My objection, highlighting noise concerns

This is the full text of my objection to the St Joseph's planning application. It was submitted to the planning website on Saturday, 6 June 2026. If you want to use this to help you file your own submission, you're welcome to do so but (a) you should write your response in your own words and (b) you must assume responsibility for what you write; the information below is supplied in good faith and I have tried to be accurate, but ultimately you must do your own research. (I have supplied document references for most points.) As I've remarked elsewhere, it was only after I submitted this that I spotted the response from Bristol City Council regarding noise:

I saw that the council's "Pollution Control" department—I think that is actually the Neighbourhood Enforcement Team—has filed a notice of "no objection" (see 3 June in the document list) to the proposal, albeit it has stipulated that if the plan is approved, the applicant must submit a management plan covering various topics. These undertakings would be secured as a planning condition, attached to the approval. However, the council's insubstantial treatment of those issues is precisely what I anticipated and express concern about in section 5 of my response.

------------------------- I object to application 26/11841/F on the following grounds:

1.     Main Grounds

The proposed new use, Purpose-Built Student Accommodation (PBSA), will increase the already high student numbers in and around Cotham Hill, leading to a “harmful concentration” of shared and specialist housing, contrary to policy DM2 in the Bristol Local Plan.

1.1.   The area already has a large number of student-occupied HMOs (Houses in Multiple Occupation) as well as an existing 196-bed PBSA development at Woodland Court, just across the street from St Josephs, and some smaller student blocks in Hampton Lane and further afield.

1.2.   As a result, the number of students living in the area, compared to other residents, is exceptionally high. In 2024, the percentage of 16-24 year-olds in the local population was 34% in Clifton Down ward (which includes St Josephs), according to estimates from the Office for National Statistics (Note 1). Cotham ward, next door, had a similar figure. This is double the average for the city as a whole. It is also substantially higher than the 20% level for a single age group assumed to represent a ‘balanced’ community, and beyond which local demographics are judged to be tipping towards ‘unbalanced’ (Notes 2 and 3).

1.2.1.(Note 1: 16-24 covers the student age group. It may include some young people who are living at their family home and who may or may not be students, but in the local context most people in this age group are likely to be students living in HMOs or PBSA. The 34% figure is derived from the table “Ward mid-2024 population estimates by broad age band” at https://www.bristol.gov.uk/council/statistics-census-information/population-of-bristol.)

1.2.2.(Note 2: The 20% figure comes from research by the National HMO Lobby that was used to inform BCC’s policy, adopted in 2020, on the maximum threshold for the number of HMOs in an area. This was set at 10% of total housing stock. The Lobby equated 10% HMOs to 20% of population, given HMOs’ higher occupancy compared with other housing. The Lobby further suggested that communities become unbalanced when a major sub-group exceeds 20%, and that cohesion is lost if students reach one-third of the population, as now. PBSA contributes to this trend. See 3.2 The Tipping Point at  https://www.hmolobby.org.uk/lobbystudentif.htm .)

1.2.3.(Note 3: The applicant’s Planning Statement seems to imply at paragraphs 6.26 and 6.27 that imbalance would not occur until students reached 50% of the population. This is a facile argument. As the comments above indicate, the damage that might be done to social cohesion by over-concentration of a particular cohort of people would start to occur at levels well below a threshold of 50%.)

1.3.   Such imbalance leads to alienation and antipathy between settled residents and the more transient population of students, many of whom live in the area for less than a year and don’t integrate with the rest of the community. The different lifestyles of students—who often are socialising when others are trying to sleep—lead to numerous complaints of night-time noise disturbance, whether from parties in HMOs or from loud groups walking into and out of the area as they frequent pubs, clubs and takeaways. The St Josephs proposal is likely to add to this late-night foot traffic. (If the proposal goes ahead, there could also be issues with noise from St. Josephs itself—see Section 5 below.)

1.4.   It isn’t easy to provide hard evidence of fraying social cohesion in a community, but one obvious indicator would be testimony from the people who live there. In this regard, the applicant’s pre-application online survey, which invited public opinion, is instructive. The applicant has published the results, including a full transcript of the comments submitted, in its Community Involvement Statement (CIS). By my count, 83 submissions are reproduced, of which I judge 74, or 89%, to be objections to the proposal, citing “too many students” (or versions thereof) and noise disturbance as principal reasons for opposition. (I judged another 9 responses to be ambiguous; the number of positive responses was zero—which is remarkable in itself.) Sulis, the applicant’s survey manager, has branded these responses “anti-student” (Page 10, CIS). I suggest they are merely the statements of frustrated people describing the local reality, and should not be ignored or dismissed. (Note 4)

1.4.1.(Note 4: Disclosure: Sulis also says on Page 6 that “a significant proportion [of visits to the website] were directed to the page by press articles and by a post on an anti-student blogsite – the Noise Pages. It was notable that the rate of objection comments increased following the publication of the post on the Noise Pages.” I am the publisher of the Noise Pages. I am not anti-student; I am against noise disturbance caused by students and in favour of a balanced community. My posts about St Josephs went live on 23 March and I publicised them by email to 300+ subscribers at 1pm on 24 March. Sulis’s online consultation closed at midnight on 25 March. Since most responses were negative, my posts clearly didn’t change the trend.)

