Sustainability Appraisal of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan: Final Report

June 2014

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East Sussex County Council, South Downs National Park Authority and Brighton & Hove City Council

Sustainability Appraisal of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan: Final Report

June 2014

Reference 0223921

For and on behalf of Environmental Resources Management

Approved by: Kirsten Berry

Signed:

Position: Partner

Date: 26 June 2014

This report has been prepared by Environmental Resources Management the trading name of Environmental Resources Management Limited, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above.

This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.

CONTENTS

1 NON-TECHNICAL SUMMARY 1

1.1 PURPOSE OF THIS REPORT 1 1.2 OUTLINE OF CONTENTS OF WMSP 1 1.3 LINKS TO OTHER PLANS AND PROGRAMMES 1 1.4 KEY CHARACTERISTICS OF THE PLAN AREA 2 1.5 CHARACTERISTICS OF AREAS LIKELY TO BE SIGNIFICANTLY AFFECTED 3 1.6 AREAS OF PARTICULAR ENVIRONMENTAL IMPORTANCE 4 1.7 SUSTAINABILITY APPRAISAL FRAMEWORK 5 1.8 OPTIONS 6 1.9 HOW THE ASSESSMENT WAS UNDERTAKEN 6 1.10 DIFFICULTIES ENCOUNTERED 8 1.11 LIKELY SIGNIFICANT EFFECTS OF THE WMSP 8 1.12 MITIGATION 10 1.13 MONITORING 10 1.14 STATEMENT ON THE DIFFERENCE THE PROCESS HAS MADE 10

2 INTRODUCTION AND BACKGROUND 11

2.1 PURPOSE OF THIS REPORT 11 2.2 REQUIREMENT FOR SUSTAINABILITY APPRAISAL/STRATEGIC ENVIRONMENTAL ASSESSMENT 11 2.3 EAST SUSSEX, SOUTH DOWNS AND BRIGHTON & HOVE WASTE AND MINERALS LOCAL PLAN 12 2.4 SUSTAINABILITY APPRAISAL PROCESS AND PLAN MAKING 13 2.5 CONTRIBUTING TOWARDS SUSTAINABLE DEVELOPMENT 15 2.6 CURRENT SUSTAINABILITY APPRAISAL AND SUPPORTING DOCUMENTS 16 2.7 KEY CHARACTERISTICS OF THE PLAN AREA 16 2.8 WASTE 18 2.9 MINERALS 20 2.10 SUSTAINABILITY APPRAISAL PROCESS 21 2.11 OUTLINE OF CONTENTS OF WMSP 21 2.12 LINKS TO OTHER PLANS AND PROGRAMMES 22

3 METHODOLOGY 23

3.1 APPRAISAL FRAMEWORK 23 3.2 DIFFICULTIES ENCOUNTERED 24 3.3 COMPLIANCE WITH THE SEA DIRECTIVE AND REGULATIONS 25

4 SUSTAINABILITY CONTEXT AND ISSUES 27

4.1 REVIEW 27 4.2 SUSTAINABILITY ISSUES AND PROBLEMS 27 4.3 CHARACTERISTICS OF AREAS LIKELY TO BE SIGNIFICANTLY AFFECTED 39 4.4 AREAS OF PARTICULAR ENVIRONMENTAL IMPORTANCE 39

5 SUSTAINABILITY APPRAISAL FRAMEWORK 43

5.1 INTRODUCTION 43 5.2 OBJECTIVES AND DECISION-MAKING CRITERIA 43

6 OPTIONS APPRAISAL 49

6.1 INTRODUCTION 49 6.2 DESCRIPTION OF OPTIONS 49 6.3 APPRAISAL RESULTS 50 6.4 PREFERRED OPTION 51

7 APPRAISAL OF SITES 53

7.1 METHODOLOGY 53

8 APPRAISAL OF WMSP POLICIES AND OBJECTIVES 55

8.1 METHODOLOGY 55 8.2 APPRAISAL OF POLICIES 56 8.3 COMPATIBILITY CHECK OF STRATEGIC OBJECTIVES 58

9 CUMULATIVE EFFECTS AND INTERRELATIONSHIP BETWEEN EFFECTS61

9.1 CUMULATIVE EFFECTS 61 9.2 INTERRELATIONSHIP BETWEEN EFFECTS 65

10 MONITORING 67

10.1 PROPOSALS FOR MONITORING 67

11 NEXT STEPS 69

11.1 CONSULTATION 69 11.2 PROPOSED SUBMISSION WMSP 69

Annex A: Review of Policies, Plans and Programmes Annex B: Sustainability Baseline Annex C: Maps Annex D: Policy Appraisal Annex E: Options Appraisal Annex F: Appraisal of Sites Annex G: Review of Other Plans and Programmes

1 NON-TECHNICAL SUMMARY

1.1 PURPOSE OF THIS REPORT

This report sets out the findings and conclusions of a Sustainability Appraisal (SA), incorporating the requirements of the EU Strategic Environmental Assessment Directive1, of the Waste and Minerals Sites Plan (WMSP) for East Sussex and Brighton & Hove.

The WMSP is the second of two documents to be prepared as part of the Waste and Minerals Local Plan. The first document prepared by the Authorities was the East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan (WMP). This was adopted in February 2013 and sets the Authorities’ strategic spatial planning policies governing waste management and minerals production in the Plan Area up to the year 2026.

1.2 OUTLINE OF CONTENTS OF WMSP

The draft WMSP sets out all the spatial details related to the requirements identified in the WMP for East Sussex, part of the South Downs and Brighton & Hove over the period to 2026. It sets out proposed site allocations for development of new waste recovery and recycling facilities, and safeguards those that already exist. It also safeguards mineral resources, certain types of minerals facilities and railheads and wharves. The WMSP also identifies requirements to deal with wastewater but does not currently contain any allocations for wastewater treatment sites.

