DH1/H - Station Road

Comment

Representation ID: 17298

Received: 22/03/2021

Respondent: The Great Northern Railway Trail Development Group

Station Road already has detailed planning permission. The Great Northern Railway Trail is to built alongside this housing development within the development site. However, it was struggle to get Bradford planners and the developer to assist by recognising the importance of this proposed section of the Trail as part of the National Cycle Network. We were treated as a third party with no weight to co-operate other than as a formal consultee. If planning policy is to change direction towards sustainable travel in future, then much more collaboration is needed from the outset.

Object

Representation ID: 19722

Received: 23/03/2021

Respondent: Bradford District Ward Councillor (Conservative)

Denholme is perhaps the most ill served with infrastructure of all our villages, yet it is to have a further 72 houses DH1/H. The attendant cars will significantly increase traffic already contending with numerous heavy goods vehicles that blight people's lives.

Comment

Representation ID: 19883

Received: 01/04/2021

Respondent: Natural England

The site lies in proximity to the South Pennine Moors (Phase 2) SPA and has potential to lead to the loss of functionally linked land for SPA birds.

We welcome the approach taken in the draft plan, SPD and assessments to loss of functionally linked land.

The council has a copy of a model to identify the suitability of sites for SPA golden plover and recommend that allocations are screened against this dataset taking the following approach:

• Maximum Training Sensitivity plus Specificity (MTSS) layer: full survey for Golden Plover likely to be required. The WY Ecology Service SPA Bird Survey Methodology should be followed.

• Minimum Training Presence (MTP) layer or 10 Percentile Training Presence (10PTP) layer: scoping survey to determine if a full Golden Plover full survey required. A desk based survey may be sufficient for sites within the MTP whereas a walkover survey may be required for sites within the 10PTP;

• Not within an area of predicted presence: No survey required for Golden Plover.

Where loss of functionally linked land cannot be ruled out at this stage we recommend that allocation requirement text in the plan sets out survey and mitigation requirements clearly.

Comment

Representation ID: 28725

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.