Comment

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

Representation ID: 24895

Received: 24/03/2021

Respondent: CEG Land Promotions Ltd

Agent: Lichfields

Representation Summary:

Section C2 of the policy relates to such evidence that may be reasonably required to demonstrate whether land proposed for development affects foraging habitat for qualifying species of the SPA. The policy should therefore allow for evidence to demonstrate that SPA birds are not present on the land in question, rather than simply protecting a particular habitat type, in order to ensure that the policy correctly reflects the Conservation of Habitats and Species Regulations 2017 (as amended). The text of policy C2 should be updated to read:

‘2. In Zone B it will be considered, based on such evidence as may be reasonably required, whether land proposed for development affects foraging habitat <DEL: for qualifying species of the> <INSERT: used by SPA birds>. Further guidance can be found in the South Pennine Moors SPD.’

In the interests of clarity it is requested that Section D of the policy, which cross-refers to the South Pennine Moors SPD, makes reference to the specific part of the policy to which it applies (on the basis that SP11 C 3 b relates to a calculated financial contribution, rather than bespoke mitigation provided pursuant to SP11 C 3 a) as follows:
D. The South Pennine Moors SPD sets out a strategic mitigation scheme and a mechanism for the calculation of the financial contributions <INSERT: under policy SP11, C, 3b> to mitigate recreational impacts on the SPA and SAC as a consequence of housing growth and subsequent population increases.

These amendments will also ensure that reference to the provision of new recreational greenspace, or improved open space, as having the potential to mitigate recreational pressure on the SPA/SAC as referred to in Policy CO1 is consistent with the provision of Policy SP11 and the accompanying SPD