1.3 LINKS TO OTHER PLANS AND PROGRAMMES

In March 2012, the Government published the National Planning Policy Framework (the Framework) establishing the approach to achieving sustainable development. Emphasis was placed on the importance of ensuring that Local Plan policies contribute to achieving sustainable development, in terms of promoting sustainable economic growth. The WMSP has been prepared in compliance with the Framework.

The WMP was adopted in February 2013. This sets out the how the East Sussex County, Brighton & Hove City Councils and the South Downs National Park Authority propose that waste should be managed and minerals produced within their spatial context up to 2026, and aims to ensure that waste is managed and minerals produced in sustainable ways. It identifies strategic areas for the location of sites and sets the context for identifying sites for waste management and minerals development. It also includes a suite of

(1) European Directive EC/2001/42

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 1 development control policies. The WMSP seeks to support the WMP in promoting the sustainable management of waste and minerals by identifying and allocating potential sites for new waste development.

1.4 KEY CHARACTERISTICS OF THE PLAN AREA

The Plan Area comprises the county of East Sussex and the city of Brighton & Hove, and is characterised by a densely populated urban coastal zone and a dispersed settlement pattern in rural areas. Three quarters of the total population live in the coastal area with the highest concentration in Brighton & Hove. The need for additional waste management and minerals supply is underlined by population increases across the Plan Area.

Health deprivation is a significant problem in parts of the Plan Area, most notably across parts of Hastings and Brighton & Hove. In Hastings, life expectancy for both men and women is below the national average and the lowest in the Plan Area, while men in Brighton & Hove and Eastbourne also demonstrate a life expectancy below the national average.

Employment and income deprivation are significant problems in parts of Hastings and in other parts of the Plan Area. Low skill levels and poor education attainment are issues in some areas.

The Plan Area possesses an array of sites designated as being of international, national, regional and local importance for biodiversity. There are five Special Areas of Conservation (SAC), two Special Protection Areas (SPA) and one Ramsar site. A proposed extension to the SPA and Ramsar designation at Dungeness/Rye Harbour is currently being reviewed.

National designations include over 13,000 ha of Sites of Special Scientific Interest (SSSI) that are important for wildlife or geological interest, four National Nature Reserves and 10% of East Sussex is covered by Ancient Woodland. There are also designations of local importance including 1,771.3 ha of Local Nature Reserves and 366 Sites of Nature Conservation Importance.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 2 Sussex and Brighton & Hove and identifies areas where development may affect historical/archaeological remains.

The strategic road network serving the Plan Area comprises the A/M23, M25, A21 and A27/A259. Primary routes which link into the strategic road network and serve the Plan Area are the A22, A26, and the A272. In general the quality of the highway and trunk road network in East Sussex and Brighton & Hove is currently not designed for carrying long distance strategic traffic and this leads to vehicles using inappropriate rural roads, with key trunk roads at or near to capacity.

The rail network links the main coastal towns and their rural hinterland with London, Southampton and the continent. The freight carrying potential of the network may not be fully utilised and some spare capacity exists on routes such as those south of Gatwick Airport.

Air quality is generally good in the Plan Area. However, there are a number of locations which exceed air quality thresholds and Air Quality Management Areas (AQMA) have been declared in Brighton & Hove, Lewes and Hastings. In addition, Newhaven has possible exceedences of nitrogen dioxide.

There is an overall general decline in carbon dioxide emissions across the Plan Area, reflecting a similar position in the South East region. Per capita emissions in the Plan Area are low compared to regional and national data.

Only one in five surface water bodies have ‘good ecological status’ and 40% are at least ‘good’ biological status. 43% of groundwater meets ‘good’ quantitative status and 63% meets ‘good’ chemical status.

Risk of both fluvial and coastal flooding is a significant issue in the Plan Area.

1.5 CHARACTERISTICS OF AREAS LIKELY TO BE SIGNIFICANTLY AFFECTED

Although a number of the waste sites are clustered around the main settlements of Brighton & Hove, Newhaven, Eastbourne, Bexhill and Hastings, there are also waste sites scattered throughout smaller settlements and rural areas in East Sussex. It can therefore be said that local areas within much of the county have the potential to be significantly affected. The sustainability characteristics at individual allocated sites are described in Annex F. However, in reality, it is not known which of these sites might come forward for development, and therefore it is not possible to say with any certainty whether any specific areas are likely to experience significant effects.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 3 1.6 AREAS OF PARTICULAR ENVIRONMENTAL IMPORTANCE

There are five Special Areas of Conservation (SAC), two Special Protection Areas (SPA) and one Ramsar site in the Plan Area, which are strictly protected by the EU Habitats and Birds Directives. A proposed extension to the SPA and Ramsar designation at Dungeness/Rye Harbour is currently being reviewed. Table 1.1 presents the issues and problems that are occurring at these designated sites.

Table 1.1 Issues and Problems at Sites of International Nature Conservation Importance

Site Issues and problems

Ashdown Forest SAC Insufficient grazing Spread of scrub and bracken Long-term drying out of site Possible impact of extraction

Ashdown Forest SPA Lack of management Succession from open heathland to woodland Lack of grazing Spread of invasive species Intense recreational use

Lewes Downs SAC Scrub encroachment Leaching and spray drift from surrounding farmland

Castle Hill SAC Scrub encroachment Leaching and spray drift from surrounding farmland

Hastings Cliffs SAC Erosion by surrounding coastal protection measures and offshore activities Visitor pressure Adjacent farming practices

Dungeness SAC Disturbance by vehicles and walkers Illicit gravel extraction Invasion of willows Water abstraction Air pollution

Dungeness to Pett Level Coastal erosion SPA and proposed Predation of bird populations Ramsar site Aircraft disturbance Recreational and leisure activities Changing agricultural practices Heavy grazing Lowering water levels

Dungeness, Romney Unknown, but likely to be as above Marsh and Rye Bay potential SPA

Pevensey Levels Ramsar Introduction/invasion of non-native plant species site

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 4 Site Issues and problems Pollution from domestic sewage

1.7 SUSTAINABILITY APPRAISAL FRAMEWORK

A review was undertaken of plans, policies and programmes that are relevant to sustainable development in the Plan Area and to the management of waste and minerals. This set the policy context for the WMSP. The review identified the key sustainable development policy objectives and relevant targets which have fed into the identification of sustainability issues and enabled a framework of sustainable development policy objectives relevant to the WMSP to be drawn up.

