CC29/H - Former college Old Building, Great Horton Road

Comment

Representation ID: 28839

Received: 24/03/2021

Respondent: Environment Agency

Site in Flood Zone 1 ONLY
Mitigation should be set above the 1 in 100 plus cc level for the site as suitable for the proposed vulnerability classification (EA standing advice should cover this).

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.

For developments 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 possible the sites within close proximity to Flood Zones 3b, 3 and 2 may be subject to future risk identified within the SFRA (to follow) which may affect its allocation or how development should be sequentially laid out on the site.

Consideration must be made to making space for water and providing betterment in terms of flood risk management where ever possible.

Object

Representation ID: 29161

Received: 29/03/2021

Respondent: Historic England

There is a requirement in the 1990 Act that “special
regard” should be had to the desirability of preserving Listed Buildings or their setting or any features of special architectural or historic interest which they possess. Although this requirement only relates to the determination of planning applications, failure to take
account of this requirement at this stage may mean that, when a Planning Application is submitted, even though a site is allocated for development in the Local Plan, the need to pay special regard to the desirability of preserving a Listed Building or its setting may mean that either, the site cannot actually be developed or the
anticipated quantum of development is undeliverable.
In order to demonstrate that the allocation of this area is not incompatible with the requirements of the NPPF, as part of the Evidence Base underpinning the Plan there needs to be an assessment of what contribution this area makes to those elements which contribute to the significance of these heritage assets and what effect the development might have upon their significance.
Before allocating this site for
development:
(1) An assessment needs to be undertaken of the contribution which this site makes to those elements which contribute towards the significance of the
Conservation Area and Listed Buildings in its vicinity, and what impact the loss of this site and its subsequent development might have upon their significance.
(2) If it is considered that the development of this site would harm elements which contribute to the significance of the
Conservation Area and Listed Buildings,
then the measures by which that harm
might be removed or reduced need to be
effectively tied into the Plan.
(3) If, at the end of the process, it is
concluded that the development would
still be likely to harm elements which
contribute to the significance of the
Conservation Area and any of these Listed
Buildings, then this site should not be
allocated unless there are clear public
benefits that outweigh the harm (as is
required by NPPF, Paragraph 195 or 196).

Comment

Representation ID: 29949

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):

CC29/H - Heritage/ severe build cost implications given existing properties and CA. We note application 20/01221/MAF is pending consideration since being submitted in March 2020. There appear to be ongoing issues with HE objections and with BMDC highways. It is unclear if they are surmountable. Even in
the event of consent, we are concerned that the site can reach an appropriate benchmark land value.