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

Comment

Representation ID: 11543

Received: 17/03/2021

Respondent: Yorkshire Wildlife Trust

We would recommend that this policy considers the inclusion of the requirement for developers to apply the Building with Nature standards to all proposals.

Building with Nature is a framework that enables developers to integrate high-quality multifunctional green infrastructure to create places in which people and nature can flourish. It provides developers with a possible mechanism to deliver several local and national policies/guidance, relating to biodiversity, SuDs, and community wellbeing.

We would advocate for the application of this tool and its inclusion within policy, due to its ability to proving an overarching framework by which to deliver multifunctional green infrastructure and climate action commitments made locally and nationally.

Comment

Representation ID: 11544

Received: 17/03/2021

Respondent: Yorkshire Wildlife Trust

We feel that section B of this policy could be better worded to incorporate Building with Nature Standards as a mechanism for delivery, supporting the multifunctional aspirations highlighted by the local plan.

Comment

Representation ID: 11545

Received: 17/03/2021

Respondent: Yorkshire Wildlife Trust

We note that these distances have not been amended since our previous response to the 2019 partial review consultation. We previously stated: Due to the sensitivity of the habitats and species present, including to disturbance (through visitor pressure and domestic animals), pollution and hydrological impacts etc. we consider the 400m of Zone A to be extremely minimal and would encourage further consideration of widening of this buffer to at least 1km.

We would also encourage the consideration of the implementation of strategy and policy to mitigate the recreational and air quality impacts on the SAC/SPA site.

Comment

Representation ID: 11547

Received: 17/03/2021

Respondent: Yorkshire Wildlife Trust

Green infrastructure is becoming ever more important, and it is important for inclusion within local policy to ensure local developments deliver multifunctional green spaces that help achieve national goals to become carbon neutral and enhance and reconnect biodiversity, as well as reconnecting people with nature.

Therefore, as stated above, would encourage the inclusion of Building with Nature standards as a means by which multifunctional green infrastructure should be delivered on sites. Whilst we appreciate the anticipation of the Natural England national standards, the recent trials have highlighted the need for incorporating Building with Nature as a mechanism for delivery as the two are very closely aligned, with the Building with Nature framework already developed, functional and supported in practice.

Worth noting that policy documents can also achieve Building with Nature accreditation, hence should this policy be expanded and the requirement for multifunctional green infrastructure be reflected throughout the document.

Comment

Representation ID: 11567

Received: 17/03/2021

Respondent: Yorkshire Wildlife Trust

Pleased to see commitment to at least 10% net gain for biodiversity included within supporting text. To ensure clarity would be better within the policy wording.

Would support rewording of supporting text (4.26.16 onwards) - this is misleading and misrepresents purpose of the mitigation hierarchy and biodiversity net gain (BNG). Should be made clear that the Mitigation Hierarchy is not part of BNG considerations; it is additional to the application of the mitigation hierarchy which must first be considered in line with legislation.

Clarity should be made that loss of and impacts upon designated sites and priority habitats are not appropriate for inclusion within any metric calculations and bespoke compensation will be required, should avoidance not be possible for reasons of overriding public interest.

Policy - Section K - clarity should be made that offsets will need to be secured and maintained/monitored for a minimum of 30 years (BS 8683).

Comment

Representation ID: 11568

Received: 17/03/2021

Respondent: Yorkshire Wildlife Trust

Local Infrastructure Plan - as outlined above, we would welcome inclusion of consideration of Building with Nature Standards throughout this document to ensure good quality multifunctional green infrastructure is delivered.

Object

Representation ID: 11570

Received: 17/03/2021

Respondent: Yorkshire Wildlife Trust

We are disappointed to see that the Bradford Wildlife Habitat Network is not included on the interactive map to allow consideration of the appropriate location of site allocations.

We object to the loss of any of the Wildlife Habitat Network and any such allocations which may directly or indirectly impact upon these areas must commit to retain and enhance the network.

Comment

Representation ID: 11571

Received: 17/03/2021

Respondent: Yorkshire Wildlife Trust

This site lies immediately adjacent to Odsal Wood Local Wildlife Site and ancient woodland (irreplaceable habitat) and is near to Railway Terrace and Raw Nook Local Nature Reserve and Local Wildlife Site and Toad Holes Beck, Local Wildlife Site.

These areas must be protected from any direct or indirect impacts as a result of development, including cumulative impacts and should seek to enhance the condition of all sites and connectivity between them.

Comment

Representation ID: 11573

Received: 17/03/2021

Respondent: Yorkshire Wildlife Trust

This site lies near to Judy Woods, Local Wildlife Site, and ancient woodland (irreplaceable habitat) which should be protected from direct and indirect impacts of development, including increases in footfall and other disturbance as a result of increased population in the local area.

Comment

Representation ID: 11574

Received: 17/03/2021

Respondent: Yorkshire Wildlife Trust

Buck Park Quarry - this site encompasses Buck Park Quarry Local Wildlife Site and as such we object to its inclusion within the allocations. The inclusion of such a site will mean that national and local policy cannot be adhered to due to the loss of habitats of significant biodiversity interest.