SUSTAINABILITY-APPRAISAL-OF-LDF-OPTIONS

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					                                                                                                                                               ANNEX C
SUSTAINABILITY APPRAISAL OF LDF OPTIONS

DRAFT OPTIONS                                SUSTAINABILITY APRRAISAL - SUMMARY                         BOROUGH COUNCIL COMMENTARY

ISSUE – SETTLEMENT IDENTITY                  Option 1 appears to be generally positive,                 The preferred option (option 1) provisionally
                                             maintaining coherent communities, preserving the           agreed by the LDF Panel at the meeting of 21st
Option 1 – Maintain the gaps between         countryside / wildlife and perhaps promoting               April performed well - better than the alternative
settlements                                  tourism. Option 2 generally acts against such              option - in terms of sustainability.
                                             benefits.
Option 2 – Do not maintain the gaps
between settlements


ISSUE – COUNTRYSIDE PROTECTION               Little impact overall from either option – much of the     The preferred option (option 1) provisionally
                                             benefit of SLAs is delivered anyway through Green          agreed by the LDF Panel at the meeting of 21st
Option 1 – Retain the three Special          Belt policy. Insofar as this policy is strengthened, the   April is unlikely to generate negative sustainability
Landscape Areas and include policies in      impact of the SLAs on preserving landscapes will be        effects, overall.
the Core Strategy to conserve and            offset by restrictions on development (with attendant
enhance their landscape character            affordability implications for housing)

Option 2 – Do not retain the three Special
Landscape Areas


ISSUE – RURAL SETTLEMENT                     Allowing development only where existing / potential       The preferred option (option 2) provisionally
HIERARCHY                                    services are available seems to be the most                agreed by the LDF Panel at the meeting of 21st
                                             sustainable option, promoting mix of uses and              April performed well - better than the alternative
Option 1 – Allow minor development (or       reducing the need to travel, although possibly at          option - in terms of sustainability.
in some cases only infilling) within all     some cost to habitats and landscapes.
rural settlements (business-as-usual)

Option 2 – Allow further development
only at those rural settlements which
contain a minimum level of services (or
reasonable access to them) and restrict
new housing at other rural settlements
more remote from services.
DRAFT OPTIONS                               SUSTAINABILITY APRRAISAL - SUMMARY                       BOROUGH COUNCIL COMMENTARY

ISSUE – LEVEL OF AFFORDABLE                 While all three options will deliver affordable          The preferred option (option 3) provisionally
HOUSING                                     housing, it seems likely that the options two and        agreed by the LDF Panel at the meeting of 21st
                                            three would mean a greater proportion of houses          April is unlikely to generate significant negative
Option 1 – Continue to require the          built would be affordable. There is some risk that       sustainability effects. The one concern is that
provision of affordable housing on sites    fewer houses overall might be built if developers find   affordability is considered at odds with the capital
in excess of 25 units across the Borough    it harder to make a profit on a given development, of    cost of installing renewable energy generating
(business as usual)                         course. Affordable houses are less likely to be able     facilities, which may hamper the delivery of SA
                                            to incorporate innovations, such as renewable            objective 18 ' To increase energy efficiency and
Option 2 – Apply the affordable housing     energy sources, therefore options 2 and 3 could          the proportion of energy generated from
requirement to sites of 15 or more          work against the provision of renewables.                renewable sources in the Borough'. However, this
dwellings (or above 0.5ha) across the                                                                issue is addressed, to an extent - although not
Borough (subject to changes in                                                                       directly - through draft policy CP1 of the Core
Government Guidance being confirmed)                                                                 Strategy which seeks the inclusion, where
                                                                                                     appropriate, of renewable energy technologies
Option 3 – Require affordable housing                                                                within developments.
provision on sites of 15 or more
dwellings (or above 0.5ha) in urban areas                                                            Furthermore, Housing Associations are
and sites of 5 or more dwellings (or                                                                 encouraged by the Housing Corporation to be
above 0.17ha) in rural areas (subject to                                                             developing sustainable homes and the new South
changes in Government Guidance being                                                                 East Regional Housing Strategy requires an
confirmed).                                                                                          EcoHomes rating of 'Very Good' to be achieved
                                                                                                     on new homes as a condition of grant funding.
                                                                                                     There are also a range of grants available to
                                                                                                     RSLs for renewable energy, although it has to be
                                                                                                     said that these tend to concentrate on community
                                                                                                     based schemes. In any case, the feasibility of
                                                                                                     incorporating renewable energy technologies is a
                                                                                                     detailed matter that can be addressed at the
                                                                                                     planning application stage through conditions and
                                                                                                     possibly a Section 106 agreement.
DRAFT OPTIONS                                SUSTAINABILITY APRRAISAL - SUMMARY                         BOROUGH COUNCIL COMMENTARY

