8 Southdown Road
Westbury on Trym
Bristol
BS9 3NN
5 November 2021
Westbury on Trym
Bristol
BS9 3NN
5 November 2021
Dear Mr Wilkinson
Planning Application 21/04837/F: Former Toilet Site
The Society has reviewed this application and objects for a number of reasons.
The first issue is the loss of a community facility, contrary to Core Strategy policy BCS12.
Policy BCS12 of the Bristol Core Strategy (2011) states that community facilities should be retained unless it can be demonstrated that there is no longer a need to retain the use or where an alternative provision is made.
The agent asserts that ‘the Council’s decision to close several public facilities would have been proposed following review and assessment of the need to serve the larger community and considers that this assessment must have provided evidence that the site was not required to maintain the public facility or alternative measures could be adopted. The community were not invited to comment on the closure of the toilets. The agent advises that alternative facilities exist in Grupo lounge, Canford Park and Canford Crematorium. Grupo Lounge, which is nearby, may have agreed to take part in the scheme to make available their toilets for others to use, but this is certainly not commonly known by the community and there is no sign advising that this is the case at the premises. Furthermore, this arrangement would not be known by visitors to Westbury on Trym, which is still a reasonably vibrant shopping and service centre.
The other toilets referred to are so far away from the centre of Westbury as to not be reasonable alternatives in any event.
The toilets are a community asset, but were closed for the most dubious political reasons. The council could have considered offering them to the local community to manage, but instead it decided to sell the building. The redevelopment of the toilet site removes any possibility of the use being re-commenced. The Society, therefore, objects to the principle of the use. The best use for the site is the one that previously existed.
Turning to the plans themselves, the Society considers them to be ill conceived. The ground floor area is so small, at 20m2 that the idea that this might function as a café is not feasible. There is no space for outdoor seating, nor for preparation, toilet facilities and storage. Similarly running a small shop there would be extremely difficult with no storage space and toilet. The viability of the ground floor use is relevant, as policy BCS 21 requires development to produce ‘buildings and spaces that are adaptable to changing social, technological, economic and environmental conditions’. A use either entirely for commercial or residential purposes seems to be the only realistic use, if the council should override conflict with policy BCS12.
A properly planned commercial outfit for offices or small shop or solicitor's or medical use (eg with a reception/waiting/toilet on ground floor and 2 surgeries above for example) - the ground and first floors can be used for clients and the top for storage/staff etc. or a dwelling with a ground floor living/kitchen area and one/two beds, with bath or shower above. Contrary to para 3.1.2 of the Design & Access Statement, the Society does not consider that the development ‘responds intelligently to the identified site constraints’.
The Society accepts the argument in relation to the TPO’d yew tree that it can never grow to be larger given the very constrained nature of the site, only 600mm from the building. The Society would ask that space is identified within the village centre for the required replacement trees. It should be noted that the development would also require the removal of the street litter bin, which is currently sited behind the footway, ensuring that it does not obstruct it. In the event of any planning permission which allows the frontage to be brought forward, a replacement bin should be provide by the developer in a location which does not impinge on pedestrian use. With the ground floor use being separate from the upper floor, the result is a building that is no longer a background building of small scale but one which is now prominent and sits uncomfortably between the bank/substation and the adjoining two storey building. The Society does not consider that the development complies with policy DM26, Local Distinctiveness. The Society fails to see how the design reflects the local context and takes ‘inspiration from the High Street centre and residential areas within proximity of the site’
The agent claims that the conservation area character appraisal identifies this as a ‘negative building’ within the conservation area. This is not our interpretation of the drawing for the High Street area within the conservation area appraisal. It will be seen that it is not marked in any particular colour. Because of the insignificance of the present building in the street scene, this is not an issue.
The Society does not consider the design and massing to be well structured and of appropriate scale and massing, as claimed, and it does not relate well to the adjoining properties. The roof is particularly jarring and even the fenestration details are at odds with the adjacent buildings.
The balcony, which provides amenity space is directly above the street and during the daytime, the noise from traffic movement in the village will make this space unattractive to use, again in conflict with BCS21.
