Sevenoaks Local Plan 2015-2035

Sustainability Appraisal

SA Report to accompany Draft Local Plan Consultation: Sevenoaks District Local Plan

July 2018

Sevenoaks Local Plan 2015-2035 Sustainability Appraisal (SA) Regulation 18 SA Report

Quality information

Prepared by Checked by Approved by Cheryl Beattie Nick Chisholm-Batten Steve Smith Environmental Planner Associate Technical Director Chris McNulty Environmental Consultant Nick Chisholm-Batten Associate

Revision history

Revision Revision date Details Authorised Name Position V1.0 12th July 2018 Consultation 12th July 2018 Nick Chisholm- Associate version Batten

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© 2018 AECOM Infrastructure & Environment UK Limited. All Rights Reserved.

This document has been prepared by AECOM Infrastructure & Environment UK Limited (“AECOM”) for sole use of our client (the “Client”) in accordance with generally accepted consultancy principles, the budget for fees and the terms of reference agreed between AECOM and the Client. Any information provided by third parties and referred to herein has not been checked or verified by AECOM, unless otherwise expressly stated in the document. No third party may rely upon this document without the prior and express written agreement of AECOM.

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Table of Contents

Introduction

1. Introduction ...... 1 Background ...... 1 Current stage of plan making ...... 3 What is the plan seeking to achieve? ...... 3 2. Sustainability Appraisal for the Sevenoaks Local Plan ...... 5 Sustainability Appraisal (SA) explained ...... 5 This SA Report ...... 5 What is the scope of the SA? ...... 6

Part 1: What has plan making/ SA involved up to this point?

3. Plan making and SA process to date ...... 11 4. Options appraised in 2017 ...... 12 5. Appraisal of development strategy options ...... 15 Housing numbers to deliver through the Local Plan ...... 15 Appraisal of sites for potential allocation ...... 15 Appraisal of spatial strategy options ...... 16 Spatial strategy options assessed ...... 18 Appraisal findings: spatial strategy options ...... 22 Overview of the reasons for choosing the preferred strategy for the Local Plan ...... 33 Latest version of the planning policies ...... 35

Part 2: What are the SA findings at this current stage?

6. Appraisal of policy approaches presented in the latest version of the Sevenoaks Local Plan ...... 37 Purpose of this chapter ...... 37 Approach to the appraisal ...... 37 Biodiversity and Geodiversity ...... 38 Climate Change ...... 42 Landscape and Historic Environment ...... 45 Environmental Quality ...... 49 Land, Soil and Water Resources ...... 51 Population and Communities ...... 53 Health and Wellbeing ...... 56 Transportation ...... 58 Economy ...... 60 Town and Local Centres ...... 62

Part 3: What are the next steps?

7. Next Steps ...... 65 Next steps for plan making / SA process ...... 65

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Appendix A: Spatial strategy options: detailed location of sites ...... 66

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1. Introduction Background 1.1 AECOM has been commissioned to undertake an independent Sustainability Appraisal (SA) in support of Sevenoaks District Council’s emerging Local Plan.

1.2 Sevenoaks District Council is currently preparing a new Local Plan to replace the Core Strategy (adopted Feb 2011) and the Allocations and Development Management Plan (adopted Feb 2015). The new Local Plan, which will cover the period to 2035, will include strategic and detailed planning and development management policies, land allocations for housing, employment and mixed uses and identify areas in the District for protection.

1.3 Key information relating to the Local Plan is presented in Table 1.1.

Table 1.1: Key facts relating to Sevenoaks Local Plan 2015-2035

Name of Responsible Authority Sevenoaks District Council (SDC)

Title of Plan Sevenoaks Local Plan 2015-2035

Subject Spatial plan

Purpose The Sevenoaks Local Plan will set out the strategy for future growth within Sevenoaks District in the period to 2035. It will replace the saved policies of previous Core Strategy (February 2011) and the Allocations and Development Management Plan (February 2015).

Timescale To 2035

Area covered by the plan Sevenoaks District.

(Figure 1.1)

Summary of content The Sevenoaks Local Plan will present the spatial vision for the District, strategic planning policies, development management policies, site specific allocations and proposals map.

Plan contact point Helen French, Planning Policy, Sevenoaks District Council

Email address: [email protected]

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Current stage of plan making 1.4 This SA Report accompanies the current consultation on the Local Plan (Sevenoaks District Draft Local Plan: Consultation July 2018).

1.5 At the current stage of plan-making SDC is consulting on a draft plan. The current draft Local Plan is being consulted on under Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations.

1.6 The consultation follows previous consultation undertaken on ‘Issues and Options’ for the Local Plan, which was undertaken in July 2017.1 The aim of the Issues and Options consultation was to gain stakeholders’ views on the approach Local Plan policies could take on various key planning issues, including alternative development strategies for the District. The document was an initial stage in developing the Local Plan.

1.7 The current draft plan consultation precedes the release of the Local Plan for further ‘Regulation 19’ consultation in November 2018. Drawing on consultation responses received at the current stage of plan-making and new evidence base studies undertaken to inform the Local Plan, the forthcoming Regulation 19 document will set out the proposed policies for the Local Plan, including a preferred development strategy for submission to the Secretary of State. What is the plan seeking to achieve? 1.8 The vision and objectives for the Local Plan were developed during initial stages of plan making.

1.9 The vision for the Local Plan is as follows:

“Sevenoaks District will strive to meet housing and employment needs without compromising the built and natural environment that is cherished by people who live, work and relax in the area. We will work with partners to ensure that growth is accompanied by a wide range of supporting infrastructure, particularly for education, health, transport and open space. Sevenoaks District will continue to thrive as a desirable place where people choose to build their lives.

People and Housing

The District is made up of patchwork of distinct communities with strong local character and we will protect this local identity for existing and future generations. People will be safe and healthy and proud of the area in which they live and work. There will be a choice of accommodation to meet the needs of the residents of the District, including affordable housing and homes for older people.

The District will help the delivery of new homes in a sustainable way, by making effective use of urban land within existing settlements and other brownfield land, thereby continuing to protect the Green Belt. Green Belt boundaries will only be altered in ‘exceptional circumstances’.

Jobs and the Economy

The potential of the District’s accessible location along major transport routes will be maximised to ensure a dynamic local economy, both urban and rural. The range of employment opportunities available in the District will be maintained and strengthened, and town centres will be the focus for retail and leisure opportunities. Broadband connectivity will be widely established, particularly to support rural communities and the visitor economy will be thriving. The District will benefit from the delivery of new employment opportunities, especially in offices. Retail and leisure activity in the town centres will be thriving. Challenges associated with the M25 (including air quality) and infrastructure provision (particularly medical and education

1 Sevenoaks District Council (July 2017) Local Plan Issues & Options Consultation Document

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facilities) are recognised and we will work with partners to facilitate improvements in these areas.

Nature and the Environment

All of the District’s landscapes, habitats, historic and heritage assets, including the two Areas of Outstanding Natural Beauty, will continue to be conserved and enhanced in a way which protects local identity and distinctiveness. New development will be of high quality sustainable design responding to local character.”

1.10 Implementing this vision, the Local Plan has the following six objectives:

Table 1.2: Sevenoaks Local Plan objectives

Topic Objective ‘Housing’ 1. Promote housing choice for all

‘Natural and Built 2. Promote well designed, safe places and safeguard and enhance the Environment’ District’s distinctive high quality natural and built environments ‘Economy’ 3. Support a vibrant local economy both urban and rural

‘Infrastructure’ 4. Support lively communities with well performing town and village centres which provide a range of services, facilities and infrastructure ‘Health’ 5. Promote healthy living opportunities

‘Green Future’ 6. Promote a greener future

1.11 In the context of the above vision and objectives, the current version of the Local Plan sets out the following:

 A proposed spatial strategy for the District.  A series of proposed planning policies to guide development in the District to 2035.  Proposed site allocations and policies for housing, mixed use development and employment uses.

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2. Sustainability Appraisal for the Sevenoaks Local Plan Sustainability Appraisal (SA) explained 2.1 SA considers and communicates the likely significant effects of an emerging plan, and the reasonable alternatives considered during the plan making process, in terms of key sustainability issues. The aim of SA is to inform and influence the plan-making process with a view to avoiding or mitigating negative effects and maximising positive effects. Through this approach, the SA seeks to maximise the emerging Local Plan’s contribution to sustainable development.

2.2 An SA is undertaken in line with the procedures prescribed by the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations) which transpose into national law the EU Strategic Environmental Assessment (SEA) Directive.2 SA also widens the scope of the assessment from focusing on environmental issues to also include social and economic issues.

2.3 The SEA Regulations require that a report is published for consultation alongside the draft plan that ‘identifies, describes and evaluates’ the likely significant effects of implementing ‘the plan, and reasonable alternatives’. The report must then be taken into account, alongside consultation responses, when finalising the plan.

2.4 The ‘likely significant effects on the environment’, are those defined in Annex I of the SEA Directive as ‘including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors’. Reasonable alternatives to the plan need to take into consideration the objectives for the plan and its geographic scope. The choice of 'reasonable alternatives' is determined by means of a case-by-case assessment and a decision.3 This SA Report 2.5 At the current stage of plan-making, SDC is consulting on a Draft Local Plan under Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations.

2.6 This report has therefore been produced with the intention of informing this stage of preparation of the Local Plan. Specifically, this report presents an appraisal of the proposed Local Plan, and reasonable alternatives. This is for the benefit of those who might wish to make representations through the consultation and for the benefit of the plan-makers tasked with selecting preferred approaches for the Local Plan.

2.7 This SA Report has been structured into three parts, as follows:

 Part 1 provides an outline of plan making to date, in association with the parallel SA process  Part 2 assesses the current version of the Local Plan, which this SA Report accompanies for consultation  Part 3 sets out the next steps for the Local Plan/ SA process.

2 Directive 2001/42/EC 3 Commission of the European Communities (2009) Report from the Commission to the Council, The European Parliament, The European Economic and Social Committee and the Committee of the Regions on the application and effectiveness of the Directive on Strategic Environmental Assessment (Directive 2001/42/EC). (COMM 2009 469 final).

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What is the scope of the SA?

SA Scoping Report 2.8 The SEA Regulations require that: “When deciding on the scope and level of detail of the information that must be included in the report, the responsible authority shall consult the consultation bodies”. In England, the consultation bodies are the Environment Agency, Historic England and Natural England.4 These authorities were consulted on the scope of the Local Plan SA in September 2016.

2.9 The baseline information (including baseline data and context review) initially included in the SA Scoping Report has been updated in the period since 2016 and provides the basis for the SA process. SA Framework 2.10 Drawing on the review of the sustainability context and baseline, the SA Scoping Report identified a range of sustainability problems / issues that should be a particular focus of SA, ensuring it remains targeted. These issues were then translated into an SA ‘framework’ of objectives and appraisal questions.

2.11 The SA Framework provides a way in which the sustainability effects of the Local Plan and alternatives can be identified and subsequently analysed based on a structured and consistent approach.

2.12 The SA Framework and the appraisal findings in this Interim SA Report have been presented under ten SA Themes, reflecting the range of information being considered through the SA process. These are:

 Biodiversity  Climate Change  Landscape and Historic Environment  Environmental Quality  Land, Soil and Water Resources  Population and Communities  Health and Wellbeing  Transportation  Economy  Town and Local Centres 2.13 The SA Framework is presented in Table 2.1 below.

4 In line with Article 6(3).of the SEA Directive, these consultation bodies were selected because “by reason of their specific environmental responsibilities,[they] are likely to be concerned by the environmental effects of implementing plans and programme”.

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Table 2.1: SA Framework for the Sevenoaks Local Plan 2015-35

SA Themes SA Objectives Appraisal questions: Will the option/proposal help to... Biodiversity and Protect and enhance all biodiversity and geological  Support continued improvements to the status of the SSSIs present in the District? geodiversity features  Protect and enhance semi-natural habitats?  Protect and enhance priority habitats, and the habitat of priority species?  Enhance regional ecological networks?  Support the provisions of the Kent Biodiversity Strategy, including relating to Biodiversity Opportunity Areas?  Achieve a net gain in biodiversity?  Protect and enhance the District’s rich geodiversity resource?  Support access to, interpretation and understanding of biodiversity and geodiversity? Climate change Promote climate change mitigation in Sevenoaks  Promote the use of sustainable modes of transport, including walking, cycling and District public transport?  Reduce the need to travel?  Promote use of energy from low carbon sources?  Reduce energy consumption and increase efficiency? Support the resilience of Sevenoaks District to the  Ensure that no development takes place in areas at higher risk of flooding, taking potential effects of climate change into the likely effects of climate change into account?  Sustainably manage water run-off, ensuring that the risk of flooding is not increased (either within the plan area or downstream) and where possible reduce flood risk?  Improve green infrastructure networks in the District area to support adaptation to the potential effects of climate change? Landscape and Protect, maintain and enhance Sevenoaks  Conserve, and where possible, enhance cultural heritage assets and their Historic Environment District’s cultural heritage resource, including its settings? historic environment and archaeological assets.  Conserve, and where possible, enhance the District’s conservation areas?  Reduce the number of features and areas in the District deemed to be ‘at risk’?  Support access to, interpretation and understanding of the historic environment? Protect and enhance the character and quality of  Support the integrity of the Kent Downs AONB, including in conjunction with the Sevenoaks District’s landscapes and townscapes. provisions of the AONB Management Plan?  Support the integrity of the High Weald AONB, including in conjunction with the provisions of the AONB Management Plan?  Conserve and enhance landscape and townscape character?

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SA Themes SA Objectives Appraisal questions: Will the option/proposal help to...  Conserve and enhance local diversity and distinctiveness?  Support the integrity of the District’s conservation areas?  Preserve the historic settlement pattern of the District? Environmental Improve air, soil and water quality.  Maintain or improve local air quality? Quality  Promote the remediation of contaminated land?  Protect and improve the area’s chemical & biological water quality?  Protect groundwater resources? Land, Soil and Water Ensure the efficient use of land.  Avoid the use of land classified as the best and most versatile agricultural land? Resources  Promote the use of previously developed land? Promote sustainable waste management solutions  Reduce the amount of waste produced? that encourage the reduction, re-use and recycling  Move waste up the waste hierarchy? of waste. Use and manage water resources in a sustainable  Minimise water consumption? manner. Population and Provide everyone with the opportunity to live in  Support the provision of a range of house types and sizes? Communities good quality, affordable housing, and ensure an  Support enhancements to the current housing stock? appropriate mix of dwelling sizes, types and  Meet the needs of all sectors of the community? tenures.  Provide quality and flexible homes that meet people’s needs?  Promote the use of sustainable building techniques, including use of sustainable building materials in construction?  Provide housing in sustainable locations that allow easy access to a range of local services and facilities? Cater for existing and future residents’ needs as  Promote the development of a range of high quality, accessible community well as the needs of different groups in the facilities? community, and improve access to local, high-  Encourage and promote social cohesion and encourage active involvement of quality community services and facilities. local people in community activities? Reduce deprivation and promote more inclusive  Minimise fuel poverty? and self-contained communities.  Maintain or enhance the quality of life of residents?  Improve the availability and accessibility of key local facilities, including specialist services for disabled and older people? Health and Wellbeing Improve the health and wellbeing of Sevenoaks  Promote accessibility to a range of leisure, health and community facilities for all District’s residents. age groups?  Encourage healthy lifestyles and reduce health inequalities?

