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

Comment

Representation ID: 19895

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: 19896

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: 19897

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: 19898

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: 19899

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: 19900

Received: 01/04/2021

Respondent: Natural England

We note that the following allocations are on land which may be best and most versatile agricultural land. The plan should safeguard the long term capability of such land (NPPF para 170).

In order to inform the sustainability appraisal and ensure an accurate assessment of the impact of the plan on soil resources we recommend that allocations over 5ha, or at least those over 20ha, have ALC surveys undertaken in order to determine the ALC grade and help inform master planning and soil handling going forward.

Comment

Representation ID: 19901

Received: 01/04/2021

Respondent: Natural England

We note that the following allocations are on land which may be best and most versatile agricultural land. The plan should safeguard the long term capability of such land (NPPF para 170).

In order to inform the sustainability appraisal and ensure an accurate assessment of the impact of the plan on soil resources we recommend that allocations over 5ha, or at least those over 20ha, have ALC surveys undertaken in order to determine the ALC grade and help inform master planning and soil handling going forward.

Comment

Representation ID: 19902

Received: 01/04/2021

Respondent: Natural England

We note that the following allocations are on land which may be best and most versatile agricultural land. The plan should safeguard the long term capability of such land (NPPF para 170).

In order to inform the sustainability appraisal and ensure an accurate assessment of the impact of the plan on soil resources we recommend that allocations over 5ha, or at least those over 20ha, have ALC surveys undertaken in order to determine the ALC grade and help inform master planning and soil handling going forward.

Comment

Representation ID: 19903

Received: 01/04/2021

Respondent: Natural England

We note that the following allocations are on land which may be best and most versatile agricultural land. The plan should safeguard the long term capability of such land (NPPF para 170).

In order to inform the sustainability appraisal and ensure an accurate assessment of the impact of the plan on soil resources we recommend that allocations over 5ha, or at least those over 20ha, have ALC surveys undertaken in order to determine the ALC grade and help inform master planning and soil handling going forward.

Comment

Representation ID: 19904

Received: 01/04/2021

Respondent: Natural England

We note that the following allocations are on land which may be best and most versatile agricultural land. The plan should safeguard the long term capability of such land (NPPF para 170).
In order to inform the sustainability appraisal and ensure an accurate assessment of the impact of the plan on soil resources we recommend that allocations over 5ha, or at least those over 20ha, have ALC surveys undertaken in order to determine the ALC grade and help inform master planning and soil handling going forward.

The sites lies on or in close proximity to woodlands and trees identified in the ancient woodland and veteran trees inventories.
NPPF para 175 sets out a strong presumption against development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees). Natural England and the Forestry Commission have produced standing advice on ancient woodland, ancient and veteran trees.