The SA objectives for the appraisal of the WMSP are:

1. To avoid negative effects and enhance, where possible, positive effects on health. 2. To protect the amenity of residents and neighbouring land uses. 3. To improve equality and access to sustainable waste management. 4. To minimise waste generation and disposal to land. 5. To ensure the sustainable use of local mineral resources. 6. To maintain and improve water quality. 7. To seek the protection of and sustainable use of water resources. 8. To reduce risk and impact of flooding. 9. To limit the causes of and adapt to climate change. 10. To protect air quality and reduce air pollution. 11. To reduce adverse impacts of transporting waste and minerals on the environment. 12. To conserve and enhance important soil functions and types. 13. To protect, conserve and enhance East Sussex and Brighton & Hove’s countryside and historic and built environment. 14. To protect, conserve and where appropriate enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity. 15. To increase energy efficiency and the proportion of energy generated from renewable sources. 16. To contribute to the growth of a sustainable and diversified economy. 17. To provide employment opportunities and develop and maintain a skilled workforce.

These objectives have been further developed by the inclusion of decision- making criteria to define the SA objectives in greater detail. The WMSP has been appraised against this SA framework to determine the contribution of the WMSP to achieving or supporting the SA framework objectives and decision-making criteria.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 5 1.8 OPTIONS

In developing the WMSP, a single category of options has been considered, that of the number of waste sites to be allocated.

The following options have been developed:

• A1: Allocate all sites that are suitable for development. • A2: Allocate the minimum number of sites sufficient to manage the higher end of the capacity gap. • A3: Allocate more sites than the minimum to provide flexibility, but not all.

Each of these has been appraised against the SA objectives of the appraisal framework and the results of the appraisal are set out in Section 7 of this report.

The different options that have been developed and the reasons for selecting these options are given below.

Allocating sites based on suitability rather than need would provide the most flexibility for the waste industry and would allow the WMSP to be more responsive to technological innovation. However, there would be considerable uncertainty for local communities and could also result in inappropriate spatial concentration of facilities in one part of the Plan Area and a danger of over-provision of capacity.

Allocating the minimum number of sites would provide the greatest level of certainty for local communities. However it would also be very inflexible for the waste industry and leave the WMSP unable to accommodate any changes of circumstance which could affect the deliverability of identified sites.

The final option would be to reduce the number of potentially suitable sites to a determined quantity for inclusion on the shortlist. This approach would allocate those sites that have the greatest sustainability benefits, and the number allocated could be set to ensure sufficient flexibility but also to manage community knowledge. Sites potentially suitable but not taken forward could still come forward using criteria based policies.

1.9 HOW THE ASSESSMENT WAS UNDERTAKEN

The SA has tested the draft WMSP against a framework of objectives that reflect relevant sustainable development policy objectives. Table 5.1 sets out the framework of objectives that has been used to appraise the WMSP.

The appraisal determined the likely effects arising from the WMSP. This applied largely to the objectives and policies, to a series of options and to the

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 6 sites with potential for waste development. The appraisal was done by assessing each element of the WMSP against the appraisal objectives in turn and making a largely qualitative assessment, with reference also to the baseline data from the Scoping Report.

In reporting the results of the appraisal, the following symbols have been used to indicate the broad nature of the predicted effect:

+ effect likely to be positive - effect likely to be negative 0 no significant effect ? effect unknown

If the appraisal objective was not relevant to the element of the WMSP being appraised, no symbol is given.

Multiple symbols have been used (e.g. ++) to indicate a different scale of impact over time, or where the impacts of an option are substantially better or worse than others.

The effects were also rated for their significance in terms of the importance for achieving each appraisal objective. Effects were rated as high, medium or low significance, taking account of a number of factors. The factors were:

• the expected scale of the effects or the degree to which the effects are likely to contribute to the achievement of the SA objective in the Plan Area overall; • the certainty or probability that the effect is likely to occur as a consequence of the WMSP; • whether the effects would be permanent or reversible; • whether the effect will occur as a direct result of the WMSP or not, in other words whether the WMSP is key for achieving or controlling effects; • whether the effect is more strongly dependent on other interventions or other factors; and • how important the SA objective is to the scope of the WMSP.

The assessment of significance is indicated in the tables in this report by colour: Not relevant No significance Medium significance High significance

The tables make an assessment of effects over short, medium and long-term timeframes. The SA has also assessed the likely significant cumulative effects of the WMSP in its entirety and in combination with other relevant plans and

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 7 projects, and considered the interrelationship between effects. The conclusions of this are set out in Section 9.

1.10 DIFFICULTIES ENCOUNTERED

A number of difficulties were encountered in undertaking the appraisal:

• Data. A common problem affecting SA is the availability and reliability of data. Although data has been collected to illustrate a number of the conditions and trends relevant to the SA of the WMSP, some data sets are more useful than others, and some data sets are known to be old, incomplete or unreliable. In some cases, no data is available. It is therefore almost impossible to quantify effects with total certainty, and the quality of available data could in some situations lead to a false impression of accuracy, which should be avoided.

• Uncertainty. It is not known what type of facility is likely to be proposed on any site and therefore it is not possible to predict with any certainty what the likely effects might be of development at a site. Similarly the scale of any development is not known with any accuracy and therefore the size of effects is also unknown. Furthermore, it is not known which of the allocated sites are likely to be proposed by developers for waste facilities and therefore the exact location and distribution of developments are not known. It is also unknown what the waste catchment area will be for any site which is developed and therefore the amount of waste transport arising in connection with site development is unknown. Finally, the location of any new minerals sites is also unknown, as is the future level of demand for primary, secondary and recycled minerals, and therefore the effect of minerals transport is uncertain.