1.5.   Another form of evidence would be complaint statistics. Unfortunately, little of the anti-social activity mentioned by respondents to the survey is captured by official figures. Bristol City Council’s noise complaints page (https://www.bristol.gov.uk/residents/pests-pollution-noise-and-food/noise-complaints) says it cannot investigate “noise in the street, such as ... shouting ...“ Also, while it can investigate noise from “noisy neighbours, like loud music, shouting or DIY at night”, it will only do so if the noise happens “regularly” (that is, by the same people at the same address). So even most student-party noise from HMOs is ignored. (Residents could be kept awake every night, but if the noise comes from a different address each time, it doesn’t meet BCC’s criteria.) If residents ring the police on 101, they are told noise is a council problem (even though the police can deal with noise under anti-social behaviour powers). The only hope residents have is Operation Beech, a police patrol paid for by University of Bristol that operates three nights a week in areas near the university. Its existence is itself evidence there is a problem that needs attention. However, the main focus of Beech is party noise from student-occupied HMOs. Beech does also respond to complaints about street noise in places such as Cotham Hill, but often the perpetrators have dispersed by the time officers arrive. Residents can email complaints to UoB, which investigates (next day) and may fine students found to have breached the university’s community-behaviour rules. But these complaints can only succeed when the culprits can be associated with an address, which is often not possible in cases of street noise. The result is that street disturbance may be both the most common form of noise and the least reported.

2.     Loss of Care Home

I also object because the proposed change of use represents the loss of a care home, which is a form of housing that is also in demand as our population ages (Note 5). Many of the transport benefits that the applicant identifies at the site would advantage a care use also. A major internal rebuild, which is what the applicant proposes for the PBSA, would (in a different configuration) no doubt deal with any shortcomings the building had as a care facility and bring it up to date. Keeping the current use designation would help to retain a broad housing mix, in line with the Core Strategy of the existing Local Plan.

2.1.   (Note 5: I can say this with confidence because Savills, the property consultancy that acts as agent for this application—and which wrote the PBSA-promoting Planning Statement—operates in the care market also, and says in its February 2026 Roundup and Outlook: “Care Homes, Hospitals and Primary Care all present compelling investment opportunities in 2026, reflecting strong demand for services and limited new supply entering the market.” (https://www.savills.co.uk/research_articles/229130/386666-0/uk-healthcare-roundup-and-2026-outlook#).)

3.     Affordable Housing A further consideration is what contribution, if any, the proposals would make to affordable housing, which is a high priority in Bristol’s Local Plans (existing and emerging) as well as the National Planning Policy Framework (NPPF).

3.1.   My word searches show only two mentions of “affordable” in the Planning Statement, and both are in quotations of text from the NPPF. Given the Statement’s apparent preference to be judged by the NPPF rather than either of the Local Plans, which Savills disparages as compromised and worthy of only limited weight in decision-making, it seems odd that the priority the NPPF accords to affordable housing is not addressed.

3.2.   Furthermore, Policy H7 (PBSA) in the emerging Local Plan, which Savills seems to think should be largely ignored, says (in Policy Text): “Development in all locations will be expected to include an appropriate proportion of affordable student housing to meet identified need.” H7’s accompanying Explanatory Text says at Paragraph 6.88a that the proportion of affordable housing should be 35%. Perhaps this is another reason why the applicants would rather not be judged against Policy H7. The policy is in any case further advanced than they acknowledge. Public consultation on modifications made during the planning inspectorate’s examinations will close on 12 June 2026. While H7 has been subject to modifications, principally in relation to bedspace caps in certain designated areas, the changes are not fundamental to the policy, the intent of which remains intact. H7 therefore deserves if not full weight, then significant weight in the final decision. The policy is certainly better aligned with NPPF priorities than Harringay’s application.

4.     Misleading Arguments

The Planning Statement’s recitation of arguments in favour of PBSA at the St Josephs site contains a great many misleading statements.

