Sustainability Appraisal & Strategic Environmental Assessment – Interim Report

Showing comments and forms 1 to 23 of 23

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 17325

Received: 23/03/2021

Respondent: Avant Homes

Agent: ID Planning

Representation Summary:

We support the findings of the Sustainability Appraisal for the site which concludes that the site could deliver a major positive effect for residents on the health objectives as a result of being within the target distances for all the necessary health facilities.
-The site scores negatively major adverse effect for two objectives relating to, 3. Land and Buildings and, 6. Biodiversity and geodiversity. In relation to Land and Buildings the SA states;
“There is a large area of greenfield land within the boundary and therefore development on this area would be considered as an inefficient use of the land resource. Southern portion of the site has some hardstanding and an existing building which might present opportunities for reusing structures or construction
materials. ALC Grade 4.”
-This score is based on the size of the site. We agree with the score in accordance with the methodology but note that preferred policy SP5 sets out exceptional circumstances for the release of Green Belt sites to meet the housing requirement. A mixed site, WI1/H is allocated in Wilsden and two greenfield allocations including site WI3/H are allocated to meet the requirement.
-The effect on 6. Biodiversity and geodiversity is scored as major adverse in the sustainability appraisal for all the proposed allocations in Wilsden including site
WI3/H.
-Based on the methodology in the Interim SA/ SEA report and size of the site we consider the score for site WI3/H should be minor adverse. With regard to the potential impact on the local or regional designations, further information is required to inform if there is any negative impact on sites more than 3km away.
-Site WI3/H scores negatively (minor adverse) in relation to energy and greenhouse gases, waste, water resources, landscape and townscape, cultural heritage and air quality. It is considered that future site specific information and development proposals will ensure adverse effects on these criteria are avoided or mitigated.
-Positive scores are given to all other 10-19 socio economic themed sustainability objectives which we support.
- We support the Green Belt Assessment which concludes that the site performs a low role when assessed against the purposes of the Green Belt. The existing green belt boundary in the area is weak, development of the site could provide a new boundary consistent with the landscape character of the area.

Full text:

SEE ATTACHMENTS FOR SUBMISSION IN RELATION TO SITES WI3/H (WILSDEN) & IL/044 (ILKLEY)

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 19924

Received: 01/04/2021

Respondent: Natural England

Representation Summary:

Natural England notes that the Interim Sustainability Appraisal (SA) Report provided in support of the Draft Local Plan is not intended, and is not able, to fully satisfy the requirements of a Strategic Environmental Assessment (SEA) Environmental Report at this stage of the plan-making process, and a that a further iteration will be undertaken following public consultation, which will take into account changes to the Draft Local Plan, as well as comments on the SA itself.

At this stage, Natural England advise that while Section 2.1.3 of the Interim SA Report sets out the key sustainability issues for consideration, we note that there are other sustainability issues that should be included, including amending the assessment criteria to include greater consideration of the protection of BMV agricultural land and soil resources from inappropriate development.

We also consider that there is scope for further consideration of opportunities that enhance ecological connectivity as part of the assessment criteria. There is a risk that in some situations, development on land of limited biodiversity value in its own right can lead to the creation of islands of biodiversity, permanently severed from other areas. We therefore suggest adding additional wording that captures the principle of ensuring that current ecological networks are not compromised, and future improvements in habitat connectivity are not prejudiced.

Notwithstanding the above, overall Natural England has concluded that a significant amount of further work is required to complete the SA for the Draft Local Plan, and on this basis, we will provide detailed comments once the finalised SA has been published for further consultation.

Full text:

Dear Local Plan Team

Thank you for consulting Natural England on the above. Please find attached our response to the Draft Bradford District Local Plan Preferred Options (Regulation 18) February 2021 including the Draft South Pennine Moors SPA/SAC Planning Framework Supplementary Planning Document, Habitats Regulations Assessment and Sustainability Appraisal.