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SA Themes SA Objectives Appraisal questions: Will the option/proposal help to...  Enhance multifunctional green infrastructure networks in the District?  Provide and enhance the provision of community access to green infrastructure?  Improve access to the countryside for recreation?  Enhance the energy efficiency and quality of the housing stock? Transportation Promote sustainable transport use and reduce the  Reduce the need to travel through sustainable patterns of land use and need to travel. development?  Encourage modal shift to more sustainable forms of travel?  Enable transport infrastructure improvements?  Facilitate working from home and remote working? Economy Promote the economic vitality of Sevenoaks  Support the economic vitality and viability of the District’s settlements? District.  Create opportunities for a variety of businesses to flourish in the District?  Enable transport infrastructure improvements?  Support the rural economy?  Support the visitor economy?  Facilitate working from home, remote working and home-based businesses?  Enhance educational opportunities? Town and Local Promote the vitality of Sevenoaks District’s Town,  Support the vitality and viability of Sevenoaks District’s Town, Local, Centres Neighbourhood and Village centres. Neighbourhood and Village Centres?  Support the retail offer of Sevenoaks, Swanley, Edenbridge and Westerham town centres, including retail markets?  Promote a daytime and night time economy of Sevenoaks, Swanley, Edenbridge and Westerham town centre?  Preclude the development of out of centre shopping precincts?  Promote the local offer of the District’s Local Service Centres, Neighbourhood Centres and Village Centres?

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Part 1: What has plan making/ SA involved up to this point?

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3. Plan making and SA process to date

3.1 The aim of Part 1 of this SA Report is to explain work undertaken between 2017 and 2018 to develop and then appraise reasonable alternatives. It also seeks to explain how the Council has taken into account the findings of the appraisal of reasonable alternatives when developing the latest version of the draft Local Plan. Presenting this information is important given regulatory requirements.5

3.2 Preparation of the Sevenoaks Local Plan 2015-2035 began in 2015. As highlighted above, one consultation has been undertaken to date, on Local Plan Issues and Options.

3.3 Figure 3.1 below summarises the key documents prepared to date as part of the Local Plan and SA processes.

Figure 3.1: Key outputs of the Sevenoaks Local Plan and accompanying SA process to date

3.4 A key element of the SA process is the appraisal of ‘reasonable alternatives’ for the Local Plan. The SEA Regulations6 are not prescriptive as to what constitutes a reasonable alternative, stating only that the SA Report should present an appraisal of the ‘plan and reasonable alternatives taking into account the objectives and geographical scope of the plan’.

3.5 The focus of reasonable alternatives development has been with respect to the spatial strategy and the allocation of land in the District. The following chapters therefore describe how the SA process to date has informed the preferred spatial strategy for the District and potential locations for proposed development. Specifically, the chapters explain how the Local Plan’s spatial strategy has been developed in terms of housing numbers and distribution.

5 There is a requirement for the SA Report to present an appraisal of ‘reasonable alternatives’ and ‘an outline of the reasons for selecting the alternatives dealt with’. 6 Environmental Assessment of Plans and Programmes Regulations 2004

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4. Options appraised in 2017

4.1 The Interim SA Report (July 2017) accompanying the Local Plan - Issues and Options document appraised options for a number of plan issues. The aim of the consultation was to gain stakeholders’ views on the approach Local Plan policies could take on various key planning issues, including high level alternative spatial strategies for the District. In this context options for eight issues were appraised, as follows:

 Broad development strategy options for housing  Options for meeting affordable housing need in the District  Options for delivering affordable housing in rural areas  Options for providing housing for older people  Options for delivering Gypsy and Travellers accommodation  Options for the redevelopment of existing employment land for non-residential uses  Options for undertaking retail impact assessments  Options for allocating new retail floorspace

4.2 A key element of the appraisal was the assessment of options for the first issue above, relating to broad development strategy options for housing. This considered alternative approaches to housing growth, or ‘development strategy alternatives’. Given that presenting a development strategy for housing is at the heart of the plan objectives, early alternatives appraisal provided a focus on this matter.7

4.3 In light of this, the Council identified five different approaches that endeavour to accommodate the housing need identified for the District, which were subsequently appraised through the SA proces. The five options were as follows:

Option H1: Brownfield Green Belt

4.4 Option H1 seeks to maximise development of available brownfield sites in the District. In addition to maximising supply through directing development to brownfield sites within the District’s settlements, it also directs development to available brownfield sites within the Green Belt.

4.5 Brownfield or ‘Previously Developed Land’ (PDL) is defined in national policy (NPPF) as land “which is or was occupied by a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed) and any associated fixed surface infrastructure”. The NPPF then lists a number of exclusions such as land that has been used for agriculture and forestry, minerals and waste workings.

4.6 However, for the purposes of the identification of potential land, ‘brownfield’ land was defined in the widest sense i.e. land that has been previously developed (is no longer a green field), without considering the exclusions outlined in the National Planning Policy Framework (NPPF). This is referred to in the Draft Local Plan as ‘Locally Defined Brownfield’.

4.7 In addition to the Call for Sites process, through which landowners across the District were asked to submit land that might be suitable for development for consideration by the Council, SDC has contacted every Town and Parish Council in the District to understand if there are other brownfield sites in their areas which may be suitable. This

7 Recent case-law (most notably Friends of the Earth vs. Welsh Ministers, 2015) has established that planning authorities may apply discretion and planning judgement when determining what should reasonably be the focus of alternatives appraisal.

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combined process has yielded sites which could accommodate approximately 1,500 units on suitable brownfield land in the Green Belt.8

4.8 Overall it is anticipated that this option will yield in the region of 6,500 dwellings (including existing commitments, windfall, and non-green belt sites), which is just over 50% of the OAHN for the District.

Option H2: Green Belt land adjacent to higher-tier settlements

4.9 In addition to maximising supply through directing development to brownfield sites within the District’s settlements, Option H2 enables the allocation of housing on sites within the Green Belt in the District where ‘exceptional circumstances’ can be proven.

4.10 SDC are monitoring a number of different initiatives in relation to the top tier settlements within the District which may eventually have the potential to provide exceptional circumstances for Green Belt release. Although the NPPF does not define exceptional circumstances, the Local Plan will seek to interpret national policy in order to provide clearer guidance. For example, exceptional circumstances may occur where new housing development achieves the sustainable reuse of brownfield land; ensures the delivery of new and needed key infrastructure; is needed to achieve regeneration and/or helps achieve significant compensatory improvements in the Green Belt.

Option H3: Brownfield Green Belt and Green Belt land adjacent to higher-tier settlements

4.11 Option H3 comprises a hybrid of Option H1 and H2. In addition to maximising supply through directing development to brownfield sites within the District’s settlements, Option H3 potentially enables development to take place on brownfield sites within the Green Belt and on sites within the Green Belt in the District where ‘exceptional circumstances’ can be proven to apply.

Option H4: Housing delivery through a large urban extension or a new settlement

4.12 In addition to maximising supply through directing development to brownfield sites within the District’s settlements, Option H4 enables the delivery of a large urban extension or a new settlement.

4.13 During 2016, SDC consulted on the option of a Swanley Garden Village for 3,000 new homes as part of the Swanley Master Vision. After giving consideration to consultation responses received, SDC has resolved not to promote a garden village as part of the regeneration options for Swanley, and will instead focus on options that do not entail as much Green Belt release. More recently, substantial areas of land that could accommodate new settlements or larger scale development have been submitted to SDC through the call for sites process. Whilst these sites are in the Green Belt, they will be assessed in the same way as other sites received under the call for sites process. They will form part of an updated SHELAA in 2018.

Option H5: Housing delivery on Green Belt land near transportation hubs

4.14 In addition to maximising supply through directing development to brownfield sites within the District’s settlements, the option seeks to enable development within the Green Belt on weakly performing Green Belt land near transportation hubs.

4.15 This partially responds to the recent Housing White Paper (2017) which suggests that ‘when carrying out Green Belt review, local planning authorities should look first at using any Green Belt land which has been previously developed and/or which surrounds transport hubs’. It is suggested that this is a reference to public transport hubs, such as train stations and bus interchanges. This approach will be considered in more detail once the Government provides additional clarification as to what it considers constitutes a ‘transport hub’ and also as further local evidence is gathered. The potential housing yield from this option is not yet known.

8 Category 2 and 3 sites, SDC (April 2017) Strategic Housing and Economic Land Availability Assessment (SHELAA) http://cds.sevenoaks.gov.uk/mgAi.aspx?ID=8418

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4.16 Further detail on these options appraised at this stage of the SA process and their appraisal is presented in the Interim SA Report which can be accessed at:

https://www.sevenoaks.gov.uk/downloads/file/987/interim_sustainability_assessment_sa_report

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5. Appraisal of development strategy options Housing numbers to deliver through the Local Plan 5.1 In September 2015, an estimate of objectively assessed housing need (OAHN) for Sevenoaks District was published in the Sevenoaks and Tunbridge Wells Strategic Housing Market Assessment (SHMA).9

5.2 The September 2015 OAHN, which had regard to relevant underlying trends (including the latest available demographic projections, anticipated economic growth and market signals), established a need for 12,400 dwellings to be delivered in the District over the period 2013-2033. This equates to an annual average of 620 new dwellings per annum.

5.3 In September 2017, the Department for Communities and Local Government (now Ministry of Housing, Communities and Local Government, MHCLG) published a consultation on a new methodology for determining OAHN. This set out a new ‘standardised approach’ for assessing housing need which would be implemented through revisions to the NPPF.

5.4 Given the timeframes for Local Plan, the Local Plan should take account of the new methodology, which is based on the latest published household projections produced by the ONS adjusted to take account of affordability issues. For Sevenoaks, this means an increase from 12,400 homes to 13,960 homes over the plan period from 2015 to 2035.

5.5 This equates to the delivery of 698 new homes each year. By means of comparison, 250 homes have been delivered on average each year in Sevenoaks District since 2008, and the Core Strategy target is 165 homes per year. As such, OAHN is significantly higher than historic delivery rates. Appraisal of sites for potential allocation 5.6 To support the consideration of which sites to potentially allocate through the Local Plan, various site assessments have been undertaken through the Local Plan process.

5.7 Between 2015 and 2018 Sevenoaks District Council has undertaken an ongoing Call for Sites. This process will be ongoing until the publication of the draft Local Plan at Regulation 19 consultation. The purpose of the Call for Sites has been to invite local residents, landowners, developers, businesses and other interested parties to put forward sites for development within Sevenoaks District that might be suitable for future development and inclusion in the new Local Plan.

5.8 These sites were then considered through the Strategic Housing and Economic Land Availability Assessment (SHELAA) process, undertaken by SDC in 2017 and updated in 2018. A further update of the SHELAA is planned for publication in late 2018, to include assessments of new sites submitted after October 2017. The purpose of the SHELAA was to establish the amount of land that is available and suitable to meet the District’s housing and employment needs. In addition to the sites submitted through the Call for Sites, existing allocations were also considered in the SHELAA.

5.9 The SHELAA includes:

 A plan of each site showing the relevant constraints;  An assessment of the suitability, availability and achievability of each site; and

9 GL Hearn (September 2015). Sevenoaks & Tunbridge Wells Strategic Housing Market Assessment: Final Report https://www.sevenoaks.gov.uk/downloads/file/699/strategic_housing_market_assessment_shma_september_2015

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 An estimated development capacity that could be delivered on each site assessed to be suitable. 5.10 To support the SHELAA process, a separate appraisal of each of the c.450 sites was also undertaken through the SA process, with the aim of informing the proposed allocation of sites through the Local Plan. Evaluating the constraints and opportunities on each site, the sites were appraised through the SA against a set of consistent criteria which were developed specifically for the SA process. Based on these criteria, a ‘red/amber/green’ rating was then applied to each site for each criterion to provide an indication of site constraints and opportunities and the relative sustainability merits of the sites.

5.11 The findings of the appraisal of the sites undertaken through the SA process, accompanied by an explanation of the criteria utilised for the appraisal, is presented in the Local Plan Site Appraisals document accompanying the Draft Local Plan Consultation. This can be accessed with the Draft Local Plan consultation paper at www.sevenoaks.gov.uk/draftlocalplan . Appraisal of spatial strategy options 5.12 The need to develop a broad growth strategy for the District was identified early on in the development of the Local Plan. As such, it was recognised that this issue should be addressed via appraisal of reasonable alternatives through the SA process.

5.13 As discussed above, the sites which have come forward through the Local Plan Call for Sites have been considered for their suitability, availability and achievability through the SHELAA process. This was supported by the appraisal of the sites undertaken through the SA process.

5.14 Whilst the SHELAA and appraisal of sites undertaken through the SA process provided details on the suitability and sustainability of sites, they did not consider any policy constraints or site specific information that could be material considerations in any decision to allocate. As such SDC undertook a deliverability assessment for all sites, which allowed these elements to be considered. This included through potentially enabling suitable brownfield sites and greenfield sites in the Green Belt to be delivered where social and community infrastructure is proposed.

5.15 Essentially, the deliverability assessment introduced a policy-on approach. This was particularly important given the significant constraints that exist within the District, including 93% Green Belt and 60% AONB coverage.

5.16 The deliverability assessments considered the following issues:

 Whether an existing use would be lost;  Any access requirements;  For sites within the Green Belt, whether the Green Belt in that location is performing well and if there are any boundary issues;  Any viability issues;  Whether new social and community infrastructure is proposed;  Whether any input from technical specialists is required; and  Any other site specific considerations. 5.17 Taking account of the SHELAA, SA and deliverability assessment findings, SDC assigned a colour category to each site considered with regards to whether the site would be included in the Draft Local Plan for consultation. These site appraisal conclusion categories were:

Green sites (include in Plan):

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The site is consistent with the Local Plan Strategy and:

 There are no overriding constraints to restrict development;  The development is unlikely to have an impact on any protected land, heritage assets;  There are no site specific issues which are likely to be insurmountable e.g. access;  The site is deliverable with no viability issues; and  The proposed loss of the existing use is acceptable. Yellow sites (Include in Plan, subject to further information):

The site is consistent with the Local Plan Strategy but more information is required to assess if:

 There are no overriding constraints to restrict development  The development is unlikely to have an impact on any protected land, heritage assets;  There are no site specific issues which are likely to be insurmountable e.g. access;  The site is deliverable;  The proposed infrastructure and/or community benefits relate to an evidenced local need; and  The proposed loss of the existing use has not yet been assessed. Orange sites (not currently for inclusion in this plan (contrary to strategy):

The site is not consistent with the Local Plan Strategy but has no overriding issues which may make it unsuitable including if:

 The site is promoted for housing and is greenfield with no proposed infrastructure and/or community benefits to warrant exceptional circumstances in accordance with the strategy; and/or  The site is promoted for housing and is part greenfield, part PDL/brownfield on the edge of a settlement where the PDL/brownfield element alone would result in a site not capable of accommodating at least 5 units and the site does not meet the criteria for greenfield exceptional circumstances. Red sites (not for Inclusion in plan):

The site is not appropriate for development (if one or more of the following applies):

1. The site lies within an area of land wholly or mostly designated as an “absolute constraint”:  Site of Special Scientific Interest  National or European designated site  Floodplain 3b  Scheduled Ancient Monument  Registered Park and Garden  Ancient Woodland 2. The site lies within an area of land wholly or mostly designated as:  Local Wildlife Site  Floodplain 3a  Local Nature Reserve  Historic Park and Garden in Kent (local designation) 3. The site is greenfield, does not lie adjacent to an existing settlement Green Belt boundary, is considered to be in an unsustainable or unsuitable location.

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4. The site lies within the strategic gap between Green Belt settlements. 5. The site cannot be developed due to impacts or restrictions unlikely to be overcome, including but not limited to:  Impact on the Area of Outstanding Natural Beauty  Inadequate access arrangements  Impact on air quality or impact of an AQMA  Loss of habitat and impact on biodiversity and wildlife  Existing allocations for a protected use  Sites with multiple constraints  Overdevelopment of site  Development will have a detrimental impact on local character Spatial strategy options assessed 5.18 In light of the OAHN established for Sevenoaks District, and the new methodology for assessing housing needs emerging through revisions to the NPPF (Section 5.1), three spatial strategy options were developed and have been appraised through the SA process. These reflect different approaches to delivering and distributing housing in the District, including in light of the challenges for housing delivery in the District relating to the significant constraints present locally. The options draw on the categories outlined above by putting forward three approaches for delivering sites for allocation through the Local Plan.