4.1.   Foremost among these is the repeated suggestion that building PBSA at St Josephs will relieve pressure on the local housing stock (Note 6)—that is, it will either (a) reduce demand for the conversion of family homes into HMOs for student occupation, or (b) will allow existing HMOs to be returned to the general housing supply.

4.1.1. (Note 6: As an example of many such statements, see Paragraph 6.14, third bullet, and in particular its use of the phrase “within the local area”. Or Paragraph 6.30: “The application ... is considered to provide a beneficial alternative in this area of the city to traditional private house lettings, particularly HMOs.” )

4.1.2.It is true that relieving pressure on the general housing supply is mentioned in Local Plan policies as a potential benefit of PBSA; but this can only be understood at a high level, eg city-wide, and in the broadest sense. There is nothing to suggest that building PBSA at Cotham Hill will benefit the community at that location. The wave of PBSA construction has already been under way for many years (including at sites not far from Cotham Hill, as noted in the Planning Statement and on Page 11 of the Design and Access Statement)—yet we have not seen any obvious reduction in the number of HMOs in Clifton Down and Cotham wards. Nor is there any reason to expect this to happen. Since these wards are close to the university, any student accommodation there, HMOs or PBSA, is likely to remain in demand for years to come—at least, until enough PBSA has been built to satisfy all student-bed demand (if we ever get to that point). So in local terms, Relief(b), release of HMOs back to general supply, is not likely in the foreseeable future, if at all. Relief (a), creation of fewer new HMOs, is also a mirage. Bristol’s introduction in 2020 of restrictions on the creation and expansion of HMOs in areas such as Clifton Down that already have high numbers has effectively closed off that route already. (Supplementary Planning Document: Managing the development of houses in multiple occupation, adopted November 2020.)

4.1.3. In light of the 2020 restrictions, it would be difficult, now, to get planning approval for 1 new HMO in this area, let alone 22, which is roughly what 132 PBSA beds equates to in HMO terms. Still, perhaps more PBSA in Cotham Hill would reduce demand for HMOs in some other part of Bristol? Possibly—but why should Cotham Hill, an area already saturated with student accommodation, be forced to accept still more to protect other, less encumbered districts?

4.2.   In its survey of planning policies and considerations that might be relevant to the proposal, the Planning Statement often cites superficially supportive wording but commonly ignores important caveats and qualifications in the original text. Bristol’s Local Plan policies frequently exhibit concern that new developments should not harm the existing character and amenity of residential areas. It is worth quoting at length from Policy DM2: Residential Sub-divisions, Shared and Specialist Housing (see Page 9, Bristol Local Plan – Site Allocations and Development Management Policies – Adopted July 2014); the passage states the concerns very plainly:

4.2.1.[EXCERPT STARTS]

General Criteria

2.2.5 Whilst making a valuable contribution to the city’s housing requirements both subdivisions of existing accommodation and shared housing can have an impact on residential amenity and the character and housing mix of an area. Specific issues common to both forms of housing can include:

* Noise and disturbance associated with intensification of the residential use and/or the lifestyles of occupants;

*Pressure for on-street parking;

*A shift from permanent family housing to more transient accommodation;

*Impacts on social cohesion;

*A shift in the character of shops and businesses supporting the community;

*Impact of external alterations;

*Poor waste management.

2.2.6 When making assessments on new development, consideration is to be given to the particular qualities and characteristics of a residential area or residential uses that might contribute to it being an enjoyable or otherwise satisfactory place to live. These usually include generally quieter surroundings; a reasonable level of safe, accessible and convenient car parking; a well-maintained or visually attractive environment and the preservation of buildings and structures that contribute to the character of a locality. Harmful concentrations are likely to arise when issues commonly associated with these uses, listed in para. 2.2.5 above, cumulatively result in detrimental effects on these residential qualities and characteristics. Harmful concentrations will also result where the choice of housing is reduced and no longer provides for the needs of different groups within the community.

[EXCERPT ENDS]

4.2.2.Virtually all of the concerns expressed in the foregoing passage, especially in the bulleted list, apply in Cotham Hill and would be exacerbated by a large PBSA development that will put more students on the streets, especially at night.

