Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 13586

Received: 18/03/2021

Respondent: Canal & River Trust

Representation Summary:

The site is located on the non-towpath side of the Leeds & Liverpool Canal, owned and managed by the Trust.
The land is on a gradient that slopes down towards the canal. The construction of new buildings here could impose loading, that could impact the stability of this land, increasing the risk of land slip. To ensure that the Local Plan complies with the aims of paragraphs 178 (part a) from the National Planning Policy Framework, we advise that the development considerations should include the need for contextual information to demonstrate that the development will not result in land instability. Suggested text is provided below:
“Development will need to demonstrate that it will not impose adverse loading that could adversely impact land stability towards the canal”
At application stage, we advise that cross sections would be required to indicate the initial impact on slope stability. Further stability analyses may be required subject to the sections provided.
Our records also show that there is a culvert below the site, which also runs below the canal. We advise that consideration should be given towards ensuring that the development does not damage any underground watercourse here, as it could otherwise result in localised flooding.
The development considerations argue that mitigation is required to reduce the impact of development on the canal and listed building. We agree with this statement. The canal corridor is presently enhanced by existing vegetation on the bank where the development is proposed. We advise that any future development proposal should seek to retain these trees.
We note that the development considerations advise that design principles should be developed based on further investigation of contextual considerations, constraints, landscape, and an understanding of the canal side setting and heritage. Strengthening the established buffer between site and canal may well be the best approach. A landscape visual impact assessment would be required to recognise the value of the setting of canal, locks and make a reasoned evaluation and recommendations. Provisions for this could be included within the ‘Development Considerations’.
In line with the principles of paragraph 170 (part d) of the National Planning Policy Framework (NPPF), development on site should seek to minimise impacts on and provide for net gains to biodiversity. Given the vegetated nature of the site, there is a risk that development could harm biodiversity associated with the Green and Blue infrastructure along the canal. To ensure the Local Plan is effective and accords with the principles of the NPPF, we advise that the development considerations should require the provision of biodiversity assessments and enhancement strategies for the site.