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

Comment

Representation ID: 13577

Received: 18/03/2021

Respondent: Canal & River Trust

Reference to the canal (within part Ac) and blue infrastructure within the policy text would help to make the Local Plan more effective as it would make it clearer to decision makers that our network forms part of the wider GI network in Bradford District, and that the policies apply to our waterway corridor.

Comment

Representation ID: 13582

Received: 18/03/2021

Respondent: Canal & River Trust

The general policy text should help ensure that the Local Plan is effective in meeting the aims of section 16 of the National Planning Policy Framework.
The Leeds & Liverpool forms an important heritage asset through the district, including through the Saltaire World Heritage Site. Whilst we welcome in part C(2) the reference to industrial heritage, we believe that reference to the canal itself should be included. This would make the plan more effective as it would make it clearer to decision makers that the waterway itself is a heritage asset. The is pertinent as the multifunctional role of the canal is such that its heritage value is not otherwise immediately obvious to decision makers and developers.

Comment

Representation ID: 13585

Received: 18/03/2021

Respondent: Canal & River Trust

The reference to the need to link developments to the wider landscape and to extend blue infrastructure networks into sites is generally welcomed, as it would help make the Local Plan more effective in promoting good design and links to the wider walking and cycling network, including our canal network

Comment

Representation ID: 13586

Received: 18/03/2021

Respondent: Canal & River Trust

The site is located on the non-towpath side of the Leeds & Liverpool Canal, owned and managed by the Trust.
The land is on a gradient that slopes down towards the canal. The construction of new buildings here could impose loading, that could impact the stability of this land, increasing the risk of land slip. To ensure that the Local Plan complies with the aims of paragraphs 178 (part a) from the National Planning Policy Framework, we advise that the development considerations should include the need for contextual information to demonstrate that the development will not result in land instability. Suggested text is provided below:
“Development will need to demonstrate that it will not impose adverse loading that could adversely impact land stability towards the canal”
At application stage, we advise that cross sections would be required to indicate the initial impact on slope stability. Further stability analyses may be required subject to the sections provided.
Our records also show that there is a culvert below the site, which also runs below the canal. We advise that consideration should be given towards ensuring that the development does not damage any underground watercourse here, as it could otherwise result in localised flooding.
The development considerations argue that mitigation is required to reduce the impact of development on the canal and listed building. We agree with this statement. The canal corridor is presently enhanced by existing vegetation on the bank where the development is proposed. We advise that any future development proposal should seek to retain these trees.
We note that the development considerations advise that design principles should be developed based on further investigation of contextual considerations, constraints, landscape, and an understanding of the canal side setting and heritage. Strengthening the established buffer between site and canal may well be the best approach. A landscape visual impact assessment would be required to recognise the value of the setting of canal, locks and make a reasoned evaluation and recommendations. Provisions for this could be included within the ‘Development Considerations’.
In line with the principles of paragraph 170 (part d) of the National Planning Policy Framework (NPPF), development on site should seek to minimise impacts on and provide for net gains to biodiversity. Given the vegetated nature of the site, there is a risk that development could harm biodiversity associated with the Green and Blue infrastructure along the canal. To ensure the Local Plan is effective and accords with the principles of the NPPF, we advise that the development considerations should require the provision of biodiversity assessments and enhancement strategies for the site.

Comment

Representation ID: 13587

Received: 18/03/2021

Respondent: Canal & River Trust

The site offers a good opportunity in principle to benefit the canal side through the restoration/retrofitting of the existing building and development of the site. Due to the heritage value of the existing building, which is characteristic of the former industrial use of the canal and helps to complement the Saltaire World Heritage Site buffer zone, we advise that conversion of the building should be sought over its replacement and redevelopment.
We advise that careful redevelopment of the site is required to minimise the prominence of any parking or service areas, which would be to the detriment of the waterside location.
The site borders a canal basin, and we advise that consideration should be given to minimising any adverse loading or vibrations during and post construction that could damage the canal. Measures to protect the canal could be included within the ‘Development Considerations’. Suggested wording is provided below:
“The development will need to be designed to minimise any adverse loading onto the canal”

Comment

Representation ID: 13588

Received: 18/03/2021

Respondent: Canal & River Trust

The site is at a lower level to the canal, which is supported above the site by a shallow embankment. The site would be vulnerable to any breach or leakage from the canal. We therefore advise that any future planning proposals should consider the risk within the flood assessment, including any mitigation to reduce the risk of flooding in the event of any breach. We advise that this risk should be included within the development considerations to ensure that this risk is appropriately identified and mitigated against.
Changes to levels on site also have the potential to impact the stability of the embankment. To ensure that the Local Plan complies with the aims of paragraph 170 and 178 from the National Planning Policy Framework with regards to stability, we advise that the development considerations should include the need for contextual information to demonstrate that the development will not result in land instability. Suggested text is provided below:
“Development will need to demonstrate that it will not adversely impact the embankment supporting the canal above the site”
At application stage, we advise that cross sections would be required to indicate the initial impact on slope stability. Further stability analyses may be required subject to the sections provided.
The development would introduce a significant new population next to the canal, likely to utilise the canal towpath for leisure and active transport. The Trust maintain our towpaths to a steady state, and additional contributions would likely be required from new development to accommodate the needs of new residents, and to prevent any deterioration of the towpath surface associated with additional usage. Consistent with the wording for site SH10/H, we advise that the development considerations should include reference to the need to “Contribute to appropriate and proportionate improvements to the canal towpath”.
Redevelopment of the site could alter outward views from the canal. Wording concerning the need for a heritage statement and mitigation is therefore welcome, as it would help to make the plan more effective in ensuring that redevelopment complements the canal corridor and Saltaire World Heritage Site Buffer. Reference to the local wildlife corridor associated with the Leeds & Liverpool canal, and aims to retain trees on site, should help to ensure that impacts to biodiversity are considered and mitigated against.