• Significance. There are very few agreed sustainability thresholds or constraints, as little work has been done in the UK on this issue, although the idea of ‘living within environmental limits’ is increasingly being operationalised. Because of this, it is not always possible to assess the significance of any impacts with certainty. In some circumstances thresholds are set by legislation or by statutory authorities, for example on air and water quality. Where possible reference has been made to such information.

1.11 LIKELY SIGNIFICANT EFFECTS OF THE WMSP

By safeguarding existing waste sites and allocating new sites, the WMSP will help to ensure sufficient facilities within the Plan Area to deal with waste arisings, maximising the recovery of value from waste and minimising disposal to landfill. This will minimise waste transport distances and promote waste recycling and energy recovery, leading to reduced energy use and reduced greenhouse gas emissions. It will also help to reduce waste transport

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 8 distances and contribute to avoiding adverse impacts on air quality from waste transport. By seeking to prevent existing waste facilities from being prejudiced from development proposals, the WMSP will indirectly help to ensure that adverse impacts on health and amenity from waste facilities on surrounding uses are prevented.

The WMSP will support businesses involved in sustainable waste management activities, and ensure the supply of recycled minerals to support sustainable construction.

By safeguarding secondary and recycled aggregates facilities, the WMSP will indirectly help to conserve geological resources in the Plan Area. This will support the efficient management of mineral resources and will also indirectly support sustainable construction and demolition. It will also indirectly help to reduce adverse impacts of mining on landscape and countryside.

The WMSP directly seeks to safeguard mineral sites and facilities to safeguard mineral resources and manage them efficiently, which will help to encourage local supplies of minerals. This will support economic growth both by providing materials to support construction of housing and infrastructure and by providing or protecting jobs, including in some of the more deprived areas. It also safeguards wharves and railheads which will help to ensure supply of minerals to support economic growth. The WMSP supports the sustainable transport of minerals and reduces the likelihood of adverse impacts on air quality and amenity from road transport of minerals, and helps to avoid greenhouse gas emissions.

Many of the sites are constrained in some way by features of biodiversity value and adverse cumulative impacts on biodiversity are possible, including from reduced air quality, disturbance, direct land-take, predation, litter and fragmentation of networks. Several are also within flood risk areas, which could lead to increased flood risk from development of more than one site within a catchment, although development could also present an opportunity for works to reduce the risk and impact of flooding and therefore the likelihood of effects on flood risk is uncertain. Some sites are close to the SDNP, AONB and historic assets and adverse impacts are possible. Development should be of high quality design to reduce the likelihood of impacts on landscape and historic assets and to protect residential amenity. For some sites, opportunities to co-locate waste facilities and use sustainable modes of transport have been identified, and this could help to further reduce road transport of waste. Some sites have potential for connection to heat networks, which would help to increase energy efficiency and reduce greenhouse gas emissions. Some sites are close to an AQMA and vehicles could add to poor air quality, but in many cases effective routing of vehicles could avoid adverse impacts. Although many sites are on previously developed land, some are greenfield and soil and open space will be lost if these are developed.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 9 1.12 MITIGATION

In addition to appraising the policies and objectives of the WMSP and a series of types of options, the SA has also undertaken an appraisal of each site with potential for waste development. As a part of the appraisal of sites, a large number of recommendations have been made for measures to prevent or reduce as much as possible the possible or likely significant adverse effects of development at each site. These mitigation recommendations are set out in detail in Annex F.

1.13 MONITORING

The SA has developed a set of recommendations for monitoring the predicted and unforeseen impacts of implementation of the WMSP. These are set out as a series of indicators related to the sustainability appraisal framework based on the likely and possible impacts of the WMSP. The recommended indicators should be incorporated into the Annual Monitoring Report for the WMLP Plan and are set out in Section 10.

1.14 STATEMENT ON THE DIFFERENCE THE PROCESS HAS MADE

From the outset, as the SA has been developed it has informed the preparation of the WMSP.

The relationship between the SA appraisal objectives and the criteria used within the Site Assessments can be found in Appendix 4 of the Site Assessment Methodology and Options Paper. This then fed through to the Site Assessment work. Summaries of the SA for the sites identified within the WMSP can be found in their Site Profiles located in Appendix A of the WMSP. The SA of Options A1-3 informed the chosen approach of sites selected, and more information is provided on this in the Site Assessment Methodology and Options Paper.

The SA of the Plan policies has given the Authorities confidence that the WMSP will achieve the objectives of the Waste and Minerals Local Plan.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 10 2 INTRODUCTION AND BACKGROUND

2.1 PURPOSE OF THIS REPORT

Sustainability Appraisal is a systematic process undertaken during the preparation of a Local Plan. Carrying out a Sustainability Appraisal will help East Sussex County Council, the South Downs National Park Authority and Brighton & Hove City Council to assess whether, and to what extent, emerging policies and proposals impact upon environmental, social and economic conditions. It also provides a means of identifying and addressing any adverse effects that draft policies and proposals might have and making recommendations for mitigating potential adverse effects or capitalising on opportunities for benefits.

2.2 REQUIREMENT FOR SUSTAINABILITY APPRAISAL/STRATEGIC ENVIRONMENTAL ASSESSMENT

The Planning and Compulsory Purchase Act 2004 requires that an SA is carried out for all development plan documents (DPD). As the Waste and Minerals Site Plan sets a framework for future development consent of projects that are likely to have significant environmental effects, a Strategic Environmental Assessment (SEA), as required by the European Directive EC/2001/42 (the SEA Directive), is also necessary. The National Planning Policy Framework (the Framework) also states that an SA, incorporating the requirements of the SEA Directive, is integral to the plan making process.

The SA process plays an important role in demonstrating that a DPD is contributing to achieving sustainable development through the integration of environmental, social and economic considerations into the DPD. It is a systematic and iterative process which assesses the likely significant effects of the Plan on the environment, the economy and society.

SEA introduces a systematic assessment of the environmental effects of plans and programmes, including land use plans. Its objective is ’to provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes, with a view to promoting sustainable development, by ensuring that, in accordance with this Directive, an environmental assessment is carried out on certain plans which are likely to have significant effects on the environment.’