5.19 The three options developed for the purposes of the SA process are presented in Table 5.1 below.

Table 5.1: Options considered as spatial strategy alternatives

Spatial Total capacity of sites under this distribution Sites considered under option option option Option 1 220 dwellings Green sites Option 2 8,712 dwellings Green sites and yellow sites Option 3 13,706 dwellings Green sites, yellow sites and orange sites

5.20 The following three maps highlight the District-wide distribution of the sites considered under each option, with Appendix A presenting more detailed maps presenting the boundaries of the relevant sites.

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Appraisal findings: spatial strategy options 5.21 The spatial strategy options presented above have been appraised against the SA Framework developed during the scoping stage of the SA and presented under the SA themes (Section 2.13).

5.22 In undertaking the appraisal, the proposed options were reviewed to determine the likelihood of positive or negative effects under each SA theme.

5.23 Where a causal link between the options and SA themes was established, impacts were identified on the basis of professional judgment with reference to the evidence base. The appraisal was undertaken with reference to the criteria in Schedule 1 of the SEA Regulations, that is:

 the probability, duration, frequency and reversibility of the effects;  the cumulative nature of the effects;  the transboundary nature of the effects;  the risks to human health or the environment (for example, due to accidents);  the magnitude and spatial extent of the effects (geographical area and size of the population likely to be affected);  the value and vulnerability of the area likely to be affected due to- o special natural characteristics or cultural heritage; o exceeded environmental quality standards or limit values; or o intensive land-use; and o the effects on areas or landscapes which have a recognised national, community or international protection status. 5.24 Every effort was made to predict effects accurately; however, this is inherently challenging given the strategic nature of the options considered. Because of the uncertainties involved, there was a need to exercise caution when identifying and evaluating significant effects and ensure that assumptions were explained in full. In many instances it was not possible to predict significant effects, but it was possible to comment on the merits (or otherwise) of the options in more general terms.

5.25 The appraisal findings are summarised below. These have been presented in a series of tables which present the findings of the assessment by SA theme.

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Table 5.2: Biodiversity and Geodiversity

Spatial strategy options Option 1: 220 dwellings Green sites Option 2: 8,712 dwellings Green sites and yellow sites Option 3: 13,706 dwellings Green sites, yellow sites and orange sites Whilst the significance of the effects from each option on features and areas of biodiversity interest largely depends on the location, scale and nature of development and the incorporation of biodiversity enhancement measures, it can be considered that a higher level of housing development in an area increases the likelihood (and potential magnitude) of negative effects on the designated and non-designated sites present in the vicinity of the area. This is linked to an increased likelihood of direct effects, such as from land take, disturbance or the loss of key features of ecological value, and an increased likelihood of indirect effects, such as from a reduction of ecological connectivity, and changes in land use patterns. In this context, Option 3, and to a lesser extent, Option 2, through delivering a significantly higher level of housing provision in the District, has greater potential for negative effects of a greater magnitude than the other options, including on habitats and ecological networks; however, there remains an element of uncertainty given that the effects are still largely dependent upon other factors such as siting and massing, and the integration of biodiversity enhancements. In terms of nationally designated nature conservation sites, 18 Sites of Special Scientific Interest (SSSIs) are present in Sevenoaks District, which amounts to approximately 4% of the total land area. SSSI Impact Risk Zones (IRZs) are a GIS tool/dataset which maps zones around each SSSI according to the particular sensitivities of the features for which it is notified. They specify the types of development that have the potential to have adverse impacts at a given location. Natural England is a statutory consultee on development proposals that might impact on SSSIs. A large proportion of the District’s land area is within an SSSI IRZ for the types of development which may take place through the Local Plan. In relation to Sevenoaks town, the whole of the town is within an IRZ for one or more SSSIs. In terms of the Sevenoaks Gravel Pits SSSI, which is located to the north of the town, Option 1 does not propose any sites within an IRZ for the SSSI in terms of the type of development likely to be taken forward through the option. Option 2 however proposes nine sites within an IRZ for the SSSI in terms of the type of development likely to be taken forward, and Option 3 proposes twelve sites. As such both Option 2 and 3 have the potential to lead to significant effects on the integrity of the SSSI without appropriate mitigation and avoidance measures. With regards to the Great Brickworks SSSI, Option 2 and Option 3 would both allocate a site which would cover the whole of the SSSI. Option 1 is therefore the only option which has limited potential for significant negative effects on the site. In relation to the Knole Park SSSI, Option 3 allocates one site within an IRZ for the SSSI for the type of development likely to be taken forward through the option. Option 3 also allocates one site within the applicable IRZ for the Dryhill SSSI. Option 1 and 2 do not allocate sites within the appropriate IRZs for the two SSSIs. In relation to the other SSSIs in the vicinity of Sevenoaks, none of the options propose allocations within a relevant IRZ for Hubbard’s Hill SSSI. With regards to the SSSIs in the wider vicinity of Swanley, namely the Farningham Woods SSSI and the Ruxley Gravel Pits, none of the options propose allocations within an IRZ for the type of development likely to be taken forward through the option. Westerham is heavily constrained by the presence of the Westerham Woods SSSI. The IRZ for the SSSI relating to “All planning applications (except householder) outside or extending outside existing settlements/urban areas affecting greenspace, farmland, semi natural habitats or landscape features such as trees, hedges, streams, rural buildings/structures” covers the whole town. In this regards, Option 1 allocates one site within this IRZ, Option 2 allocates seven sites within the IRZ, and Option 3 allocates eight sites within the IRZ. Options 2 and 3 therefore have increased potential for significant negative effects on the SSSI. None of the sites put forward through the options in the vicinities of Edenbridge, Hartley, New Ash Green, South Darenth, Horton Kirby, West Kingsdown are within SSSI IRZs for the type of development likely to be proposed. In terms of locally designated sites, one of the sites proposed through Option 1 intersects with a Local Wildlife Site (at Crockenhill). In terms of Option 2, seven of the sites intersect with a Local Wildlife Site (including at Kemsing, Badgers Mount, Edenbridge, Halstead and West Kingsdown) and four sites (including at West Kingsdown, Edenbridge and Hartley) are within 50m of a Local Wildlife Site. Option 3 puts forward further allocations which are within 50m of a Local Wildlife Site, including at Knockholt and Bessels Green. To support the choice of site allocations, an analysis of the biodiversity value of each site was undertaken, and scores provided for each site, based on a ‘high’, ‘medium’ or ‘low’ value. In this context Option 1 would allocate three sites which have been determined to be of high biodiversity value, Option 2 would allocate 28 sites of high biodiversity value and Option 3 would allocate 45 sites of high biodiversity value. The significance of the effects from each option on features and areas of geodiversity interest largely depends on the location of the proposed development, with effects of development typically limited to direct effects on the site in question and its immediate surroundings. Unlike biodiversity, effects on geodiversity are less likely to occur over a wider scale.

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Table 5.3: Climate Change

Spatial strategy options Option 1: 220 dwellings Green sites Option 2: 8,712 dwellings Green sites and yellow sites Option 3: 13,706 dwellings Green sites, yellow sites and orange sites In assessing the impact of the options on climate change, impacts on the following have been considered:  Climate change mitigation; and  Climate change adaptation. Climate change mitigation Road transport is a significant contributor to greenhouse gas emissions in Sevenoaks District. High car dependency, high car ownership and the rural nature of parts of the District, as well as issues relating to public transport provision contributes to higher per capita CO2 emissions than the averages for Kent and the South East. In this respect emissions from transport are a significant contributor to overall greenhouse gas emissions in the District. It is considered that development in the vicinity of Sevenoaks Urban Area (Sevenoaks, Bat & Ball, Dunton Green), Swanley and Edenbridge (Edenbridge and Edenbridge Town), which have the most comprehensive rail links in the District, the most comprehensive bus network as well as the widest range of services, facilities and amenities in the District have increased potential to encourage the use of sustainable modes of transport. Similarly development in Hartley (Longfield), South Darenth (Farningham Road), Eynsford, Shoreham, Otford, Kemsing, Halstead/Knockholt, Chiddingstone Causeway (Penshurst) and Leigh, which also have access to nearby railway stations, would also encourage the use of sustainable transport modes. In this respect all of the options promote allocations in the vicinities of Swanley, Sevenoaks and Penshurst Station, with Options 2 and 3 proposing allocations in the vicinity of Knockholt, Longfield, Eynsford, Bat & Ball, Otford, Farningham Road, Kemsing, Edenbridge and Edenbridge Town stations. Only Option 3 proposes allocations in the vicinity of Shoreham, and none of the options’ proposed allocations are in locations readily accessible to Leigh, Hever or Cowden railway stations. The appraisal criteria for the Local Plan has sought to focus on accessibility to services and facilities. Therefore the majority of sites within all three the options are close to existing settlements. Some brownfield sites are located further from settlements but are seeking to reuse existing developed land within the Green Belt and rural areas. In terms of further aspects relating to greenhouse gas emissions, the sustainability performance of developments depends on elements such as the integration of energy efficient design within new development and the provision of renewable energy. This however can only be assessed on a site by site basis. It should be noted though that the higher quantum of development proposed through Option 3 will do more to increase the built footprint of Sevenoaks District, with associated overall increases in greenhouse gas emissions (although it should also be noted that this does not provide an indication of per capita emissions). In terms of carbon sequestration, this depends on elements such as the integration of green infrastructure enhancements within new development areas and the on and off-site provision of carbon sinks. Climate change adaptation Fluvial flood risk in the District is linked to the presence of the River Darent, the River Eden, the River Medway and the District’s underlying geology. The River Darent (Main River) presents flood risk affecting South Darenth, Eynsford, Shoreham, Chipstead, Farningham, Otford, Sundridge, Brasted and Westerham. The River Medway (Main River) has affected Leigh and Penshurst. Flood risk associated with the River Eden affects Edenbridge and Penshurst. There are also significant issues relating to surface water and groundwater flooding in parts of the District. In relation to the potential effects of the options, flood risk for the component sites making up each of the options has been evaluated and discussed through the site assessment undertaken for the Local Plan and the SA process (see Section 5.6). In terms of fluvial flood risk, no sites proposed by Option 1 are within Flood Zone 3, 13 sites proposed by Option 2 where up to 50% of the site intersects with Flood Risk Zone 2 and 3, and 23 sites proposed by Option 3 are within Flood Zone 3. Surface water flood risk is also present on a number of the sites. Whilst all options have the potential to lead to development in flood zones, or in areas with elevated levels of flood risk, it is considered that the provisions of the NPPF and national policy in relation to flooding will help guide development away from flood risk areas and ensure that appropriate mitigation measures are implemented. For example the NPPF does not permit development within flood risk areas or where the effect would be to increase flood risk elsewhere without appropriate mitigation measures. Likewise, adherence to the recommendations and guidance presented in the Sevenoaks SFRA will help limit effects Where appropriate, flood risk assessments (FRAs) will be undertaken on each site brought forward with potential flood risk issues. The FRAs will incorporate appropriate allowances for climate change, in accordance with Environment Agency guidance,10 to help to minimise vulnerability and provide resilience to flooding. For

10 Environment Agency (2016) Flood risk assessments: climate change allowances [online] available at: https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances).

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fluvial risk, it should be noted that there is a need to include a 70% allowance for climate change (peak river flows) to inform the location, impacts and design of a transport scheme. For example, to improve flood risk resilience, new or improved highway infrastructure should be sited above the 1% plus climate change (70%) flood level plus an appropriate freeboard allowance. In regards to the cumulative impacts of development, there is potential for negative effects within settlements and on watercourses / catchments, if unmitigated. In respect to the settlements where most development is likely to be allocated through the options, the cumulative effect of development in each settlement could result in a significant change in the provision of hard standing which may lead to an increase in surface water flood risk locally. In addition, there is the potential for cumulative effects where development in a number of settlements along the same river will lead to a change to the flow rate to the watercourse and increased risk of flooding. For example Edenbridge and Penshurst are both on the Eden, and Eynsford, Shoreham, Chipstead, Farningham, Otford, Sundridge, Brasted and Westerham are on the River Darent. However, due to the requirements in national and local planning policy, development should not increase flood risk elsewhere, through the use for example of SUDs. It is therefore considered that the cumulative effects as a result of the three options will not be significant.

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Table 5.4: Landscape and Historic Environment

Spatial strategy options Option 1: 220 dwellings Green sites Option 2: 8,712 dwellings Green sites and yellow sites Option 3: 13,706 dwellings Green sites, yellow sites and orange sites Landscape character 60% of the District is covered by either the Kent Downs Area of Outstanding Natural Beauty or the High Weald Area of Outstanding Natural Beauty. In relation to the Kent Downs AONB, five sites proposed through Option 1 are within or close to the boundaries of the AONB, approximately 40 sites proposed through Option 2 are within or close to the boundaries of the AONB and over 50 sites proposed through Option 3 are within the AONB. As such Option 3 and Option 2 both have potential for significant effects on landscape character the AONB without appropriate mitigation measures. In relation to the High Weald AONB. Option 1 and 2 propose one site which is located within 500m of the AONB, near Penshurst Station, and Option 3 proposes two sites near Penshurst Station located within 500m of the AONB. However, given existing topography and screening, the sites are unlikely to significantly affect the setting of the AONB. As such there is not significant difference between the options in relation to the integrity of the High Weald AONB. More broadly, the additional development to be delivered through Option 3 has increased potential to lead to significant impacts on landscape character in the District. This is given increased potential for impacts on existing landscape features, characteristics, and the condition and the value or importance of the existing landscape and visual resources. However, impacts will principally depend on the scale, bulk, layout, location and design of each proposed development. It is therefore considered that significant negative effects on local landscape and townscape character could arise at any of the locations where development is proposed if it is poorly located and designed. Alternatively, development in some locations, such as on brownfield sites, could improve local landscape and townscape character, resulting in positive effects, if high quality design is implemented. Notwithstanding these considerations, given the increased potential for landscape changes to arise through the option, Option 3 has the most potential to lead to significant impacts on landscape character in the District. Historic environment Whilst the significance of the effects from each option on features of cultural, built and archaeological heritage assets depends on the location, scale and nature of development, it can be considered that a higher level of housing development within a settlement increases the likelihood (and potential magnitude) of negative effects on the heritage assets locally. This is linked to an increased likelihood of direct and indirect impacts on the fabric and setting of features and areas of historic environment interest in the vicinity of the settlement. In this context, Options 2 and 3 are considered in many locations to have greater potential than Option 1 for effects given the higher level of development proposed through the options, with Option 3 having the potential to lead to the most significant effects. This includes in the vicinities of settlements with a particularly sizeable historic environment resource, such as Sevenoaks, Westerham, Eynsford, Shoreham and Horton Kirby. In relation to conservation areas in the District, one of the sites proposed through Option 1 is within or adjacent to a conservation area, 13 sites proposed through Option 2 are within or adjacent to a conservation area and 23 sites proposed through Option 3 are within or adjacent to a conservation area. Whilst development has the potential to have negative effects on the fabric and setting of the historic environment, it should also be noted that well sited and high quality design and layout can support enhancements to cultural heritage assets and their settings. Likewise new development areas in Sevenoaks’ towns and villages offer significant opportunities to rejuvenate disused and underutilised heritage assets and enhance their settings. As such, effects on the historic environment have the potential to be both positive and negative.

