Object

Representation ID: 27595

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

ZONE A - The policy does not state whether the partial inclusion of the site in Zone A excludes development across the whole site or whether it is only that part of the site within the 400m zone that is excluded. The policy must be made clear that only areas within 400m of the Habitats site are affected and not the entirety of potential development sites that may straddle the 400m zone.
The Zone A exclusion is based on the recommendations within the HRA for the draft Local Plan. All of the cited evidence for excluding residential development from the zone within 400m of the SPA originates from studies of lowland habitats, particularly heathland. In the case of lowland heaths the scientific evidence is very poor and a causal relationship between residential development within 400m and birds numbers or habitat degradation has never been established. There is no evidence that residential development within 400m of moorland and other upland habitats has any detrimental impact upon either SPA birds or the habitats which are the interest features of the SAC. There is no empirical evidence provided in the HRA for the draft Local Plan to suggest the assertion that ‘urban edge effects’ impact on upland habitats. Studies specific to lowland cannot be simply transposed to upland habitats which have very different characteristics and are not accessed in the same way or subjected to the same pressures as lowland heaths. The relevance to the qualifying species of the SPA has not been established. The HRA cites the impact pathway of cat predation however there is no evidence that cats have any adverse effects on bird populations a view which is not supported by the RSPB (see link).
This policy zonation is entirely unjustified by any scientific evidence and should be removed from the policy.