Consultation Question 12

Object

Representation ID: 293

Received: 19/02/2021

Respondent: Ms Mel Frances

This needs to be stronger - building on and destroying existing habitat can not be offset by trying to recreate it elsewhere.

Object

Representation ID: 1913

Received: 17/03/2021

Respondent: Burley Parish Council

3.11.6 The HRA does not conclusively state that it is South Pennine Moors, rather than the North pennine Moors, that will suffer from the impact of development at Burley-in-Wharfedale, it merely states a ‘likelyhood’. Neither does the HRA exclude the possibility of functional links to the North Pennine Moors AONB. There is no consideration of a functional link between Burley-in-Wharfedale and the AONB, despite its proximity to the settlement. This needs consideration alongside the impact on the SPA/SAC, particularly given there is a river crossing regularly used by residents and visitors to reach the AONB for recreation.

Menston is roughly equidistant from the AONB and SPA/SAC, so similar considerations apply.

Support

Representation ID: 2284

Received: 19/03/2021

Respondent: Clive Brook Planning

POLICY SP11:- PROTECTING THE SOUTH PENNINE MOORS SPA/SAC AND THEIR ZONE OF INFLUENCE:- On behalf of my clients we support the policy content but would wish to see positive and proactive working with landowners and developers particularly where they are able to facilitate substantial improvements to supporting habitat provision and other recreation opportunities outside the SPA/SAC .
See also our more specific comments on the Supplementary Planning Document for the South Pennine Moors SPA/SAC

Support

Representation ID: 2520

Received: 20/03/2021

Respondent: Mr Peter Down

I support the proposed Policy SP11. No further comment.

Object

Representation ID: 2756

Received: 21/03/2021

Respondent: Mrs Helen Owen

Areas should be left as they are. Requirements for developers will be ignored as usual. Derisory fines do not discourage these practices.

Support

Representation ID: 3274

Received: 22/03/2021

Respondent: Wilsden Parish Council

We note the reference in Policy SP11 to developer contributions in the Zone of Influence C of the S Penning Moors SP/SAC to develop additional natural greenspace and appropriate facilities to deflect pressure from moorland habitats. These contributions would be to address the long-term maintenance and management of that greenspace for areas in Zone C of the S Pennine Moors SPA zone of influence. As the majority of Zone C is parished it would appropriate that this is delivered through town and parish councils.

Object

Representation ID: 3679

Received: 23/03/2021

Respondent: Mr Philip Sutcliffe

he green belt was set up to stop urban expansion. In the case of
Bradford, to stop it becoming part of Leeds. Bradford planning office
being completely undemocratic wishes to pour cement and tarmac all
over the green belt in Tong. The reason I say undemocratic is as
follows. ~There has not been one survey, or opinion poll taken in
Bradford, which agrees with Bradford councils views on building on
green belt. In fact approx 90 % of population of Bradford totally
disagree with Bradford councils housing and road plans. However, the council which claims
represents the people is acting like a fascist state.

Your new road and housing plans directly effect my Grade II house and
land. However, you have not had the decency to contact me over the
last 10 years. I doubt you care less about me than the environment and
the creatures that need it.

Support

Representation ID: 3777

Received: 23/03/2021

Respondent: Mr Andrew Lund

I support this Policy, and note that full observance will force the removal of site IL1/H from the proposed development of 130 housing units

Support

Representation ID: 3816

Received: 23/03/2021

Respondent: Jenny Woodward

I support much of the above. One comment though on Point C3. Replacing GS is not always possible - there needs to be high standards set i.e. you can't remove ancient habitat and replace it with a new playpark, for example. Could an assessment of the biodiversity lost be made and the new provision has to match this. I am not sure how that works technically but I am sure there are experts who can give it a go! My reason for this comment is that there have been examples of mature trees felled and replaced by saplings - that is no way comparable for nature.

Object

Representation ID: 3965

Received: 23/03/2021

Respondent: Mrs Susan Burn

I would like to see much stronger protections in place. I am deeply worried that property developers would abuse the system. I learned through the consultation process of property developers destroying natural habitats.
What enforcement procedures would there be? There needs to be an effective system of enforcement.