ISSUE – LOCATION OF AFFORDABLE               Option 2 seems to offer the more sustainable               The preferred option (option 2) provisionally
HOUSING IN RURAL AREAS                       solution, particularly in reducing the need to travel      agreed by the LDF Panel at the meeting of 21st
                                             and ensuring that sufficient affordable houses are         April performed well - better than the alternative
Option 1 – Identify and allocate sites for   built. It is uncertain whether the option will reuse       option - in terms of sustainability.
affordable housing in the countryside        significant amounts of brown field land. It is noted
adjacent to various rural settlements        that according to the Council, there are significant
with a minimum level of services             brownfield opportunities at Borough Green (albeit in
                                             the Green Belt) which are not available elsewhere in
Option 2 – Concentrate the development       the Borough. Equally it is possible that there may
of rural affordable housing at the rural     be enhanced opportunities to incorporate renewable
service centre of Borough Green              energy generation and other aspects of sustainable
                                             design into larger developments.
                                             Option 1 appears unsustainable – limited service
                                             provision in small settlements suggests, in
                                             particular, that there will be increased need to travel
                                             since accessibility is poor by definition. There is also
                                             some doubt about how many affordable houses
                                             would actually get built under this option.


ISSUE – MAJOR DEVELOPED SITES IN             The sites identified for redevelopment have                A few minor concerns, in sustainability terms,
THE GREEN BELT                               generally been redeveloped as housing (since this is       about the preferred option (option 2)
                                             most likely to achieve the environmental                   provisionally agreed by the LDF Panel at the
Option 1 – Employ the criteria in PPG2 to    improvements required given the Green Belt                 meeting of 21st April. Of greatest concern are the
govern the infill or redevelopment of the    designation). Option 1 implies business-as-usual in        last two caveats that only allow housing
sites identified as major developed sites    this respect. Option 2 implicitly acknowledges that        development that makes a positive contribution to
in the Green Belt (business-as-usual)        redevelopment is likely to focus on housing and            the Green Belt and only allow the minimum
                                             introduces various caveats governing future housing        necessary to secure the redevelopment of the
Option 2 – Employ the criteria in PPG2 to    at these sites.     Principal among these is the           site. It was concluded that this could point
govern the infill and redevelopment of       presumption against housing redevelopment in               towards more bespoke executive style housing,
certain sites identified in the Green Belt   locations remote from existing settlements and             which would conflict with SA objective 1 'To help
but introduce caveats which:                 services. This could potentially help to reduce the        ensure that everyone has the opportunity to live in
                                             need to travel with corresponding positive                 a decent, sustainably constructed and affordable
        presume against housing
                                             implications for air quality etc. The caveats also         home'. To mitigate this, the caveats to this option
         development in locations                                                                       will require further clarification, and possible
         remote from existing                include only allowing housing if it makes a positive
                                                                                                        amplification, to avoid this potential outcome. It is
DRAFT OPTIONS                                SUSTAINABILITY APRRAISAL - SUMMARY                          BOROUGH COUNCIL COMMENTARY
         settlements and services;           contribution to the Green Belt and only allow only          considered that PPG2 and the criteria identified in
        allow for housing development       the minimal housing necessary to secure the                 that document provide sufficient guidance to no
         only if it makes a positive         redevelopment of the site. This implies relatively          longer warrant two separate policies to deal with
         contribution to the Green Belt;     low-density executive style housing. It could be            the issues of infilling and redevelopment.
         and                                 helpful for the Council to elaborate on what is meant
                                             by ‘positive contribution’ to the Green Belt.
                                             Given the differences in scale between infilling and
        allow only the minimum              redevelopment it could be advisable to have a policy
         housing necessary to secure         relating to infilling and a further stricter policy on
         the redevelopment of the site       redevelopment since the implications of the latter
                                             will be greater. It is difficult to appraise the
                                             implications of infilling since its impacts are likely to
                                             be minor.

ISSUE – SAFEGUARDED LAND                     The options generally perform well in relation to           The preferred option (option 1) provisionally
                                             objectives for increasing affordable housing and            agreed by the LDF Panel at the meeting of 21st
Option 1 – Continue to identify the          reducing social exclusion since they may provide for        April is unlikely, overall, to generate significant
existing Reserve Sites at Tonbridge          significant levels of housing and affordable housing        negative sustainability effects.
North of Lower Haysden Lane and North        in the future. Since the options potentially involve
of Dry Hill Park Road as Safeguarded         land take for housing they could have generally
Land (business-as-usual)                     adverse implications for biodiversity and the
                                             countryside. Option 2 involves reducing the extent
Option 2 – Alter the extent of the Reserve   of the site (with presumably corresponding
Site North of Lower Haysden Lane to          implications for the number of houses including
avoid the flood plain and higher ground      affordable houses that might ultimately be provided)
on its western margin                        but is beneficial in environmental terms since it
                                             avoids possible future development in the flood
Option 3 – Include the Reserve Site          plain. Option 3 has the most immediate implications
North of Dry Hill Park within the confines   since it involves firmly allocating the Reserve Site
and firmly allocate it for housing (i.e.     North of Dry Hill Park for housing. Option 4 is
delete it as a Reserve Site)                 perhaps the most negative since it involves
                                             removing land from the Green Belt. It should be
Option 4 - Remove land within the line of    noted that there is no certainty that safeguarded
Woodgate Way from the Green Belt and         land will come forward for development and the
identify it as a new Reserve Site            impacts identified at this stage are largely
                                             hypothetical (except for Option 3 which involves an
                                             actual allocation).
DRAFT OPTIONS                                SUSTAINABILITY APRRAISAL - SUMMARY                        BOROUGH COUNCIL COMMENTARY