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Table 5.5: Environmental Quality

Spatial strategy options Option 1: 220 dwellings Green sites Option 2: 8,712 dwellings Green sites and yellow sites Option 3: 13,706 dwellings Green sites, yellow sites and orange sites Air quality Eleven AQMAs have been declared in the District, based on nitrogen dioxide emissions from transport. Whilst five of these cover parts of the strategic road network (including the M20, M26, M25 and A20) AQMAs exist in Swanley, Sevenoaks, Westerham and Seal, as follows:  Swanley: London Road (east), High Street, Bartholomew Way and parts of central town area  Seal: High Street  Sevenoaks: High Street and part of London Road, Pembroke Road and parts of the town centre; Bat and Ball junction with A25; and between Dunton Green and Riverhead  Westerham: High Street, Market Square, Vicarage Hill, and London Road (A233) . Whilst proposed allocations under Option 3 are not within the Swanley AQMA, the increased number of allocations under this option when compared to Option 1 and 2 has additional potential to increase emissions from transport within the AQMA. This includes through the stimulation of additional traffic flows. Option 3 will also deliver a significantly more development than Option 1 and Option 2 in the vicinity of Sevenoaks. This has the potential to increase traffic flows in the three AQMAs in the area, with impacts on air quality at these sensitive locations. The option also has increased potential to lead to impacts on emissions within the AQMA at Seal, which is located to the east of the town along the A25. In Westerham, given that Option 3 will deliver only one additional site over Option 2, both Option 2 and 3 are likely to have similar impacts on air quality in the town. As Option 2 includes a proposal for a relief road which has not yet been tested, it cannot yet be determined if the impact on air quality will be negative or positive. In contrast Option 1, through allocating one small site is likely to have negligible impacts on air quality. Water quality Groundwater Source Protection Zones (SPZs) have been defined by the Environment Agency in England and Wales to protect groundwater sources such as wells, boreholes and springs that are used for public drinking water supply. The zones show the risk of contamination from activities that might cause groundwater pollution in the area. Reflecting the vulnerability of groundwater in the area to pollution, Zone 1 SPZs are located in a number of locations in the District. In this context: Option 2 and 3 will deliver four allocations within the Zone 1 SPZ in the vicinity of Bat and Ball rail station/Sevenoaks Hospital; Option 2 will deliver one allocation and Option 3 two allocations within the Zone 1 SPZ east of Seal; Option 2 will deliver one allocation and Option 3 two allocations within the Zone 1 SPZ at Hartley; and Option 3 will deliver one allocation within the Zone 1 SPZs in the vicinity of New Ash Green. None of the options seek to allocate within the Zone 1 SPZs close to Knole House/Sevenoaks School, east of Seal or to the north west of Westerham; Eynsford; Farningham. Option 1 will also not deliver allocations within a Zone 1 SPZ. Soil quality Given there is no detailed information on contaminated land currently available for the District, it is not possible to differentiate between the options with regards to soil quality. Agricultural land quality has been discussed under the ‘Land, Soil and Water Resources’ SA theme below.

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Table 5.6: Land, Soil and Water Resources

Spatial strategy options Option 1: 220 dwellings Green sites Option 2: 8,712 dwellings Green sites and yellow sites Option 3: 13,706 dwellings Green sites, yellow sites and orange sites Soil resources As discussed above, a key element of the appraisal of the sites undertaken through the Local Plan process has been to categorise sites within the Green, Yellow, Orange, Red categories. In this respect sites considered as ‘Green’ and ‘Yellow’ are frequently on previously developed and locally defined brownfield sites in the Green Belt and where they lie within a weakly performing Green Belt parcel. A larger number of sites within the ‘Yellow’ category are also located on previously developed land within the Green Belt than within the ‘Orange’ category. It can be considered therefore that a higher proportion of sites categorised as ‘Green’ and ‘Yellow’ will support the efficient use of land, including previously developed land. In light of this, it can be considered that Option 1 and 2, which promote the allocation of ‘Green’ and ‘Yellow’ sites will support the efficient use of land. In terms of the location of the Best and Most Versatile Agricultural Land (i.e. land classified as Grade 1, 2 and 3a), no land has been classified as Grade 1 land in the District. Land classified as Grade 2 land is present in the north of the District, in the vicinity of Swanley and Horton Kirby, as well as in a band running from Eynsford, Otford and Chevening to the western edge of the District. In this respect, Option 3, through allocating significantly more sites in the vicinity of Swanley and Hextable than Option 1 and Option 2, has increased potential to lead to the loss of the Best and Most Versatile Agricultural Land in the far north west of the District. However all three options have the potential to lead to the sizeable loss of the Best and Most Versatile Agricultural land in this area, with the potential for significant negative effects. Both Option 2 and Option 3 have the potential to lead to the loss of Grade 2 land in Horton Kirby. However, given the relatively limited area of the Best and Most Versatile Agricultural Land lost through these options, these impacts are unlikely to be significant. In relation to the Grade 2 agricultural land running in a band from Eynsford, Otford and Chevening to the western edge of the District, both Options 2 and 3 have the potential to lead to the loss of this land classified as the Best and Most Versatile. Whilst significant areas of Grade 3 land are present in the District, recent land classification has not been carried in most locations to determine whether this comprises land classified as the best and most versatile (i.e. Grade 3a land) or land classified as Grade 3b land. However all options have the potential to lead to the loss of areas of Grade 3a land, with Option 3 and (to a lesser extent) Option 2 likely to lead to the most significant effects in this regard. Waste The generation of waste is an inevitable consequence of development, including both waste generated by construction, as well as waste generated subsequently in occupation. In this context, the higher the level of growth proposed; the higher level of waste that will be generated. As such Option 3 is likely to lead to the highest increases in the generation of waste in the District. The management of waste, including the minimisation of waste and the encouragement of the re-use, recycling and recovery of waste materials would all be undertaken on a site by site basis; however all development would be required to meet the relevant legislative requirements with regard to waste. Given the legislative and regulatory requirements regarding waste it is considered that individually development is unlikely to have a significant negative impact on waste; however the cumulative effect of all development in Sevenoaks District has the potential for significant negative effects if not mitigated or managed.

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Table 5.7: Population and Communities

Spatial strategy options Option 1: 220 dwellings Green sites Option 2: 8,712 dwellings Green sites and yellow sites Option 3: 13,706 dwellings Green sites, yellow sites and orange sites In relation to housing delivery, at a District level, only Option 3 is likely to meet the OAHN for Sevenoaks District. Overall, through delivering a larger number of dwellings, this option also has the most potential to deliver a broader range of housing types and tenures in the District. Accessibility to social and community services and facilities is a key influence on community cohesion, settlement vitality and the quality of life of residents. In this respect the appraisal criteria for the Local Plan has sought to focus on accessibility to services and facilities through including sites within more accessible locations. Accessibility is also linked to access to sustainable transport links, including public transport and walking and cycling networks. In this respect, development in the vicinities of Sevenoaks Urban Area, Swanley and Edenbridge, which have the best railway links in the District, the most comprehensive bus networks as well as the widest range of amenities have increased potential to support accessibility to services and facilities. Development in Hartley, Eynsford, Shoreham, Otford, Kemsing, Halstead/Knockholt, Chiddingstone Causeway and Leigh, which also have access to nearby railway stations, would also support accessibility through promoting the rail use. In this respect all of the options promote allocations in the vicinities of Swanley, Sevenoaks and Penshurst Station, with Options 2 and 3 proposing allocations in the vicinity of Knockholt, Longfield, Eynsford, Bat & Ball, Otford, Farningham Road, Kemsing, Edenbridge and Edenbridge Town stations. Only Option 3 proposes allocations in the vicinity of Shoreham, and none of the options’ proposed allocations are in locations readily accessible to Leigh, Hever or Cowden railway stations. Relating to existing pressures on services and facilities, new development has the potential to place increasing demands on existing amenities that will affect the quality of services used by existing residents. However, due to the requirements of developers to support infrastructure and services, for example the Community Infrastructure Levy (CIL) and Section 106 agreements/payments, there is significant potential for new development support the provision of new and enhanced facilities and services, as well as transport links. This will support accessibility to services and amenities. In addition growth at some locations has the potential to support the vitality and vibrancy of settlements through supporting existing and new services, facilities and amenities. In this respect Option 2 and 3, through facilitating additional growth, will facilitate enhancements to community provision. This however depends on the extent to which sites (including major development sites) contribute to similar new provision.

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Table 5.8: Health and Wellbeing

Spatial strategy options Option 1: 220 dwellings Green sites Option 2: 8,712 dwellings Green sites and yellow sites Option 3: 13,706 dwellings Green sites, yellow sites and orange sites Health and wellbeing in the District is closely related to a number of factors, including accessibility to services and facilities, the use of healthier modes of travel, access to high quality green infrastructure provision, the quality of housing, levels of crime and security and optimising the benefits that the natural environment offers to the health-and wellbeing of residents and visitors. Accessibility to community services and health and recreational facilities are a key influence on health and wellbeing. In this respect, development within settlements will enhance accessibility through directing housing to the locations with the broadest range of services and facilities; this will support accessibility to the wider range of amenities located in these settlements, with benefits for the health and wellbeing of residents. In addition, the larger settlements in the District have a wider range of health services, including primary health care services, and sports and recreational facilities supporting residents’ health and wellbeing. Furthermore, locating more housing in closer proximity to the facilities available in the larger settlements will also encourage healthier modes of travel including walking and cycling. In this respect the appraisal criteria for the Local Plan has sought to focus on accessibility to services and facilities through including more accessible sites within all Options. Depending on existing pressures on services and facilities, an increased level of housing delivery through Option 3 could place increased pressures on existing services, potentially affecting the quality of services received by existing residents. However, due to the requirements of developers to support infrastructure and services, for example through the Community Infrastructure Levy (CIL) and Section 106 agreements, payments may support the development of new and enhanced facilities which support health and wellbeing, including community provision, green infrastructure networks or enhanced walking and cycling provision. This however depends on the extent to which sites (including major development sites) contribute to similar new provision.

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Table 5.9: Transportation

Spatial strategy options Option 1: 220 dwellings Green sites Option 2: 8712 dwellings Green sites and yellow sites Option 3: 13,706 dwellings Green sites, yellow sites and orange sites It is considered that development in the vicinities of Sevenoaks Urban Area, Swanley and Edenbridge, which have the best railway links in the District, the most comprehensive bus networks as well as the widest range of amenities have increased potential to encourage the use of sustainable modesof trasnporta nd reduce the need to travel. Similarly, development in Hartley, Eynsford, Shoreham, Otford, Kemsing, Halstead/Knockholt, Chiddingstone Causeway and Leigh, which also have access to nearby railway stations, would also encourage the use of sustainable transport modes. In this respect all of the options promote allocations in the vicinities of Swanley, Sevenoaks and Penshurst Station, with Options 2 and 3 proposing allocations in the vicinity of Knockholt, Longfield, Eynsford, Bat & Ball, Otford, Farningham Road, Kemsing, Edenbridge and Edenbridge Town stations. Only Option 3 proposes allocations in the vicinity of Shoreham, and none of the options’ proposed allocations are in locations readily accessible to Leigh, Hever or Cowden railway stations. The majority of sites within the options are close of existing settlements therefore allowing easy access to existing services and facilities and reducing the need to travel.

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Table 5.10: Economy

Spatial strategy options Option 1: 220 dwellings Green sites Option 2: 8,712 dwellings Green sites and yellow sites Option 3: 13,706 dwellings Green sites, yellow sites and orange sites New housing provision will support the District’s towns and villages’ economic vitality through promoting the viability of local services and facilities, enhancing local economic offer, increasing the local market for goods and services and supporting cultural activities. In this respect, through delivering a higher number of dwellings in the District than Option 1 and Option 2, Option 3 provides additional potential for supporting the economic vitality of the District. The provision of housing in more accessible locations, including specifically in relation to the rail network, will support access to employment opportunities in London and elsewhere. In this regard, all of the options promote allocations in the vicinities of Swanley, Sevenoaks and Penshurst Station, with Options 2 and 3 proposing allocations in the vicinity of Knockholt, Longfield, Eynsford, Bat & Ball, Otford, Farningham Road, Kemsing, Edenbridge and Edenbridge Town stations. Only Option 3 proposes allocations in the vicinity of Shoreham, and none of the options’ proposed allocations are in locations readily accessible to Leigh, Hever or Cowden railway stations. As discussed above, the appraisal criteria for the Local Plan has sought to include sites within accessible locations. The majority of sites within all options are located close to existing settlements and therefore put forward approaches which will support the economic vitality of existing settlements. However, Option 3, through delivering an increased level of development in the wider vicinity of a number of settlements, will also support these towns and villages’ economic vitality through supporting local markets. Development in more rural locations of the District, which typically do not have access to employment or training opportunities, is less likely to provide significant benefits for the District’s economy. However an element of new development in these locations will support the rural economy by facilitating the provision of housing for the rural workforce. In this respect Option 3 may provide increased opportunities for delivering affordable housing in rural locations appropriate for rural workers. Options 2 and 3 include large scale mixed use developments including new employment land. By promoting new land for employment close to existing and/or proposed housing, these options provide opportunities to support the District’s economy by meeting existing and future employment needs.

Table 5.11: Town and Local Centres

Spatial strategy options Option 1: 220 dwellings Green sites Option 2: 8,712 dwellings Green sites and yellow sites Option 3: 13,706 dwellings Green sites, yellow sites and orange sites New housing provision will support the vitality of the District’s town and local centres through promoting the viability of local services and facilities, enhancing local economic offer, increasing the local market for goods and services and supporting cultural activities. In this context, through delivering a higher number of dwellings in the vicinity of a number of settlements in the District, Option 3 provides additional potential for supporting the vitality of town and local centres. The appraisal criteria for the Local Plan have sought to focus on accessibility to services and facilities through including sites within more accessible locations. The majority of sites within all options are close to existing settlements and therefore put forward allocations which will support the vitality and vibrancy of nearby town and local centres. However, Option 3, through delivering an increased level of development in the wider vicinity of many of these settlements, also has potential to support their vitality and vibrancy through supporting local markets and demand for services.

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Overview of the reasons for choosing the preferred strategy for the Local Plan 5.26 In light of the various appraisals which have been undertaken, including the SA of broad strategy options, the following presents an overview of Sevenoaks District Council’s reasons for selecting the preferred strategy approach for the Local Plan.

5.27

Housing Strategy

5.28 The strategy for identifying land for new housing development is as follows:

 Maximising densities in existing settlements (non-Green Belt);

 Redeveloping sustainable brownfield sites in the Green Belt (PDL and locally defined brownfield); and

 Developing greenfield sites in the Green Belt only where there are convincing exceptional circumstances such as the inclusion of evidenced social and community infrastructure that benefits the existing community as well as the proposed.

5.29 The starting point for the Local Plan housing strategy was to try and maximise the potential of land within existing settlements, which does not fall in the Green Belt. This is because these towns and villages have existing services and facilities, including education, health, retail and transport connections, and therefore are the most sustainable locations for future development. The Local Plan seeks to maximise densities in these areas to promote sustainable patterns of development. However, only 7% of land within the District falls within existing settlements and therefore there is an insufficient supply of land in these locations to meet the identified housing need. In accordance with the NPPF, the Plan then considers the contribution that ‘Brownfield’ or ‘Previously Developed Land’ (PDL) can make to meeting housing need. The recycling or re-use of land that has been previously developed is sustainable in that it means that potentially less greenfield Green Belt land needs to be considered for development. The Local Plan only considers brownfield or PDL in sustainable locations, close to existing settlements, in order to again promote sustainable patterns of development and allow residents to access services and facilities. However, the contribution of sites within existing settlements and brownfield land only provides for approximately half of the identified Local Housing Need for the District. Therefore the Local Plan considers the potential contribution of land in the Green Belt. National Planning Policy states that Green Belt boundaries can only be amended in ‘exceptional circumstances’ (EC) through the preparation of a Local Plan. The decision as to whether Green Belt boundaries will be amended will rest on the robustness of the EC cases that are proposed. There is not a national definition of EC but, in order to facilitate and fund the delivery of much-needed infrastructure, and to ensure that the Local Plan builds communities rather than just housing, the Local Plan outlines that any development on greenfield Green Belt land would need to provide social and community infrastructure, in addition to any housing. This infrastructure must address genuine existing evidenced infrastructure deficiencies in the area, rather than just the infrastructure needs of the proposed development. This approach to the Green Belt is considered appropriate and sustainable as it will ensure that any new development is supported by much-needed social and community infrastructure.

Employment Strategy

5.30 The strategy for identifying new sustainable employment land is as follows:

 Sites close to the existing transport network, particularly the strategic road and rail network;

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 Sites adjacent to or close to existing protected employment land; and  Sites on the edge of existing settlements. 5.31 This strategy was chosen to reflect that the location of economic and employment land, and therefore jobs, is particularly important. Workers need to be able to have access to jobs and services and the employment providers need to have good access to transport links especially where large and heavy good vehicles are necessary. Sustainable employment land is also best placed in areas where the potential employment use will not have an unacceptable impact on the living conditions of existing and future residents.

