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Sharing PG Group response to the S73 Planning comments

There have been a number of objections to the proposals. PG has taken the time to review the feedback and respond openly and honestly to the points made, as well as making some of the changes discussed to improve the design, so please take a look and make your own decision. This scheme is important to the area and will provide much needed housing at both a private and social level as well as significant public space, regular markets and new commercial units. 

This response is tabled below as text and also as a PDF download. 

1. Planning process using Minor Amendments and S73

Legal advice on the decision as to whether the application is classified as a S73 or full planning application has been sought from Clarke Wilmot LLP who consider that it would be lawful for the Council to approve these changes under section 73.   This advice has been submitted with the revised plans for this application. 

2. Ashley Rd frontage - reduction/removal of commercial architectural language to commercial units and visual signifier to commercial arcade/public space entrance.

This is not factually accurate. If the revised design is seen as changing the architectural language of these units that is simply an opinion and not a factually accurate. The intention is to bring the commercial unit frontage in line with Tuckett House by pulling the horizontal line of the units along in to the Ashley Road frontage. There is no intention to have flats on the ground floor on this facade or on the internal courtyard, other than the apartments that were included at ground floor level on the approved scheme this is a spurious suggestion and entirely without foundation. 

3. Ashley Rd frontage changes to aesthetics eroding design principles of community vision. Shops don’t look like shops, public need to see entrance to courtyard and shops from Ashley Rd and Stokes Croft. Pick up on format of 108 Stokes Croft (Victorian high ceilings and cornicing) and smaller Georgian/Dickensian feel of Picton St. Way the shops are drawn suggests there will be a change in use, via PDR, to flats.

The changes to the design of the Ashley Road frontage are to reduce the build cost. The revised design improves the visibility of the courtyard by widening the entrance. PG has said on a number of occasions to CAG that they are happy to review the design of the frontage and agreed to add more horizontality and variated brickwork. The revised design, which is being submitted in August includes introduction of Bathstone to emphasise the horizontality of the building. Variated brickwork for increased visual interest.  Framing windows in Bathstone. Breaking up the frontage through the introduction of Juliet balconies on certain residential units. Commercial units have reverted back to the Assael drawings. Recessing the fifth floor by 4-5m so this is no longer visible from Picton St (top of). 

4. Revisions to North entrance of Courtyard (Ashley Road) - removal of key commercial unit. Current design provides clear route and chamfered unit is shown clearly to public to draw people in and support financial viability. Design eroded in current iteration. 

There is no reduction in the number of commercial units on Ashley Road. This is not an accurate representation of the design.  The changes to the entrance design into Carriageworks public courtyard from Ashley Road have been included to widen the entrance and draw people in to the scheme. The commercial unit at the entrance to the site retains its glass frontage, but not in the original curved design. Recessing the entrance was necessary to meet and improves access for emergency vehicles.  This also increases the presence of the entrance on Ashely Road and from the view on Stokes Croft. Whether this is eroding the design is entirely a personal opinion not a factual objection. On the commercial units the architects have addressed the concerns about 'mirroring the Victorian high ceilings', only to be accused of designing the shop units in readiness to change them to apartments which is definitely not part of the proposal.  

5. Removal of roof gardens - minor amendment removed Block D. Rest of roof terraces to be removed in this application. Removal of roof terraces compromises quality of accommodation for children living on the scheme.

This is not correct. PG did remove the roof gardens on Block D, but only in response to feedback from the various Registered Social Landlords, none wanted the responsibility or financial implications of this feature on the social housing. The roof gardens on Block A have not altered significantly from the previous application. Included as part of the BREEAM requirements, the Ecologists have advised that running the material under the Photo Voltaic served no purpose. It is also an additional weight on the structure. PG has retained the green roof on the rest of Block A. 

6. Redesign and reduction of bin storage - returning 108 Stokes Croft bins to entrance arcade compromising appeal and viability. Making bins less convenient to users. Appears to be a reduction in bins and recycling provision.

The architects have redesigned the bin storage to the advantage of residents of Block A. This includes an entirely appropriate amount of recycling and bin storage provision for this scheme. The design has been revised to make provision for Tuckett House - 106-108 Stokes Croft. All other commercial enterprises on Stokes Croft and Ashley Road currently make provision for their own waste and recycling.

