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

Object

Representation ID: 29334

Received: 29/03/2021

Respondent: Historic England

See attachment for full representation
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).

Object

Representation ID: 29381

Received: 29/03/2021

Respondent: Historic England

This site should not be allocated for development.
The site in an area identified by the WHS Management Plan 2014 as important to the WHS setting. The development of this area could harm elements which contribute to the significance of the WHS.
National policy guidance makes it clear that World Heritage Sites are regarded as being in the category of designated heritage assets of the highest significance where substantial harm to their significance should be wholly exceptional. The NPPF makes it clear that the significance of a heritage asset can be harmed by
development within its setting.
The landscape setting of Saltaire is a key element of its significance. In 2005, Bradford MDC commissioned and published the “Saltaire World Heritage Site Environmental Capacity Study” to help guide
the management of the site. As part of this work, the Study sought to evaluate the contribution which the surrounding landscape made to the significance of the World Heritage Site. Based upon an analysis of their historic significance, their ability to demonstrate key aspects of the Site’s character, and their relationship with
principal buildings on the Site, the Study identified a number of areas which it considered contributed to the setting of Saltaire. This open area lies within one of the areas identified as being critical to the setting of the World Heritage Site. This evidence was subsequently used to inform the WHS Management Plan 2014.
The Heritage Impact Assessment (HIA) for this site considered that, dependant on the proposed scale of development, the scale of impact on the critical views from the buffer zone and rural backdrop would be Moderate. The HIA concluded that the overall impact on
significance following mitigation measures would be Less than Substantial Harm (of and Acceptable Level).
Development of the site would significantly encroach into the important landscape setting of the WHS. As acknowledged in the HIA, View 18 across the site from the hillside north of the village is identified in the WHS Management Plan as Critical and “provides rare uninterrupted and notably aesthetic views of Saltaire along its length.” This remains the case. Historic England considers that the HIA has undervalued the contribution which this site makes to the setting of the WHS and, as a result, the harm which its loss and subsequent development might have upon its significance. In
addition, the introduction of a green landscape buffer along the
sites northern boundary, proposed as a mitigation measure for
development on the site, would only serve to further interrupt views
of the World Heritage Site and thereby the ability to appreciate its
planned layout.
Therefore, the loss of this area is considered likely to cause considerable harm to one of the key elements which contributes to the significance of Saltaire. As such, its Allocation and eventual development would run contrary to the advice set out in the NPPF .

Object

Representation ID: 29382

Received: 29/03/2021

Respondent: Historic England

See attachment for full representation
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).

Support

Representation ID: 29383

Received: 29/03/2021

Respondent: Historic England

The site lies adjacent to the Prince of Wales Park, a Grade II Registered Park and Garden. Whilst the site is located outside of the boundary of the Saltaire World Heritage Site (WHS) buffer zone it is within an area where tall buildings could affect its setting. The
development of this area could harm elements which contribute to the significance of these designated heritage assets. The Heritage Impact Assessment for this site, which includes land to the west of the allocated site up to the boundary with the Registered Park and Garden, considered that development of the west end of this site would result in further loss of the original contextual surroundings from which the park was originally forged.
The HIA concluded that development towards the west end of this site cannot be mitigated and the resulting effect of development would be less than substantial negative harm (of an unacceptable level). Development to east of the park boundary, as a continuation of the modern development would have a less than substantial (of acceptable level) to negligible negative impact.
Historic England would concur with this analysis and with the assessment of the degree of harm that the development of this site would be likely to cause. Historic England would also endorse the removal of the area of land identified as highly sensitive in the HIA from the allocated site, and the mitigation measures which have
been put forward in the Heritage Impact Assessment. We consider that these are likely to be effective in reducing the harm to the level indicated.

Object

Representation ID: 29385

Received: 29/03/2021

Respondent: Historic England

See attachment for full representation
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).

Support

Representation ID: 29387

Received: 29/03/2021

Respondent: Historic England

The site is located adjacent to the Leeds Liverpool Canal
Conservation Area. The development of this area could harm elements which contribute to the significance of this designated heritage asset. Whilst we welcome the inclusion of a reference to the proximity of this designated heritage asset as a Constraint in the sites pro forma, we consider that the first bullet point under the Development
Considerations for this site should be amended to be worded more positively. , replace the first bullet point
under the Development Considerations for this site with the following:
‘Development should conserve and, where possible, enhance those elements which contribute to the significance of the Leeds Liverpool Canal Conservation Area.’

Object

Representation ID: 29388

Received: 29/03/2021

Respondent: Historic England

See attachment for full representation
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).

Support

Representation ID: 29389

Received: 29/03/2021

Respondent: Historic England

The site is close to the Grade II Prince of Wales Registered Park and Garden. Whilst the site is located outside of the boundary of the Saltaire World Heritage Site (WHS) buffer zone it is within an area where tall buildings could affect its setting. The development of this
area could harm elements which contribute to the significance of these designated heritage assets. The Heritage Impact Assessment for this site, which also includes the small field to the west of the allocated site, considered that development of this site would encroach into the open landscape setting of the park, reducing its visual value and rendering the unaltered setting increasingly tenuous. The views from within the park across the grassland pasture contribute positively to its varied character at present. The HIA concluded that development of the western part of the site could not be acceptably mitigated without appearing congruous and would therefore cause less than substantial negative harm (of an unacceptable level). Development to the eastern part of the site, subject to carefully considered mitigation could achieve a less than substantial (of acceptable level) negative impact.
Historic England would concur with this analysis and with the assessment of the degree of harm that the development of this site would be likely to cause. Historic England would also endorse the removal of the area of land identified as being of medium sensitivity in the HIA from the allocated site, and the mitigation measures
which have been put forward in the Heritage Impact Assessment. We consider that these are likely to be effective in reducing the harm to the level indicated.

Object

Representation ID: 29390

Received: 29/03/2021

Respondent: Historic England

The site is within an area identified by the Saltaire World Heritage Site (WHS) Management Plan 2014 as important to its setting. The site is also located in an area where tall buildings could affect the setting of the WHS. Stock-A-Close Farmhouse & Barn, both Grade II Listed Building, are located 230 metres to the west of the site. The development of this area could harm elements which contribute to the significance of these designated heritage assets.
See attachment for full representation
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).

Object

Representation ID: 29391

Received: 29/03/2021

Respondent: Historic England

See attachment for full representation
There are three Scheduled Monuments consisting of prehistoric cup, ring and groove marked rock carvings to the north west of the site, with the closest located around 85 metres from the site. Rombalds Moor is particularly rich in remains of prehistoric activity, with one of the densest concentrations of prehistoric rock carvings
in upland Britain.
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).