Purpose of this SPD

1.3 "In the absence of certainty, the plan should not proceed", yet at
1.4 you move immediatley to mitigation.
In 1.5 you identify additional recreaction pressure, but fail to mention the other Urban effects on the SPA/SAC such as Dumping, wild fires, pollution through traffic increases, noise levels, volumes of particulates given off from vehicles, domestic chemical runoff, mountain biking, dog walking and fouling ,and , most dangerous of them all, Cat predation .
The deterioration and loss of supporting "Functional Habitats" is Key, especially after the devastaing fires in 2019 & 2020

It is wholly inaccurate relying on wrong assumptions and developer reports which should not be accepted due to a serious conflict of interest.
Burley in Wharfedale development will have a significant impact on wildlife and this is not being fully investigated by either the council or developers.

1.3 "In the absence of certainty, the plan should not proceed", yet at
1.4 you move immediately to mitigation.
In 1.5 you identify additional recreation pressure, but fail to mention the other Urban effects on the SPA/SAC such as Dumping, wild fires, pollution through traffic increases, noise levels, volumes of particulates given off from vehicles, domestic chemical runoff, mountain biking, dog walking and fouling ,and , most dangerous of them all, Cat predation .
The deterioration and loss of supporting "Functional Habitats" is Key, especially after the devastating fires in 2019 & 2020

Purpose of this SPD
1.3 "In the absence of certainty, the plan should not proceed", yet at
1.4 you move immediately to mitigation.
In 1.5 you identify additional recreation pressure, but fail to mention the other Urban effects on the SPA/SAC such as Dumping, wild fires, pollution through traffic increases, noise levels, volumes of particulates given off from vehicles, domestic chemical runoff, mountain biking, dog walking and fouling ,and , most dangerous of them all, Cat predation .
The deterioration and loss of supporting "Functional Habitats" is Key, especially after the devastating fires in 2019 & 2020

I consider that the the SPD document is wholly inaccurate for the reasons set out in my summary.

1.3 "In the absence of certainty, the plan should not proceed", yet at 1.4 you move immediately to mitigation.
In 1.5 you identify additional recreation pressure, but fail to mention the other urban effects on the SPA/SAC such as dumping, wild fires, pollution through traffic increases, noise levels, volumes of particulates given off from vehicles, domestic chemical runoff, mountain biking, dog walking and fouling and, most dangerous of them all, cat predation!
The deterioration and loss of supporting "Functional Habitats" is key, especially after the devastating fires in 2019 & 2020

1.2 states risks need to be addressed before planning permission is granted. Permission has been but this is yet to complete. This is a procedural breach.
1.3 In the absence of certainty, the plan should not proceed. You are very far from "certainty". In 1.4 you are already fully looking at mitigation as if this consultation and document are irrelevant and can be ignored. This is a procedural breach.
Why is 1.5 only mentioning recreational pressure. What about the increase in traffic pollution, noise, the serious effects of pets on wildlife and domestically sourced pollution.
What is described in this chapter is NOT the purpose of the SPD.

My comments on the South Pennine Moors SPD Document
There were a very large number of shenanigans with regards to developer CEG, and also their lawyers Freeth's, rewriting Bradford Council’s Policy SC8 back in May 2016 (note: produced concurrently with the public hearings into the Core Strategy at Saltaire in May 2016).

Therefore the current 2021 consultation is still referring to the documents which were produced back in in May 2016: especially Policy SC8 and thus the policy basis for this SPD. These both assume mitigation of the effects of more development is lawful.

However, Bradford Council has not incorporated into their proposals all of Natural England's comments: those which were made in both June 2016 and Feb 2019.
In particular, Bradford Council have NOT INCORPORATED into either policy SC8 nor this South Pennine Moor SPD document the legally-binding advice from Natural England: namely that Bradford Council have been formally advised that some development sites needed to be avoided: not mitigated. You have also been told that all developments should have a net gain in biodiversity

Furthermore in 2019 (see attached) Natural England advised Bradford Council that Habitats Regulation's policies have hardened up in the past three years. However Bradford has nothing to change SC8 to incorporate this change in the law. Therefore this latest SPD is simply out-of-date and bnbased on the wrong laws.

Therefore as Bradford Council policy SC8 has not been revised since May 2016, this current South Pennine Moors SPA/SAC Planning Framework Supplementary Planning Document (SPD) is not compliant with what Natural England have said is now legal under the Habitats Regulations

Accordingly Natural England believe that this South Pennine Moors SPA/SAC Supplementary Planning Document (SPD) is illegal under the Habitats Regulations!

See attachments of CEG’s representation to the Draft Bradford District Local Plan Preferred Options (Regulation 18) Consultation. This includes:
-Appendix 1 Assessment of the Housing Requirement proposed within Policy SP8
-Appendix 2 Commentary on Evidence Base Documents
-Appendix 3 The Secretary of State’s decision and Inspector’s Report regarding application
16/07870/MAO (reference APP/W4705/V/18/3208020)
-Appendix 4 Burley-in-Wharfedale Alternative Site Assessment (2016)
-Appendix 5 Burley-in-Wharfedale Updated Alternative Site Assessment (April 2019)
-Appendix 6 Scalebor Park Land Registry Extract
-Appendix 7 Response to the HRA, associated policies and the South Pennine Moors
SPA/SAC Planning Framework SPD (prepared by Baker Consultants