7. Reconfiguring stairwells - resulting in a reduction to natural light in internal corridors, increasing travel distances, reducing quality of environment

Having listened to feedback, this has now been redesigned to significantly reduce any impact on Ashley Rd and the surrounding buildings. That said, the purpose of this reconfiguration of Block A is to increase the number of apartments whilst keeping the impact on the mass and height of the block to a minimum.  The change from the original scheme is minimal. Windows have been retained and increased, taking in both sides of the stairwell.  Internal corridors have been improved to provide a more attractive and wider access to apartments combined with improved circulation routes along corridors.  There is an improvement rather than a reduction in the quality of the environment.

8. Redesign of internal elevations to remove evidence of commercial element of scheme. Ultimate intention being to remove this element from the scheme.

This is just completely wrong. PG recognises that the commercial element of the scheme is integral to its success, so it is not clear what this comment means. 

9. Lack of intention and transparency - respecting original vision and architectural strategies used to develop this resulting in a reduction of quality and amenity. 

This is an opinion not a fact. The original strategy has not changed in the slightest. Some of the architectural strategies used by the previous architects have been amended but the amenities remain true to the vision developed by the community.

10. Omitting key drawings when submitting or describing unclearly or inaccurately - not providing all changes - basically inadequate drawings.

This comment is incorrect. No key drawings have been omitted from this application, if any had been missed, the Council would have requested they be provided. All drawings to support any changes being requested have been submitted to match the Assael drawings from the approved application. It should also be noted that if necessary drawings were missing then BCC would have refused to register the application.

11. Addition of 2-storeys to block A - adding 2-floors to North of Block A - original scheme was turned down. Compromises Tuckett House. 3-storey brick wall 13m from roof terrace - overbearing.  5-Storey block 5m to South-east. Loss of privacy on 108. Guidance is 22m min-distance between habitats. Living spaces looking in to living spaces plus balconies which are not labelled in the drawings but are same as other drawings where balconies used. Drawing use of grey is misleading. Adding 2 storeys to the North end of Block A does not constitute increasing the height of the whole building by 2-storeys as has been inferred in a number of the objections.

The PG Group has explained on many occasions that the cost of developing this site has been significantly higher than could realistically been expected. It was impossible to undertake some of the surveys required in advance of taking ownership of the scheme and the amount of remediation required has far exceeded expectations. In addition, the build costs on the scheme have also increased due to a combination of material costs and market uncertainty. It is for these reasons alone that the additional units are being sought. Without them the project is unviable.PG has said they are more than happy to work with CAG and discuss options for a design solution with the owner of Tuckett House.  The use of grey on the drawings is entirely appropriate in the context of the selected Powder Coated Metal System chosen as the cladding for these floors.

12. Blocking light to 108 Stokes Croft. Drawing that could prove this was not included. 

The Council will confirm if this Survey is required, and the withdrawing by 4-5m of the 5th floor reducing any blocking of light.

13. Height of parapet - application says the addition of a 4th floor does not exceed height if 108 parapets. It is non sensical to compare the two as 108 has a pitched roof.

Nevertheless the height of the 4th floor does not exceed the height of 108’s parapet.

14. Ground floor flats on Block A and D - block D revision was included in some consultation and now it has been removed.

The Block D revision was something PG was keen to increase the number of Social Housing units. However it was made clear that PG would have built an extra storey on block D providing a net 2 of additional social apartments, to retain and increase the social housing provision. This would have enabled the two ground floor units to be converted to commercial units.   This was rejected by CAG and Hepburn Road residents. 

15. Block A and D rear window style has been changed overlooking Hepburn Rd despite PG saying they could remain as original scheme.

This has now reverted to the original Assael design and this information was confirmed at the CAG meeting on 10/7/19

16. Revisions to commercial area frontage. Removal of doors and glazing reduced flexibility to create smaller/larger units depending on need. Workshop units completely removed from elevations.

There is no intention to remove any commercial units. The unit sizes are flexible so the largest unit is defined in the planning approval. The sizes are 140m2 for D1, D2 or B1 use and 113m2 for A1, A2, A3 or A4 use. PG has now reverted to the original Assael design for ground floor commercial units as far as possible with the revised layout.

17. Cultural Plan - public toilets, storage, electric hook up, deliveries procedures not shared.
The Cultural Plan is not at a stage to be shared. It has been developed in conjunction with a Steering Committee that includes 3 members of CAG, 3 members from PG and the appointed consultants, Willis Newson. During the discussions the provision for stall holders within the market has confirmed that toilets, storage, electric hook up and deliveries access will be provided. Until planning has been finalised, PG has confirmed there is little point in sharing or creating an expectation of the cultural plan. Without a financially viable scheme, the Cultural plan will not proceed.