If you have any further questions about this response please do not hesitate to contact me.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29085

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

The Environmental Assessment of Plans and Programmes Regulations 2004 – which implement the Strategic Environmental Assessment (SEA) Directive creates a legal duty and require that a plan’s cumulative climate impacts are assessed and taken into account. This includes assessing the consistency of proposed policies with all relevant climate objectives and targets.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29088

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Local Plans should consider the capacity and quality of water supply systems and any impact development may have on the environment, including understanding the supply and demand patterns now and in the future across the LPA area.

Projected water availability should take account of the impact of a changing climate. Water companies hold information and data to help with this and LPAs should work closely with water companies when they are producing their Local Plans.

This information should be reflected in the Sustainability Appraisal (SA) of the Local Plan.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29089

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Flood Risk

The policy and site allocations in Local Plans provide an opportunity to address flood risk and coastal change. The Sustainability Appraisal (SA) for the Local Plan is an opportunity to incorporate evidence and advice into plan making. The SA should include baseline information and objectives on flood risk and coastal change.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29114

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Local Plans should be produced with an understanding of how local communities use their groundwater and the location of potentially contaminated land. The
Sustainability Appraisal (SA) for the Local Plan is an opportunity to incorporate evidence and advice into plan making. The SA should reflect groundwater and
contaminated land matters.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29115

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

The policy and site allocations in Local Plans provide an opportunity to address flood risk and coastal change. The Sustainability Appraisal (SA) for the Local Plan is an
opportunity to incorporate evidence and advice into plan making. The SA should include baseline information and objectives on flood risk and coastal change.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29291

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

SA Objective 2: Waste

We welcome and support this objective. Waste Local Plans provide an opportunity to improve the management of waste and resources.

Please also see our comments on waste within the relevant polices and the covering letter in our other response letters.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29292

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

SA Objective 4: Climate Change

We welcome and support this objective. Please note our comments within the covering letter on climate change and how the UK planning and environmental legislation sets out that local plans must include robust evidence-based carbon targets.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29293

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

SA Objective 5: Water Resources

We welcome and support this objective. We welcome the reference made to ecological and chemical status of surface waters under the Water Framework Directive (WFD) which has been identified as a key indicator for the SA Objective 5.

Reference to groundwater and preventing pollution should also be included here. Local Plans should be produced with an understanding of how local communities use their groundwater and the location of potentially contaminated land. The Sustainability Appraisal (SA) for the Local Plan is an opportunity to incorporate evidence and advice into plan making. The SA should reflect groundwater and contaminated land matters

Please also see our comments on water resources and water quality within the relevant polices in our other response letters. We consider that water resources should be better reflected within the Local Plan objectives to reflect this SA objective.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29295

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

SA Objective 6: Biodiversity & Geodiversity

We welcome and support this objective.

As above, we welcome the reference made Water Framework Directive (WFD) which has been identified as a key indicator for the SA Objective 5, we would also recommend that this is replicated within SA Objective 6: ‘To conserve and enhance geodiversity, biodiversity, including the internationally, nationally and locally valued wildlife species and habitats’ as blue infrastructure and improved water quality is also fundamental to supporting biodiversity (along with green infrastructure, which has been identified) and improving our surface waters will support ecological connectivity across Bradford Metropolitan District Council (MDC). This should be reflected also in Table 2.1: SA Framework.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29297

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

SA Objective 6: Biodiversity & Geodiversity

You may also wish to consider an indicator that considers the km of rivers protected and enhanced via WFD and net gain ambitions. We would encourage this.
An indicator should be included in relation to measureable biodiversity net gain and achieving 10% or more on developments in line with the emerging Environment Bill.

Please also see our comments on biodiversity and water within the relevant polices in our other response letters.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29301

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Relevant Policies, Plans & Programmes - Appendix A

25 Year Environment Plan

We welcome the inclusion of DEFRA’s 25 Year Environment Plan in Appendix-A (A17). The Local Plan policies should consider the emerging challenges and the key goals identified in the Government’s 25 Year Environment Plan, including the need to improve air quality and tackle the climate emergency through sustainable development, applying the biodiversity net gain principle and the use of nature based solutions.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29304

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Relevant Policies, Plans & Programmes - Appendix A