(2) European Directive EC/2001/42

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 11 Although the requirements of SA and SEA are distinct, a single joint appraisal incorporating SA and SEA requirements will be carried out, in accordance with national guidance, to ensure that all issues are considered.

2.3 EAST SUSSEX, SOUTH DOWNS AND BRIGHTON & HOVE WASTE AND MINERALS LOCAL PLAN

East Sussex County Council, the South Downs National Park Authority (SDNPA) and Brighton & Hove City Council are the three waste and minerals planning administrations (collectively referred to as the Authorities) for the Plan Area. The Authorities are responsible for preparing the Waste and Minerals Local Plan (WMLP) (formerly known as the Waste and Minerals Development Framework), which consists of statutory land-use planning policies, and for determining planning applications for minerals and waste development.

The WMLP will consist of two development plan documents

• Waste and Minerals Plan (WMP); • Waste and Minerals Sites Plan (WMSP, or the Plan).

These Plans will replace the East Sussex and Brighton & Hove Waste Local Plan (2006) and the Minerals Local Plan (1999).

The first document prepared by the Authorities was the East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan (WMP). This was adopted in February 2013 and replaces the majority of the planning policies in the Waste Local Plan and Minerals Local Plan. The Plan sets the Authorities’ strategic spatial planning policies governing waste management and minerals production in the Plan Area up to the year 2026.

The second document to be prepared is the Waste and Minerals Sites Plan (WMSP). This will safeguard existing and allocate new sites that are suitable for the management of waste, and set policies for the safeguarding and transportation of mineral resources.

2.3.1 The Relationship between the Planning Authorities

The South Downs National Park Authority was created in April 2010. The National Park extends from Winchester in the west to Eastbourne in the east, extending over an area of more than 1600 km2 and covering parts of Hampshire, East and West Sussex and Brighton & Hove. The geography of the National Park (and therefore the SDNPA administration) partially overlaps with the geography of East Sussex County Council, Brighton & Hove City Council, Eastbourne Borough Council, Lewes District Council and Wealden District Council.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 12 As a planning authority, the SDNPA has a role to control and influence the development of land and buildings within its boundaries. In order to do this, it has negotiated partnership agreements with the 15 local authorities operating within the National Park boundaries, working alongside them and overseeing planning applications. Of these, 11 of the local authorities deal with the majority of planning applications in their geographical area, while the SDNPA deals with the more significant applications. Included in these 11 are East Sussex County Council and Lewes District Council. The other four authorities, which include Brighton & Hove City Council, Eastbourne Borough Council and Wealden District Council, do not determine planning applications within the boundaries of the National Park. These are determined by the SDNPA.

The SDNPA is also carrying out joint working in the preparation of planning policy documents, including the MWLP.

For clarity in reading this SA Report, when describing the baseline conditions in the Plan Area the report usually refers to East Sussex and Brighton & Hove, which should be understood as the land falling within the boundaries of East Sussex County Council and Brighton & Hove City Council. This constitutes the Plan Area. Parts of this Plan Area include land within the National Park, but not all of the Plan Area. Furthermore, the National Park extends over a much wider area than the Plan Area.

2.4 SUSTAINABILITY APPRAISAL PROCESS AND PLAN MAKING

The first Scoping Report for the Waste and Minerals Local Plan (known at that time as the Waste and Minerals Development Framework) was published in 2007 and was prepared as a basis for appraising the Waste and Minerals Plan (known at that time as the Waste & Minerals Core Strategy). A Scoping exercise for the SA of the WMSP was undertaken in 2013, which culminated in the publication of a Scoping Report in November 2013. This was issued for consultation with the three statutory authorities, namely the Environment Agency, Natural England and English Heritage. The Scoping Report incorporated the findings from an earlier Pre-Scoping exercise in which a Pre- Scoping Report had been published for consultation with the statutory authorities in July 2013 in order to get early comments from the authorities on the scope of the SA.

As a result of comments received from the consultees, a number of small changes were made to the appraisal framework, to include additional decision-making criteria on landscape and visual impact and on effects on biodiversity.

SA forms an integral part of the preparation process of Development Plan Documents (DPDs) of which the WMSP is one, as the diagram below shows.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 13 Figure 2.1 The Development Plan Preparation Process

The process of preparing an SA is made up of stages and specific tasks as detailed in Government guidance1. This SA Report covers the second two stages of the process, Stages B and C, which include the following tasks. Stage A was the Scoping stage, which was undertaken in 2013 and is covered in the Scoping Report2 published in November 2013.

(3) 1 Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents (ODPM, 2005); Planning Practice Guidance on Strategic Environmental Assessment and Sustainability Appraisal, March 2014

(4) 2 Sustainability Appraisal of Local Plan: Scoping Report, URSUS Consulting Ltd, September 2013

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 14 Table 2.1 Stages of SA Covered by this Report

Stage B Developing and refining options and assessing effects

Task B1 Testing the WMSP objectives against the SA framework

Task B2 Developing the WMSP options

Task B3 Predicting the effects of the WMSP

Task B4 Evaluating the effects of the WMSP

Task B5 Considering ways of mitigating adverse effects and maximising beneficial effects

Task B6 Proposing measures to monitor the significant effects of implementing the WMSP

Stage C Preparing the Sustainability Appraisal Report

Task C1 Preparing the SA Report

This SA Report sets out the results of Stages B and C, which have been carried out between March and May 2014, and includes an appraisal of the draft policies, proposed development allocations and spatial options.

2.5 CONTRIBUTING TOWARDS SUSTAINABLE DEVELOPMENT

Development plan documents are required by the Planning and Compulsory Purchase Act 2004 to contribute towards the achievement of sustainable development, which is the idea of ensuring a better quality of life for everyone, now and in the future. A commonly used definition is:

’development that meets the needs of the present without compromising the ability of future generations to meet their own needs’ (Bruntland Commission, 1987).

