CU2/H - Cullingworth Mill

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Comment

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

Representation ID: 28717

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

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.

Comment

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

Representation ID: 28831

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Conservative)

Representation Summary:

b) CU2/H - Cullingworth Mill

1. The access to potential sites is via a narrow lane which currently can’t sustain construction traffic and will need to be upgraded before any prior works.

2. The site has significant water flooding issues that must be addressed.

Comment

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

Representation ID: 29263

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

We note that the following sites offer opportunity to open up lengths of previously culverted watercourse, with benefits to Green-Blue Infrastructure and Biodiversity Net Gain.

We would like to see this listed within the paragraphs on opportunities and development considerations, and wish to see the opening of these watercourses promoted as a benefit to the environment and a contribution to green space and the Wildlife Habitat Network:

o CU2/H Cullingworth Mill: derelict mill site. Opportunity to open Manywells Beck as Green-Blue Infrastructure and to achieve the riverine element of BNG.

Object

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

Representation ID: 29427

Received: 29/03/2021

Respondent: Historic England

Representation Summary:

See attachment for full representation.
The boundary of the Cullingworth Conservation Area is close to the sites north-west corner. There are also three Grade II Listed Buildings in close proximity to the site, including the Cullingworth War Memorial and Cullingworth Baptist Church. The site contains buildings associated with the former Cullingworth Mill.
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 Listed Buildings in its vicinity, and what impact the loss of this undeveloped 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 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 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

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

Representation ID: 29652

Received: 14/03/2021

Respondent: Cullingworth Parish Council

Representation Summary:

We agree in principle, but make the following observations: Significant surface water plus a culvert running under the site could give rise to significant issues. The mill building could be regarded as undesignated heritage asset and the site is adjacent to a Grade II listed building. The existing access is through an archway which is very narrow and the site is close to a busy road junction. Pedestrian access may be an issue as existing access is very narrow with no existing footpath. There are good public transport connections.

Surface water flooding mitigation would be needed and may significantly constrain the site. There is a culvert under the site which could need to be reconfigured.
Bat alert area and ecological surveys would be required. Existing heritage assets including entrance arch would need to be considered and potentially incorporated into the design. There are significant challenge in terms of surface water flooding and access. Heritage will also need to be considered.