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.