CC19/H - 16-18 Mill Street

Comment

Representation ID: 28824

Received: 24/03/2021

Respondent: Environment Agency

Flood Zones 2, 3 and the current/draft 3b/3a(i) within site boundary.

There is to be no development with the 3b/3a(i) extent unless considered water compatible or essential infrastructure. Where this is the case the development must demonstrate no increase in risk to others, no loss of Functional Floodplain and suitable mitigation measures for use and the lifetime of the development.

Development on site should follow a sequential layout so as to prevent unnecessary development within Flood Zones 3b, 3 and 2 wherever possible. If the site is considered Greenfield then surface water discharge rates post development should be restricted to the pre development Greenfield discharge rate.

If the site is considered Brownfield then there should be a 30% reduction in surface water discharges, or restricted to Greenfield rates, there should be no increase in brownfield surface water discharge rates post development. So as to support prevention of cumulative increases to flood risk and should be in line with SuDs design principles. Some SuDs principles such as storage ponds should not be solely relied upon within areas at risk of fluvial flooding as they may not be operational during a flood.

Development must be shown to be safe for the lifetime of the development. See the Adept Guidance of Access and Egress plans. Hazard ratings may need to be assessed as part of the proposal.

Mitigation such a proofing measures and raised Finished Floor Levels, must be set above the 1 in 100 plus Climate Change level for the site. Current Guidance is on .gov.

The applicant must ensure there is no increase in risk to others for the lifetime of the development (including climate change). Where on Greenfield sites compensatory storage must be actively sought.

Consideration must be made to making space for water and providing betterment in terms of flood risk management where ever possible. For development near ordinary watercourses we would recommend an 8 metre easement strip along the length of the riverbank, or a 45degree angle from the bed in the case of culverts, to be kept clear of permanent structures such as buildings. This is to maintain access to the riverbank for any improvements or maintenance. A Flood Defence Consent may be required for the LLFA for works in/affecting an ordinary watercourse.

For main rivers, we generally require an 8 metre easement strip along the length of the riverbank to be kept clear of permanent structures such as buildings, or a 45degree angle from the bed in the case of culverts. This is to maintain access to the riverbank for any improvements or maintenance. Environmental Flood Risk Activity Permits may be required for development near rivers.

It is likely these sites are going to show changes/increases in flood risk as a result of climate change.

The SFRA (to follow) is going to consider future flooding including future Functional Floodplain this may identify sites at more future risk than others which may affect its allocation or how development should be sequentially laid out on the site.

Support

Representation ID: 29148

Received: 29/03/2021

Respondent: Historic England

The site comprises 16 and 18 Mill Street, a Grade II Listed Building. The site is within the Cathedral Precinct Conservation Area. The development of this area could harm elements which contribute to the significance of this designated heritage asset.
We welcome the inclusion of a reference to the designated heritage
assets in the Constraints and Opportunities section of the sites pro
forma, and that the Development Considerations highlight that
development should respond sensitively to the surrounding historic
context and safeguarding the character and setting of the Listed
Building and the Conservation Area. This will alert potential developers of the need to take account of those elements which contribute to their significance, and ensure that they are not harmed by development proposals.

Comment

Representation ID: 29944

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

A significant proportion of the city centre sites carry risk and if relied upon Bradford may not be able to deliver the quantum of housing envisaged. Our summary assessment of these sites is set out below (Table 1 – Savills City Centre Housing Supply Site Assessment):

CC19/H - Site on area of flood zone and in use as existing car park. Unclear if consistent with NPPF sequential test policy. Heritage/ build cost implications involved given Grade II listed building. No clear evidence site is viable.