House (south east) converted for spaces for community and school.
- Main vehicle access one way route in from Westbury Park then back out.
- Resident vehicle access for four cottages from corner of Bayswater Avenue.
- Pedestrian entrances from Westbury Park, Bayswater Avenue and The Glen.
- 65 parking spaces are spread around the site.
- Various gardens between the buildings.
Key Issues
Overdevelopment: too much building, too high, too close to neighbours. And that overdevelopment has negative impacts –
(a) in heritage terms on our area and on The Downs (the site and its surrounds are in The Downs Conservation Area),
(b) on the setting of the Grade II listed Grace House (dramatically overwhelmed by 6, 5 and 4 storey buildings very near it),
(c) on the privacy and outlook of neighbouring houses and
(d) on the serious loss of trees in the highly significant ‘copse’ visible from the corner of Bayswater Avenue and St. Helena Road. (Well, visible now but try to find it on the image above!)
The Risk of Overspill Parking. The evidence we and SCAN are compiling strongly suggests that 65 spaces will not be enough and that would lead to significant overspill onto surrounding streets, with related traffic problems. This is another aspect on which an objection would carry real weight. And if there is overspill parking, then there are concerns about pedestrian gates onto The Glen and Bayswater Road, making it easy for people to park then nip into the development. Objections on that would carry weight (but be aware that this would not apply so much if enough parking was provided.)
Traffic. Objections about traffic generally into/from the Westbury Park entrance/exit would carry little weight because it is likely to be less than when St. Christopher’s was fully operational. But objections about vehicle access at the Bayswater Avenue corner (if only for four residents’ cars) would be worth doing.
Ecology, biodiversity and wildlife. The tree loss in the site corner (above) is part of the overdevelopment issue but many trees all across the site will be removed and – the developers say – replaced. But, again, there is poor and unconvincing evidence about that and all other aspects of ecology, including the site’s role as a wildlife corridor. An objection on these issues now carries more weight with a legal requirement for a ‘net gain’ in biodiversity.
Other issues included the lack of affordable housing and the failure to make any provision for educational special needs (SEND)
The WPCA Objection and Other Objections
The Community Association opposed the application on a number of grounds, most notably the overdevelopment of the site with large apartment buildings up to six storeys high being proposed on the back land area of the site close to surrounding houses. We also opposed it on parking grounds as the number of parking spaces proposed could lead to overspill parking on surrounding roads. A further objection related to the inadequacy of the community engagement programme undertaken by the applicant and the failure to address the many concerns expressed by the Community Association and many others.
The proposals were also vehemently opposed by the St. Christophers Action Network (SCAN) which had been set up by largely by residents in roads close to the St. Christopher's site and therefore most affected by the proposals. SCAN has been instrumental in publicising the proposals and rallying opposition.
There were over 700 objections to the planning application from local residents and a number of City Council officers / teams also expressed major concerns. Objections also came from from Bristol North West MP Darren Jones, local councillors, Bristol Civic Society, Historic England and The Tree Forum. Quite late in the day the Council’s Transport Development Management Team also commented, saying that the application failed to demonstrate that pedestrians, cyclists and motorists can safely access and move around the site and concluded that “If the applicant is not willing to withdraw the application then it must be refused on the grounds that it would be detrimental to highway safety”.
The Revised Proposals, December 2022
Faced with all the criticism of the original application the applicant submitted revised plans to Bristol City Council in December 2022 in an attempt to address the many fundamental objections to the original plans. Proposed changes included a reduction in the total number of units from 122 to 116, reducing the height of villa B fron six to five storeys, changing the footprint and positioning of villas A, B, C and D, removing the vehicular access to the site from Bayswater Avenue and removing fewer trees.
The Community Association regard these changes as largely cosmetic and go no where near addressing the concerns we and many others expressed in making objections to the original proposal. We expressed these views in a note circulated to WPCA members on 9th December 2022.
The Community Association submitted a new objection to the revised proposals on 4th January - a day before the deadline for submitting comments to Bristol City Council. The objection related to the overdevelopment of the site, the unacceptable height and positioning of the proposed new villas, the failure to respect the setting of Grace House (a listed building) and the character of the Conservation Area, the insufficient number of parking spaces and the lack of community engagement on the revised proposals.
By the 5th January deadline for submitting comments an estimated 1,100 objections had been posted on the City Council's Planning Portal.
Refusal of the Application, August 2023
The planning application was due to be considered by the Council's Development Committee on 31st May 2023 but on the previous day the applicant requested that the application be withdrawn from the agenda and subsequently submitted a rebuttal of the officer report expressing strong concerns regarding the report to Committee. These concerns related to matters of fact, missing information and analysis, misleading comments, and an overall failure to provide a balanced review of the application.
The application was finally decided by the Council's Development Control Committee on the 9th of August. After discussion on various aspects of the proposal, the Committee unanimously refused the St. Christopher’s planning application mainly on the grounds of overdevelopment and loss of trees.
The August 9th Committee Meeting
St. Christopher’s was the only item on the agenda which gave time for 16 members of the public to address the Committee (with a time limit of just one minute!). Over 60 statements had been submitted in advance of the meeting, including a statement from the Community Association.
