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

Object

Representation ID: 24893

Received: 24/03/2021

Respondent: CEG Land Promotions Ltd

Agent: Lichfields

REFERENCE TO BU2/H
We note the process by which the Council is required to assess and compare reasonable alternative sites, and the screening criteria for initially rejecting any sites which are not reasonable or realistic options – i.e. where it is unlikely that development on that site is achievable (paragraph 4.2). It is considered that the fundamental issues associated with delivery of this site referenced above suggest that it should have been initially screened out as not being a reasonable or realistic site in accordance with the methodology adopted within the Site Assessment Update Report (February 2021).

In particular, the table at paragraph 4.3 presents a number of ‘Screening Criteria’ which are to be applied and which are considered to render sites unsuitable for allocation. This includes ‘Green Belt sites which are not adjacent and contiguous to the built up area and or could not reasonably form an acceptable urban extension’.

Object

Representation ID: 24894

Received: 24/03/2021

Respondent: CEG Land Promotions Ltd

Agent: Lichfields

We note that the more detailed proformas and analysis which sit behind the conclusions reached for rejected sites as set out within (this report) have not been made available for comment as part of this consultation on the evidence. CEG reserve the right to view and comment on this information, which is pertinent to the strategy of site selection to meet the local housing apportionment, when these are made available.

Based on the above conclusions, none of these sites should be considered for allocation in future iterations of the emerging plan.

Object

Representation ID: 24897

Received: 24/03/2021

Respondent: CEG Land Promotions Ltd

Agent: Lichfields

In summary, there are a number of errors which need to be addressed reflected in the next iteration of the HRA including:
1 Incorrect references in Table 3, page 47, to proposed allocated site BU/H (Sun Lane) as having a risk of likely significant effects upon the South Pennine Moors SAC/SPA, based on the presumption that the site is considered to have suitable supporting habitat types that could be used by the SPA birds. This assessment is incorrect as it has been established on the basis of objective evidence that the land is not used by SPA birds for foraging.
2 Lack of reference within the HRA of the draft Local Plan to the HRA adopted by the Secretary of State for application 16/07870/MAO, which was based on empirical evidence. Vantage Point surveys by Baker Consultants found no movement of birds between the SPA and the development site (or the surrounding land) and consequently, the SoS’s HRA of the Sun Lane development concluded the following basic principles which must be acknowledged in future iterations of the HRA:
i That land can only be supporting habitat if it is regularly used by SPA birds (i.e. those birds which are breeding on the SPA). The presence of SPA species on a development site does not prove that the development site contains supporting land as many of the species are widespread and are not associated with the SPA. If for example, the birds present are breeding on the land then they cannot, by definition, originate from the SPA and the land cannot, therefore, be considered as supporting habitat. This was established in the SoS’s HRA of Sun Lane.
ii That if birds such as golden plover are feeding on a development site, but they are not birds that are associated with the SPA, then the land is not supporting habitat for the SPA. Again, this point was established in the SoS’s HRA of Sun Lane where vantage point surveys established no movement of birds to and from Sun Lane and the SPA.