For the reasons given above, the Society considers the application should be refused.
Yours sincerely
A C Renshaw MRTPI
For the Westbury on Trym Society
The first issue is the loss of a community facility, contrary to Core Strategy policy BCS12.
Policy BCS12 of the Bristol Core Strategy (2011) states that community facilities should be retained unless it can be demonstrated that there is no longer a need to retain the use or where an alternative provision is made.
The agent asserts that ‘the Council’s decision to close several public facilities would have been proposed following review and assessment of the need to serve the larger community and considers that this assessment must have provided evidence that the site was not required to maintain the public facility or alternative measures could be adopted. The community were not invited to comment on the closure of the toilets. The agent advises that alternative facilities exist in Grupo lounge, Canford Park and Canford Crematorium. Grupo Lounge, which is nearby, may have agreed to take part in the scheme to make available their toilets for others to use, but this is certainly not commonly known by the community and there is no sign advising that this is the case at the premises. Furthermore, this arrangement would not be known by visitors to Westbury on Trym, which is still a reasonably vibrant shopping and service centre.
The other toilets referred to are so far away from the centre of Westbury as to not be reasonable alternatives in any event.
The toilets are a community asset, but were closed for the most dubious political reasons. The council could have considered offering them to the local community to manage, but instead it decided to sell the building. The redevelopment of the toilet site removes any possibility of the use being re-commenced. The Society, therefore, objects to the principle of the use. The best use for the site is the one that previously existed.
Turning to the plans themselves, the Society considers them to be ill conceived. The ground floor area is so small, at 20m2 that the idea that this might function as a café is not feasible. There is no space for outdoor seating, nor for preparation, toilet facilities and storage. Similarly running a small shop there would be extremely difficult with no storage space and toilet. The viability of the ground floor use is relevant, as policy BCS 21 requires development to produce ‘buildings and spaces that are adaptable to changing social, technological, economic and environmental conditions’. A use either entirely for commercial or residential purposes seems to be the only realistic use, if the council should override conflict with policy BCS12.
A properly planned commercial outfit for offices or small shop or solicitor's or medical use (eg with a reception/waiting/toilet on ground floor and 2 surgeries above for example) - the ground and first floors can be used for clients and the top for storage/staff etc. or a dwelling with a ground floor living/kitchen area and one/two beds, with bath or shower above. Contrary to para 3.1.2 of the Design & Access Statement, the Society does not consider that the development ‘responds intelligently to the identified site constraints’.
The Society accepts the argument in relation to the TPO’d yew tree that it can never grow to be larger given the very constrained nature of the site, only 600mm from the building. The Society would ask that space is identified within the village centre for the required replacement trees. It should be noted that the development would also require the removal of the street litter bin, which is currently sited behind the footway, ensuring that it does not obstruct it. In the event of any planning permission which allows the frontage to be brought forward, a replacement bin should be provide by the developer in a location which does not impinge on pedestrian use. With the ground floor use being separate from the upper floor, the result is a building that is no longer a background building of small scale but one which is now prominent and sits uncomfortably between the bank/substation and the adjoining two storey building. The Society does not consider that the development complies with policy DM26, Local Distinctiveness. The Society fails to see how the design reflects the local context and takes ‘inspiration from the High Street centre and residential areas within proximity of the site’
The agent claims that the conservation area character appraisal identifies this as a ‘negative building’ within the conservation area. This is not our interpretation of the drawing for the High Street area within the conservation area appraisal. It will be seen that it is not marked in any particular colour. Because of the insignificance of the present building in the street scene, this is not an issue.
The Society does not consider the design and massing to be well structured and of appropriate scale and massing, as claimed, and it does not relate well to the adjoining properties. The roof is particularly jarring and even the fenestration details are at odds with the adjacent buildings.
The balcony, which provides amenity space is directly above the street and during the daytime, the noise from traffic movement in the village will make this space unattractive to use, again in conflict with BCS21.
For the reasons given above, the Society considers the application should be refused.
Yours sincerely
A C Renshaw MRTPI
For the Westbury on Trym Society
