Object

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

Representation ID: 29381

Received: 29/03/2021

Respondent: Historic England

Representation Summary:

This site should not be allocated for development.
The site in an area identified by the WHS Management Plan 2014 as important to the WHS setting. The development of this area could harm elements which contribute to the significance of the WHS.
National policy guidance makes it clear that World Heritage Sites are regarded as being in the category of designated heritage assets of the highest significance where substantial harm to their significance should be wholly exceptional. The NPPF makes it clear that the significance of a heritage asset can be harmed by
development within its setting.
The landscape setting of Saltaire is a key element of its significance. In 2005, Bradford MDC commissioned and published the “Saltaire World Heritage Site Environmental Capacity Study” to help guide
the management of the site. As part of this work, the Study sought to evaluate the contribution which the surrounding landscape made to the significance of the World Heritage Site. Based upon an analysis of their historic significance, their ability to demonstrate key aspects of the Site’s character, and their relationship with
principal buildings on the Site, the Study identified a number of areas which it considered contributed to the setting of Saltaire. This open area lies within one of the areas identified as being critical to the setting of the World Heritage Site. This evidence was subsequently used to inform the WHS Management Plan 2014.
The Heritage Impact Assessment (HIA) for this site considered that, dependant on the proposed scale of development, the scale of impact on the critical views from the buffer zone and rural backdrop would be Moderate. The HIA concluded that the overall impact on
significance following mitigation measures would be Less than Substantial Harm (of and Acceptable Level).
Development of the site would significantly encroach into the important landscape setting of the WHS. As acknowledged in the HIA, View 18 across the site from the hillside north of the village is identified in the WHS Management Plan as Critical and “provides rare uninterrupted and notably aesthetic views of Saltaire along its length.” This remains the case. Historic England considers that the HIA has undervalued the contribution which this site makes to the setting of the WHS and, as a result, the harm which its loss and subsequent development might have upon its significance. In
addition, the introduction of a green landscape buffer along the
sites northern boundary, proposed as a mitigation measure for
development on the site, would only serve to further interrupt views
of the World Heritage Site and thereby the ability to appreciate its
planned layout.
Therefore, the loss of this area is considered likely to cause considerable harm to one of the key elements which contributes to the significance of Saltaire. As such, its Allocation and eventual development would run contrary to the advice set out in the NPPF .