In March 2012, the UK Government published the Framework, which sets out what sustainable development means in practice for the planning system. In defining sustainable development, it refers to the five guiding principles set out in the UK Sustainable Development Strategy – Securing the Future (2005), as follows:

• Living within environmental limits • Ensuring a strong, healthy and just society • Achieving a sustainable economy • Promoting good governance, and • Using sound science responsibly

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 15 2.6 CURRENT SUSTAINABILITY APPRAISAL AND SUPPORTING DOCUMENTS

The Waste and Minerals Sites Plan Sustainability Appraisal is a daughter document of the Waste and Minerals Plan Sustainability Appraisal. The relevant existing documents and evidence base is comprised of the following:

• East Sussex and Brighton & Hove Waste and Minerals Core Strategy and Minerals Site Development Plan Document Sustainability Appraisal Scoping Report, March 2007;

• Draft Habitats Regulations Assessment of the Waste and Minerals Plan, 2011;

• East Sussex, South Downs and Brighton & Hove Waste and Minerals Development Framework Sustainability Appraisal Report, February 2013 (the 2013 SA Report);

• East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan Post Adoption Statement, 2013;

• East Sussex, South Downs and Brighton & Hove Waste and Minerals Local Plan: Sustainability Appraisal of the Waste and Minerals Sites Plan Pre- Scoping Report, July 2013;

• Scoping Report for the Sustainability Appraisal of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan;

• Draft Habitats Regulations Assessment Screening of the East Sussex South Downs and Brighton & Hove Waste Sites Short List, April 2014;

2.7 KEY CHARACTERISTICS OF THE PLAN AREA

The Plan Area comprises the county of East Sussex and the city of Brighton & Hove. The county of East Sussex contains the boroughs of Eastbourne and Hastings and the districts of Lewes, Rother and Wealden. Parts of the Plan Area fall within the boundary of the South Downs National Park. The Plan Area is characterised by a densely populated urban coastal zone and a dispersed settlement pattern in rural areas. The population of the Plan Area totals 800,040, of which 526,671 live in East Sussex and 273,369 live in Brighton & Hove.1 Three quarters of the total population live in the coastal area with the highest concentration to the west, in Brighton & Hove. The need for additional waste management and minerals supply is underlined by population increases across the Plan Area, with the population of Brighton & Hove having increased by 10% since 2001, and the population of East Sussex having increased by 7% over the same time period.

(5) Population figures taken from Census 2011

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 16 Health deprivation is a significant problem in parts of the Plan Area, most notably across large areas of Hastings and Brighton & Hove. In Hastings, life expectancy for both men and women is below the national average and the lowest in the Plan Area, while men in Brighton & Hove and Eastbourne also demonstrate a life expectancy below the national average. 59% of Super Output Areas (SOA) in Hastings and 44% in Brighton & Hove fall within the 20% most health deprived SOA nationally.

Employment and income deprivation are significant problems in Hastings, and in other parts of the Plan Area. Low skill levels and poor education attainment are issues in some areas. Eastbourne and Hastings have a greater proportion of people with no qualifications than the national average.

Much of the Plan Area is recognised for its high quality landscape which forms an important part of the area’s distinctive character. The South Downs National Park and High Weald Area of Outstanding Natural Beauty (AONB) cover around two thirds of the Plan Area. The Low Weald is a landscape of considerable historic complexity. The South Downs National Park was confirmed by statute in April 2010, with the National Park Authority becoming fully operational in April 2011.

The Plan Area possesses an array of sites designated as being of international, national, regional and local importance for biodiversity. There are five Special Areas of Conservation (SAC), two Special Protection Areas (SPA) and one Ramsar site, which are strictly protected by the EU Habitats and Birds Directives. A proposed extension to the SPA and Ramsar designation at Dungeness/Rye Harbour is currently being reviewed.

National designations include over 13,000 ha of Sites of Special Scientific Interest (SSSI) that are important for wildlife or geological interest, four National Nature Reserves and 10% of East Sussex is covered by Ancient Woodland, the highest proportion of any county in England. There are also designations of local importance including 1,771.3 ha of Local Nature Reserves and 366 Sites of Nature Conservation Importance.

East Sussex and Brighton & Hove possess highly valued built and cultural environments, which include 325 scheduled ancient monuments, 127 conservation areas, many listed buildings and some registered parks and gardens, battlefields and wrecks. There are over 14,000 entries on the Historic Environment Record which records and maps the known archaeology of East Sussex and Brighton & Hove and identifies areas where development may affect historical/archaeological remains. Apart from the known components of the historic environment there is much that is not identified but may be discovered through developing a site.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 17 the quality of the highway and trunk road network in East Sussex and Brighton & Hove is not fit for purpose for carrying long distance strategic traffic and this leads to vehicles using inappropriate rural roads, with key trunk roads at or near to capacity.

The rail network links the main coastal towns and their rural hinterland with London, Southampton and the continent, via Ashford International Station in Kent. The freight carrying potential of the network is not fully utilised and some spare capacity exists on routes such as those south of Gatwick Airport.

There are ports at Newhaven, Shoreham and Rye, which import marine dredged aggregates and crushed rock. Newhaven is the only port in East Sussex that is still accessible by rail for the movement of freight, including waste and minerals. Aggregates are imported into Shoreham and Newhaven, and crushed rock and secondary materials are imported into Rye and Newhaven, all of which are subsequently transported by road. The average distance aggregates travel from their source is 30 miles, although there are exceptions to this where the market allows due to local needs.

Risk of both fluvial and coastal flooding is a significant issue in the Plan Area.

2.8 WASTE

Waste is defined as materials or goods we discard because they are no longer needed. The Waste Strategy for England (2007) emphasises the importance of moving the treatment of waste away from landfill and up the waste hierarchy. This message has been reiterated by Government; through the Government Review of Waste Policy in England 2011 and the consultation draft Updated National Waste Planning Policy: Planning for Sustainable Waste Management. Whatever the origin of the waste material, it is important that it is viewed as a valuable resource which can be reused, recycled or used to recover energy rather than being discarded or disposed of without any value being extracted.