Support

Representation ID: 4677

Received: 23/03/2021

Respondent: Menston Parish Council

The zones of influence must be protected according to the policy.

Object

Representation ID: 5358

Received: 24/03/2021

Respondent: Mr Bernard Poulter

Current Core Strategy Policy SC8 (now to be superseded by SP11) is a watered down version of the original, proposed by the Councils own HRA producers, and considered to provide reasonable protection for the conservation objectives of the SPA/SAC. This was then effectively re-written by the agents of the Property Developers , CEG, during the Examination in public stage of the Core Strategy. The idea that developers could EVER decide what was in the best interest of the wildlife living and using a profitable potential development site is , at the very least, naïve. It assumes a level of altruism that simply does not exist. It MUST be that the Council decide on independent HRA's carried out on ALL land within, as a very minimum, the 2.5 km Zone. To combine the 2.5 km zone & the 7KM ignores the works included in the bibliography references of your own SPD

Support

Representation ID: 5377

Received: 24/03/2021

Respondent: Mr Peter Jenkins

Good aspirations but need evidence of planning and financial commitment

Support

Representation ID: 5466

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We fully support and welcome this policy.

Support

Representation ID: 5988

Received: 24/03/2021

Respondent: SHMS

Support [for policy as set out in the SPA] but policy should be further enhanced in hindsight should have been much stronger. Damage done by fires, vehicles and ramblers during Covid from urban area unfamiliar with need to protect habitats and ecology of the area.
Regulations - Protection of habits also links into climate change and pollution, activities experienced by farmers during the pandemic highlight more work is needed both with the Conservation of Habitats and species Amendment (EU exit) Regulations 2019 which should also link in with the Environment Bill and flood prevention measures (natural wetlands). A pro active approach rather than re-active when ecologically important species have been lost Which is particular important to rural areas in the Bradford District.
Zone approach - Support but question whether this is working in practice, any mitigation appears to come along after development. Also have noticed issues with some ecology reports not being comprehensive enough, being picked up by council officers. Would question the practicality of not providing car parking identified in table 1 below. In addition several uncontrolled parking areas (rough ground) are common throughout the district This causes problems for enforcement and waste issues.
CIL is not delivering the funding forecasted. However consider any development in the 0-7km zone should be a last resort after development in towns and city on pdl sites. Concern that the headroom(profit margin) identified in the CIL viability appraisal and consultation, will allow for an additional S106 cost and developers could seek to overide this in a site specific viability appraisal. Any needed funding for mitigation should be provided up front or in early stages of development to ensure mitigation measures are delivered in a timely manner (e.g. before specific site occupations) Also suggests developers are encouraged to contribute by incorporation of defensive hedgerows in preference to close boarding fencing, protect and supplement existing trees (1 fruit per garden minimum)

Comment

Representation ID: 9804

Received: 12/03/2021

Respondent: Bradford District Ward Councillor (Labour)

SP 11 As noted above I was disappointed in the lack of consultation with Pennine Prospects – I have passed on the information to the Chief Executive. It should be mentioned that a substantial part of Bradford countryside is within the South Pennines Park. Its contribution to mitigating the effects of climate change are substantial and if treated with respect could be part of a developing tourism offer for our area.

Comment

Representation ID: 10913

Received: 18/03/2021

Respondent: Mr Steve Dresser

it’s very difficult to comment when the authority makes reference to the policy changing, sounding as though even it doesn’t quite understand what to do here. Clearly there are challenges around habitats, scheduled monuments and archaeological sites and it seems absurd that this land is considered suitable for homes, given the above

Comment

Representation ID: 10957

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We do not take any particular issue with this policy and note that it largely reflects the position in the adopted Core Strategy, which promoted 1,000 new homes to be delivered in and around Queensbury and this was deemed acceptable in 2017.

Queensbury and its hinterlands fall within Zone C - land within 7km of the SPA/SAC boundaries where development of homes needs to consider the potential for new households to place recreational pressures on the SPA/SCA. We support the Policy wording that allows for on or off site mitigation to be provided & flexibility re the best type of mitigation to be offered.

