Comment

Representation ID: 19897

Received: 01/04/2021

Respondent: Natural England

The site lies in proximity to the South Pennine Moors (Phase 2) SPA and has potential to lead to the loss of functionally linked land for SPA birds.

We welcome the approach taken in the draft plan, SPD and assessments to loss of functionally linked land.

The council has a copy of a model to identify the suitability of sites for SPA golden plover and recommend that allocations are screened against this dataset taking the following approach:

• Maximum Training Sensitivity plus Specificity (MTSS) layer: full survey for Golden Plover likely to be required. The WY Ecology Service SPA Bird Survey Methodology should be followed.

• Minimum Training Presence (MTP) layer or 10 Percentile Training Presence (10PTP) layer: scoping survey to determine if a full Golden Plover full survey required. A desk based survey may be sufficient for sites within the MTP whereas a walkover survey may be required for sites within the 10PTP;

• Not within an area of predicted presence: No survey required for Golden Plover.

Where loss of functionally linked land cannot be ruled out at this stage we recommend that allocation requirement text in the plan sets out survey and mitigation requirements clearly.