Draft South Pennine Moors SPA/SAC Planning Framework Supplementary Planning Document

1. The document as drafted does not give enough emphasis or positive support for bespoke on or near site mitigation proposals for both recreation and habitat improvements/linkages etc ( see Dorset Heathlands SPD for a much more positive approach).
2. The title chosen for section 3 "Enabling Development" requires clarification and a distinction in the following text between enabling development to take place via proposed mitigation and the positive enabling contributions which can be made by proactive and co-operative landowners/developers where significant habitat and other environment enhancements can be achieved via the master planning and release of large areas of land associated with enabling residential development.
3. It is necessary to include recognition of the opportunities to create/enhance SANGS and the equivalent of HIPS alongside enabling development which in a number of cases will inevitably be located in tracts of Green Belt close to the urban area and in the 400m-2.5km zone of the SPA/SAC (see again section 4 of the Dorset Heathlands SPD March 2020).
4. In relation to comment 3 above we have already submitted master plan and written proposals to Bradford Council on large sites to the east and west of Ilkley which involve residential development proposals but where the majority of the landholdings are proposed for environmental enhancement, habitat improvements and associated recreation provision. We will also be submitting a major opportunity combining recreation and environmental enhancements in association with the two proposed residential allocations at Addingham (AD3/H & AD4/H). The provision for the delivery of such opportunities should not be excluded from this SPD. Text and clear policy guidance should be included which indicate the circumstances where such initiatives will be supported (see Dorset Heathlands SPD paras 4.18 to 4.21).
5. The document as drafted over-concentrates on the calculation of the recreation tariffs. Further guidance is required for landowners/developers on supporting habitat provision, habitat enhancement, linkages to biodiversity net gain, ecological networks.