Gypsy and Traveller Accommodation Strategy

5.32 The strategy to identify locations for additional permanent pitches has been developed, subject to site sustainability and suitability, as follows:

 Identifying existing temporary pitches that can be made permanent;  Identifying additional permanent pitches on sites with existing pitches within the current site boundary to achieve a higher density; and  Identifying additional permanent pitches on sites with existing pitches with small scale minor boundary amendments in consultation with Local Members. 5.33 It was decided to focus new pitches on or adjacent to existing sites as the majority of the District G&T need is from new household formation from the existing G&T community. In addition the majority of sites submitted through the ‘Call for Sites’ currently have existing pitches and by focusing on these sites the plans seeks to protect the openness of the Green Belt and landscape character by making the best use of existing land.

Retail Strategy

5.34 The strategy for the retail need for the District focuses on:

 Redeveloping, regenerating and intensifying existing town centres;  Allocating additional retail floorspace within suitable employment or mixed use allocations; and  Providing additional retail floorspace on suitable brownfield land located close to transport hubs.

5.35 The strategy was chosen to reflect the changing nature of town centres by providing a more flexible approach to retail and town centre uses. Additional retail floorspace is also best placed in existing town centres and where communities are able to access day-to- day service and facilities, with good access to transport links and parking. By using sustainable brownfield locations, the plan seeks to prevent retail uses being located in inappropriate out-of-centre locations which are not connected with adequate transport links

5.36 In terms of housing delivery, the current version of the Local Plan seeks to deliver between 6,600 – 13,400 homes in the plan period. The lower 6,600 figure reflects the incorporation of sites which it is deemed appropriate to take forward through the Local Plan without building on greenfield land within the Green Belt. This incorporates all the sites within the ‘Green’ category as well as the sites in existing settlements and Green Belt brownfield sites within the ‘Yellow’ categories. The higher figure incorporates the mixed use greenfield sites within the Green Belt where the promoters are suggesting that there are convincing exceptional circumstances through the inclusion of evidenced social and community infrastructure that benefits the existing community as well as the proposed, these are also within the ‘Yellow’ category.

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5.37 Overall the Local Plan proposes that 79 sites are taken forward for allocation for housing or mixed use. Of the 79, 28 are within existing settlement boundaries, 39 are on brownfield land in the Green Belt, and 12 are greenfield sites in the Green Belt where exceptional circumstances are proposed (through the inclusion of social and community infrastructure). This reflects the outcome of the site appraisal process undertaken for the Local Plan process, the assessment of reasonable alternatives through the SA process (including at the Issues and Options stage) and the findings of further evidence base studies undertaken for the Local Plan. Latest version of the planning policies 5.38 The planning policies for the Local Plan have been developed in response to evidence base studies, the appraisal of reasonable alternatives undertaken through the SA process and to reflect consultation responses on plan-making to date, including the consultation on Issues and Options undertaken for the Local Plan in July 2017.

5.39 The 19 policies presented in the latest version of the Local Plan (Sevenoaks District Draft Local Plan Consultation July 2018) document are as follows:

Policy 1 A Balanced Strategy for Growth in a Constrained District Policy 2 Housing and Mixed Use Site Allocations Policy 3 Landscape and AONB Policy 4 Development in the Green Belt Policy 5 Ashdown Forest Policy 6 Safeguarding Places for Wildlife and Nature Policy 7 Transport and Infrastructure Policy 8 Market and Affordable Housing Mix Policy 9 Provision of Affordable Housing Policy 10 Housing in Rural Areas Policy 11 Provision for the Gypsy and Traveller Community Policy 12 Housing Density Policy 13 Supporting a Vibrant and Balanced Economy Policy 14 Town and Local Centres Policy 15 Design Principles Policy 16 Historic Environment Policy 17 Heritage Assets Policy 18 Health and Wellbeing, Air Quality, Climate Change and Flooding Policy 19 Open Space, Sport and Leisure

5.40 The planning policies presented in the latest version of the Local Plan have been appraised in Part 2 of this SA Report.

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Part 2: What are the SA findings at this current stage?

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6. Appraisal of policy approaches presented in the latest version of the Sevenoaks Local Plan Purpose of this chapter 6.1 This chapter presents appraisal findings and recommendations in relation to the current Draft Sevenoaks Local Plan 2015-2035 (July 2018). Approach to the appraisal 6.2 The appraisal of the policies in the Sevenoaks Draft Local Plan (July 2018) has been presented through the ten SA Themes. In undertaking the appraisal, the proposed polices were reviewed to determine which are likely to have a positive or negative environmental effect under each SA Theme.

6.3 Where a causal link between polices and SA Themes is established, significant effects are identified through the judgement of the consultants with reference to the evidence base (i.e. the scoping information). The appraisal uses the criteria in Schedule 1 of the SEA Regulations, that is:

 the probability, duration, frequency and reversibility of the effects;  the cumulative nature of the effects;  the transboundary nature of the effects;  the risks to human health or the environment (for example, due to accidents);  the magnitude and spatial extent of the effects (geographical area and size of the population likely to be affected);  the value and vulnerability of the area likely to be affected due to- o special natural characteristics or cultural heritage; o exceeded environmental quality standards or limit values; or o intensive land-use; and o the effects on areas or landscapes which have a recognised national, community or international protection status. 6.4 Where likely significant effects have been identified, these are described in summary tables for each SA Theme.

6.5 Every effort is made to predict effects accurately; however, this is inherently challenging given the strategic nature of the Sevenoaks Local Plan. The ability to predict effects accurately is also affected by the limitations of the baseline data. Because of the uncertainties involved, there is a need to exercise caution when identifying and evaluating significant effects and ensure assumptions are explained in full.11 In many instances it is not possible to predict significant effects, but it is possible to comment on merits (or otherwise) in more general terms.

6.6 For each SA theme, the appraisal has been presented two-fold.

 Commentary on the proposed Local Plan spatial strategy; and

11 As stated by Government Guidance (The Plan Making Manual, see http://www.pas.gov.uk/pas/core/page.do?pageId=156210): "Ultimately, the significance of an effect is a matter of judgment and should require no more than a clear and reasonable justification."

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 Commentary on the draft plan as a whole. Biodiversity and Geodiversity

Commentary on proposed Local Plan spatial strategy 6.7 All potential site options have been subject to SA, and as part of the Council’s site assessment process, any sites that were identified for biodiversity constraints that could not be overcome e.g. the presence of nationally designated biodiversity sites or Ancient Woodland, were subject to boundary amendments to exclude any protected or sensitive areas. Therefore, the process effectively ‘sieves out’ those sites with the greatest potential to lead to significant negative effects, and the allocations presented in the current version of the plan are those sites that have performed relatively well in sustainability terms – achieving a ‘Green’ or ‘Yellow’ site appraisal conclusion.

6.8 Of the 87 housing and mixed use site options (including the uncombined site options), 21 are identified as being located within a SSSI Impact Risk Zone, and development at these sites may require further consultation with Natural England in regards to impacts on SSSI(s) in the vicinity of the site. Similarly, of the 15 employment site options, seven are also located within a SSSI Impact Risk Zone and may also require further consultation. None of the Gypsy and Traveller site options are located within a SSSI Impact Risk Zone.

6.9 Whilst the Council’s site assessment has effectively removed site options that may significantly affect nationally designated biodiversity sites, the following sites have been identified as either containing a small proportion of a locally designated biodiversity (Local Wildlife Sites) or lying directly adjacent to one. Development at these sites have the potential for short to long-term minor negative effects on biodiversity, and will require further mitigation:

 HO368 – Calcutta Club and Polhill Business Centre, London Road, Badgers Mount (housing site option)  MX24 – Fort Halstead, Crow Drive, Halstead (housing site option)  HO104 – Baldwins Yard, Noahs Ark, Kemsing (housing site option)  GT8 – Knatts Valley Caravan Park, Knatts Valley Road, West Kingsdown (Gypsy & Traveller site option)

6.10 25 of the 87 housing and mixed use site options, two of the 15 employment site options (including mixed use) and six of the 14 Gypsy and Traveller site options (including mixed use) are also identified as containing or lying directly adjacent to Biodiversity Action Plan (BAP) Priority Habitats (predominantly Deciduous Woodland). Development at any of these site options should seek to retain and enhance habitats on site, and may require mitigation (such as buffer zones) to minimise the potential for negative effects.

6.11 A Biodiversity Analysis of Sevenoaks District has been undertaken for the Local Plan and has informed the SA process. The study has categorised all of the land within the District as having either a ‘low’, ‘medium’ or ‘high’ biodiversity value. Minor portions of the following site options have been identified as having a ‘high’ biodiversity value, usually along the edge. These sites may require mitigation to reduce the extent of potential negative effects as a result of development at the site:

 MX29 – Sevenoaks Community Centre, Otford Road, Sevenoaks (mixed use)  MX43 – Sevenoaks Quarry, Bat and Ball Road, Sevenoaks (mixed use)  MX49 – Land west of Chevening Road, Chipstead (mixed use)  MX50 – Land rear of the Village Hall, London Road, Dunton Green (mixed use)  HO198 – The Woodlands, Hilda May Avenue, Swanley (housing)

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 MX48 – Land at Pedham Place (mixed use)  MX54a – Land between Beechenlea Lane and the railway line, Swanley (mixed use)  MX54b – Land between Beechenlea Lane and Highlands Hill, Swanley (mixed use)  HO364 – Edenbridge & District War Memorial Hospital, Mill Hill, Edenbridge (housing)  HO189 – Land south of Skinners, Edenbridge (housing)  MX51 – Land south west of Crouch House Road, Edenbridge (mixed use)  MX55 – The Manor House, North Ash Road, New Ash Green (mixed use )  MX52 – Land at Corinthians Sports Club, Valley Road, Fawkham (mixed use)  MX53 – Land between Parkfield and Fawkham Road, Fawkham (mixed use) (majority of site is ‘high’ biodiversity value)  HO150 – Chelsfield Depot, Shacklands Road, Badgers Mount (housing)  HO368 – Calcutta Club and Polhill Business Centre, London Road, Badgers Mount (housing)  HO51 – Eureka Naturist Club, Manor Lane, Fawkham (housing) (majority of site is ‘high’ biodiversity value)  HO378 – Grange Park Farm, Manor Lane, Fawkham (housing)  MX24 – Fort Halstead, Crow Drive, Halstead (mixed use)  MX41 – Land at Broke Hill Golf Course, Sevenoaks Road, Halstead (mixed use)  HO73 – The Parish Complex, College Road, Hextable (housing) (all ‘high’ biodiversity value)  HO225 – Oasis Academy, Egerton Avenue, Hextable (housing)  HO133 – Land south of West End, Kemsing (housing)  HO342 – Meadow Cottage, Goathurst Common, Ide Hill (housing)  HO78 – Florence Farm Mobile Home Park, Main Road, West Kingsdown (housing)  EM12 – Former Park and Ride, Otford Road, Sevenoaks (employment) (majority of site is ‘high’ biodiversity value)  EM10 – Land west of Chaucer Industrial Park, Honeypot Lane, Kemsing (employment)  GT1 – Bournewood Brickworks, Stones Cross Road, Crockenhill (Gypsy and Traveller)  GT2 – Early Autumn, East Hill, Shoreham (Gypsy and Traveller)  GT8 – Knatts Valley Caravan Park, Knatts Valley Road, West Kingsdown (Gypsy and Traveller)

6.12 The analysis further identifies that 26 of the 87 housing and mixed use site options, four of the 15 employment site options (including mixed use), and four of the 14 Gypsy and Traveller site options (including mixed use) are considered to have a portion of ‘medium’ biodiversity value, in which development may require some mitigation.

6.13 35 of the 87 housing and mixed use site options, six of the 15 employment site options (including mixed use), and seven of the 14 Gypsy and Traveller site options (including mixed use) are considered to have a ‘low’ biodiversity value, and it is considered that development proposals at these sites have the potential to enhance the biodiversity value of the sites.

6.14 All of the allocations taken forward by the current version of the Local Plan have the potential to take place in locations where protected species are present. However, on many sites, there are also significant opportunities for on-site biodiversity improvements to support enhancements to local and sub-regional ecological connections. These issues have been considered through an appraisal of the current Local Plan policies.

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6.15 Potential effects of Local Plan allocations on European designated nature conservation sites will be considered through the Habitats Regulations Assessment (HRA) screening undertaken for the Local Plan. Commentary on draft Local Plan as a whole 6.16 Whilst there are no European designated sites for nature conservation within the Plan area, there are four such sites within 10km of the boundary of the District, and most significantly, Ashdown Forest Special Area of Conservation (SAC) and Special Protection Area (SPA) is located around 6km south of the District boundary. As identified above, the Local Plan will be accompanied by an HRA to ascertain the potential for adverse effects on the integrity of the European sites, either alone or in combination with other plans or projects. Alongside this, the Local Plan proposes Policy 5 (Ashdown Forest) to ensure that development supports the Strategic Access Management and Monitoring strategy for the site and provides the relevant contributions.

6.17 The District is rich in biodiversity and wildlife with a range of different habitats and protected areas. Whilst no significant negative effects on biodiversity assets from the spatial strategy can be readily identified, there will be a need for potential effects on biodiversity linked to the allocations associated with the spatial strategy to be avoided and mitigated. In this context, the Local Plan sets out provisions which will 1) help limit potential effects from new development on features and areas of biodiversity interest in the District and 2) support enhancements.

6.18 The Local Plan recognises that nationally designated sites are afforded protection from development due to their biological or geological importance (for example through the National Planning Policy Framework), and as such Policy 6 (Safeguarding Places for Wildlife and Nature) places emphasis on local level designations to enhance protections for biodiversity and wildlife. Policy 6, in addition to national designations, affords local areas of importance for biodiversity protections from development, including; Local Wildlife Sites, Local Nature Reserves, Kent Wildlife Trust Reserves, Roadside Nature Reserves, Country Parks and Ancient Woodland.

6.19 Further to this, Policy 6 creates targeted conditions for new development to both minimise its impact on existing features – for example, through seeking the retention of as many existing natural features as is feasible, and through a requirement that development ‘must result in no net loss in biodiversity value’ – and maximise its potential to support biodiversity in the District – for example, through the requirement that new development ‘must also include new habitat and biodiversity features’ and that these must be ‘secured for the lifetime of the development’. Typical enhancements that development could include as part of any proposal are identified within the policy, and further requirements such as ensuring that new planting is native and wildlife friendly, as well as the inclusion of a range of nectar rich and berry producing plants which flower at different times of the year, will support long term resilience in the District’s ecological networks.

6.20 Ecological networks in the District are further supported by the policy provisions which promote open space and green infrastructure enhancements (including the riparian environment as the Local Plan refers to the blue/green infrastructure within the District). In this context, Policy 19 (Open Space, Sport and Leisure) seeks to retain existing open spaces, as well as incorporate open space alongside onsite blue/green infrastructure and biodiversity features in new development. Early consideration of biodiversity is promoted through Policy 15 (Design Principles) which further reiterates the requirement for development to ‘maintain and enhance biodiversity’. The design policy seeks incorporation of natural features such as trees, hedges and ponds in new development, as well as opportunities for increasing biodiversity potential and the avoidance or mitigation of potential harm to a site’s existing biodiversity and blue/green infrastructure values.

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6.21 The policy framework is considered to take a proactive and positive approach to maintaining and enhancing biodiversity within the District, and its wider connections to designated sites and habitats outside of the Plan area.

