Object
Draft South Pennine Moors SPA/SAC Planning Framework Supplementary Planning Document
Representation ID: 5743
Received: 24/03/2021
Respondent: Mr Nick Jones
In 2.5 You identify that an HRA should assess any "possible harm", yet the work continues to immediately support mitigation, rather than avoidance.
Under 2.8 you identify that the NPPF refers to "providing net gains for biodiversity", yet you do not give any details throughout the SPD of just how that should be measured? Are you planning on using the DEFRA Biodiversity Metric 2.0 in your assessment? Will the UK Biodiversity Indicators, produced by the JNCC be used, and how does the current work on indicator C1 'Protected Areas' tie in with your future plan?
In 2.5 You identify that an HRA should assess any "possible harm", yet the work continues to immediately support mitigation, rather than avoidance.
Under 2.8 you identify that the NPPF refers to "providing net gains for biodiversity", yet you do not give any details throughout the SPD of just how that should be measured? Are you planning on using the DEFRA Biodiversity Metric 2.0 in your assessment? Will the UK Biodiversity Indicators, produced by the JNCC be used, and how does the current work on indicator C1 'Protected Areas' tie in with your future plan?