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

Support

Representation ID: 19874

Received: 01/04/2021

Respondent: Natural England

Natural England considers that the approach set out in CO1 to open space provision is robust and based on up-to-date evidence. We welcome the inclusion of item D which sets out the requirement for the mitigation of recreational pressure on the South Pennine Moors SPA and SAC arising from residential development which is defined as Use Class C3, and advise that this could be strengthened by the case-by-case consideration of all major proposals for C1, C2, and C4 development, and for sui generis uses such as caravan and camp sites.

Furthermore, we note also that there is still disparity around the Use Classification of student accommodation, with local authorities adopting different elements of the Use Class Order including C1, C2, C3 or sui generis uses. Major proposals for Purpose-Built Student
Accommodation should also be included within this policy in relation to the potential for increased recreational pressure on designated sites arising from this type of development, to be assessed on a case-by-case basis.

Object

Representation ID: 19875

Received: 01/04/2021

Respondent: Natural England

Natural England welcomes the approach set out within Policy DS2, which states that plans and development proposals should take advantage of existing features, integrate development into the wider landscape and create new quality green spaces and landscape features.

We advise that item F could be made more robust by the inclusion of the following wording:
Use plant species which are appropriate to the local character and conditions, and which reinforce existing and priority ecosystem services as identified in Policy EN2.

Policy DS2 should have regard for the National Design Guide which was adopted in 2019 (with further updates made in 2021) and is a material planning consideration - its high level principles regarding design for nature include:
- N1 Provide a network of high quality, green open spaces with a variety of landscapes and activities, including play;
- N2 Improve and enhance water management; and
- N3 Support rich and varied biodiversity.

Comment

Representation ID: 19876

Received: 01/04/2021

Respondent: Natural England

The site lies in proximity to the South Pennine Moors (Phase 2) SPA and has potential to lead to the loss of functionally linked land for SPA birds.

We welcome the approach taken in the draft plan, SPD and assessments to loss of functionally linked land.

The council has a copy of a model to identify the suitability of sites for SPA golden plover and recommend that allocations are screened against this dataset taking the following approach:

• Maximum Training Sensitivity plus Specificity (MTSS) layer: full survey for Golden Plover likely to be required. The WY Ecology Service SPA Bird Survey Methodology should be followed.

• Minimum Training Presence (MTP) layer or 10 Percentile Training Presence (10PTP) layer: scoping survey to determine if a full Golden Plover full survey required. A desk based survey may be sufficient for sites within the MTP whereas a walkover survey may be required for sites within the 10PTP;

• Not within an area of predicted presence: No survey required for Golden Plover.

Where loss of functionally linked land cannot be ruled out at this stage we recommend that allocation requirement text in the plan sets out survey and mitigation requirements clearly.

Comment

Representation ID: 19877

Received: 01/04/2021

Respondent: Natural England

The site lies in proximity to the South Pennine Moors (Phase 2) SPA and has potential to lead to the loss of functionally linked land for SPA birds.

We welcome the approach taken in the draft plan, SPD and assessments to loss of functionally linked land.

The council has a copy of a model to identify the suitability of sites for SPA golden plover and recommend that allocations are screened against this dataset taking the following approach:

• Maximum Training Sensitivity plus Specificity (MTSS) layer: full survey for Golden Plover likely to be required. The WY Ecology Service SPA Bird Survey Methodology should be followed.

• Minimum Training Presence (MTP) layer or 10 Percentile Training Presence (10PTP) layer: scoping survey to determine if a full Golden Plover full survey required. A desk based survey may be sufficient for sites within the MTP whereas a walkover survey may be required for sites within the 10PTP;

• Not within an area of predicted presence: No survey required for Golden Plover.

Where loss of functionally linked land cannot be ruled out at this stage we recommend that allocation requirement text in the plan sets out survey and mitigation requirements clearly.

Comment

Representation ID: 19878

Received: 01/04/2021

Respondent: Natural England

The site lies in proximity to the South Pennine Moors (Phase 2) SPA and has potential to lead to the loss of functionally linked land for SPA birds.

We welcome the approach taken in the draft plan, SPD and assessments to loss of functionally linked land.

The council has a copy of a model to identify the suitability of sites for SPA golden plover and recommend that allocations are screened against this dataset taking the following approach:

• Maximum Training Sensitivity plus Specificity (MTSS) layer: full survey for Golden Plover likely to be required. The WY Ecology Service SPA Bird Survey Methodology should be followed.

• Minimum Training Presence (MTP) layer or 10 Percentile Training Presence (10PTP) layer: scoping survey to determine if a full Golden Plover full survey required. A desk based survey may be sufficient for sites within the MTP whereas a walkover survey may be required for sites within the 10PTP;

• Not within an area of predicted presence: No survey required for Golden Plover.

Where loss of functionally linked land cannot be ruled out at this stage we recommend that allocation requirement text in the plan sets out survey and mitigation requirements clearly.

Comment

Representation ID: 19879

Received: 01/04/2021

Respondent: Natural England

The site lies in proximity to the South Pennine Moors (Phase 2) SPA and has potential to lead to the loss of functionally linked land for SPA birds.

We welcome the approach taken in the draft plan, SPD and assessments to loss of functionally linked land.