Table 6.1: Likely significant effects, Biodiversity and Geodiversity

Likely significant effect Effect dimensions Improved ecological resilience. Direct, long-term, permanent and positive Enhancements to ecological Direct and indirect, long-term, permanent and positive. networks through blue and green infrastructure enhancements

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Climate Change

Commentary on proposed Local Plan spatial strategy 6.22 Overall, the delivery of 13,960 new dwellings over the plan period as well as the provision of around 11.6ha of new employment land and 32,000m2 of retail floorspace in the District has the potential to increase the built footprint of Sevenoaks, with associated increases in greenhouse gas emissions. However, the extent to which this takes place on a per capita basis depends on the implementation of policies designed to limit emissions, which is explored further in the commentary on the draft Plan as a whole below.

6.23 In terms of climate change mitigation, the sustainability performance of the Local Plan’s spatial strategy largely depends on elements such as the integration of energy efficient design within new development, the provision of renewable energy and policies encouraging the use of sustainable modes of transport. These elements have also been considered in the commentary on the draft Plan as a whole below.

6.24 In terms of climate change adaptation, none of the site options within the Local Plan are located wholly within a Flood Risk Zone, however; the following sites are identified as lying partially within (less than 50% of the site) or adjacent to Flood Risk Zones 2 and 3 and will require mitigation to alleviate / reduce the extent of the potential negative effects:

 HO382 – Archery and Far End, Chipstead Lane, Chipstead, Sevenoaks (housing)  HO189 – Land south of Skinners Lane, Edenbridge (housing)  HO190 – Land north of Skinners Lane, Edenbridge (housing)  HO223 – Land east of Bray Road, Edenbridge (housing)  MX25 – Land east of Four Elms Road and north of Skinners Lane, Edenbridge (mixed use)  MX10 – Land at Breezehurst Farm, Crouch House Road, Edenbridge (mixed use)  HO354 – Holmesdale Works, Holmesdale Road, South Darenth (housing)  EM23 & EM24 – Bartram Farm, Old Otford Road, Sevenoaks (employment)  EM12 – Former Park and Ride, Otford Road, Sevenoaks (employment) 6.25 A number of the site options included in the Local Plan are affected to some level by surface water flooding, and are likely to require mitigation measures, including sustainable drainage systems to manage these effects. The potential for surface water flooding is identified at 40 of the 87 housing site options, eight of the 15 employment site options (including mixed use), and eight of the 14 Gypsy and Traveller site options (including mixed use).

6.26 The additional policy approaches proposed by the Local Plan relating to flood risk have been discussed below. Commentary on draft Local Plan as a whole 6.27 A key SA objective is to address the causes of climate change through reducing emissions of greenhouse gases.

6.28 In relation to energy efficiency, the Local Plan seeks to promote the energy efficiency of new housing and employment provision in the District. Policy 18 (Health and Wellbeing, Air Quality, Climate Change and Flooding) asserts that the Local Plan will ‘contribute to reducing the causes and effects of climate change by promoting best practice in sustainable design and construction to improve the energy and water efficiency of all new development’. Also of note; Policy 18 requires that ‘all new non-domestic development (including conversions) must achieve BREEAM ‘Excellent’ standards’ and

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to achieve these standards new development will need to incorporate energy efficient design.

6.29 It should be noted that, with regard to residential development, the scope to set standards for residential building performance was radically curtailed by the Government’s Housing Standards Review. The Ministerial Statement published on 25th March 2015 outlined the Government’s new national planning policy on the setting of technical standards for new dwellings and Local Plan making. The Code for Sustainable Homes was formally withdrawn so targets against this should no longer be set in policy, and Local Authorities are no longer able to require higher standards as a planning condition for new approvals. The Deregulation Act (2015) also brought in a Clause which amended the Planning and Energy Act 2008 to prevent local authorities from requiring higher levels of energy efficiency than existing Building Regulations. The implication of this is that whilst the proposed Local Plan policies do not include stretching targets for energy efficiency for residential development, they sit appropriately within the context of national policy.

6.30 In terms of renewable energy provision, Policy 18 (Health and Wellbeing, Air Quality, Climate Change and Flooding) supports the delivery of renewable energy provisions within the District, including: small scale community led renewable energy schemes; small scale renewable and low carbon technologies where appropriate; and opportunities for decentralised energy and heating where appropriate. Policy 7 (Transport and Infrastructure) further requires all non-residential development with car parking to include electric vehicle charging points and all schemes must include publically accessible rapid electric vehicle charging points where possible and appropriate. These measures will support climate change mitigation with the potential for long term positive effects.

6.31 Further to the above, the Local Plan presents a number of provisions for supporting sustainable transport use and reducing the need to travel. This will support a limitation of greenhouse gas emissions from transport with the potential for minor long term positive effects. Policy 7 (Transport and Infrastructure) identifies that ‘the Local Plan will mitigate any adverse travel impacts created by new developments, including impacts on congestion and safety, environmental and noise impacts, air quality and impacts on amenity, health and wellbeing’, seeking to ensure that adequate provisions or contributions are made through new development for integrated and improved transport infrastructure. The policy seeks to expand public transport options, particularly promoting the inclusion of safe and convenient cycle routes where development is situated in sustainable locations with access to day-to-day services and facilities. This will reduce the need to travel and promote alternative options to the private car, reducing reliance in this respect, with the potential for long term positive effects. Sustainable transport use will also be supported by policies which promote enhancements to green infrastructure, including specifically Policy 6 (Safeguarding Places for Wildlife and Nature) and Policy 19 (Open Space, Sport and Leisure), which support active travel in attractive routes.

6.32 This will be further supported by Policy 1 (A Balanced Strategy for Growth in a Constrained District), which will enhance accessibility by sustainable transport modes and reduce the need to travel by focusing development in the main settlements (Sevenoaks, Swanley, Edenbridge and Westerham) with the broadest range of services, facilities and amenities; with more moderate development within settlements further down the Settlement Hierarchy.

6.33 Whilst the potential for negative effects on flood risk have been identified through the Spatial Strategy, the policy framework provides sufficient mitigation to ensure that development does not lead to any significant negative effects in relation to flood risk. Policy 18 (Health and Wellbeing, Air Quality, Climate Change and Flooding) seeks to minimise potential impacts by; requiring that residential ‘must’ avoid, and non-residential development ’should’ avoid areas at risk of flooding, and the Policy states that ‘no development should take place in Flood Zones 2 and 3 without agreement from the Environment Agency’. Development proposals over 1ha in Flood Zone 1 are required to

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undertake a Flood Risk Assessment to address the risk of flooding from surface water, groundwater and ordinary watercourses and identify appropriate mitigation measures where relevant. Further to this, the policy also requires that ‘all developments must incorporate sustainable drainage provision which mimics natural flows and drainage pathways and ensures that surface water run-off is managed as close to its source as possible’.

6.34 The Natural Environment White Paper recognises that green infrastructure is ‘one of the most effective tools available’ to manage ‘environmental risks such as flooding and heat waves’. In this context, Policy 6 (Safeguarding Places for Wildlife and Nature) and Policy 19 (Open Space, Sport and Leisure) both seek to ensure that new development retains and incorporates important blue/green infrastructure features such as existing trees and open spaces; and facilitates biodiversity and green infrastructure enhancements. This will provide long term indirect support for improved resilience in light of the effects of climate change.

Table 6.2: Likely significant effects, Climate Change

Likely significant effect Effect dimensions Limitation in greenhouse gas emissions resulting from Direct and indirect, long-term, permanent growth through reducing the need to travel and and positive promoting a modal shift Limitation in greenhouse gas emissions resulting from Direct and indirect, long-term, permanent growth through the development of low carbon and and positive renewable energy installations and the promotion of energy efficient development Enhancements to improve resilience to the effects of Direct and indirect, short, medium and climate change long-term, permanent and positive

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Landscape and Historic Environment

Commentary on proposed Local Plan spatial strategy 6.35 The delivery of 13,960 new dwellings a year over the plan period, as well as 11.6ha of new employment land and 32,000m2 of retail floorspace, has the potential to have impacts on the historic environment, and landscape and townscape character if not appropriately located and designed.

6.36 The following site allocations proposed through the current version of the Local Plan are located within the Kent Downs Area of Outstanding Natural Beauty, with the potential for negative effects on this designated landscape:

 HO382 – Archery and Far End, Chipstead Lane, Chipstead, Sevenoaks (housing)  HO86 – Chaucers of Sevenoaks, London Road, Dunton Green (housing)  MX49 – Land west of Chevening Road, Chipstead (mixed use)  MX48 – Land at Pedham Place (mixed use)  HO46 – Land between Granville Road and Farleycroft, Westerham (housing)  HO327 – Crockham Hill House, Main Road, Crockham Hill (housing)  HO371 – Land south of Farley Lane, Westerham (housing)  HO372 – Land north of Farley Lane, Westerham (housing)  HO373 – Land east of Croydon Road, Westerham (housing)  HO374 – Land south of Madan Road, Westerham (housing)  HO102 – Otford Builders Merchants, High Street, Otford (housing)  HO150 – Chelsfield Depot, Shacklands Road, Badgers Mount (housing)  HO368 – Calcutta Club and Polhill Business Centre, London Road, Badgers Mount (housing)  HO315 – Gorse Hill Nursery, Gorse Hill, Farningham (housing)  HO326 - Maplescombe Farm, Maplescombe Lane, Farningham (housing)  HO49 – Highfield Farm and Knocka Villa, Crow Drive, Halstead (housing)  MX24 – Fort Halstead, Crow Drive, Halstead (mixed use)  HO340 – Land east of Whitebeam Close and south of Pilgrim Way Cottages, Kemsing (housing) (adjacent to the AONB boundary)  HO104 – Baldwins Yard, Noahs Ark, Kemsing (housing)  HO44 – 51-59 Mount Pleasant Road and land to the rear, Sevenoaks Weald (housing)  HO47 – 1-6 Gilchrist Cottages and land to the rear, Mount Pleasant Road, Sevenoaks Weald (housing)  HO336 – Car park east of Sundridge House, Main Road, Sundridge (housing)  HO342 – Meadow Cottage, Goathurst Common, Ide Hill (housing)  HO129 – Terry Lodge Farm, Terrys Lodge Road, Wrotham (housing)  EM3, EM5, EM11 & EM21 – Dunbrik Hub A25 Main Road, Sundridge (employment)  EM4 – Land at Pedham Place, Swanley (employment)  EM20 – Westerham Garage and land to rear, London Road, Westerham (employment)  EM17 – Land north and east of Westerham (Which Way Westerham) (employment)

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 EM1 – Land south of High Street, Brasted (employment)  EM9 – The White House and land to the rear, High Street, Brasted (employment)  EM10 – Land west of Chaucer Industrial Park, Honeypot Lane, Kemsing (employment)  GT2 – Early Autumn, East Hill, Shoreham (Gypsy and Traveller)  GT3 – St George’s Stables, Well Hill, Shoreham (Gypsy and Traveller)  GT8 – Knatts Valley Caravan Park, Knatts Valley Road, West Kingsdown (Gypsy and Traveller)  GT9 – Hollywood Gardens, School Lane, West Kingsdown (Gypsy and Traveller)  GT10 – Two Barns, Knatts Lane, West Kingsdown (Gypsy and Traveller)  GT16 – Park Lane Farm, Park Lane, Swanley Village, Swanley (Gypsy and Traveller)

6.37 Nine of the 87 housing and mixed use site options, one of the 15 employment site options (including mixed use), and none of the 14 Gypsy and Traveller site options are identified as having ‘high’ landscape sensitivity. Further to this eleven housing site options, five employment site options and five Gypsy and Traveller site options were found to have ‘moderate’ landscape sensitivity.

6.38 A number of the site options were found to have the potential to affect designated heritage assets, and the following sites are identified for having the potential for effects of greater significance (scoring ‘red’ in the SA of site options), where mitigation will be required to reduce the extent of the potential negative effects, and maximise the potential for positive effects, particularly through effective design as the majority of these sites are located within a Conservation Area:

 HO382 – Archery and Far End, Chipstead Lane, Chipstead, Sevenoaks (housing)

 MX49 – Land west of Chevening Road, Chipstead (mixed use)

 HO10 – Old Forge Yard, Swanley Village Road, Swanley (housing)

 HO298 – Land rear of Cedar Lodge, Wood Street, Swanley Village (housing)

 HO357 – Swanley Village Nursery, Swanley Village Road, Swanley Village (housing)

 MX48 – Land at Pedham Place (mixed use)

 HO364 – Edensbridge & District War Memorial Hospital, Mill Hill, Edenbridge (housing)

 MX55 – The Manor House, North Ash Road, New Ash Green (mixed use)

 HO102 – Otford Builders Merchants, High Street, Otford (housing)

 MX52 – Land at Corinthians Sports Club, Valley Road, Fawkham (mixed use)

 MX24 – Fort Halstead, Crow Drive, Halstead (mixed use)

 HO73 – The Parish Complex, College Road, Hextable (housing)

 HO354 – Holmesdale Works, Holmesdale Road, South Darenth (housing)

 HO340 – Land east of Whitebeam Close and south of Pilgrim Way Cottages, Kemsing (housing)

 HO336 – Car park east of Sundridge House, Main Road, Sundridge (housing)

 EM1 – Land south of High Street, Brasted (employment)

 EM9 – The White House and land to the rear, High Street, Brasted (employment)

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6.39 A further twelve housing site options, one employment site option and two Gypsy and Traveller site options were found to have the potential for minor negative effects, scoring ‘amber’ in the SA of site options. Also, 31 of the housing site options, six of the employment site options, and four of the Gypsy and Traveller site options were considered to have the potential for archaeological values that should be explored prior to any development at the sites. Commentary on draft Local Plan as a whole 6.40 Sevenoaks has a rich historic environment and distinctive landscapes that should be conserved and enhanced. This is reflected by the planning policies proposed for the Local Plan, which have a strong focus on supporting landscape and townscape character in the District, conserving and enhancing the fabric and setting of the historic environment and supporting local distinctiveness.

6.41 Given that over 60% of the District lies within the Kent Downs or High Weald Areas of Outstanding Natural Beauty (AONB), Policy 3 (Landscape and Areas of Outstanding Natural Beauty) specifically seeks to manage the effects of development on a largely sensitive landscape character. The policy sets out a range of provisions for protecting and enhancing landscape character in the District. This includes through seeking to ensure that the relevant AONB management plan, associated documents and position statements inform new development proposals. It also sets out that ‘the landscape character of the District and the countryside, including areas of tranquillity, will be conserved and the distinctive features that contribute to the special character will be protected and enhanced where possible’.

6.42 This is supported by Policy 15 (Design Principles) which requires development to ‘exhibit high quality design and respond to the distinctive local character of the area’. The design of new development / redevelopment is a key contributor to local character and as such, the policy identifies design criteria relating to: character; working with the site and its context; and natural landscaping, blue/green infrastructure, biodiversity, outdoor lighting and flooding to ensure that development positively contributes to landscape/townscape character and local distinctiveness.

6.43 A key aspect of the Plan is the proposal to increase housing density to accommodate more development outside of areas constrained by the Green Belt and / or sensitive landscapes. However it is recognised that this again has the potential to impact upon landscape character and the historic environment, and as such Policy 12 (Housing Density) requires development to further demonstrate that proposals are of high quality design, respect local character, and that the area is able to accommodate additional development. This should ensure that policy directions for increased density do not lead to significant negative effects on landscape and townscape character.

6.44 The Settlement Hierarchy directs development to the main settlement areas, which are the most ‘built-up’ areas and most able to accommodate further development in terms of existing infrastructure, services and facilities. This in turn will support the limitation of negative effects on the open countryside.

6.45 Similarly, Policy 16 seeks to ensure that development reflects local distinctiveness, as well as the condition and sensitivity to change of the historic environment. The policy requires that development ‘should demonstrate an awareness and commitment to the overall protection and, where possible, enhancement of the historic environment of the District’. Proposals are required to demonstrate ‘clear consideration of the relationship with the historic evolution of the District and local area’, ‘a broad appreciation of the historic character of the local area including current conditions’ and ‘an understanding of the presence of heritage assets and their associated significance, vulnerabilities and opportunities’. The policy further identifies the need for new development to accord with supporting documents such as Conservation Area Appraisals, the Sevenoaks Landscape Character Assessment and the Sevenoaks District Historic Environment Review. This

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should ensure that values attributed to assets and fully understood and reflected in design proposals, with the potential for long term positive effects.

