Consultation Question 12
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 27415
Received: 24/03/2021
Respondent: Mr Richard Bardsley
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 27444
Received: 24/03/2021
Respondent: Paul Warren
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 27566
Received: 24/03/2021
Respondent: Danny Thompson
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 27595
Received: 24/03/2021
Respondent: Persimmon Homes (West Yorkshire)
Agent: Lichfields
ZONE A - The policy does not state whether the partial inclusion of the site in Zone A excludes development across the whole site or whether it is only that part of the site within the 400m zone that is excluded. The policy must be made clear that only areas within 400m of the Habitats site are affected and not the entirety of potential development sites that may straddle the 400m zone.
The Zone A exclusion is based on the recommendations within the HRA for the draft Local Plan. All of the cited evidence for excluding residential development from the zone within 400m of the SPA originates from studies of lowland habitats, particularly heathland. In the case of lowland heaths the scientific evidence is very poor and a causal relationship between residential development within 400m and birds numbers or habitat degradation has never been established. There is no evidence that residential development within 400m of moorland and other upland habitats has any detrimental impact upon either SPA birds or the habitats which are the interest features of the SAC. There is no empirical evidence provided in the HRA for the draft Local Plan to suggest the assertion that ‘urban edge effects’ impact on upland habitats. Studies specific to lowland cannot be simply transposed to upland habitats which have very different characteristics and are not accessed in the same way or subjected to the same pressures as lowland heaths. The relevance to the qualifying species of the SPA has not been established. The HRA cites the impact pathway of cat predation however there is no evidence that cats have any adverse effects on bird populations a view which is not supported by the RSPB (see link).
This policy zonation is entirely unjustified by any scientific evidence and should be removed from the policy.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 27641
Received: 24/03/2021
Respondent: Persimmon Homes (West Yorkshire)
Agent: Lichfields
ZONE B relates to such evidence that may be reasonably required, as to whether land proposed for development affects foraging habitat for qualifying species of the SPA. The guidance in the HRA for the draft Local Plan (see below) and the South Pennine Moors SPA/SAC SPD does not adequately describe what evidence will be required (for example, survey effort and methods) to establish whether land is or is not functionally linked to the South Pennine Moors SPA/SAC. The HRA of the draft Local Plan and SPD should be based on field survey evidence of the presence of SPA birds rather than just desk-based study and the modelling of habitat types. It is essential to first establish whether or not a potential development site supports SPA birds (i.e. birds which are actually associated with CBMDC Draft Local Plan Review Persimmon Homes West Yorkshire 4 the SPA and are regularly moving between the SPA and the development site).
If this policy is to remain then it must be reworded to reflect that fact that it is only land that is used by SPA birds which may be regarded as functionally linked land not simply habitat that may be used theoretically.
“In Zone B it will be considered, based on such evidence as may be reasonably required, whether land proposed for development affects foraging habitat DEL<for> INS<used by> DEL<the qualifying species of the> SPA INS<birds>. Further guidance can be found in the South Pennine Moors SPD.”
Comment
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 27644
Received: 24/03/2021
Respondent: Persimmon Homes (West Yorkshire)
Agent: Lichfields
ZONE C - Section D referenced the ‘roof tax’ approach to mitigation of recreational effects that the Council is proposing to introduce through the SPD as such the policy should be clearly linked to policy SP11, C 3 b which it addresses. We suggest the following update to the wording of the text.
The South Pennine Moors SPD sets out a strategic mitigation scheme and a mechanism for the calculation of the financial contributions "< under policy SP11, C, 3b>" to mitigate recreational impacts on the SPA and SAC as a consequence of housing growth and subsequent population increases.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 27691
Received: 24/03/2021
Respondent: Peter Cartwright
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 27725
Received: 24/03/2021
Respondent: Mrs Ann Todd
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 27798
Received: 24/03/2021
Respondent: Richard Briggs
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 27829
Received: 24/03/2021
Respondent: Claire Shouler
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 27893
Received: 23/03/2021
Respondent: Samantha Armitage
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 28192
Received: 24/03/2021
Respondent: Sarah Lucas
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 28282
Received: 24/03/2021
Respondent: Stephen Mould
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 28387
Received: 23/03/2021
Respondent: Joint Committee (GNRTDG, Keighley Town Council & Parish Councils of Cullingworth, Denholme, Haworth, Cross Roads & Stanbury, and Wilsden
Great Northern Railway Trail is currently protected in the UDP & RUDP and planning permission has already been approved for the most part.
Thank the Council for their proposed continued protection of the route between Keighley and Queensbury and refer to policies SP7, SP10, SP11, SP14, SP15, SP16 and TR1, TR2, TR3 & TR4 in their support
Policy SP11: Protecting the South Pennine Moors SPA /SAC and their zone of influence
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 29215
Received: 23/03/2021
Respondent: Rachel Wood
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 29568
Received: 23/03/2021
Respondent: Harvey Bosomworth
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 29608
Received: 17/03/2021
Respondent: Mr Mark Summerson
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 30007
Received: 23/03/2021
Respondent: Daniel Spencer
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 30088
Received: 23/03/2021
Respondent: Mrs Savia Lorain Hughes
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
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 30171
Received: 23/03/2021
Respondent: Catherine Terry
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.