Queensbury is surrounded by a network of public rights of way that provide immediate access to the open countryside. The development of the Queensbury Golf Course site will provide a large area of open space that would provide suitable mitigation on site and create links to existing PRoW networks in the vicinity see indicative site appraisal masterplan.

Object

Representation ID: 11406

Received: 17/03/2021

Respondent: Mr Robert Felstead

HRA does not conclusively state that it is South Pennine Moors, rather than the North Pennine Moors, that will suffer from the impact of development at Burley In Wharfedale. It merely states a ‘likelihood.’ nor does it exclude the possibility of functional links to the North Pennine Moors (AONB), but it does conclude that “the requirements of policy SP11 continue to be relevant.”

No mention/consideration of a functional link between Burley in Wharfedale and the AONB, despite its proximity. Needs to be included and incorporated into the Plan along with the impact on the SPA/SAC. There are many river crossings along the River Wharfe which link to the AONB (SSSI). This is particularly true at Burley, where a river crossing is regularly used by visitors and residents to reach the AONB for recreational purposes.

Menston is roughly equidistant from the AONB and SPA/SAC, so similar considerations will apply.

Comment

Representation ID: 11545

Received: 17/03/2021

Respondent: Yorkshire Wildlife Trust

We note that these distances have not been amended since our previous response to the 2019 partial review consultation. We previously stated: Due to the sensitivity of the habitats and species present, including to disturbance (through visitor pressure and domestic animals), pollution and hydrological impacts etc. we consider the 400m of Zone A to be extremely minimal and would encourage further consideration of widening of this buffer to at least 1km.

We would also encourage the consideration of the implementation of strategy and policy to mitigate the recreational and air quality impacts on the SAC/SPA site.

Support

Representation ID: 17290

Received: 22/03/2021

Respondent: The Great Northern Railway Trail Development Group

The Trail largely lies within the Zone C. Part of the policy states:
‘The South Pennine Moors SPD sets out a strategic mitigation scheme and a mechanism for the calculation of the financial contributions to mitigate recreational impacts on the SPA and SAC as a consequence of housing growth and subsequent population increases. The mitigation may be:
that the developer elects to offer, either on-site and / or deliverable outside the boundary of the development site, such as the provision of accessible natural greenspace and/or other appropriate measures; or in the form of a financial contribution from the developer’…
We ask that Bradford Council identifies the Great Northern Railway Trail as an opportunity to increase the amount of greenspace as a mitigation measure for schemes that come under this policy. This project needs to be registered as part of a mitigation management scheme. So far, it has been overlooked.

Support

Representation ID: 19839

Received: 01/04/2021

Respondent: Natural England

We welcome the inclusion of item D of Policy SP11 in that it emphasises the strategic mitigation scheme and mechanism for the calculation of the financial contributions to mitigate recreational impacts on the SPA and SAC as a consequence of housing growth and subsequent population increases which is set out within the South Pennine Moors SPD.

Please see our comments below in relation to Policy CO1: Open Spaces, Sport and Recreation for further discussion of the consideration of mitigation of recreational impacts arising from new development.

Comment

Representation ID: 21615

Received: 23/03/2021

Respondent: Bradford District Ward Councillor (Conservative)

The zones of influence must be protected according to the policy.

Object

Representation ID: 21805

Received: 23/03/2021

Respondent: Duncan Watson

3.11.6 The HRA does not conclusively state that it is South Pennine Moors, rather than the North pennine Moors, that will suffer from the impact of development at Burley-in-Wharfedale, it merely states a ‘likelyhood’. Neither does the HRA exclude the possibility of functional links to the North Pennine Moors AONB. There is no consideration of a functional link between Burley-in-Wharfedale and the AONB, despite its proximity to the settlement. This needs consideration alongside the impact on the SPA/SAC, particularly given there is a river crossing regularly used by residents and visitors to reach the AONB for recreation.

Menston is roughly equidistant from the AONB and SPA/SAC, so similar considerations apply.