The council has a copy of a model to identify the suitability of sites for SPA golden plover and recommend that allocations are screened against this dataset taking the following approach:

• Maximum Training Sensitivity plus Specificity (MTSS) layer: full survey for Golden Plover likely to be required. The WY Ecology Service SPA Bird Survey Methodology should be followed.

• Minimum Training Presence (MTP) layer or 10 Percentile Training Presence (10PTP) layer: scoping survey to determine if a full Golden Plover full survey required. A desk based survey may be sufficient for sites within the MTP whereas a walkover survey may be required for sites within the 10PTP;

• Not within an area of predicted presence: No survey required for Golden Plover.

Where loss of functionally linked land cannot be ruled out at this stage we recommend that allocation requirement text in the plan sets out survey and mitigation requirements clearly.

Comment

Representation ID: 19880

Received: 01/04/2021

Respondent: Natural England

The site lies in proximity to the South Pennine Moors (Phase 2) SPA and has potential to lead to the loss of functionally linked land for SPA birds.

We welcome the approach taken in the draft plan, SPD and assessments to loss of functionally linked land.

The council has a copy of a model to identify the suitability of sites for SPA golden plover and recommend that allocations are screened against this dataset taking the following approach:

• Maximum Training Sensitivity plus Specificity (MTSS) layer: full survey for Golden Plover likely to be required. The WY Ecology Service SPA Bird Survey Methodology should be followed.

• Minimum Training Presence (MTP) layer or 10 Percentile Training Presence (10PTP) layer: scoping survey to determine if a full Golden Plover full survey required. A desk based survey may be sufficient for sites within the MTP whereas a walkover survey may be required for sites within the 10PTP;

• Not within an area of predicted presence: No survey required for Golden Plover.

Where loss of functionally linked land cannot be ruled out at this stage we recommend that allocation requirement text in the plan sets out survey and mitigation requirements clearly.

Comment

Representation ID: 19881

Received: 01/04/2021

Respondent: Natural England

The site lies in proximity to the South Pennine Moors (Phase 2) SPA and has potential to lead to the loss of functionally linked land for SPA birds.

We welcome the approach taken in the draft plan, SPD and assessments to loss of functionally linked land.

The council has a copy of a model to identify the suitability of sites for SPA golden plover and recommend that allocations are screened against this dataset taking the following approach:

• Maximum Training Sensitivity plus Specificity (MTSS) layer: full survey for Golden Plover likely to be required. The WY Ecology Service SPA Bird Survey Methodology should be followed.

• Minimum Training Presence (MTP) layer or 10 Percentile Training Presence (10PTP) layer: scoping survey to determine if a full Golden Plover full survey required. A desk based survey may be sufficient for sites within the MTP whereas a walkover survey may be required for sites within the 10PTP;

• Not within an area of predicted presence: No survey required for Golden Plover.

Where loss of functionally linked land cannot be ruled out at this stage we recommend that allocation requirement text in the plan sets out survey and mitigation requirements clearly.

Comment

Representation ID: 19883

Received: 01/04/2021

Respondent: Natural England

The site lies in proximity to the South Pennine Moors (Phase 2) SPA and has potential to lead to the loss of functionally linked land for SPA birds.

We welcome the approach taken in the draft plan, SPD and assessments to loss of functionally linked land.

The council has a copy of a model to identify the suitability of sites for SPA golden plover and recommend that allocations are screened against this dataset taking the following approach:

• Maximum Training Sensitivity plus Specificity (MTSS) layer: full survey for Golden Plover likely to be required. The WY Ecology Service SPA Bird Survey Methodology should be followed.

• Minimum Training Presence (MTP) layer or 10 Percentile Training Presence (10PTP) layer: scoping survey to determine if a full Golden Plover full survey required. A desk based survey may be sufficient for sites within the MTP whereas a walkover survey may be required for sites within the 10PTP;

• Not within an area of predicted presence: No survey required for Golden Plover.

Where loss of functionally linked land cannot be ruled out at this stage we recommend that allocation requirement text in the plan sets out survey and mitigation requirements clearly.

Comment

Representation ID: 19884

Received: 01/04/2021

Respondent: Natural England

The site lies in proximity to the South Pennine Moors (Phase 2) SPA and has potential to lead to the loss of functionally linked land for SPA birds.

We welcome the approach taken in the draft plan, SPD and assessments to loss of functionally linked land.

The council has a copy of a model to identify the suitability of sites for SPA golden plover and recommend that allocations are screened against this dataset taking the following approach:

• Maximum Training Sensitivity plus Specificity (MTSS) layer: full survey for Golden Plover likely to be required. The WY Ecology Service SPA Bird Survey Methodology should be followed.

• Minimum Training Presence (MTP) layer or 10 Percentile Training Presence (10PTP) layer: scoping survey to determine if a full Golden Plover full survey required. A desk based survey may be sufficient for sites within the MTP whereas a walkover survey may be required for sites within the 10PTP;

• Not within an area of predicted presence: No survey required for Golden Plover.

Where loss of functionally linked land cannot be ruled out at this stage we recommend that allocation requirement text in the plan sets out survey and mitigation requirements clearly.