4.2.3.This could have subtle, indirect effects. For example, in January 2026, The Whitmore Tap public house (previously The Penny) on Whiteladies Road (around the corner from Cotham Hill) was granted a licence extension to remain open on Friday and Saturday nights until 1.30am the following morning. While it is not possible to say that student custom was the main reason why the pub sought an extension, clearly the management believed there was sufficient late-night demand to justify it. Students are one group who are active at that time. The risk is that when one outlet seeks later hours, others nearby will follow, and the area may then become a late-night “destination” in a way it was not before. While the main approach to the pub is via Whiteladies Road, there are alternative approaches via Cotham Hill. Customers coming from student-populated areas further to the east can approach via Hampton Park, Aberdeen and Abbotsford Roads and the St Michael’s Hill end of Cotham Hill. In other words, the concern about St Josephs is not just about potential impacts the development may have in its immediate vicinity but also about indirect effects, such as increasing the overall circulation of foot traffic at night and possibly helping to change the character of the wider area. The Planning Statement shows no recognition of this concern.

4.3.   The Planning Statement places great emphasis on the development being “car-free” and says students won’t be able to get parking permits. Whether or not that can be guaranteed, students are great users of taxis and home-delivery companies that service their customers by car or van. St Josephs may therefore not be as “car-free” as claimed.

4.4.   It is said the development will contribute to hitting Bristol’s challenging housing targets, which is technically true. However, the Planning Statement notes that PBSA beds are converted to housing equivalents at a ratio of 2.5:1 and therefore St Josephs would be counted as equal to “around 52” traditional dwellings (Paragraph 6.14). That is a useful number, but not a lot. It seems insufficient to justify BCC approving the application purely on housing grounds, given the risks of harm by further expanding the student population at Cotham Hill and the fact there seems to be adequate land supply for PBSA in parts of the city designated for this form of accommodation.

5.     Noise Concerns

There are several grounds for concern about noise and management of the building. These contribute to the case for rejection of the application. If, despite objections, it is granted, these issues will nevertheless need to be addressed.

5.1.   There are three ways St Josephs residents might contribute to noise in the district:

(a) Noise on the street, as more students join the night-time throng.

(b) Noise from the building, whether from the common room or individual flats.

(c) Noise from night-time use of the garden.The applicant should be asked how it or the future operator will manage those risks:

5.2.   (a) Street noise. Other than signage or e-messaging urging its students to be mindful of other residents of the area when they are out and about, there is not much the operator will be able to do directly.

5.2.1.To prevent Cotham Hill becoming unruly as night-time numbers increase, a potential response would be a night-warden patrol paid for by local PBSA operators, the university and some of the commercial outlets relying on late-night custom.

5.3.   (b) Noise from the building. The applicant has clearly realised this is a possibility, and its Noise Impact Assessment models a potential scenario. Unfortunately, to anyone with actual experience of student-generated noise (Note 7), the conclusions are not convincing. The applicant should be pushed to provide a robust management plan.

5.3.1.(Note 7: I have no technical training in noise assessment but as publisher of The Noise Pages website (www.thenoisepages.com), I collated complaints about roughly 600 student-noise incidents in Redland, Cotham, Clifton Down and adjoining areas in the academic years 2017-18 to 2023-24. I witnessed dozens of them personally.)

5.3.2.The Assessment says on Page 1: “A precautionary but realistic assessment approach has been adopted, including consideration of amplified music use within the common room, with use assumed to cease by 23:00 hours.” Although 11pm is the normal cutoff that would apply to an officially licensed event, it is not realistic to assume students at an unlicensed event would observe such an early stop-time. Most student parties (in HMOs) are barely getting started at 11pm and often continue into the early hours of the morning.

5.3.3.No doubt the applicant is going to say the operator will have night staff on duty who will intervene if this happens. Any such statement should be challenged. How many staff? If it’s just one, will this person be able to exert control over an event that may be attended by dozens of people? If not, what extra resources will this person be able to call upon (at midnight or later)? Indeed, how will the operator and its day/night staff regulate the number of guests in the building (or on site) at any time in the 24-hour cycle? This also has implications for fire safety. A capacity of 60 people is advised for the common room by the applicant’s Fire Strategy Report (see table, Page 10). That would be quite a modest gathering for a student event. In HMOs, we have seen that students invite friends, and then the friends invite their friends, and before you know it, you have more than 100 people in the property.

5.3.4.The assessment of how much noise might be heard by neighbours was apparently conducted on a computer, using an acoustic model of St Josephs and other nearby buildings. The results of such an assessment must obviously depend to a significant degree on the accuracy of assumptions made in constructing the model. In these circumstances, one would expect the predicted outcomes to be presented as a range, illustrating a spread of possible results from best- to worst-case, or similar. Instead, the results presented in Table 6.2, Page 3, of the Noise Impact Assessment are discrete numbers. The result given for noise modelled to be received at Hillside, the nearest residential property to the north-west of St Josephs, is stated to be 40dB, which is 4dB less than the assumed 44dB threshold for acceptability. This result was achieved by applying an assumed noise source of 75 dB(A) in the common room of the acoustic model.

