Object
Draft South Pennine Moors SPA/SAC Planning Framework Supplementary Planning Document
Representation ID: 5295
Received: 24/03/2021
Respondent: Mr Robin McDonell
Again, in para 2 , you state that " depending on these findings, ensure any impacts are addressed through mitigation..." and yet it is an accepted fact that mitigation cannot eliminate all the effects of development on the protected area when it is so close to the limit.
The statement at Chap.1. para 1.3 is preeminent at this point: " A competent Authority should only give effect to a plan.........after having ascertained that it will not adversely affect the integrity of the European Site. This means that in the absence of certainty, the plan/project should not normally proceed (subject to the further exceptional tests set out in legislation).
In 2.11" latest standard method for assessing local housing need "This is not correct. The ONS and the National Statistics office are currently reviewing the way in which their work has been misinterpreted by several councils, in view of the migration away from certain cities within the last 4 years. This has not been accurately reflected in housing Predictions. The Aireborough case highlighted that the use of Greenbelt land was unnecessary.
You state that "With this scale of growth, their is likely to be a number of consequential risks to the moorland and other biodiversity features". All of Burley -in - Wharfedale is situated within 2.5km of the SPA/SAC, and therefore in the most delicate of zones of protection within the policy SC8.
To leap to mitigation strategy that cannot give certainty of protection, I refer to 1.3: "This means that in the absence of certainty, the project/plan should not normally proceed".