In general terms, waste is categorised as the following:

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 18 • Non-inert (non-hazardous) waste: this is potentially biodegradable or may undergo significant physical, chemical or biological change if deposited at a landfill site. It is made up of household, industrial and commercial waste.

• Inert waste: this does not normally undergo any significant physical, chemical or biological change when deposited at a landfill site. It may include materials such as rock, concrete, brick, sand, some sub-soils or certain arisings from road construction or maintenance.

• Hazardous waste: this may pose a greater risk of harm to human health and the environment due to the properties of the waste (eg explosive or corrosive). It might include clinical waste.

2.8.1 Waste in East Sussex and Brighton & Hove

Around 1.75 million tonnes of solid waste are handled in the Plan Area each year. The main types are:

• Local Authority Collected Waste (LACW): this is waste collected by local authorities, generally from households, street cleaning and public parks and gardens. The current production of around 360,000 tonnes per annum makes up about 21% of all wastes in the Plan Area.

• Commercial and Industrial (C&I) Waste: this is from shops, food outlets, businesses and manufacturing activities. It is estimated that around 475,000 tonnes of C&I waste was produced in 2008/09 and makes up about 27% of wastes in the Plan Area.

• Construction, Demolition and Excavation Waste (CDEW): this is produced from building activity. The amount fluctuates considerably due to economic and social factors, with increases during periods of high development activity. Accurate figures for arisings are difficult to obtain and estimates suggest that around 906,000 tonnes was produced in 2008/09 making up about 51% of total waste arisings in the Plan Area.

• Other wastes: include hazardous waste (around 19,000 tonnes per year), low level radioactive waste, liquid waste (other than wastewater), and wastes arising from the agricultural sector. Hazardous wastes in total make up around 1% of the total waste stream in the Plan Area.

• Wastewater: this is water and solids collected from public sewers which flow to water treatment works. There are 32 waste treatment works within the Plan Area, treating 60 million cubic metres of wastewater each year.

There is a range of existing waste management facilities within the Plan Area for different types of waste streams including recycling and composting, bulk metals recycling, CDEW recycling, other recovery, hazardous treatment, non-

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 19 hazardous landfill and inert landfill. Progress is being made towards more sustainable management of waste; however a significant proportion of solid waste produced by business and industry is still landfilled, as can be seen in Table 2.2.

Table 2.2 Current Management of Waste in the Plan Area

Recycling Other Recovery Landfill

LACW 39% 60% 1%

C&I 67% 4% 29%

CDEW 45% 40% 15%

2.9 MINERALS

Minerals are naturally occurring substances including metals, rocks and hydrocarbons that are extracted from the earth by mining, quarrying and pumping. They are used in a wide range of applications related to construction, manufacturing, agriculture and energy supply.

The following minerals are found in the Plan Area:

• Aggregates: sand and gravel are important for infrastructure and buildings. There has been a low-level of extraction of land-won sand and gravel in East Sussex, and therefore imports of marine aggregates and crushed rock have been required for meeting local needs. There are several permitted sites for land-won aggregates although only two are currently being worked, one of which is located in the South Downs National Park.

• Chalk: there are no active chalk quarries in East Sussex and chalk required for agriculture has been supplied by imports.

• Clay: is extracted in East Sussex for brick and tile manufacture, and also for flood defences. There are four active sites in East Sussex for clay extraction and an extant planning permission for a new brickworks and clay pit. There are also several other dormant and inactive sites throughout East Sussex.

• Gypsum: is used for plaster and plasterboard, cement and other industrial process. There is one site in East Sussex, at Robertsbridge, which is the largest deposit of gypsum in the UK. Desulphogypsum (DSG) is a by- product and can be used as an alternative to gypsum.

• Oil and gas: exploration took place in the 1980s. This found no commercially viable resources.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 20 • Recycled and secondary aggregates: there are 17 sites in the Plan Area which recycle CDEW to produce around 308,000 tonnes of recycled/secondary aggregates.

• Wharves and railheads: marine aggregates are imported through the ports of Newhaven, Rye and Shoreham. Bottom ash produced by the Newhaven Energy Recovery Facility (ERF) is transported by rail to London. DSG is transported to the gypsum processing facility at Robertsbridge.

2.10 SUSTAINABILITY APPRAISAL PROCESS

This SA Report has been prepared by Environmental Resources Management Ltd on behalf of the Authorities. The SA process is underpinned by the requirements of the SEA Directive and the approach adopted for this report follows Planning Practice Guidance produced in March 2014 for the National Planning Policy Framework on strategic environmental assessment and sustainability appraisal. Guidance set out in the Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents (2005) has also been applied as this provides a good basis and well-understood methodology for carrying out SA.

2.11 OUTLINE OF CONTENTS OF WMSP

The draft WMSP sets out all the spatial details related to the requirements regarding sites identified in the WMP for East Sussex, part of the South Downs and Brighton & Hove over the period to 2026. It sets out proposed site allocations for development of new waste recovery and recycling facilities, and safeguards those that already exist. It also safeguards mineral resources, certain types of minerals facilities and railheads and wharves. The WMSP also identifies requirements to deal with wastewater but does not currently contain any allocations for wastewater treatment sites.

The WMSP contains the following policies:

• Policy WMSP 1 Safeguarding Waste Sites to prevent non-waste development on existing waste sites; • Policy WMSP 2 Waste Site Allocations to identify sites for new waste development; • Policy WMSP 3 Areas of Opportunity on Previously Developed or Allocated Land to identify areas of land within which a waste use will be supported in principle; • Policy WMSP 4 Areas of Search identifying areas of urban expansion proposed for mixed use development within which a waste use will be supported in principle;

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 21 • Policy WMSP 5 Physical Expansion of Existing Waste Sites identifying existing waste sites capable of expansion; • Policy WMSP 6 Existing Industrial Estates identifying estates within which a waste use will be supported in principle; • Policy WMSP 7 Waste Consultation Areas to ensure non-waste development does not compromise current or future waste facilities; • Policy WMSP 8 Mineral Safeguarding Areas and Mineral Consultation Areas for land-won minerals resources within the Plan Area to ensure minerals resources are not sterilised by development; • Policy WMSP 9 Safeguarding wharves and railheads within the Plan Area to support the transport of waste and minerals by water and rail; • Policy WMSP 10 Safeguarding facilities for concrete batching, coated materials manufacture and other concrete products within the Plan Area to ensure other development does not sterilise facilities or prejudice their use.

