Object

Representation ID: 27679

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Impacts from urban edge effects have been overstated in the HRA and no evidence is presented to demonstrate how these effects may be manifest on a large moorland site such as the South Pennine Moors. Our specific comments on this aspect of the HRA of the
draft Local Plan are set out below:
• Paragraph 4.3: It is incorrect to state that all allocated sites within 400m can cause fragmentation effects. It is the SPA/SAC which is protected not the surrounding land. Given that no development is proposed within the SPA/SAC it is impossible to see how fragmentation could be a potential impact pathway.
• Paragraph 4.12-13: The evidence provided for ‘urban edge effects’ is entirely related to lowland heathland sites. No evidence relevant to large moorland and other upland habitats is presented.
• Paragraph 4.14: The evidence regarding the impacts of domestic cats is entirely unproven, there is no evidence whatsoever to show that domestic cats affect birds at the population level.

The draft Local Plan HRA impact assessment of the loss of functionally linked land is therefore fundamentally flawed as it is not the presence of a certain type of habitat that is important, but the presence of SPA birds. This basic principle (tested in the case of Sun Lane) must be acknowledged in future iterations of the HRA. Given the various surveys that have now been carried out it is questionable whether the policy protecting land outside the SPA is necessary at all as there is no evidence of even sporadic (never mind regular) movement of birds from the SPA to surrounding land.