Bradford District Local Plan - Publication Draft (Regulation 19) (October 2026)
Appendix 17 South Pennine Moors SPA/SAC Mitigation Strategy contributions Comment
Context and current position
The Council’s South Pennine Moors SPA/SAC Planning Framework Supplementary Planning Document (SPD) was adopted in January 2022 and sets out the Strategic Mitigation Strategy for mitigating the recreational impacts of new residential development on this internationally important multi-designated habitat site, and includes a mechanism for developers to provide a financial contribution in order to help deliver the strategy and therefore ensure that developments meet the requirements of the Habitats Regulations.
The mitigation strategy provided in the SPD was prepared as part of the implementation of Policy SC8 of the adopted Bradford District Core Strategy DPD. As well as the mitigation strategy, the SPD also provides more detailed guidance for those developments which fall within Zone A (0-400m – urban edge effects, functionally linked land, and recreation impacts) and Zone B (0-2.5km - functionally linked land and recreation impacts).
As a consequence of the Government’s changes to the planning system, there is now no legislative method to update the SPD to reflect the revised policy in this Local Plan (Policy NE3).
Although the general guidance in the SPD in relation to Zones A and B is still relevant and applicable (and should still be taken into account for relevant applications which fall within those zones), the measures and costings in the strategic mitigation strategy, in relation to Zone C (recreational impacts), need to be revised to better reflect the proposed level of housing growth over the plan period, and therefore the level of recreational impacts which may occur as a result.
The general range and types of mitigation set out in the SPD are still considered to be relevant, but the scale and cost of the measures will need to be adjusted to reflect changes since the strategy was originally prepared, as well as considering whether new measures need to be introduced. The Council will therefore undertake a review of the mitigation strategy and associated measures and costings.
Charges for implementing the strategic mitigation strategy
Table 17.1 of this appendix sets out a new indicative per dwelling charge for new dwellings within Zone C. This figure has been calculated taking a proxy approach - by applying inflationary increases to the original costings to reach a new indicative overall cost of the current mitigation strategy measures. This has then been divided by the overall number of dwellings to be provided over the Local Plan period that fall within Zone C (this includes the estimated number of dwellings from allocations, regeneration areas in Keighley and Shipley, and a proportion of the windfall allowance).
This Appendix will be updated on the adoption of the plan and in subsequent plan reviews (i.e. every five years), or where a new mitigation strategy and relevant costings are prepared (this may include an annual review of costings/monitoring fees etc).
The revised per dwelling charge and full set of detailed revised mitigation measures and costings will be made available once they have been finalised following a review of the mitigation strategy measures and once the number of dwellings to be delivered in Zone C has been confirmed.
Table 17.1 – Indicative per dwelling charge for strategic mitigation of the South Pennine Moors SPA/SAC*
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Indicative revised costs of mitigation measures: |
£7,900,000 |
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Estimated total dwellings to be delivered within Zone C (7km recreational impacts zone): |
12,250 |
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Indicative charge per dwelling for implementing the mitigation strategy: |
£645 |
Administration and Monitoring Fees
The Council has set out the different methods in which the mitigation contribution can be secured including through an upfront fee, a unilateral undertaking, or Section 106 agreement. Details of these methods are provided on the Bradford Council website.
Where applicants choose to use the unilateral undertaking or Section 106 agreement methods, they are expected to also meet the Council’s administration and monitoring costs associated with any drafting, checking, overseeing, and approving of the Unilateral Undertaking/S106. This fee is in addition to the statutory planning application fee and the contribution itself and must be reasonable.
The Council has introduced a flat rate fee per application to meet these administration and monitoring costs. This fee is also published on the Bradford Council website. This fee will be subject to review annually.