EA Managing Water Abstraction

In light of the above, we recommend including the Environment Agency’s Managing Water Abstraction. Our Catchment Abstraction Management Strategy process assesses the availability of water resources for each river catchment, produces a strategy and feeds into investigations to identify failing water quality. See here: https://www.gov.uk/government/publications/managing-water-abstraction

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29309

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Relevant Policies, Plans & Programmes - Appendix A

National Flood and Coastal Erosion Risk Management Strategy

We also recommend that the reference to the National Flood and Coastal Erosion Risk Management Strategy, this was updated in 20201. The Strategy has three core ambitions concerning future risk and investment needs:

1. Climate resilient places: working with partners to bolster resilience to flooding and coastal change across the nation, both now and in the face of climate change

2. Today’s growth and infrastructure resilient in tomorrow’s climate: Making the right investment and planning decisions to secure sustainable growth and environmental improvements, as well as resilient infrastructure.

3. A nation ready to respond and adapt to flooding and coastal change: Ensuring local people understand their risk to flooding and coastal change, and know their responsibilities and how to take action.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29312

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Relevant Policies, Plans & Programmes - Appendix A

We welcome the inclusion of the EU Water Framework Directive (2000/60/EC). With EU Exit, this Directive has now been transposed into law in England and Wales by The Water Environment (Water Framework Directive) (England and Wales) Regulations 2017. The Water Environment (WFD) establishes a legislative framework for the protection of surface waters (including rivers, lakes and coastal waters) and ground waters. The overall aims and objectives of the WFD are to:
 enhance the status and prevent further deterioration of surface water bodies, ground water bodies and their ecosystems;
 ensure progressive reduction of groundwater pollution;
 reduce pollution of water, especially by priority substances and certain other pollutants, as set out in the list of chemicals for Water Framework Directive assessments;
 contribute to mitigating the effects of floods and droughts;
 achieve at least good surface water status for all surface water bodies and good chemical status in ground water bodies or good ecological potential in the case of artificial or heavily modified water bodies; and
 promote sustainable water use.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29313

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Relevant Policies, Plans & Programmes - Appendix A

River Basin Management Plan

We encourage more explicit inclusion and reference to the Humber River Basin Management Plan (RBMP), as a spate plan to be considered. The Humber RBMP sets out the state of the water environment within the Humber River Basin District and indicates where local government can support other regulators and operators in applying the relevant legislation and policy to improve the water environment. This is in the process of being updated, with a new plan due to be published in early 2022.
We recommend that the objectives of WFD, where all waterbodies should reach good ecological status by 2027 or sooner, should be considered in the development of environmental planning policy to ensure that the riverine environment is incorporated in nature conservation. Additional information on WFD is provided within our Local Plan consultation responses, including a map of WFD status for ecological elements within the Yorkshire Dales (this currently only include Yorkshire detail, but we aim to provide the whole area in due course).
Further details and the RBMPs themselves can all be found here: https://www.gov.uk/government/collections/river-basin-management-plans-2015

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29315

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Relevant Policies, Plans & Programmes - Appendix A

YW Water Resource Management Plan

Yorkshire Water’s Water Resource Management Plan (WRMP) (2019) and the upcoming Drainage and Wastewater Management Plan (due to be published in 2022) should also be recognised as long-term frameworks for the management of water to support sustainable growth in the region. Water companies have to produce WRMPs every five years to show how demand for water is going to be managed and met over a twenty-five year period. They assess in detail the pressures on future water supplies, including changes in demand and changes to the availability of water resources. WRMPs are therefore an essential evidence source for ascertaining water availability within an area. The WRMPs for the period 2020-25 are available from the Yorkshire Water2 website.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29316

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Relevant Policies, Plans & Programmes - Appendix A

YW Water Resource Management Plan

Yorkshire Water’s Water Resource Management Plan (WRMP) (2019) and the upcoming Drainage and Wastewater Management Plan (due to be published in 2022) should also be recognised as long-term frameworks for the management of water to support sustainable growth in the region. Water companies have to produce WRMPs every five years to show how demand for water is going to be managed and met over a twenty-five year period. They assess in detail the pressures on future water supplies, including changes in demand and changes to the availability of water resources. WRMPs are therefore an essential evidence source for ascertaining water availability within an area. The WRMPs for the period 2020-25 are available from the Yorkshire Water2 website.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29317

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Relevant Policies, Plans & Programmes - Appendix A

EA Catchment Flood Risk Management Plans

We recommend the inclusion of Environment Agency Catchment Flood Risk Management Plans. These provide an overview of the flood risk across the river catchments and recommended ways of managing the risk now and over the next 50 to 100 years.

