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

Comment

Representation ID: 19864

Received: 01/04/2021

Respondent: Natural England

Please see our comments on Policy SP10: Green Infrastructure above.

Support

Representation ID: 19865

Received: 01/04/2021

Respondent: Natural England

Natural England broadly welcomes the approach proposed within this policy. Overall Policy EN2 sets out a clear strategy for the protection and enhancement of biodiversity. The policy seeks to provide considerable net gains in biodiversity, to deliver a coherent and high quality ecological network, and to protect and enhance the most valuable habitats and species.

Object

Representation ID: 19866

Received: 01/04/2021

Respondent: Natural England

Reference to the North Pennine Moors SPA/SAC should be added to the table to ensure consistency.

Various improvements are suggested to strengthen the policy relating to:
- refer to the Nature Recovery Network and recognition of the role of the Network as a major commitment in the government’s 25 Year Environment Plan.
- Reference could also be made to opportunity areas (which should be mapped) so developers understand where they are located and ensure that any biodiversity net gain contributes to local biodiversity priorities.
- include a footnote or link to the Defra Metric2 in Policy EN2.
- including the requirement for net gain to be provided ‘in perpetuity’ and identifying links between net gain and the Nature Recovery Network.
- Referencing that biodiversity net gain does not apply to irreplaceable habitats and any biodiversity net gain which may impact on protected sites is additional to any existing legal or policy requirement for statutory protected areas
- Reference could also be made to the delivery mechanism - planning conditions or S106 agreements?

Object

Representation ID: 19867

Received: 01/04/2021

Respondent: Natural England

Specific reference to biodiversity 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: 19868

Received: 01/04/2021

Respondent: Natural England

Natural England welcomes this policy and note that it is in accordance with NPPF paragraph 175 c) in seeking the strongest protection for ancient woodland and veteran trees.

Support

Representation ID: 19869

Received: 01/04/2021

Respondent: Natural England

Natural England welcomes Policy EN5, and the use of our National Character Areas for England in developing this policy, which is supported by Bradford’s adopted Landscape Character SPD. We also welcome the evolution of the policy to address issues such as local distinctiveness, securing biodiversity net gains, and the need for landscape enhancement, particularly in the urban fringe.

Comment

Representation ID: 19870

Received: 01/04/2021

Respondent: Natural England

We note that there are no designated Protected Landscapes within the Local Authority boundaries, although the District abuts the Yorkshire Dales National Park and Nidderdale Area of Outstanding National Beauty to the north-east. We also note that MHCLG are currently consulting on proposed changes to NPPF Chapter 15: Conserving and enhancing the natural environment, including a new paragraph 175 which has been amended in response to the Glover Review of Protected Landscapes, to clarify that the scale and extent of development within the settings of National Parks and Areas of Outstanding Natural Beauty should be sensitively located and designed so as to avoid adverse impacts on the designated landscapes.

On this basis, Natural England welcomes the approach undertaken within the Sustainability Appraisal in assessing potential allocations for new development in Addingham, Burley in Wharfdale, and Ilkley for any potential impacts on Protected Landscapes outwith the District boundaries, including impacts on tranquillity which falls within the setting of the AONB

Comment

Representation ID: 19871

Received: 01/04/2021

Respondent: Natural England

We welcome the approach set out within Policy EN8 to tackling air pollution and improving air quality throughout the District, particularly the recognition of the important part which can be played be green infrastructure in absorbing pollutants.

The Draft Local Plan should acknowledge that new agricultural development (e.g. intensive pig and poultry) may also pose risk to air quality.

Please see Annex 1 extract below for further guidance regarding how the Draft Local Plan could address the impacts of air quality on the natural environment.

Air pollution
We would expect the plan to address the impacts of air quality on the natural environment. It should address the traffic impacts associated with new development, particularly where this impacts on European sites and SSSIs. The environmental assessment of the plan (SA and HRA) should also consider any detrimental impacts on the natural environment, and suggest appropriate avoidance or mitigation measures where applicable.

Natural England advises that one of the main issues which should be considered in the plan and the SA/HRA are proposals which are likely to generate additional nitrogen emissions as a result of increased traffic generation, which can be damaging to the natural environment.

The effects on local roads in the vicinity of any proposed development on nearby designated nature conservation sites (including increased traffic, construction of new roads, and upgrading of existing roads), and the impacts on vulnerable sites from air quality effects on the wider road network in the area (a greater distance away from the development) can be assessed using traffic projections and the 200m distance criterion followed by local Air Quality modelling where required. We consider that the designated sites at risk from local impacts are those within 200m of a road with increased traffic, which feature habitats that are vulnerable to nitrogen deposition/acidification. APIS provides a searchable database and information on pollutants and their impacts on habitats and species.

Object

Representation ID: 19872

Received: 01/04/2021

Respondent: Natural England

Overall, Natural England consider the scope of the pollutants considered within Policy EN9 to be adequate but advise that the wording of this policy could be strengthened by including:

- policy requirement for development to provide a robust evidence base and field surveys where necessary, to establish the status of agriculture land that could be Best and Most Versatile
- Further emphasis on the importance of soil as a finite resource
- Recognition that soils of high environmental value (e.g. wetland and carbon stores such as peatland) should also be considered as part of ecological connectivity. This should also be reflected within Policy EN2: Biodiversity and Geodiversity

The Draft Local Plan policies should also refer to the Defra Construction Code of Practice for the Sustainable Use of Soils on Construction Sites. It is important to recognise that development (soil sealing) has an irreversible adverse (cumulative) impact on the finite national and local stock of BMV land. Avoiding loss of BMV land is priority, as mitigation is rarely possible. Retaining higher quality land enhances future options for sustainable food production and helps secure other important ecosystem services. In the longer term, protection of BMV land may also reduce pressure for intensification of other land.

Natural England also advise that Policy EN9 could be made more robust by including further consideration of the impacts of light pollution. Light pollution has negative impacts on local amenity, intrinsically dark landscapes and nature conservation (especially bats and invertebrates). The Draft Local Plan should address the impacts of light pollution on the natural environment through Policy EN9 and other policies as appropriate (e.g. design policies). Light pollution mapping is available from CPRE.

Object

Representation ID: 19873

Received: 01/04/2021

Respondent: Natural England

Natural England welcomes the approach set out within Policy EN10 at item E5 requiring an assessment of environmental impacts arising from proposals for major renewable and low carbon energy generation schemes to consider fully any cumulative landscape and visual impacts, and to demonstrate that development will have no adverse impact on the integrity of the South Pennine Moors SPA/SAC.