Most people spoke against the proposal, covering a range of issues including economic viability, the loss of trees and biodiversity, the loss of special educational needs provision, the parking impact on surrounding roads, the lack of affordable housing, traffic generation and the unacceptable scale of development. People from the applicant’s team gave presentations in support of the application.
Discussion among Committee members focussed on:-
- the loss of trees (and one ‘veteran’ tree in particular);
- the basis for the £550,000 figure agreed with the applicant to offset the loss of SEND (special educational needs) provision;
- whether the proposed development should be considered use class C2 – which would not require any affordable housing, or use class C3 - which would require it, (it remained as use class C2) and
- the proposed area parking measures that would prevent overspill parking (set against a corporate City Council policy of not allowing any further resident parking areas!!).
All seven councillors voted in support of the officer report recommendation to refuse the application on the grounds as in detail below –
- The proposed development would be out of scale and context with the Downs Conservation Area and the Grade II Listed building ‘Grace House’. The quantum and massing of development would result in a loss of the site’s verdant character and would crowd and overbear existing buildings and create a harmful relationship between proposed buildings.
- The proposed development would fail to integrate important existing trees by causing the loss of T52 and T65 and would likely cause T7 to deteriorate by undertaking works within the Root Protection Area.
What Happens Now?
The ball is firmly in the court of the applicant who would seem to have several options:-
(i) Appeal against the refusal to the Government’s Planning Inspectorate. This would almost certainly lead to a public inquiry probably held some time in 2024. Applicants have six months to lodge an appeal from the time they receive the Council’s decision letter.
(ii) Submit a further planning application seeking to overcome the reasons for refusing the current application. If this were to happen there would be another extensive round of consultation and negotiation.
(iii) Consider whether they should abandon plans for an extra care development on the St. Christopher’s site and look at alternative uses or a mix of uses.
(iv) Try to sell the site to another developer, almost certainly for conventional private housing (unless – which may be the case - there was a restriction in their site purchase to prevent this).
We will of course let you know about any appeal – probably the likeliest option - or any other approaches the developers may choose to put forward. Whatever happens, do not hold your breath!
It is likely that the applicant will appeal against the refusal.
The planning application documents can be found at :-
https://pa.bristol.gov.uk/online-applications/applicationDetails.do?keyVal=R8HHLODN0DG00&activeTab=summary
If you have any queries, comments, etc. about St. Christopher's please email the Community Association at westburyparkca@gmail.com
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Cossins Road
There is no decision as yet on the planning application to build six houses on the garage court in Cossins Road which was submitted in February 2023 despite the Bristol Planning Portal giving a determination deadline of 13th April. Approximately forty representations were made on the planning application, almost all objecting to the proposal - predominantly on parking impacts on local roads and loss of wildlife habitats.
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A Note on House Extensions and Permitted Development
Certain ‘small’ changes can be made to our houses through what is generally called ‘permitted development’. Planning permission is not required but you have to send drawings to the Bristol City Council planners for them to check and confirm that is the case (or not, in which case permission must be secured).
What counts as permitted development has been extended in recent years, including in one area where there has been concern expressed by many living in Westbury Park – house extensions. The new regulations allow larger side and rear extensions to be built without requiring planning permission (e.g. up to three metres high at the eaves if the proposed extension is within two metres of a property boundary and, in the case of terraced houses, up to three metres beyond the rear wall of the original house). The changes may be welcomed by those wishing to extend their properties but there will often be downsides – the negative impacts on neighbours (loss of light, greater enclosure), neighbour disputes and the loss of gardens.
Regulations have also been relaxed in other areas. For example, if someone owns a shop and wishes to convert it to a house, that is usually now a permitted development.There are examples in our area where this has happened both before the changes to the regulations (e.g. the launderette on Coldharbour Road) and since.The new relaxed regime further threatens neighbourhood shopping streets like ours and all those around the country.
The general feeling nationally is that the extension and easing of permitted development rights has been damaging but it is unlikely that the regulations will be tightened up again in the short term.
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Planning “Densification” – Appropriate for Westbury Park?
Increasing housing densities is a concept doing the rounds a lot at the moment with government as well as planners, architects and others as it is seen as potentially beneficial in relation to climate change and sustainability.
The idea is that if we could get more development in all our neighbourhoods and increase the population that would make local shops and facilities more viable and closer to more people and therefore reduce the need for people to travel, especially by car. It is often summed up as ’20 minute neighbourhoods’, i.e. all you need day-by-day within easy walking distance (for most).
Bristol City Council are pushing 20 minute neighbourhoods by trying to raise housing densities across the city hence ‘densification’. Note also that the idea was mentioned by one of the team involved with the St. Christopher’s proposals as some sort of spurious justification for their attempt to put a quart of development into the pint pot of a highly constrained site.
So it is important to be aware of these pressures but to question where and how far densification should be applied. It may be appropriate for lower density neighbourhoods but should it be applied to areas where housing densities are high? Westbury Park is already a 20 minute neighbourhood – we have shops, restaurants, cafes, cinema, library, churches, schools all within a 20 minute walking distance. Do we need to be further densified.