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

Support

Representation ID: 29295

Received: 24/03/2021

Respondent: Environment Agency

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.

Object

Representation ID: 29297

Received: 24/03/2021

Respondent: Environment Agency

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.

Support

Representation ID: 29301

Received: 24/03/2021

Respondent: Environment Agency

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.

Support

Representation ID: 29304

Received: 24/03/2021

Respondent: Environment Agency

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

Object

Representation ID: 29309

Received: 24/03/2021

Respondent: Environment Agency

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.

Support

Representation ID: 29312

Received: 24/03/2021

Respondent: Environment Agency

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.

Object

Representation ID: 29313

Received: 24/03/2021

Respondent: Environment Agency

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

Object

Representation ID: 29315

Received: 24/03/2021

Respondent: Environment Agency

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.

Object

Representation ID: 29316

Received: 24/03/2021

Respondent: Environment Agency

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.

Object

Representation ID: 29317

Received: 24/03/2021

Respondent: Environment Agency

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.