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

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

Consultation Question 29

Representation ID: 29066

Received: 29/03/2021

Respondent: Historic England

Representation Summary:

We welcome the reference to decisions on whether the
managed release of sites is required being based on, amongst the other principals, the need to prioritise and not undermine proposals for urban regeneration.
The Bradford District has a strong, hugely characterful and distinctive historic environment which make a significant contribution to the areas identity and sense of place. There is significant potential within the District for the sensitive reuse and adaptation of both designated and nondesignated heritage assets, in particular buildings related to the textile industry, to create attractive and sustainable new homes, workplaces and cultural spaces.

Object

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

Consultation Question 30

Representation ID: 29069

Received: 29/03/2021

Respondent: Historic England

Representation Summary:

There are historic areas within Bradford where the densities being proposed would result in considerable harm to their character. Paragraph 4.15.6, add the following text after the second sentence: ‘Densities below those set out in Policy HO2 may be allowed where it can be demonstrated that it is necessary in order to better-reflect the character of that area or to safeguard the setting of a heritage asset.’

We welcome the stipulation within Criterion A of the need
for densities to take account of their surroundings and those areas where local character would warrant lower densities. This will ensure that the densities of new residential developments reflect the character of the area in which they are located. We also welcome the references under Criteria B and C to site specific considerations or local area characteristics justifying lower housing densities in some cases. However, as currently written, it could be interpreted that
similar considerations will not be applied within the City
Centre and Principal Towns. The City Centre and Principal Towns contain the highest concentration of heritage assets in the District which, in some cases will provide opportunities for delivering higher densities, in others may justify developments providing lower densities.To avoid confusion, and to ensure that heritage assets are appropriately conserved, a similar caveat to that provided in Criteria B and C is required under Criterion D relating to development in the City Centre and Principal Towns.

Object

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

Consultation Question 31

Representation ID: 29070

Received: 29/03/2021

Respondent: Historic England

Representation Summary:

Whilst, we support the intention under Criterion A that the
Council will seek to ensure that urban housing schemes in
urban areas are high quality appropriate to their context in
terms of urban grain, height and massing, roofscape,
materials and appearance.

Support

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

Consultation Question 36

Representation ID: 29071

Received: 29/03/2021

Respondent: Historic England

Representation Summary:

We support the requirement that proposals for sites for
gypsy and travellers should avoid significant adverse effects
upon the environment and incorporate appropriate design
and landscaping standards

Support

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

Consultation Question 41

Representation ID: 29072

Received: 29/03/2021

Respondent: Historic England

Representation Summary:

We support this policy which will protect and enhance the
contribution that trees and woodland make to the character of the District. In particular we welcome the inclusion of Criterion C which applies a presumption in favour of the retention of trees, woodland and hedgerow which contributes towards the character of a settlement or its setting, or the amenity of the built-up area, and an area's sense of place or local distinctiveness.

Support

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

Consultation Question 42

Representation ID: 29073

Received: 29/03/2021

Respondent: Historic England

Representation Summary:

We support 4.28.1 - 4.28.5 which sets out a good outline of the considerable wealth of heritage assets of the District, the contribution which they make towards the distinctive character of Bradford, to its economic well-being, and to the quality of life of its communities, together with some of the challenges these assets are likely to face in the future.
We support 4.28.7 - 4.28.9 which sets out a good summary of the significance of Saltaire. We particularly welcome the requirement that development proposals should have regard to the World Heritage Site Management Plan, the World Heritage Site Environmental Capacity study and the Saltaire Conservation Area Appraisal.

Object

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

Consultation Question 42

Representation ID: 29074

Received: 29/03/2021

Respondent: Historic England

Representation Summary:

Historic England’s Local Authority Profile for Bradford
District (2020) indicates a different number of
designated heritage assets to those listed under paragraph 4.28.10. Amend the list of designated heritage assets as follows:
 Saltaire World Heritage Site
 2,293 listed buildings, including 23 Grade I
and 69 Grade II*
 59 Conservation Areas
 15 Historic Parks and Gardens
 195 Scheduled Monuments
 Historic Battlefield Site at Adwalton Moor, Tong

The meaning of the final sentence to paragraph 4.28.16 is not clear at all. - Amend accordingly.

Policy EN4, C, amend to: ‘Require that all proposals for development conserve and where appropriate, enhance the heritage significance and setting of Bradford's heritage assets.’
E, amend to: ‘E. The alteration, extension or substantial demolition of a listed building will only be permitted if it can be demonstrated that the proposal:
1. Would not have any adverse effect upon the special architectural or historic interest of the building or its setting;
2. Is appropriate in terms of design, scale, detailing and materials; and
3. Would minimise the loss of historic fabric of the building.
or
4. If there is harm to the special interest of the building, that this is outweighed by the public benefits of the proposal.’

Support

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

Consultation Question 43

Representation ID: 29075

Received: 29/03/2021

Respondent: Historic England

Representation Summary:

We support this Policy particularly Criterion B.2. It is
especially important given the character of the District that
the landscape setting of its settlements and heritage assets
is fully taken into account in determining the
appropriateness of development proposals.

Support

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

Consultation Question 45

Representation ID: 29076

Received: 29/03/2021

Respondent: Historic England

Representation Summary:

We support this Policy. Flooding and its prevention as well as the management of water resources can have impacts on the historic environment and the significance of heritage assets, including the contribution made by their setting. It is therefore important that in the management and reduction of flood risk, and in the management of the water environment, it is done in a manner that ensures the conservation and enhancement of the historic environment, this includes sustaining and enhancing local character and distinctiveness of historic townscapes and landscapes.

Object

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

Consultation Questions 48

Representation ID: 29077

Received: 29/03/2021

Respondent: Historic England

Representation Summary:

Whilst we fully support the requirement that applicants fully appraise the environmental impacts of major new energy infrastructure proposals, it needs to be made clear in the supporting text that this also includes consideration of potential impacts on the historic environment. Paragraph 4.34.31, amend third sentence to read:
‘Policy EN10 therefore requires that applicants fully appraise the environmental impacts (including those on the historic environment) and identify any mitigation
measures to be incorporated into the proposal.’
We welcome the requirement for energy infrastructure
proposals to be supported by a full appraisal of the
potential environmental impacts and identify appropriate
mitigation measures. However, we consider it necessary to highlight in the supporting text to the Policy EN10 that this appraisal should also include consideration of the historic environment.
Paragraph 4.34.31, amend the third sentence to read:
‘Policy EN10 therefore requires that applicants fully appraise the environmental impacts (including those on the historic environment) and identify any mitigation
measures to be incorporated into the proposal.’

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