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

Object

Representation ID: 19832

Received: 01/04/2021

Respondent: Natural England

Natural England advise that item B3 of Policy SP1 could be strengthened as follows:

"It will meet the environmental objectives by the inclusion of a suite of policies designed to protect, conserve, restore and enhance the District’s environmental assets, by focusing development within its main urban areas and by investing in public transport infrastructure in the process, reducing the need to travel by car and reducing climate change emissions;"

We welcome the commitment to ensuring that a sequential approach is taken to site selection and allocation as set out within item B5 of Policy SP1, and advise that item e) could be fortified by expanding the areas for consideration within the context of adverse environmental impacts, and by referring to the mitigation hierarchy, as follows:

"Ensures that wherever possible development enables the enhancement of the built and natural environment and minimises the adverse environmental impacts of growth, in particular with regards to climate change, air quality, biodiversity, geodiversity, ancient woodlands, soils, priority habitats, ecological networks and protected species."

Object

Representation ID: 19833

Received: 01/04/2021

Respondent: Natural England

Natural England welcome the acknowledgement throughout the Draft Local Plan of the internationally important status of the South Pennine Moors as a Special Protection Area (SPA), and the inclusion of item 7 within Policy SP2, and advise that the wording could be made more robust, as follows:

"Protect, restore and enhance the District’s environmental resources for all including areas of international and national importance, such as the South Pennine Moors, the character and qualities of the Districts heritage, landscape and countryside and maximise the contribution they can make to the delivery of wider economic and social objectives."

We also welcome the inclusion of items 8 and 9 of Policy SP2, in that they relate to minimising and mitigating environmental threats, building resilience to climate change, and to enhancing biodiversity in the Metropolitan District.

Object

Representation ID: 19834

Received: 01/04/2021

Respondent: Natural England

As per our comments above, Natural England broadly welcomes the approach taken within the Draft Local Plan to ensuring that a sequential approach is taken to site selection and allocation, which is detailed within Policy SP4.

We would ask that the Nature Recovery Network is also recognised as a consideration, through the inclusion of an appropriate item under section B of this policy, as per footnote 57 to paragraph 174a) and Annex 2 of the NPPF.

Object

Representation ID: 19835

Received: 01/04/2021

Respondent: Natural England

We advise that the wording of item E of Policy SP5 could be strengthened by including opportunities for enhancement as well as development requirements for particular sites, as follows:

"All sites identified as being released from the Green Belt will be required to offset the impact of removing land from the Green Belt by
a) identifying opportunities for on-site environmental enhancement and the delivery of environmental net gain through new development
Proposals which increase the beneficial use of the Green Belt, by enhancing green infrastructure, biodiversity, visual amenity and landscapes or improving derelict land and opportunities for access, outdoor sport and recreation, will be supported where this does not conflict with Green Belt or other policy objectives."

Object

Representation ID: 19836

Received: 01/04/2021

Respondent: Natural England

As outlined earlier, Natural England welcomes the commitment to ensuring that a sequential approach is taken to site selection and allocation, which is expanded upon within the supporting text for Policy SP8.

We would ask you to note that Brownfield sites can comprise Open Mosaic Habitat (OMH) (a priority habitat). Where development is proposed on sites where OMH is identified, the relevant policies should set out appropriate mitigation measures for any loss of this habitat, such as bespoke green/blue roofs and/or landscaping measures to be incorporated into development proposals and secured by condition.

Object

Representation ID: 19837

Received: 01/04/2021

Respondent: Natural England

We advise that wording of both points 3 and 4 could be made more robust through the following amendments which emphasise the role of the natural environment in delivering measures to reduce the effects of climate change through nature-based solutions (for example tree planting to moderate heat island effects), and the importance of restoring natural assets where possible:

3. Incorporating green infrastructure into the scheme from the outset, including such measures as the provision of: areas of green space and green corridors, landscaping, tree planting and retention of existing trees and hedgerows, and nature-based solutions such as green roofs and walls, and SuDS (Policy SP10).

4. Facilitating the management, restoration, enhancement and expansion, of vulnerable habitat types: primarily blanket bog and woodland, which are important for carbon sequestration; and ensuring a net gain in biodiversity (Policy EN2).

Specific reference to net gain is also made within policies SP9, SP10 and TR2, however, the minimum 10% net gain is only stated in TR2. For the sake of consistency it is recommended that these policies either state the 10% minimum net gain requirement or make specific reference to Policy EN2.

Object

Representation ID: 19838

Received: 01/04/2021

Respondent: Natural England

Natural England welcomes the strategic approach set out within Policy SP10 to protecting existing green and blue assets, and to delivering an enhanced and expanded Green Infrastructure Network.

We note the inclusion of a Green Infrastructure Network Map in support of this policy at Appendix 14 of the Draft Local Plan, and suggest that this should be complemented by a Green Infrastructure Strategy, to underpin the strategic approach.

Although we note below the commitment to frame the wording of Thematic Policy EN1 in terms of requiring new development to meet the emerging Framework of Green Infrastructure Standards1 as defined by Natural England once published, we advise that in order to strengthen this section further, this should be included here to give prominence to the strategic importance of Green Infrastructure.

Once the Standard become available, the Plan could include an objective to use the new standards to assess Green Infrastructure provision across the Metropolitan District.

Specific reference to net gain is also made within policies SP9, SP10 and TR2, however, the minimum 10% net gain is only stated in TR2. For the sake of consistency it is recommended that these policies either state the 10% minimum net gain requirement or make specific reference to Policy EN2.

Support

Representation ID: 19839

Received: 01/04/2021

Respondent: Natural England

We welcome the inclusion of item D of Policy SP11 in that it emphasises the strategic mitigation scheme and mechanism for the calculation of the financial contributions to mitigate recreational impacts on the SPA and SAC as a consequence of housing growth and subsequent population increases which is set out within the South Pennine Moors SPD.

Please see our comments below in relation to Policy CO1: Open Spaces, Sport and Recreation for further discussion of the consideration of mitigation of recreational impacts arising from new development.

Object

Representation ID: 19840

Received: 01/04/2021

Respondent: Natural England

Natural England advise that the wording of this policy could be strengthened by the addition of the following at item 4:

4. Providing a well-connected network of attractive green routes and spaces that are safe and easy to use and move around for all members of the community, and which help to connect people with nature.

Object

Representation ID: 19854

Received: 01/04/2021

Respondent: Natural England

Natural England advise that the supporting text for this policy could be improved by making specific reference to the Local Nature Partnership within the introductory paragraphs, in accordance with paragraph 25 of the NPPF.