My supplementary response

This is the full text of the supplementary comments I submitted to the planning website on 18 August 2026 following a council invitation to participate in a second round of consultation. (I assume everyone who objected in the first round received this invitation. For most people, the second round closed on 19 August 2026.)

-----------------------

I OBJECT to application 26/11841/F:

Thank you for your letter of 5 August 2026 notifying revisions to this application and providing a further opportunity to comment.

The letter does not make clear whether these comments should be confined only to the revisions, or whether this is in effect a new consultation on all aspects of the revised plan.

For the avoidance of doubt, I wish to make clear that I maintain my objection to the change of use to student accommodation, for all the reasons I gave in my original submission in June 2026. The reduction from 132 proposed bed spaces to 126, and other revisions, do not fundamentally change the proposal or my objections to it.

I would however like to comment on the applicant’s attempted justifications in the supporting document “Applicant’s Note on PBSA Overconcentration” listed on 6 August 2026:

1. Introduction:

The applicant writes:

“The application for a change of use of the former care home at St Joseph’s (26/11841/F) states that it would not create a harmful concentrations of student population, and the building will be managed to prevent any adverse impacts on the amenity of local residents, in compliance with adopted Policy DM2. This has been acknowledged and accepted by BCC (Noise) Pollution Control and Transport Development Management.”

No. The Noise and Transport consultees commented on matters within their remit. They did not pronounce on the suitability of change of use or the issue of harmful concentration.

2. Site context:

The applicant notes that the site is “adjacent to” the university precinct and the Bristol Central Area. In other words, it is *not* in those areas. This is the whole point: There are two boundaries, and, from the applicant’s point of view, the site is on the wrong side of them in each case. This matters. Certain planning policies apply on one side of the line, but not on the other. Constantly repeating this “near the university” theme will not change the facts.

3. Alleviating demand for housing and HMOs:

Regardless of how many times national and local policy documents refer to the potential for PBSA to relieve pressure on local housing stock, there is no good reason to believe that building 126 PBSA beds in Cotham Hill will result in *any* of the *existing* dozens of student HMOs in the area being returned to family occupation or other non-student uses. Absent evidence, the council should dismiss this argument in the present case.

The applicant is once again guilty of selective quoting in its citations of the “emerging” Local Plan policy H7 on PBSA. The relevant section, in full, is as follows (emphasis mine; see words enclosed by asterisks):

“6.70 The council also wants to ensure that the needs of students are balanced with the needs of the whole community in terms of housing, services and amenities. Large- scale developments or clusters of student accommodation can give rise to certain issues including problems arising from intensively occupied accommodation and changes to the housing balance, function, diversity and character of an area.

“6.71 *Provided these issues are managed* the provision of purpose-built accommodation *in appropriate locations* is supported by the council and both of the city’s universities. Expected growth in student numbers should be met through this form of accommodation to ensure the local housing stock remains available to meet general housing needs and to prevent further impacts on residential areas through the growth of HMOs.”

The applicant is not keen to highlight paragraph 6.70, the first sentence of which is the essence of the policy. Nor does it acknowledge the important conditionality in 6.71.

In relation to the “emerging” nature of policy H7, it should be noted that the emergence is now almost complete. The paragraphs quoted above (and in the next section below) survived the modification process in the statutory examination and the removal of bedspace caps in certain areas made no difference to how H7 will apply to the application site.

4. Density at St Joseph’s:

The applicant looks at various ways to assess the student concentration in the area around the site. It needn’t have bothered. Policy H7 specifies an assessment method, as the applicant is obviously aware because it references the policy’s “200m radius” guideline in the first sentence of this section. The applicant must therefore also be aware that paragraph 6.87 states as follows (my emphasis):

“6.87 As a guide the council considers that a local imbalance of purpose-built student accommodation is likely to occur where bed space numbers within 200 metres of the site (including the proposal) exceed a threshold of *100* bed spaces within residential areas ... *In all cases* the proximity and concentration of houses in multiple occupation should also be taken into account. *Assessments on whether an imbalance would occur should also consider the extent to which the development provides for a mix of uses, including residential, that contributes to the diversity of uses and housing choice within the area.* “

As paragraph 6.87 states, this is a guide. But the application would not simply stretch the 100-beds-per-200m-radius guideline—it would destroy it completely. The application itself envisages 126 beds (as revised). As the applicant acknowledges, there are also 207 recognised PBSA beds nearby, most of them directly across the street. When dozens of local HMOs are also counted, as H7 requires, that will probably add circa 200-300 beds to the total of shared and specialist housing.

There is also an explicit requirement for 35% of the accommodation to be affordable (see H7 Policy Text).

5. Comparison with other Bristol LSOAs and Applications / How has concentration been assessed in BCC committee and officer reports? / How have appeals approached the issue of concentration?:

Most of the material in these three sections can be dismissed as irrelevant, out of date or misleading.

Past planning decisions are not legally binding on future ones, though they may be a material consideration. Councillors must make their judgments on the facts of the case. It is likely that the existing student concentration in Cotham Hill is more acute than in those earlier cases. In those cases that were relatively recent, Policy H7 will have had only limited influence because the Local Plan still had several stages of statutory examination to complete. It has now passed most of the remaining stages, largely intact.

Officers and appeal inspectors quoted in those earlier decisions were mostly pronouncing judgement without the benefit of an objective guideline (the 200m-radius rule) as to what constitutes overconcentration. We used to see similar comments about HMO applications before the council introduced supplementary guidance in 2020 that employed similar rules-of-thumb to aid consistent decision-making. The applicant (and possibly some inspectors) would apparently only recognise overconcentration if it reached 100%.

As for lack of evidence, the dozens of objections registered in the first round of consultation frequently cited noise, litter and other indicators of a district being taken over by a large group of people who have little commitment to the place they live in. Does the applicant think the objectors are all making it up?

In summary, what the applicant is asking councillors and residents to do is to tear up the carefully formulated policy that this city has evolved, through a democratic process of public consultations, to try to balance the legitimate concerns of residents with those of a rapaciously expanding university/developer complex.

The new Local Plan, hopefully soon to be formally adopted, makes fair provision for new purpose-built student accommodation and specifies where it should (and should not) be built. Those policies do not support a further large PBSA development in Cotham Hill.

###