6.46 The current version of the Local Plan recognises that designated heritage assets are afforded a level of protection by other policies or legislation through their designation, and that the Plan therefore presents the opportunity to afford non-designated heritage assets a higher level of protection where these contribute to the wider landscape and to the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring. In this respect, Policy 17 seeks to conserve and enhance the character, appearance and setting of both designated and non-designated assets, and will weigh the significance of potential negative effects against public benefit. The policy further requires that any development with the potential to affect heritage assets (including locally listed buildings, the setting of heritage assets and historic landscapes) will be required to submit a Heritage Statement alongside any planning application. Similarly the policy requires an archaeological assessment for proposals located within, or affecting, an area or suspected area of archaeological importance.

6.47 More broadly, landscape and townscape character, local distinctiveness and the setting of the historic environment will also be supported by the policies relating to green infrastructure (Policy 6 (Safeguarding Places for Wildlife and Nature) and Policy 19 (Open Space, Sport and Leisure)), which promote enhancements to local distinctiveness and the public realm. This will be further supported by policies relating to sustainable transport use (Policy 7 (Transport and Infrastructure) and Policy 15 (Design Principles)), which will help to reduce the impact of the transport network (and traffic) on the quality of the public realm, and support townscape character and the setting of the historic environment.

Table 6.3: Likely significant effects, Landscape and Historic Environment

Likely significant effect Effect dimensions Enhanced townscape character, Direct and indirect, long-term, permanent and positive public realm and local distinctiveness Protection and enhancement of Direct, long-term, permanent and positive heritage assets (including non- designated assets)

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Environmental Quality

Commentary on proposed Local Plan spatial strategy 6.48 The following site options are identified as being located within an AQMA where development has the potential to negatively affect air quality:

 HO217 – Sevenoaks Town Council Offices, Bradbourne Vale Road, Sevenoaks (housing)  HO365 – Sevenoaks Hospital, Hospital Road, Sevenoaks (housing)  MX50 – Land rear of Village Hall, London Road, Dunton Green (mixed use)  MX9 – Upper Hockenden Farm, Hockenden Lane, Swanley (mixed use)  HO373 – Land east of Croydon Road, Westerham (housing)  HO374 – Land south of Madan Road, Westerham (housing)  HO336 – Car park east of Sundridge House, Main Road, Sundridge (housing)  EM5 (a part of a grouped option which also includes EM3, EM11 and EM21) – Dunbrik Hub A25, Main Road, Sundridge (employment)  EM4 – Land at Pedham Place, Swanley (employment)  EM20 – Westerham Garage and land to rear, London Road, Westerham (employment)  EM17 – Land north and east of Westerham (Which Way Westerham) (employment)  EM9 – The White House and land to the rear, High Street, Brasted (employment)  GT5 – Alexis Place, Hockenden Lane, Swanley (Gypsy and Traveller)  GT17 – Land south of Broomhill, Button Street, Farningham (Gypsy and Traveller)

6.49 Further to this, another three of the 87 housing and mixed use site options, and four of the 15 employment site options (including mixed use) are located in close proximity to an AQMA, with the potential to exacerbate effects on air quality. Mitigation may be required at these sites to reduce the potential for negative effects.

6.50 57 of the housing and mixed use site options, eleven of the employment site options and twelve of the Gypsy and Traveller site options are within Groundwater Source Protection Zones. Of these sites, the following are located within Source Protection Zone 1 with the potential for effects of the greatest significance:

 HO217 – Sevenoaks Town Council Offices, Bradbourne Vale Road, Sevenoaks (housing)  HO226 – Sevenoaks Adult Education Centre, Bradbourne Road, Sevenoaks (housing)  HO349 – Godfreys, Otford Road, Sevenoaks (housing)  HO365 – Sevenoaks Hospital, Hospital Road, Sevenoaks (housing)  MX29 – Sevenoaks Community Centre, Otford Road, Sevenoaks (mixed use)  MX43 – Sevenoaks Quarry, Bat and Ball Road, Sevenoaks (mixed use)  MX53 – Land between Parkfield and Fawkham Road, Fawkham (mixed use)  HO165 – Fawkham Business Park, Fawkham Road, Fawkham (housing)  HO336 – Car park east of Sundridge House, Main Road, Sundridge (housing)  EM12 – Former Park and Ride, Otford Road, Sevenoaks (employment)

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Commentary on draft Local Plan as a whole 6.51 The policy framework provides protection for air quality through Policy 18 (Health and Wellbeing, Air Quality, Climate Change and Flooding) which requires ‘development in areas of poor air quality or development that may have an adverse impact on air quality will be required to incorporate measures to reduce impacts to an acceptable level’, and further to this the policy identifies that ‘schemes where unacceptable impacts cannot be overcome by mitigation will be refused’. In this respect, the policy framework significantly reduces the potential for negative effects on environmental quality. The policy also provides protection for water quality, specifically requiring that ‘all development must incorporate sustainable drainage provision’, and that ‘any drainage scheme must manage all sources of surface water, including exceedance flows and surface flows from off-site’.

6.52 The policies which promote enhancements to green infrastructure, including specifically Policy 6 (Safeguarding Places for Wildlife and Nature) and Policy 19 (Open Space, Sport and Leisure) will support air quality through facilitating the increased absorption and dissipation of nitrogen dioxide and other pollutants, support tranquillity through increasing absorption of noise, and promoting enhancements to water quality through managing pollutants in water run-off. Enhancements to green infrastructure will also promote modal shift (and as such help to limit the effects of traffic growth on environmental quality in the District) through improving opportunities for walking and cycling, and enhancing sustainable transport networks.

Table 6.4: Likely significant effects, Environmental Quality

Likely significant effect Effect dimensions Limitation of the effects of housing Direct, long-term, and positive and employment/retail growth on existing air quality issues in the District

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Land, Soil and Water Resources

Commentary on proposed Local Plan spatial strategy 6.53 Of the proposed site options, 20 of the 87 housing and mixed use site options, and four of the employment site options are located wholly on greenfield land. The majority of the site options are a mixture of both previously developed land and greenfield land.

6.54 21 housing site options, one employment site option, and three Gypsy and Traveller site options have been identified as containing Grades 1 and/or 2 best and most versatile agricultural land. Development at these sites has the potential therefore to result in the permanent loss of the best and most versatile agricultural land, with the potential for permanent negative effects. A further 53 housing site options, eleven employment site options, and nine Gypsy and Traveller site options were also identified as containing Grade 3 agricultural land, however the sub-grade (sub-grade 3a is classified as best and most versatile agricultural land) is unknown at this stage. Development at these sites have the potential however to result in the loss of high quality agricultural land, with an element of uncertainty at this stage. From the findings it is considered that the implementation of the Local Plan spatial strategy is likely to lead to a significant loss of agricultural land within the District. Commentary on draft Local Plan as a whole 6.55 The District is strongly constrained in terms of land use, with 93% of the its land designated as Metropolitan Green Belt and preserved as open countryside between the edge of London and the settlements of West Kent. Combined with the relative lack of availability of brownfield land, this reduces the potential for redevelopment of previously developed land. In this respect, the Local Plan development process has focussed on undertaking detailed assessments and site evaluation to identify potential opportunities to minimise the impacts of new development, and land take, on the open countryside. This includes maximising the supply of housing within existing settlements through increased density and urban regeneration. Despite this, it is still considered highly unlikely that the identified housing needs will be delivered within existing settlements, and consultations as part of the Duty to Cooperate are exploring options to deliver some of these needs outside of the District, however no such capacities have been found as of yet. Therefore, overall, it is considered likely that the Local Plan will lead to the loss of greenfield land and open countryside in the designated Green Belt.

6.56 A key element of the spatial strategy is the proposal to intensify and densify existing urban areas to improve the efficiency of land in the settlement areas, and in this respect Policy 12 (Housing Density) seeks to deliver higher density rates for housing than the average for the District (60 dwellings per hectare), and Policy 13 (Supporting a Vibrant and Balanced Economy) identifies existing employment allocations that are suitable for intensification. This will contribute to minimising the impacts of development on land resources and is likely to lead to long term positive effects in this respect.

6.57 In relation to water consumption, the Local Plan seeks to promote water efficiency in new housing and employment provisions in the District. Policy 18 (Health and Wellbeing, Air Quality, Climate Change and Flooding) asserts that the Local Plan will ‘contribute to reducing the causes and effects of climate change by promoting best practice in sustainable design and construction to improve the energy and water efficiency of all new development’. Also of note, Policy 18 requires that ‘all new non-domestic development (including conversions) must achieve BREEAM ‘Excellent’ standards’ and to achieve these standards new development will need to incorporate water efficiency in development proposals.

6.58 The policies which promote enhancements to blue and green infrastructure, including specifically Policy 6 (Safeguarding Places for Wildlife and Nature) and Policy 19 (Open Space, Sport and Leisure), and policies which promote the use of sustainable drainage

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systems, specifically Policy 18 (Health and Wellbeing, Air quality, Climate Change and Flooding) will promote enhancements to water quality through managing pollutants in water run-off.

Table 6.5: Likely significant effects, Land, Soil and Water Resources

Likely significant effect Effect dimensions Loss of best and most versatile Direct, long-term, permanent and negative agricultural land in the District Loss of greenfield land in the Direct, long-term, permanent and negative District Efficient use of land through Direct, long-term, and positive intensification of uses, increased housing densities and a focus on the use of previously developed land where possible Reduced per capita water Direct, long-term and positive consumption through improved water efficiency in new developments

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Population and Communities

Commentary on proposed Local Plan spatial strategy 6.61 Good accessibility to services and facilities is central to the quality of life of residents, for sustaining vital communities and improving health and wellbeing, in addition to reducing noise and air pollution, carbon emissions and traffic congestion related to heavy dependence on car travel. However accessibility to services and facilities is limited in some parts of the District due to the dispersed nature of settlements and limited public transport provision. In this context, the settlement hierarchy for the District set out by the Local Plan will help enhance accessibility by sustainable transport modes and reduce the need to travel by focusing an increased level of housing growth in the largest settlements of the District (Sevenoaks, Swanley, Edenbridge and Westerham). However, whilst these settlements are the most accessible locations in the District, rural accessibility is a key issue for many in the District, due in part to elements relating to the viability of services. As such, the Local Plan facilitates the provision of new housing in smaller settlements at an appropriate scale. Overall, the development strategy will reduce the need to travel and enhance accessibility for residents by focusing housing and employment provision in the settlements with a broader range of services, facilities and amenities.

6.62 Social inclusion is also closely linked to the vitality of settlements, and the provision of services, facilities and amenities. In this context whilst the spatial strategy focuses development in the main settlements of Sevenoaks, Swanley, Edenbridge and Westerham, it also seeks to support the vitality of a wider range of settlements through facilitating the provision of new housing in smaller settlements at an appropriate scale. In this context the viability of services and facilities in these settlements will be supported through increasing the ability of the local population to support these amenities. However, it should also be noted that in certain settlements, an increase in population may increase pressures on existing services and facilities without an improvement in the capacity of such amenities.

6.63 The vitality of settlements is also closely linked to the demographic make-up of residents. For example younger people are increasingly likely to be priced out of smaller settlements without a degree of housing provision. This will have effects on community vitality by limiting the diversity of age ranges present in a settlement and reducing the viability of facilities such as local schools. The vitality of settlements is also supported by housing development through increasing the local market for goods and services. As such, the development strategy provides a balance between supporting accessibility in the larger settlements of the District whilst also supporting social inclusion in smaller settlements. Commentary on draft Local Plan as a whole 6.59 The Local Plan seeks to enable the provision of around 13,960 new dwellings over the plan period, as well as 11.6 ha of new employment land and 32,000m2 of new retail floorspace to meet the identified local needs. To reflect emerging changes to the methodology for assessing housing needs (as proposed through the updates to the NPPF), the Local Plan may result in over a fourfold increase in annual delivery provisions from that outlined within the previous Core Strategy (an increase from 165 homes per year to 698 homes per year). Accommodating this significant increase in annual housing delivery will be a key challenge for the Local Plan (explored further in the Land, Soil and Water Resources SA Theme commentary), but will support residents in the long term with good access to high quality housing that meets local needs.

6.60 Policy 8 (Market and Affordable Housing Mix) seeks to ensure that development delivers a mix of housing types and tenures (including a mix of types and tenure of affordable housing) to reflect and respond to the identified needs of different groups. This will support the creation of mixed, balanced and inclusive communities with the potential for long term positive effects. This is supported by Policy 11 (Provision for the Gypsy and Traveller Community) which identifies sites for consultation (accommodating more than the identified requirements) to deliver permanent pitches for Gypsy, Traveller and Travelling Showpeople communities to meet their long-term needs.

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6.61 Key housing challenges in the District include housing affordability. The SHMA identifies a net annual need for 422 households which require financial support to meet their housing needs. The Local Plan recognises that, based on recent delivery rates of affordable housing, the annual requirement is not a realistic target without significantly increasing the overall annual housing requirement. The SHMA recommends a target of at least 35% affordable housing for all suitable sites, however, the Local Plan seeks (subject to viability) to achieve a higher target of 40% to help in meeting the identified needs. Further to this, the Local Plan identifies specific recommendations based on the geographical location and type/tenure of housing. The challenge of delivering affordable housing in the District is also constrained by national policy which prevents Local Authorities from seeking affordable housing provision in development of ten units or less (or six or less units for development within the AONB). In this respect, the housing allocations of ten dwellings or more are more likely to contribute to the delivery of positive effects in terms of affordable housing.

6.62 Policy 10 (Housing in Rural Areas) permits housing in rural areas as an exception to other Local Plan policies, provided the specified criteria have been met, including: identifying a local need through an up-to-date rural housing needs survey; ensuring the need cannot be met by any other means through the development of non-Green Belt sites within the parish or (where appropriate) adjacent parish; and a thorough site options appraisal has been carried out. The policy identifies that the expectation for these types of schemes is to provide 100% local needs (affordable) housing, though it is recognised that on rare occasions an element of market housing may be required to facilitate delivery. The policy will support smaller rural villages in meeting their housing needs, and support the delivery of affordable housing within the District with the potential for long term positive effects.

6.63 To support local communities, a key aspect of the Local Plan is delivering new development in sustainable locations which improve the accessibility of services, facilities, employment opportunities and sustainable transport modes, and reduce the need to travel. In this context, Policy 1 (A Balanced Strategy for Growth in a Constrained District), in line with the settlement hierarchy, focuses the majority of development in the main settlements (Sevenoaks, Swanley, Edenbridge and Westerham) with the broadest range of services, facilities and amenities; with more moderate development within settlements further down the Settlement Hierarchy.

6.64 This is further supported by Policy 14 (Town and Local Centres) which seeks to protect the ongoing vitality and viability of town and local centres, including through the retention and enhancement of existing community services and facilities. The policy seeks to support the role and function of these centres to ensure that they continue to support local residents in meeting their everyday needs.

6.65 The quality of housing will be supported by Policy 15 (Design Principles) which requires development to exhibit high quality design and create ‘safe, inclusive and attractive environments’. The quality of housing will also be supported by Policy 18 (Health and Wellbeing, Air Quality, Climate Change and Flooding) which seeks to improve the energy and resource efficiency of new housing, which will help limit key issues for residents’ quality of life such as fuel poverty.

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Table 6.6: Likely significant effects, Population and Communities

Likely significant effect Effect dimensions Provisions for housing Direct, long-term and positive development to meet identified housing needs of differing communities, including Gypsy and Traveller communities Maintain and enhance the vitality Direct, long-term and positive of communities by locating housing where it sustains balanced and inclusive communities Increased delivery of affordable Direct, long-term and positive housing, including rural affordable housing Improved access to services and Direct, long-term and positive facilities and enhanced provision of community infrastructure Increased use of sustainable Direct, long-term and positive transport modes, including public transport and walking and cycling High quality new housing Direct, indirect, long-term and positive development to support residents quality of life

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Health and Wellbeing

Commentary on proposed Local Plan spatial strategy 6.66 The preferred development strategy for the Local Plan seeks to focus, in the first instance, development within the boundaries of existing settlements, including building at higher density on non-Green Belt land. The four towns within the District – Sevenoaks, Swanley, Edenbridge and Westerham, will be the initial focus for development, with more moderate development within the settlements further down the Settlement Hierarchy.