5.3.5.The assessment says (Page 2): “An internal amplified music spectrum representing lively communal use has been applied, with an overall internal noise level of approximately 75 dB(A). This level is considered representative of typical use of a student common room with amplified music and conversation, and provides a realistic and proportionate basis for assessing potential noise break‑out. The adopted internal spectrum reflects the typical frequency content of amplified music, with energy concentrated in the low‑ and mid‑frequency bands and a natural roll‑off at higher frequencies.”

5.3.6.No information is provided to show whether the choice of 75 dB(A) is indeed representative, even though this is a critical and obviously significant variable. I am not in a position to offer evidence for a different figure, but having seen large concert-grade amplifiers removed from a student property after a party (and knowing of several other similar instances), I question the assumption. It appears a higher figure for the noise source might easily have pushed the result at Hillside over the target threshold (even allowing for the logarithmic nature of the decibel scale).

5.4.   (c) Noise from the garden. This is in some ways the most concerning issue, mainly because the applicant shows no awareness of it. Neither the Planning Statement nor the Noise Impact Assessment discuss this scenario, but it is all too plausible, given that a common feature of disruptive student parties in HMOs is large groups talking, shouting and generating high levels of “people noise” in the garden of the house. St Josephs’ gardens are by all accounts quite magnificent, and will be a desirable attribute of the property. They could also turn into Rave Central if not managed properly.

5.4.1.In cases of large parties that I have personally witnessed, complaints have come from residents living as far as 100m away from the source. A similar event in the garden of St Josephs would put homes on both sides of Hampton and Aberdeen Roads, as well as Hillside, within scope. Other properties might also be affected, depending how noise reflects off other buildings, and the wind direction.

5.4.2.The location potentially most impacted would be the currently vacant site to the east of St Josephs, fronting Aberdeen Road. This is marked in blue on the Site Location Plan. We are told this is also owned by Harringay, the applicant, but not what the intentions are for this plot. If the future use is residential, occupants will be fully exposed to any noise generated in the St Josephs garden at night. Given the proximity of the garden, disturbance could occur even if there are relatively small numbers of people gathered there. This is true for Hillside, too.

5.4.3.Perhaps there will be house rules banning use of the gardens after a certain time in the evening, with or without amplified music. Some kinds of students regard those sorts of rules as a challenge. Let’s say we are in May. Final exams have finished and third-year students are now coasting towards the end of their time at both the university and St Josephs. It’s warm out, and the garden provides the perfect setting for a last big bash to bring the whole experience to a memorable close. ‘Rules? What rules? We’re leaving in three weeks, so there’s nothing much anyone can do to us ...’

5.4.4.Will one or two night staff be able to cope with this? Realistically, how are one or even two people going to prevent such an event happening or bring it to a close? Unless the applicant can provide a plausible answer to these questions, this is a gaping hole in any assurances that St Josephs will not impact neighbours. It would be unwise to assume that the police will help (see my comments at 1.5 above and at 5.5 below). This will essentially be a contractual issue between the operator and tenants; it’s unclear what the police position would be. In any case, if it’s Friday or Saturday night, they may not have the resources. Operation Beech, similarly, may or may not be available; in any case, this is not what it was designed for, and its officers may have priorities elsewhere.

5.5.   I belabour these points because it is all too easy for the applicant to offer, and the planning decision-makers to accept, that such concerns will be covered by conditions attached to planning approval. The question is whether any such arrangements will be robust, practical, and backed by sufficient resources to provide assurance they will be available and effective when needed. If conditions are in place but not working, who does the community complain to? What remedies will exist, what is the enforcement route, and which department of the council (Planning?) will have lead responsibility? Will the operator provide a telephone number the public can ring if an event is in progress? Will there be any channel for community liaison between the operator and residents’ groups?

6.     Lack of Mitigation

I will end with this observation: The growing opposition to this proposal is as indicative of longstanding failures of enforcement as it is of aversion to more students. For many years the public authorities (chiefly the council and the police, but also the University of Bristol) have failed to give complaints of anti-social behaviour the priority they deserve. If the community had confidence that, when things go wrong, the authorities would respond quickly and decisively, it’s possible people would have a less negative view about student numbers. The reality, unfortunately, is that enforcement—of all kinds, from noise and waste to planning, HMO licensing conditions and university community-behaviour rules—is incredibly weak. As a result, there is no effective mitigation of the impacts of higher student numbers, and none in prospect. In these circumstances, the application is highly likely to add to existing harms and must be rejected.

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