Response to 47 High Street Planning Application

8 Southdown Road
Westbury on Trym
21 July 2023

Dear Planning Oficer

Planning Application 23/01974/F: 47 High Street

The Society notes that there have been numerous objections to this application from local residents for reasons with which the Society agrees and would like to put its own objections to the council.

This application is being considered at the same time as an application for backland development at 49 High Street, to which the Society will be making a separate objection.

Both of these sites are in the conservation area. They are also very close to adjoining residential development and commercial activities. 47 High Street abuts the Post Office sorting depot, which is active early in the morning both with staff at the building and a large number of vehicular movements in the yard. It operates 7 days a week with delivery vehicles using the yard. No account has been given by the planning consultant to this issue, which will create light noise and nuisance to the nearest dwellings. This is contrary to policy BCS23, which requires that in locating and designing new development, the impact of existing sources of noise shall be taken into account.

A further point that has not been addressed is the vegetation on the site. It appears that there are trees on the site behind the garages (and these are indicated in the existing site plan). These will be removed, but no acknowledgement of this is made and no arboricultural report has been submitted.

On page 40 of the Conservation Area Character Appraisal, the document states ‘the character and special interest of Westbury-on Trym can be preserved or enhanced through ensuring that new buildings complement their neighbours in scale, style and use of materials’. As a backland development, it should be subservient in height to the height scale, mass and form of the surrounding frontage buildings. Although the section drawing suggests that the new houses would not be as tall as the frontage dwellings, which are shown in the Conservation Area Character Appraisal to be characterful buildings, we query the details in the absence of a drawing showing levels.

Whilst the replacement commercial building responds to the presence of the landmark former Police Station adjacent, the design of the dwellings is contemporary and fails to acknowledge the neighbouring buildings, especially the housing fronting the High Street. They are too tall for their surroundings and the design has no regard for the character of the conservation area. We conclude that the development will lead to a substantial harm to the conservation area.

Aside from this, given its size and location, the site cannot reasonably be developed for five, 2.5 storey houses without serious detriment to the amenities of the occupiers of 41-45 High Street and those abutting the site on Fraley Road. It manages to cause serious detriment to neighbours by overlooking and loss of privacy. The proposed dwellings do this both to their neighbours on High Street where bedroom/office windows look straight down into rear gardens only 10 metres away and to Fraley Road where they are sited less than 6 metres from the boundary. The amenity that occupiers of plot 5 will have is frankly awful as the rear yard will have the gable wall of plot 4 overwhelming it and windows look straight down into the rear garden of 41 High Street from its boundary.

The development contravenes policies DM26, DM29 and DM30.

Car Parking Issues

Anyone familiar with Westbury on Trym will be aware of the parking stress that occurs due to the large number of dwellings in the conservation area that have no off street parking and the narrow frontages to the street. During the day the streets are fully parked with shoppers and business vehicles. When these have gone in the evening the streets are parked by local residents. Parking on the streets has a significant impact on the character of the conservation area and is referred to in the Character Appraisal. The garages on this site provide a valuable role in providing secure off street parking for those without space on or off street. The loss of this may not be controllable through the planning process, but the creation of a development that can provide for its own parking needs is paramount.

The centre of Westbury has in recent years been the subject of several planning permissions for housing with no or very little on plot parking. Recent examples are planning permissions for 1no. 2 bed, 2 no. 2 bed and 1 no. 3 bed dwellings at 1-3 Stoke Lane (17/06744/F), as amended by 19/03823/F, for 2no. 3 bed flats above 51 Westbury Hill (19/05300/F), and two 3 bedroom houses on the adjoining site (20/05326/F) and two 2 bed houses at 16 Canford Lane (18/01807/F) all where no off street parking is being provided. At 48 Stoke Lane, permission was granted under 17/01620/F for 2no. 4 bed houses and a 3 bed bungalow with 1 only off street parking space. As a result of this incremental residential development which relies on on-street parking, and due to other factors, the availability of on-street parking near the centre of the village has become very scarce. There are no plans for the council to extend the residents parking zones to Westbury on Trym.

The application of the council’s parking policies using the ‘maximum provision’ is not in conformity with the government’s 2015 Planning Update, which advised that the ‘imposition of maximum parking standards under the last administration lead to blocked and congested streets and pavement parking. Arbitrarily restricting new off-street parking spaces does not reduce car use, it just leads to parking misery. It is for this reason that the government abolished national maximum parking standards in 2011’.

Not only does the site provide 22 garages, but it also provides parking spaces for the occupants of 43 and 45 High Street. All these vehicles will end up on the streets of Westbury, where there is already parking stress.

A single parking space for each 3 / 4 bed dwelling is inadequate in the circumstances. Furthermore, the spaces are not easily accessible and as pointed out by others, access for delivery vehicles, removal vehicles etc is not available. In practice the parking space to plot 5 is only usable for a 2 car household if one of the cars is parked in the garage, which rarely occurs these days. If the householder wanted to take out the car in the garage with a car in the parking space in front of it, there would be no space on the site for such a manoeuvre.

Turning to the access, whilst there is an historic existing access, in considering a new development this needs to be safe – the fact that it is already in use, as mentioned in the planning statement, is not relevant. This application is being considered alongside the adjoining application and having two access points side by side and this one being to a poor standard cannot be proper planning.

We trust the council will refuse this application and subsequently discuss a reduced level of development with the site owner.

Yours sincerely
A C Renshaw MRTPI
On behalf of the Westbury on Trym Society