Planning Statement West Car Park of Bristol Zoo Gardens College Road, Clifton - Bristol, Clifton & West of England Zoological Society
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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 2021Planning 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: simon.prescott@bartonwillmore.co.uk 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
30418/A5/GN/bc Page 1 March 2021West Car Park of Bristol Zoo Gardens Introduction
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
30418/A5/GN/bc Page 2 March 2021West Car Park of Bristol Zoo Gardens Background on Bristol Zoological Society
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.
30418/A5/GN/bc Page 3 March 2021West Car Park of Bristol Zoo Gardens Background on Bristol Zoological Society
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.
30418/A5/GN/bc Page 4 March 2021West Car Park of Bristol Zoo Gardens The Site – Car Park to the West of Bristol Zoo Gardens
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
30418/A5/GN/bc Page 8 March 2021West Car Park of Bristol Zoo Gardens Development Proposal
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.
30418/A5/GN/bc Page 9 March 2021West Car Park of Bristol Zoo Gardens Consultation
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.
30418/A5/GN/bc Page 10 March 2021West Car Park of Bristol Zoo Gardens Consultation
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.
30418/A5/GN/bc Page 11 March 2021West Car Park of Bristol Zoo Gardens Consultation
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.
30418/A5/GN/bc Page 12 March 2021West Car Park of Bristol Zoo Gardens Consultation
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.
30418/A5/GN/bc Page 13 March 2021West Car Park of Bristol Zoo Gardens Consultation
‘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
30418/A5/GN/bc Page 14 March 2021West Car Park of Bristol Zoo Gardens Consultation
‘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’
30418/A5/GN/bc Page 15 March 2021West Car Park of Bristol Zoo Gardens Consultation
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
30418/A5/GN/bc Page 16 March 2021West Car Park of Bristol Zoo Gardens Consultation
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.
30418/A5/GN/bc Page 17 March 2021West Car Park of Bristol Zoo Gardens Planning Policy
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 with in 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 t he 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 docum ent 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 densi ty 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 desperate ly 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 efficie nt 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 me asures 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 Revie w Draft Policies and Development –
publication is set for 2022. The Plan is anticipated for adoption at the end of 20 23.
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 c onsider 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 l ocations. 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 an d 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 P ark 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 Al locations), 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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