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

Support

Representation ID: 29044

Received: 29/03/2021

Respondent: Historic England

The historic environment makes a significant contribution to the distinctive character of Bradford District, to its economic well-being, and to the quality of life of its communities. It is essential, therefore, that the Plan sets out a robust framework for how this resource will be manage, how potential threats to those assets might be addressed, and how Bradford’s historic buildings and areas might be used more positively to help deliver the wider objectives for the Local Plan area.

Consequently, we support the proposed Spatial Vision for the Bradford District in 2038, particularly the intention that:
- The District’s unique landscapes, heritage and biodiversity assets will play a vital role in making great places that encapsulate what makes Bradford so special; and
- The economic transformation of the District will be achieved based on Bradford’s key strengths, including its rich historic and cultural identity and wealth of environmental assets.

Support

Representation ID: 29046

Received: 29/03/2021

Respondent: Historic England

We welcome the inclusion of Strategic Objective 13 relating to how the Vision for Bradford District will be achieved through, amongst other things, safeguarding, enhancing and promoting the diverse historic built and natural heritage of the District which helps reinforce the local distinctiveness of places. We also welcome the reference under Strategic Objective 11 to improves cultural facilities and under Strategic Objective 12 to supporting the social, economic and physical regeneration of neighbourhoods.

Object

Representation ID: 29047

Received: 29/03/2021

Respondent: Historic England

Tourism makes an important contribution to the economy of the District. The Economic Strategy for Bradford District identifies tourism as one of the foundations for growth under the key opportunity area of Our Distinctive Offer, highlighting Brontë Country, Ilkley and the David Hockney Gallery as examples. The Strategic Objective for the economy should also include specific reference to the intention to realise the full potential which tourism can
make to the economy of the District.

Add the following additional Strategic Objective:
‘To maximise the contribution which cultural, arts and tourist assets, including the Districts rich built and archaeological heritage, can make to the economy of the area.’

Object

Representation ID: 29048

Received: 29/03/2021

Respondent: Historic England

B3 - the environmental objectives of sustainable development, a minor amendment is necessary to closely reflect the definition of the environment used in NPPF paragraph 8c. We welcome the intention that the Council’s approach to site selection under Criterion B5e will, wherever possible, enable the enhancement of the built and natural environment and minimises the adverse environmental impacts of growth, we request that a specific reference to heritage assets is added to the second half of the sentence where particular considerations are highlighted.
B.2, amend to read:
“It will meet the environmental objectives by the inclusion of a suite of policies designed to protect, conserve and enhance the natural, built and historic environment. By focussing development in its main urban areas and by
investing in public transport infrastructure in the process reducing the need to travel by car and reducing climate change emissions;
and” B.5.e, amend to read:
“e. Ensures that wherever possible development enables the enhancement of the built and natural environment and minimises the adverse environmental impacts of growth, in particular with regards to climate change, air quality, biodiversity, habitats and heritage assets.”

Support

Representation ID: 29049

Received: 29/03/2021

Respondent: Historic England

We welcome the recognition of the important contribution the historic environment of Bradford makes to the Districts economy, and the opportunities to build on the Districts distinctive and varied architectural, heritage and cultural assets.

We endorse the recognition that a good quality environment is critical to the social, economic and environmental well-being of the District and that positive environmental management will be vital if it is to be safeguard and improved. - This section would make more sense if the final sentence of paragraph 3.2.13 was located at the start of paragraph 3.2.14.

We support the requirement that planning decisions / plans strategies, programmes and investment decisions should seek to:
7: Protect and enhance the character and qualities of the Districts heritage, landscape and countryside and maximise the contribution they can make to the delivery of wider economic and social objectives;
11: Ensure that developments are of high quality and well designed and that they contribute to inclusive built and natural environments which protect and enhance local settings, and heritage and reinforce or create a sense of local character, community and distinctiveness.