6.67 In this respect many of the proposed allocations are located in more accessible locations that are well connected. Good accessibility to services and facilities is a key influence on health and wellbeing through enhancing access to health and leisure facilities and recreational opportunities. As such the spatial strategy taken forward through the Local Plan will limit the need to travel and enhance accessibility for residents by focusing housing and employment provision in the settlements with the broader range of services, facilities and amenities. This will support the health and wellbeing of residents. Commentary on draft Local Plan as a whole 6.68 Health and wellbeing in the District is closely related to a number of factors, including accessibility to services and facilities, the use of healthier modes of travel, access to high quality green infrastructure provision, the quality of housing, levels of crime and security, air and noise quality and optimising the benefits that the built and natural environment offers to the health and wellbeing of residents.

6.69 A key impact of the policies relating to health and wellbeing within the Local Plan will be through protecting and enhancing the District’s built and natural environment. This provides spaces – including natural green space – for recreation and relaxation, as well as air and water quality benefits. There is now robust evidence that access to nature improves people’s health and wellbeing through encouraging healthy outdoor recreation and relaxation. In this context, Policy 19 (Open Space, Sport and Leisure) sets out a range of standards and thresholds for open space provision relating to: sports and leisure; open space and recreation; and children’s and young people’s play spaces. This is with the aim of ensuring that all residents have good access to open space. The policy seeks to retain existing open spaces and sport and leisure provisions, and improve provision where possible, including thresholds for the provision of new play areas in housing development. The Policy also highlights that ‘connections to the existing Public Right of Way (PRoW) network must be incorporated in all new developments along with other active travel opportunities’. This will support active travel connections between, to and from open spaces in new development, with the potential for minor long term positive effects on health and wellbeing.

6.70 The Local Plan will help indirectly promote health and wellbeing improvements by supporting more sustainable modes of transport and road safety, with benefits for air and noise quality and encouraging more active travel. The Local Plan policies will also support the health and wellbeing of residents by promoting accessibility to services and facilities. In this respect Policy 7 (Transport and Infrastructure) asserts that development must consider the promotion of safe and convenient cycle routes ‘where development is situated in sustainable locations with access to day-to-day services and facilities’. This is supported by Policy 15 (Design Principles) which requires that ‘developments must all be designed to promote healthy living opportunities both mental and physical’. This policy also sets out design criteria that all development proposals must demonstrate they can meet relating to: working with the site and its context; well defined streets and spaces; and streets and access for all (including active design and travel). This is supported by the Settlement Hierarchy and Policy 1 (A Balanced Strategy for Growth in a Constrained District) which seeks to locate the majority of development in the main settlements which contain the most supporting infrastructure, services and facilities, and thus where active travel can be more readily promoted. As part of the design criteria, Policy 15 also

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requires development to ‘result in the creation of a safe and secure environment and incorporate adequate security measures and features to deter crime, fear of crime, disorder and anti-social behaviour’.

6.71 A key influence on health and wellbeing is the quality and availability of housing. As discussed under the ‘Population and Communities’ section; the Local Plan seeks to meet the identified housing needs of differing residents, including the delivery of affordable housing. Access to decent housing is an important wider determinant of health so these policies have the potential to indirectly support improved health outcomes and reduced health inequalities. Further to this, Policy 15 (Design Principles) requires development to exhibit high quality design and create ‘safe, inclusive and attractive environments’. The quality of housing will also be supported by Policy 18 (Health and Wellbeing, Air Quality, Climate Change and Flooding) which seeks to improve the energy and resource efficiency of new housing, which will help limit key issues for residents’ quality of life such as fuel poverty.

Table 6.7: Likely significant effects, Health and Wellbeing

Likely significant effect Effect dimensions Enhancements to green infrastructure networks, Indirect, long-term and positive promoting leisure and recreational opportunities and active lifestyles Enhancement of active travel opportunities Direct, long-term and positive Support for health and wellbeing through the Direct, long-term and positive delivery of high quality, energy efficient housing which meets local needs Supporting mental and physical wellbeing through Indirect, long-term and positive enhancements to the quality of the built environment

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Transportation

Commentary on proposed Local Plan spatial strategy 6.72 The preferred spatial strategy for the Local Plan seeks to focus, in the first instance, development within the boundaries of existing settlements, including building at higher density on non-Green Belt land. The four towns within the District – Sevenoaks, Swanley, Edenbridge and Westerham, will be the initial focus for development, with more moderate development within the settlements further down the Settlement Hierarchy.

6.73 In this context, the settlement hierarchy for the District set out by the Local Plan will help enhance accessibility by sustainable transport modes and reduce the need to travel by focusing an increased level of housing growth in the larger settlements. However, whilst the towns are the most accessible locations in the District, rural accessibility is a key issue for many in the District, due in part to elements relating to the viability of services and public transport links. As such, the Local Plan facilitates the provision of new housing in smaller settlements which have an appropriate range of services and facilities (including the Local Centres) and also seeks to focus development within the Green Belt in more accessible locations.

6.74 Overall, the development strategy will reduce the need to travel and enhance accessibility for residents by focusing housing and employment provision in the vicinities of the settlements with the broader range of services, facilities and amenities and public transport links. Commentary on draft Local Plan as a whole 6.75 The Local Plan seeks to deliver housing, employment and associated improvements to services, facilities and public transport to meet the needs of new and existing communities. This has the potential to reduce the need to travel and limit levels of congestion on the local transport network.

6.76 The District experiences high levels of car ownership, and the baseline recognises key congestion hotspots exist within Sevenoaks town, Swanley and Westerham. Given the level of proposed growth, and the Local Plan’s the Settlement Hierarchy and Policy 1 (A Balanced Strategy for Growth in a Constrained District) which directs the majority of this growth to the larger settlements of Sevenoaks town, Swanley, Edenbridge and Westerham, there is the potential for the Local Plan to exacerbate traffic and congestion in some locations.

6.77 More limited growth in rural areas may also increase car dependence in the District through the delivery of housing in locations with poorer public transport links.

6.78 Whilst housing and employment growth has the potential to increase traffic and car use within the District, with the potential for long term negative effects, it should be noted that the policy provisions of the current version of the Local Plan seek to reduce the extent of these negative effects. In this respect Policy 7 (Transport and Infrastructure) seeks to ensure that adverse travel impacts are mitigated and ‘adequate provision is made for integrated and improved transport infrastructure’. The policy seeks to improve cycle routes in suitable locations (including railway stations) to encourage more active travel, and also promotes the delivery of electric vehicle charging points to encourage more sustainable modes of transport. The policy provisions should ensure that no significant negative effects arise as a result of new development, however it is still anticipated that overall there will a residual minor negative effect.

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Table 6.8: Likely significant effects, Transportation

Likely significant effect Effect dimensions Growth is likely to increase overall Direct, long-term, and negative levels of car ownership and use within District. Enhanced opportunities for active Direct, long-term and positive travel

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Economy

Commentary on proposed Local Plan spatial strategy 6.79 The preferred spatial strategy for the Local Plan seeks to focus, in the first instance, development within the boundaries of existing settlements, including building at higher density on non-Green Belt land. The four towns within the District – Sevenoaks, Swanley, Edenbridge and Westerham, will be the initial focus for development, with more moderate development within the settlements further down the Settlement Hierarchy.

6.80 This will support the economic vitality of the key towns and villages in the District, including through enhancing local economic offer and employment opportunities and supporting cultural activities.

6.81 The current version of the Local Plan also seeks to allocate and maintain retail provision according to the general distribution of development. This will broadly fall across the District’s main settlements, according to the Settlement Hierarchy, namely: Principal Town (Sevenoaks); Towns (Swanley, Edenbridge & Westerham); Local Service Centres (Hartley, New Ash Green & Otford); and Villages & Hamlets. In this respect the spatial strategy for retail will support the economic vitality of towns and villages in the District through supporting appropriate retail provision. Commentary on draft Local Plan as a whole 6.82 The current version of the Local Plan has a strong focus on supporting the economic vitality of the District.

6.83 This is reflected in the proposals which identify land for employment development up to a level which is higher than identified needs for the District (though it should be noted that not all of the proposed allocations may be included in the final draft of the plan). Policy 13 (Supporting a Vibrant and Balanced Economy) seeks to support the strong and diverse economy of the District and makes provision for the delivery of new employment land. The policy offers flexibility to accommodate different business needs whilst retaining existing employment land and local employment opportunities. The Settlement Hierarchy and Policy 1 (A Balanced Strategy for Growth in a Constrained District) will support the vitality of the larger settlements in the District and support their distinct economic functions and roles. Policy 13 also identifies some employment land opportunities in the smaller settlements, at an appropriate scale and location, with a view to supporting the economic vitality of these areas. Further support for economic vitality, including the tourism and visitor economy, is provided through Policy 14 (Town and Local Centres) which is explored further in the ‘Town and Local Centres’ SA Theme below.

6.84 The District has lost a significant amount of office floorspace to residential conversion since the changes to permitted development rights in 2013. This is recognised by the current version of the Local Plan, which seeks to protect existing office floorspace in the District to ensure sufficient provisions to meet local needs. Whilst the Local Plan identifies that Article 4 directions will largely achieve this, Policy 13 (Supporting a Vibrant and Balanced Economy) also seeks to retain non-residential use of land and/or buildings and all employment sites (allocated or non-allocated) unless the use is no longer feasible or viable. All redevelopment or conversion proposals at employment sites are also expected to consider employment-generating uses before a residential scheme. This will support the vitality of local economies and ensure a range of employment uses are present to meet local needs.

6.85 Policy 13 (Supporting a Vibrant and Balanced Economy) also provides support for the maintenance and diversification of the rural economy including development for agriculture, forestry, small scale business development and rural tourism projects. This will support local economic opportunities and vitality in the rural parts of the District.

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6.86 Policy 14 (Town and Local Centres) provides support for and sets out criteria for new sustainable tourism development within Town and Local Centres which are supported by transport infrastructure and minimise impacts on the landscape / townscape. The policy therefore supports the growth of the tourism and visitor economy in suitable locations, with benefits for the overall vitality and economic performance of the District.

6.87 Supporting access to employment opportunities, the Local Plan presents a number of provisions for promoting sustainable transport use and reducing the need to travel. This will support the economic vitality of the District by improving links within the District, as well as to locations outside of Sevenoaks. Policy 7 (Transport and Infrastructure) and Policy 15 (Design Principles) seek to improve opportunities for active travel, as well as infrastructure provisions like high speed broadband which can support working from home. In addition to supporting modern working practices, this will facilitate the running of businesses from home.

Table 6.9: Likely significant effects, Economy

Likely significant effect Effect dimensions Facilitating the growth of the Direct, long-term and positive economy and employment opportunities through appropriate employment land provision Promoting the vitality and viability Direct, indirect, long-term and positive of the District’s main settlements Supporting the vitality and viability Direct, indirect, long-term and positive of the District’s smaller settlements where appropriate Supporting the District’s rural Direct, indirect, long-term and positive economy Supporting business start-ups Direct, medium to long-term and positive

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Town and Local Centres

Commentary on proposed Local Plan spatial strategy 6.88 The preferred spatial strategy for the Local Plan seeks to focus, in the first instance, development within the boundaries of existing settlements, including building at higher density on non-Green Belt land. The four towns within the District – Sevenoaks, Swanley, Edenbridge and Westerham, will be the initial focus for development, with more moderate development within the settlements further down the Settlement Hierarchy.

6.89 This will support the vitality of the key towns and villages in the District, including through promoting the viability of services and facilities, enhancing local economic offer and employment opportunities and supporting cultural activities.

6.90 The District is well supported by Local Centres, including Neighbourhood Centres and Village Centres, which are key elements of the vitality of the District. In this context the preferred spatial strategy seeks to support an element of development in settlements further down the settlement hierarchy to support the viability of services and facilities in these locations.

6.91 The current version of the Local Plan also seeks to allocate and maintain retail provision according to the general distribution of development. This will broadly fall across the District’s main settlements, according to the Settlement Hierarchy, namely: Principal Town (Sevenoaks); Towns (Swanley, Edenbridge & Westerham); Local Service Centres (Hartley, New Ash Green & Otford); and Villages & Hamlets. In this respect the spatial strategy for retail will support the vitality of towns and villages in the District through supporting appropriate retail provision. Commentary on draft Local Plan as a whole 6.92 The vitality of town and local centres is dependent upon a number of factors, including the economic role and function of these areas. The Settlement Hierarchy and Policy 1 (A Balanced Strategy for Growth in a Constrained District) identifies that the majority of development will be focused in the larger settlements of Sevenoaks, Swanley, Edenbridge and Westerham, where the infrastructure provisions and range of services and facilities can most readily accommodate further growth. This will support their vitality in the long term. Local Centres are also identified in a number of smaller settlements, which provide support for local and everyday needs of residents and reduce the need to travel. This designation will support these settlements’ viability.

6.93 The Local Plan seeks to deliver 32,000m2 of new retail floorspace to support the growth and long-term viability of town and local centres, and Policy 14 (Town and Local Centres) identifies the intention to improve the quality of town centre environments through this growth. The policy also directs retail development to existing centres, thus precluding the development of out of centre shopping precincts which can affect town and local centre viability.

6.94 Policy 14 (Town and Local Centres) further identifies that within the four main settlements (Sevenoaks town, Swanley, Edenbridge and Westerham) mixed use development that includes an element of housing provision, is supported so long as residential elements are not proposed at the ground floor. This will contribute to maintaining a day time and night time economy within town centres. This will also support enhanced access to local services and facilities and active travel, and reduce the need to travel by private car. This will indirectly benefit the overall quality and experience of town centre environments.

6.95 The Local Plan, through Policy 14, further supports development at an appropriate scale within Local Centres (Hartley, New Ash Green and Otford), Neighbourhood Centres and Village Centres. This will support the viability of smaller settlements and their ongoing vitality.

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6.96 Further to this, Policy 14 also provides protections to retain existing shops, as well as community services and facilities in all centres, where these serve a local need. This will maintain the viability of these centres and ensure that communities are supported in the long term with good access to services and facilities to meet their everyday needs.

Table 6.10: Likely significant effects, Town and Local Centres

Likely significant effect Effect dimensions Improved retail offer to meet a Direct, long-term and positive growing population’s needs Long term support for the ongoing Direct, indirect, long-term and positive vitality and viability of Town, Local, Neighbourhood and Village Centres

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Part 3: What are the Next Steps?

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7. Next Steps Next steps for plan making / SA process This SA Report accompanies the current ‘Regulation 18’ consultation on the Local Plan (Sevenoaks District Draft Local Plan Consultation July 2018).

Following the receipt of consultation responses, the Local Plan will be updated and released by Sevenoaks District Council for Regulation 19 consultation with an updated SA Report.

Once the period for representations on the Regulation 19 version of the Local Plan document / SA Report concludes, the main issues raised will be identified and summarised by the Council, who will then consider whether, in light of representations received, the plan can still be deemed ‘sound’. If this is the case, the Local Plan will be submitted for Examination, alongside a statement setting out the main issues raised during the consultation. The Council will also submit the SA Report.

At Examination, the Inspector will consider representations (alongside the SA Report) before then either reporting back on the Local Plan’s soundness or identifying the need for modifications. If the Inspector identifies the need for modifications to the Plan these will be prepared (and undergo SA) and then be subject to consultation (with an SA Report Addendum published alongside).

Once found to be ‘sound’, the Local Plan will be formally adopted by the Sevenoaks District Council. At the time of Adoption, an SA ‘Statement’ must be published that sets out (amongst other elements) ‘the measures decided concerning monitoring’.

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Appendix A Spatial strategy options: detailed location of sites

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