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

Object

Representation ID: 19924

Received: 01/04/2021

Respondent: Natural England

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.

Support

Representation ID: 19925

Received: 01/04/2021

Respondent: Natural England

Natural England notes that the evidence informing the Habitats Regulations Assessment (HRA) which has been published for Regulation 18 consultation in support of the Draft Local 3.2 Plan is currently under review, and that following the consultation the HRA will progress with further detailed evidence gathering and assessment to inform the preparation of the Local Plan at Regulation 19 stage.

We note that the scope of impact pathways identified is acceptable, and that the overall approach taken within HRA is robust in terms of referencing up-to-date case law, definitions, and guidance.

3.1 Natural England notes that the evidence informing the Habitats Regulations Assessment (HRA) which has been published for Regulation 18 consultation in support of the Draft Local 3.2 Plan is currently under review, and that following the consultation the HRA will progress with further detailed evidence gathering and assessment to inform the preparation of the Local Plan at Regulation 19 stage.

We note that the scope of impact pathways identified is acceptable, and that the overall approach taken within HRA is robust in terms of referencing up-to-date case law, definitions, and guidance.

Object

Representation ID: 19926

Received: 01/04/2021

Respondent: Natural England

We note that evidence to inform the assessment of traffic emissions on the South Pennine Moors SAC and Phase 2 SPA has not been undertaken at this stage. We recommend that this evidence is gathered and the assessment undertaken at the earliest opportunity as it may impact on the soundness and legal compliance of the proposed growth targets and spatial distribution.

Support

Representation ID: 19927

Received: 01/04/2021

Respondent: Natural England

We welcome the approach taken to assessing both the loss of functionally linked land for South Pennine Moors (phase 2) SPA birds and recreational disturbance and urban edge effects on the SPA and South Pennine Moors SAC.

Natural England would wish to be consulted on a revised version of the HRA when it is available.