Comment

Representation ID: 13591

Received: 18/03/2021

Respondent: Canal & River Trust

We note that the red line plan drawn to accompany the description is inaccurately plotted, and may need correcting.
The southern part of the site fronts onto the towpath of the Leeds & Liverpool Canal.
The site is at a lower level to the canal, which is supported above the site by a shallow embankment. The site would be vulnerable to any breach or leakage from the canal. We therefore advise that any future planning proposals should consider the risk within the flood assessment, including any mitigation to reduce the risk of flooding in the event of any breach. We advise that this risk should be included within the development considerations to ensure that this risk is appropriately identified and mitigated against.
Changes to levels on site also have the potential to impact the stability of the embankment. To ensure that the Local Plan complies with the aims of paragraph 170 and 178 from the National Planning Policy Framework with regards to stability, we advise that the development considerations should include the need for contextual information to demonstrate that the development will not result in land instability. Suggested text is provided below:
“Development will need to demonstrate that it will not adversely impact the embankment supporting the canal above the site”
At application stage, we advise that cross sections would be required to indicate the initial impact on slope stability. Further stability analyses may be required subject to the sections provided.
There is a risk that, due to the topography on site, redevelopment could result in a backward facing residential estate style development that would have a poot visual impact on outward views from the canal. The inclusion, within the development considerations, of the need for the development to provide a high quality frontage to the canal is welcome, as it may help to make the plan more effective in providing for an appropriate design.
The Trust maintain our towpaths to a steady state, and additional contributions may be required from new development to accommodate the needs of new residents, and to prevent any deterioration of the towpath surface associated with additional usage. The existing inclusion of text in the development considerations addressing this requirement should help to mitigate against this risk.

Comment

Representation ID: 13592

Received: 18/03/2021

Respondent: Canal & River Trust

We understand that the existing site is vacant.
The site is supported above the Leeds & Liverpool Canal via a tall retaining wall. There is a risk that loading from new development could result in damage to this structure, which could result in land instability next to the waterway. To ensure that the Local Plan complies with the aims of paragraph 170 and 178 from the National Planning Policy Framework with regards to stability, we advise that this constraint should be identified in the Local Plan. We also advise that the development considerations should include the need for contextual information to demonstrate that the development will not result in land instability. Suggested text is provided below:
“Development will need to demonstrate that the retaining wall next to the Leeds and Liverpool canal can accommodate the loading from new development, and will not result in land instability”
At application stage, we advise that a survey of the wall by appropriately qualified person(s) may be required to fully ascertain that the final design can be supported by the retaining structure.
The rear of the site is very visible from the canal, and there is a risk that bin stores and other services located to the rear could detract form the character and appearance of the canal. To mitigate against this risk, we advise that the development considerations should include reference to the need to ensure that any service areas and bin stores are adequately screened from the canal.

Comment

Representation ID: 13593

Received: 18/03/2021

Respondent: Canal & River Trust

The allocation site is situated at the top of a principle cutting to the Leeds & Liverpool Canal. We advise that development on the site needs to ensure it does not create a surcharge onto the cutting, which could otherwise result in land instability.
To ensure that the Local Plan complies with the aims of paragraphs 170 and 178 from the National Planning Policy Framework with regards to stability, we advise that this constraint should be identified in the Local Plan. We also advise that the development considerations should include the need for contextual information to demonstrate that the development will not result in land instability. Suggested text is provided below:
“Development will need to demonstrate that it will not impose loading on the canal cutting that could otherwise result in land instability”

Comment

Representation ID: 13594

Received: 18/03/2021

Respondent: Canal & River Trust

The site is at a lower level to the canal, which is supported above the site by an embankment. The site would be vulnerable to any breach or leakage from the canal. We therefore advise that any future planning proposals should consider the risk within the flood assessment, including any mitigation to reduce the risk of flooding in the event of any breach. We advise that this risk should be included within the development considerations to ensure that this risk is appropriately identified and mitigated against.
Changes to levels on site also have the potential to impact the stability of the embankment. To ensure that the Local Plan complies with the aims of paragraph 170 and 178 from the National Planning Policy Framework with regards to stability, we advise that the development considerations should include the need for contextual information to demonstrate that the development will not result in land instability. Suggested text is provided below:
“Development will need to demonstrate that it will not adversely impact the embankment supporting the canal above the site”
At application stage, we advise that cross sections would be required to indicate the initial impact on slope stability. Further stability analyses may be required subject to the sections provided.
There is a risk that, due to the topography on site, redevelopment could result in a backward facing residential estate style development that would have a poor visual impact on outward views from the canal. Consideration should be given in the policy text to the need for an active frontage to the canal, which would help to ensure that the development has a positive relationship with the canal and will accord with the principles of emerging policy DS2 with regards to the relationship of development to Green Infrastructure.