More details are here: https://www.gov.uk/government/collections/catchment-flood-management-plans

EU Framework Directive on Waste

The Waste (England and Wales) Regulations 2011 implement the revised Waste Framework Directive. The Waste Management Plan for England sets out the Governments ambition for moving to a more sustainable and efficient approach to resource use and management. National Planning Policy for waste (NPPW) sets out detailed waste planning policies. It should be read in conjunction with the NPPF and the National Policy Statements for Waste Water and Hazardous Waste. Waste planning has a role to play in delivering objectives, including: reducing greenhouse gas emissions; better management of resources and protecting the environment; promoting treatment of waste further up the waste hierarchy; waste planning can also contribute to the development of the circular economy and associated sustainable growth.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29318

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Relevant Policies, Plans & Programmes - Appendix A

EU Ambient Air Quality and Management Directive / EU Directive on Assessment & Management of Environmental Noise

Natural England should provide comments regarding air quality. There should be a consideration of air quality and the implications on sustainable objectives and the allocation of sites, especially those in air quality management areas (AQMAs). There are also implications on certain industrial uses that will require a permit from the EA or the Local Authority. Likewise, with the EU Directive on Assessment & Management of Environmental Noise. There is a need to consider the impact on wildlife and, including wildlife in watercourses. As highlighted in our consultation responses on the Local Plan, we encourage locations for potential new residential uses to be away from industry that creates noise or other pollution that may have an impact

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29320

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Relevant Policies, Plans & Programmes - Appendix A

Flood and Water Management Act, 2010

We welcome the inclusion of the Flood and Water Management Act, 2010. This addresses the threats of flooding and water scarcity, including responsibilities for the EA and Lead Local Flood Authorities.

Please note the following link regarding water management and planning: https://www.cisl.cam.ac.uk/business-action/business-nature/natural-capital-impact-group/news/advice-water-management

Also please note additional information CIRIA have released regarding guidance for delivering better water management through the planning system. This guidance can be found here: https://www.ciria.org/ItemDetail?iProductCode=C787F&Category=FREEPUBS

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29321

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Relevant Policies, Plans & Programmes - Appendix A

Biodiversity 2020

We welcome the inclusion of the Biodiversity 2020: A Strategy for England’s Wildlife and Ecosystem Services, Defra (2011). We would go a step further with the implications and recommend that proactive consideration is taken of biodiversity value in terms of when assessing potential site allocations. This does also include aquatic environments (rivers etc).
Groundwater
Reference should be included to ‘The Environment Agency’s approach to groundwater protection’ document and the included position statements. This should be a consideration in terms of assessing the local plan and potential site allocations in terms of groundwater. Any policy should not pose an unacceptable risk of pollution to controlled waters by mobilising potential contaminants in the ground. For example, policy involving SuDS.

Strategic Flood Risk Assessment

An SFRA examines how sources of flooding may impact on development. This should be included as a key local document within the SA. We welcome continued working with you on this in the future. Further detail is set out elsewhere in our Local Plan response.

EU Exit

We recommend you ensure that the correct references are made to all EU legislation that has now been transposed into UK (or England and Wales) law.

Full text:

Please find attached the Environment Agency response to the Draft Bradford Local Plan Regulation 18 preferred options consultation.

The response is in a number of parts (1-7), including a covering letter, policies response, sites response, SA/SEA response and appendices. The covering letter sets this out in detail along with additional comments.

We trust the attached advice is useful. If I can be of any further assistance or if you have any questions, please don’t hesitate to contact me.

We welcome the opportunity to work with you preparing your Local Plan.