Object
Draft South Pennine Moors SPA/SAC Planning Framework Supplementary Planning Document
Representation ID: 5297
Received: 24/03/2021
Respondent: Mr Robin McDonell
There should also be a presumption against development within the 2.5 km zone unless it can clearly demonstrate through an independent HRA that there are no species affected.
If the Developer carries this out, they use their own retained ( and sometimes wholly owned) subsidiaries to carry out this work, primarily as a tick box, rather than as a true reflection of the species actually using a proposed site.
This results in Functional land being wrongly categorised as suitable with mitigation.
There should also be a presumption against development within the 2.5 km zone unless it can clearly demonstrate through an independent HRA that there are no species affected.
If the Developer carries this out, they use their own retained ( and sometimes wholly owned) subsidiaries to carry out this work, primarily as a tick box, rather than as a true reflection of the species actually using a proposed site.
This results in Functional land being wrongly categorised as suitable with mitigation.