Object

Representation ID: 21888

Received: 23/03/2021

Respondent: Catherine Starling

3.11.6 The HRA does not conclusively state that it is South Pennine Moors, rather than the North pennine Moors, that will suffer from the impact of development at Burley-in-Wharfedale, it merely states a ‘likelyhood’. Neither does the HRA exclude the possibility of functional links to the North Pennine Moors AONB. There is no consideration of a functional link between Burley-in-Wharfedale and the AONB, despite its proximity to the settlement. This needs consideration alongside the impact on the SPA/SAC, particularly given there is a river crossing regularly used by residents and visitors to reach the AONB for recreation.

Menston is roughly equidistant from the AONB and SPA/SAC, so similar considerations apply.

Object

Representation ID: 21917

Received: 23/03/2021

Respondent: Dr Samantha Cook

3.11.6 The HRA does not conclusively state that it is South Pennine Moors, rather than the North pennine Moors, that will suffer from the impact of development at Burley-in-Wharfedale, it merely states a ‘likelyhood’. Neither does the HRA exclude the possibility of functional links to the North Pennine Moors AONB. There is no consideration of a functional link between Burley-in-Wharfedale and the AONB, despite its proximity to the settlement. This needs consideration alongside the impact on the SPA/SAC, particularly given there is a river crossing regularly used by residents and visitors to reach the AONB for recreation.

Menston is roughly equidistant from the AONB and SPA/SAC, so similar considerations apply.

Object

Representation ID: 21946

Received: 23/03/2021

Respondent: Birgit Almond

3.11.6 The HRA does not conclusively state that it is South Pennine Moors, rather than the North pennine Moors, that will suffer from the impact of development at Burley-in-Wharfedale, it merely states a ‘likelyhood’. Neither does the HRA exclude the possibility of functional links to the North Pennine Moors AONB. There is no consideration of a functional link between Burley-in-Wharfedale and the AONB, despite its proximity to the settlement. This needs consideration alongside the impact on the SPA/SAC, particularly given there is a river crossing regularly used by residents and visitors to reach the AONB for recreation.

Menston is roughly equidistant from the AONB and SPA/SAC, so similar considerations apply.

Object

Representation ID: 21975

Received: 23/03/2021

Respondent: Mrs Corrie Hardaker

3.11.6 The HRA does not conclusively state that it is South Pennine Moors, rather than the North pennine Moors, that will suffer from the impact of development at Burley-in-Wharfedale, it merely states a ‘likelyhood’. Neither does the HRA exclude the possibility of functional links to the North Pennine Moors AONB. There is no consideration of a functional link between Burley-in-Wharfedale and the AONB, despite its proximity to the settlement. This needs consideration alongside the impact on the SPA/SAC, particularly given there is a river crossing regularly used by residents and visitors to reach the AONB for recreation.

Menston is roughly equidistant from the AONB and SPA/SAC, so similar considerations apply.

Object

Representation ID: 22004

Received: 23/03/2021

Respondent: Carly Mitchell

3.11.6 The HRA does not conclusively state that it is South Pennine Moors, rather than the North pennine Moors, that will suffer from the impact of development at Burley-in-Wharfedale, it merely states a ‘likelyhood’. Neither does the HRA exclude the possibility of functional links to the North Pennine Moors AONB. There is no consideration of a functional link between Burley-in-Wharfedale and the AONB, despite its proximity to the settlement. This needs consideration alongside the impact on the SPA/SAC, particularly given there is a river crossing regularly used by residents and visitors to reach the AONB for recreation.

Menston is roughly equidistant from the AONB and SPA/SAC, so similar considerations apply.

Object

Representation ID: 22033

Received: 23/03/2021

Respondent: Helen Ross

3.11.6 The HRA does not conclusively state that it is South Pennine Moors, rather than the North pennine Moors, that will suffer from the impact of development at Burley-in-Wharfedale, it merely states a ‘likelyhood’. Neither does the HRA exclude the possibility of functional links to the North Pennine Moors AONB. There is no consideration of a functional link between Burley-in-Wharfedale and the AONB, despite its proximity to the settlement. This needs consideration alongside the impact on the SPA/SAC, particularly given there is a river crossing regularly used by residents and visitors to reach the AONB for recreation.

Menston is roughly equidistant from the AONB and SPA/SAC, so similar considerations apply.