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

Support

Representation ID: 29084

Received: 24/03/2021

Respondent: Environment Agency

We note there is currently no agreed SFRA Update and that the LPA is committed to producing this evidence, where data is lacking (e.g. models) the LPA will produce
information to a sufficient standard. We also note this uncertainty includes key considerations including but not limited to the removal of 3a(i) designations; agreeing
a 3b designation; and climate change that may/will affect some sites, this may affect allocation viability / requirement.

We note, in the Flood Risk Position Technical Note, the LPA is committed to amending the current Draft Plan/Allocations on the back of this the updated SFRA as needed, when available, and prior to the Reg 19 stage. The LPA makes a specific point in Appendix D that the EN7 Flood Risk Policy will be updated post the SFRA Update so as to use the best information to inform the policy, this may result in changes to the policy wording as a result. As a result it’s difficult to provide meaningful comments on the policy without the data required SFRA however, current comments on EN7 and SP9 Climate Change are within the policies supplement; these may/will change upon the review of the Updated SFRA (which is to follow).

Support

Representation ID: 29085

Received: 24/03/2021

Respondent: Environment Agency

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.

Support

Representation ID: 29088

Received: 24/03/2021

Respondent: Environment Agency

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.

Support

Representation ID: 29089

Received: 24/03/2021

Respondent: Environment Agency

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.

Support

Representation ID: 29114

Received: 24/03/2021

Respondent: Environment Agency

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.

Support

Representation ID: 29115

Received: 24/03/2021

Respondent: Environment Agency

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.

Object

Representation ID: 29253

Received: 24/03/2021

Respondent: Environment Agency

A local planning authority should demonstrate through evidence that it has considered a range of options in the site allocation process, using the Strategic Flood Risk Assessment to apply the Sequential Test and the Exception Test where necessary. This can be undertaken directly or, ideally, as part of the sustainability appraisal. Where other sustainability criteria outweigh flood risk issues, the decision making process should be transparent with reasoned justifications for any decision to allocate land in areas at high flood risk in the sustainability appraisal report. The Sequential Test can also be demonstrated in a free-standing document, or as part of strategic housing land or employment land availability assessments.

We would strongly encourage you to produce a free-standing sequential test document so it is clear how requirements of Planning Practice Guidance and the NPPF had been fulfilled. This would enable ease of reference throughout each stage of the Local Plan development and importantly at examination. We are happy to work with you on is.

Please note within the PPG that a document is provided that explains the application of the Sequential Test for Local Plan preparation. Please review this and consider it as a basis for a sequential test document. Please see further guidance here:
https://www.gov.uk/guidance/flood-risk-and-coastal-change

Support

Representation ID: 29291

Received: 24/03/2021

Respondent: Environment Agency

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.

Support

Representation ID: 29292

Received: 24/03/2021

Respondent: Environment Agency

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.

Object

Representation ID: 29293

Received: 24/03/2021

Respondent: Environment Agency

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.