Support

Representation ID: 29050

Received: 29/03/2021

Respondent: Historic England

We would endorse:
- need for development within the three Principal Towns to ensure that their distinctive character is protected and enhanced.
- need for development within the Local Growth Centres to ensure that their distinctive character is retained. This requirement also needs to be reflected in the respective section of Policy SP3.
- need for development within the Local Service Centres and rural areas to ensure that their distinctive character is retained. This is especially important in places such as Haworth whose economic welfare relies on safeguarding those elements which contribute towards its distinctive identity.
Bradford has a rich legacy of heritage assets which can act as a catalyst for, and assist in, the regeneration of the City.
Subject to the change below, we support the emphasis placed on developing a strong sense of place which reinforces the distinct identity of the City through well designed public realm and buildings. This will assist in the delivery of the Vision and its related Strategic Objectives relating to making great places that encapsulate what makes Bradford so special.

Object

Representation ID: 29051

Received: 29/03/2021

Respondent: Historic England

Regional City - concerns about the potential impact which the proposed level of housing growth for Shipley and Lower Baildon might have upon elements which contribute towards the Outstanding Universal Value of the World Heritage Site at Saltaire.

A number of the proposed allocation sites are located in areas which the Saltaire World Heritage Site Environmental Capacity Study has identified as being important components in the setting of the World Heritage Site. Three of these sites (sites SH4/H, SH5/H and SH9/H) are potentially capable of accommodating well in excess of 100 dwellings.

Policy SP3 should make it clear that housing sites around Saltaire will be required to safeguard its Outstanding Universal Value.

B, add the following additional development requirement:
‘Safeguard those elements which contribute to the Outstanding Universal Value of Saltaire.’

Object

Representation ID: 29052

Received: 29/03/2021

Respondent: Historic England

Principle Towns - Subject to the recommended change below, we welcome:

The role that heritage assets play in defining the character and setting of the Districts principal towns;

The requirement that, in identifying their potential for growth, this will be informed by the existing scale of the settlement and the contribution made by, and importance of, its environmental assets; and, High design standards being required that protect and enhance settlement character.

The second sentence of Criterion C is not explicitly clear that the heritage assets with be considered, alongside
environmental ones will be used to inform the potential for growth in the Districts principal towns.

Principal Towns, Criterion C, amend second sentence to read:
‘Potential for growth will be informed by the existing scale of the settlement, the contribution made by environmental and heritage assets as appropriate to their importance and flood risk issues.’

Object

Representation ID: 29053

Received: 29/03/2021

Respondent: Historic England

Local Growth & Service Centres - NPPF paragraph 127 states that planning policy should ensure developments establish or maintain a strong sense of place in order to create attractive, welcoming and distinctive places. Distinctiveness is not solely about the aesthetic qualities of the built and natural environment – it also reflects an area’s function, history and culture. We suggest that the term diversity is replaced by a reference to distinctiveness which encompasses this term but also covers these wider considerations of an areas function, history and culture.

Local Growth Centres, Criterion 1, amend to read:
‘Achieve a high standard of design that protects and enhances settlement and landscape character and distinctiveness.’

Service and Rural Areas, Criterion 1, amend to read:
‘Achieve a high standard of design that protects and enhances settlement and landscape character and distinctiveness.’

We support the intention that, in these settlements, the emphasis will be on smaller-scale developments which meet local needs together with the protection and enhancement of those centres as attractive, vibrant places which provide quality of place and excellent environmental conditions.

Object

Representation ID: 29054

Received: 29/03/2021

Respondent: Historic England

Subject to recommended change, we support priority given to the re-use of previously developed land/ building.
Many of these buildings make a significant contribution to the character and distinctiveness of settlements and to the District as a whole. We fully support priority being given to those sites which would reuse previous buildings. Given the embodied energy within existing buildings (in terms of the materials used for their construction, the energy that was involved in moving those materials to the site etc) coupled with the energy which would be expended in the demolition of those buildings and the removal of the waste materials, we welcome the intention to encourage the reuse of existing buildings. However, as written it could potentially be interpreted as implying that the reuse of buildings of “high environmental value” is not something which the plan would encourage. As a result, this would mean the Plan would not be encouraging the reuse or adaptation of the District’s Listed Buildings (because they are of “high environmental value”). Such an approach would not accord with the principles set out in the NPPF.
amend Criterion A.1to read:
“1. First priority to the efficient and effective re-use of deliverable and developable previously developed land and buildings, provided that it is not of high environmental value and that any heritage assets are appropriately conserved, and more efficient and effective use of existing developed areas within the City of Bradford,
the Principal Towns of Ilkley, Keighley and Bingley, the Local Growth Centres and the Local Service Centres.”