ISSUE – STRATEGIC GAP                        Impacts are somewhat dependent on the future              The SA is not conclusive about the performance
                                             status of the green wedge designations. It should         of any of the options, in sustainability terms,
Option 1 – Retain and protect the            also be noted that extending the Strategic Gap            although no significant negative effects are
existing Strategic Gap which maintains       across the Bushey Wood Area of Opportunity will           raised.
the separate identities of the urban areas   not mean that no development will occur in the area
of the Medway Towns, Maidstone and           in the longer-term.                                       The SA considers the possibility of the Bushy
the Medway Gap (business-as-usual)                                                                     Wood Area of Opportunity coming forward for
                                             Bushey Wood Area of Opportunity as it stands in the       development during the lifetime of the LDF. If
Option 2 – Extend the Strategic Gap to       current local plan could potentially be used for          there was an identified need for this to happen,
maintain the separation of Maidstone/        housing development after 2011 or before this time        then the appropriate DPDs (Development
Barming from Kings Hill and West             if there is a significant shortfall. Until it’s use for   Allocations and Environmental Protection) would
Malling                                      housing no other form of development will be              be reviewed accordingly and the necessary
                                             permitted.     Approximately 40% of the site is           policies to mitigate environmental impacts and
Option 3 – Extend the Strategic Gap          currently designated as a Site of Nature                  protect important and valued natural resources
across the Area of Opportunity at            Conservation Interest (SNCI), identified as being         and habitats would be proposed and consulted
Bushey Wood                                  regionally important. If development were to be           upon. This would address the concerns raised by
                                             permitted any loss must be mitigated by the               the consultants in their assessment.
                                             reestablishment of the habitat or features lost. A
                                             nationally important scheduled ancient monument (a
                                             Romano-British villa, Anglo-Saxon cemetery and
                                             associated remains at Eccles) lies in the middle of
                                             the site. If the development is of a large enough
                                             size, policy presently states that a primary school
                                             may also be accommodated in the area. The
                                             assumption is made that similar policies are likely to
                                             apply should the site continue to be safeguarded.
                                             Land is currently adjacent to a SSSI at Burham
                                             marshes, and the village of Eccles.
                                             The current local plan states that within the Strategic
                                             Gap, development will not be permitted which
                                             significantly extends the built confines of existing
                                             rural settlements or urban areas or other areas
                                             reserved for development.
DRAFT OPTIONS                              SUSTAINABILITY APRRAISAL - SUMMARY                       BOROUGH COUNCIL COMMENTARY

ISSUE – EAST BANK OF THE MEDWAY            Development on the site could have negative              The preferred option (option 2) provisionally
                                           impacts on nature conservation / biodiversity and        agreed by the LDF Panel at the meeting of 21st
Option 1 – Continue to safeguard the       cultural heritage, although Option 3 will presumably     April is unlikely, overall, to generate significant
exiting land at Bushey Wood as an Area     mitigate these negative impacts to an extent.            negative sustainability effects. Whilst there is
of Opportunity (business-as-usual)         However, it should be noted that in the absence of       concern that negative environmental impacts may
                                           development, nature conservation / biodiversity and      happen, it is considered that future development
Option 2 – Extend the Area of              cultural heritage interests might not be managed to      would bring benefits of management of nature
Opportunity at Bushey Wood to              the degree they might if development were to go          conservation interests and would, significantly,
incorporate the Island Site and the        ahead. The real benefit of Options 1-3 is that land      provided affordable housing at a sustainable
currently active sand workings to the      will be available for housing, including affordable      location.
south of the site                          housing, in a location close to existing urban areas
                                           and making use of brownfield land. There may also
Option 3 – Reduce the extent of the Area   be certain economic benefits both during and after
of Opportunity at Bushey Wood in the       construction. Option 4 – no development – would
light of the acknowledged constraints      preserve the site largely as it is, protecting the
within it                                  existing resources (biodiversity, cultural and mineral
                                           – although perhaps not managing them) but losing
Option 4 – Delete the Area of              the economic / housing benefits of the first three
Opportunity at Bushey Wood                 options. However, this would clearly exert pressure
                                           for development elsewhere in the Borough.

				
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