Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Support

Representation ID: 29173

Received: 24/03/2021

Respondent: Environment Agency

We support the spatial policies B 7 and 9 and are pleased to see the reference to managing river catchments for biodiversity enhancement as well as for flood mitigation.

Comment

Representation ID: 29175

Received: 24/03/2021

Respondent: Environment Agency

In principle we support the effective and efficient re-use of previously developed land. As above, we feel that in some instances previously developed land may hold (or have the potential to hold) significant environmental / ecological value. Based on this, we support the inclusion of the qualifying statement “that is not of high environmental value” within bullet point A, 1 of Policy SP4. However, the policy wording does not explain how the environmental value of prospective, previously developed sites, will be determined. For example, previously developed land immediately adjacent to river corridors, even if currently in a poor state, has a high environmental value.

Equally, rather than solely focussing on current environmental value, we feel the policy needs to consider the future / potential environmental value when determining which previously developed site are most suitable for future re-development. For example, the potential to unlock previously lost environmental value through de-culverting rivers and streams should be given weight when determining site selection.

Comment

Representation ID: 29176

Received: 24/03/2021

Respondent: Environment Agency

Previously Developed Land

Within the supporting text of this policy, under ‘Maximising brownfield land’, we recommend the inclusion and reference to NPPF paragraph 170 and 178 regarding conserving and enhancing the natural environment, along with ground conditions and pollution.

Comment

Representation ID: 29178

Received: 24/03/2021

Respondent: Environment Agency

We support the current content of Policy SP9 but also recommend the inclusion of additional wording (underlined) within bullet points B, 5 and C, 3 and C, 4 (for detail see document)

These proposals for policy wording changes are to ensure that the policy includes sufficient reference to the ‘blue’ element (i.e. the water environment) of green and blue infrastructure.

We support the inclusion of bullet point C, 1 of Policy SP9, which makes reference to SuDS, water efficiency measures and NFM.

Policy should be developed that seeks to encourage SuDS, drainage connections, habitat creation, water efficiency, naturalisation of water bodies etc

Additionally, clarification should be included with regard to flood risk. Under bullet point B, 4, this should emphasise that you should be locating development in areas of low flood risk both in the present sense and future risk sense. Development should also sequentially layout there sites to avoid areas at most flood risk (which should also be set out in Policy EN7).

Support

Representation ID: 29182

Received: 24/03/2021

Respondent: Environment Agency

We support the current content of policy SP10. We particularly support the inclusion of the word blue within green and blue infrastructure and that the District’s surface water assets are identified as strategic assets. We recommend that the policy title is updated to reflect this – so that it reads “Policy SP10 Green and Blue Infrastructure”.

Comment

Representation ID: 29184

Received: 24/03/2021

Respondent: Environment Agency

We also recommend the inclusion of additional wording (underlined) within bullet points A and B, 1 (a, b, c & d) of Policy SP10 – so that they read:

“The District's Strategic Green and Blue Infrastructure (GI) network and assets, as defined in this policy and identified on the Inset Map (Appendix 14), will be protected, maintained, and wherever appropriate possible, enhanced. Green and Blue Infrastructure is defined as a range of multi-functional spaces, routes and assets for recreation, leisure, sustainable transport and biodiversity, and which can be classified under the following themes:
a) Designated areas of open space (Policy CO1).
b) Biodiversity assets including: designated wildlife sites (SPA/SAC, SSSI, LWS, LNR), wildlife habitat networks, priority habitats, trees and woodland (Policies SP11, EN2, EN3). In Bradford the South Pennine Moors is identified as a Strategic GI asset.
c) Water assets including rivers, canals, lakes and reservoirs (Policy EN7). In Bradford area the Rivers Aire and Wharfe (as well as all of their main and non-main river tributaries such as the River Worth, Silsden Beck, Bradford Beck and other water bodies such as the Leeds-Liverpool Canal) are identified as Strategic GI assets.
d) Active travel routes including public rights of way: footpaths, bridleways, cycle paths and greenways (Policies SP7, TR1, TR2).
e) Landscapes and cultural heritage assets including: the wider open countryside and areas of Green Belt (Policies SP5, EN4, EN5, EN6)”.

and
“Development proposals should make a positive contribution to the provision of Green Infrastructure and support its multi-functionality by:
a. Designing and integrating new and/or enhanced green and blue infrastructure into the scheme from the outset. Dependent on the nature, scale and location of the development, this should include the provision of:
 New, or enhanced, areas of green and blue space (in line with the requirements of Policy CO1);
 street trees and other areas of native planting and landscaping;
 green roofs or walls;
 new wildlife habitats or assets which benefit wildlife such as Swift bricks, bat boxes, etc.;
 Sustainable Drainage System (SuDS), including the use of permeable surfaces in outdoor spaces (including for car parking);
 Undeveloped buffer zones between existing Blue Infrastructure networks (surface water body’s – including rivers and streams) and the proposed development.
b. identifying opportunities to link areas of green space together in order to fill gaps within the existing Green and Blue Infrastructure network.
c. providing new connections and enhancements to the existing Green and Blue Infrastructure network and where the development falls within or adjacent to the network, ensure that the network is not severed by putting in place sufficient mitigation measures to maintain its functionality and connectivity.
d. protecting, enhancing and securing measurable net gains in biodiversity (in line with Policy EN2).
e. ensuring that where opportunities exist the scheme connects to the existing walking and cycling networks and greenways”.

Comment

Representation ID: 29185

Received: 24/03/2021

Respondent: Environment Agency

It is important to ensure there are no adverse impacts of minerals (including oil and gas) activities on aquifers and protect surface and groundwater resources. We would encourage you to explore the potential for including a policy on Oil and Gas.

An abstraction or dewatering activity may require a license/environmental permit, and this should be referenced in policy. This could also be included with Policy EN11.
There should be consideration of delivering the Water Framework Directive (WFD) and River Basin Management Plan (RBMP) objectives and actions. Plans and policies for minerals should protect biodiversity and the wider water environment (including water quality) and minimise disturbance on the river bank and to rivers. This should also be considered in regard to restoration of sites.

The EA document called ‘The Environment Agency’s approach to groundwater protection’ which contains position statement N indicates the following: “Within Source Protection Zone 1, the Environment Agency will normally object in principle to any planning application for a development that may physically disturb an aquifer”. Therefore it is strongly recommended that strategic planning for minerals is not located in SPZ1.

Criteria should ensure that minerals are worked in ways that don’t increase flood risk, protect the floodplain and ensure that there are no adverse impacts of ancillary activities on the water environment.

Comment

Representation ID: 29187

Received: 24/03/2021

Respondent: Environment Agency

We encourage that the vision, strategy, policy and site allocations reflect the need for an integrated and adequate network of waste management facilities.

Please ensure that you follow the Waste Framework Directive objectives and relevant Articles.

We support and encourage a move away from landfilling / incineration (without energy recovery), toward reduction, reuse and recycling.

We encourage policies that promote the design of new development that enables the sustainable management of waste when the development is in use

An environmental permit may likely be a requirement and should be considered within the explanatory text.

Support

Representation ID: 29188

Received: 24/03/2021

Respondent: Environment Agency

We support inclusion of a policy which requires new developments to meet the National Green Infrastructure Standards as defined by Natural England, for the reasons provided in the question.

Support

Representation ID: 29189

Received: 24/03/2021

Respondent: Environment Agency

We support the current content of Policy EN2 – in particular the references to BNG and the use of the DEFRA Biodiversity Metric; and also the protection and strengthening of the Wildlife Habitat Network.

We would recommend that any policy referencing this includes the term ‘measureable net gain’ as per the wording in the revised NPPF2.