2.12 LINKS TO OTHER PLANS AND PROGRAMMES

In March 2012, the government published the Framework, establishing its expectation for achieving sustainable development. Emphasis has been placed on the importance of ensuring that Local Plan policies contribute to achieving sustainable development, in terms of promoting sustainable economic growth. The WMSP has been prepared in compliance with the Framework.

The East Sussex and Brighton & Hove Waste and Minerals Plan (WMP) was adopted in February 2013. This sets out the how the East Sussex County, Brighton & Hove City Councils and the South Downs National Park Authority propose that waste should be managed and minerals produced within their spatial context up to 2026, taking into account the particular environmental, demographic, and economic characteristics of the area, and aims to ensure that waste is managed and minerals produced in sustainable ways. It sets out the vision and spatial strategy for the sustainable reduction, recycling, treatment and disposal of waste, and a sustainable approach to minerals development in the area. It identifies strategic areas for the location of sites and sets the context for identifying sites for waste management and minerals development. It also includes a suite of development control policies. This replaced the majority of waste and minerals planning policy contained in the East Sussex and Brighton & Hove Waste Local Plan (2006) and the East Sussex and Brighton & Hove Minerals Local Plan (1999), although some policies have been saved from each of these earlier plans.

The WMSP seeks to support the WMP in promoting the sustainable management of waste and minerals by identifying and allocating potential sites for new waste development. The Waste and Minerals Sites Plan will replace the 1999 Minerals Local Plan and 2006 Waste Local Plan sites policies. Together, the WMP and WMSP constitute the East Sussex and Brighton & Hove Waste and Minerals Local Plan.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 22 3 METHODOLOGY

3.1 APPRAISAL FRAMEWORK

The SA has tested the draft WMSP against a framework of objectives that reflect relevant sustainable development policy objectives. This framework was developed in the Scoping Report in November 2013, and was subsequently amended following consultation with statutory consultees. This was informed by a review of policies, plans and programmes relevant to the WMSP and by the collection of baseline data for East Sussex and Brighton & Hove, building on the earlier work undertaken for the Scoping Report of the WMP in 2007 and the Pre-Scoping Report for the WMSP in July 2013. These two activities enabled the identification of key issues for East Sussex and Brighton & Hove, and the drawing up of a series of policy objectives for achieving sustainable development in the area.

The review of policies, plans and programmes is set out in Annex A, and the baseline economic, social and environmental conditions in East Sussex and Brighton & Hove are set out in Annex B.

Table 5.1 sets out the framework of objectives that has been used to appraise the WMSP.

The appraisal determined the likely effects arising from the WMSP. This applied largely to the objectives and policies, to a series of options and to the site allocations. The appraisal was done by assessing each element of the WMSP against the appraisal objectives in turn and making a largely qualitative assessment, with reference also to the baseline data from the Scoping Report.

In reporting the results of the appraisal, the following symbols have been used to indicate the broad nature of the predicted effect:

+ effect likely to be positive - effect likely to be negative 0 no significant effect ? effect unknown

If the appraisal objective was not relevant to the element of the Plan being appraised, no symbol is given.

Multiple symbols have been used (e.g. ++) to indicate a different scale of impact over time, or where the impacts of an option are substantially better or worse than others.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 23 The effects were also rated for their significance in terms of the importance for achieving each appraisal objective. Effects were rated as high, medium or low significance, taking account of a number of factors. The factors were:

The assessment of significance is indicated in the tables in this report by colour:

Not relevant No significance Medium significance High significance

The tables make an assessment of effects over short, medium and long-term timeframes. For this purpose, the SA has assumed the short term to be the first five years of implementation of the WMSP, the medium term to be the remaining years of the WMSP and the long term to be beyond the life of the WMSP. The SA has also assessed the likely significant cumulative effects of the WMSP in its entirety and in combination with other relevant plans and projects, and considered the interrelationship between effects. The conclusions of this are set out in Section 9.

3.2 DIFFICULTIES ENCOUNTERED

A number of difficulties were encountered in undertaking the appraisal:

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 24 • Uncertainty. It is not known what type of facility is likely to be proposed on any site and therefore it is not possible to predict with any certainty what the likely effects might be of development at a site. Similarly the scale of any development is not known with any accuracy and therefore the size of effects is also unknown. Furthermore, it is not known which of the allocated sites are likely to be proposed by developers for waste facilities and therefore the exact location and distribution of developments are not known. It is also unknown what the waste catchment area will be for any site which is developed and therefore the amount of waste transport arising in connection with site development is unknown. Finally, the location of any new minerals sites is also unknown, as is the future level of demand for primary, secondary and recycled minerals, and therefore the effect of minerals transport is uncertain.

Despite these limitations and uncertainties, it is still possible to draw conclusions about the overall effects that will result from the WMSP to 2026.

3.3 COMPLIANCE WITH THE SEA DIRECTIVE AND REGULATIONS

The WMSP is subject to the requirements of the European Union’s Directive on the Environmental Assessment of Certain Plans & Programmes 2001/42/EC (the SEA Directive) and the domestic legislation through which the Directive has been transposed into law in England and Wales (the Environmental Assessment of Plans & Programmes Regulations 2004 – Statutory Instrument 2004 No. 1633).

The SA of the WMSP was designed and undertaken so as to meet the legal requirements for the environmental assessment of plans. Throughout the report the term ‘Sustainability Appraisal’ should be interpreted as encompassing the SA process as required under the Planning & Compulsory Purchase Act 2004 and the Strategic Environmental Assessment process as required under the European Directive and domestic Regulations on the environmental assessment of plans and programmes.

The following table indicates the components of the SA Report that make up the Environmental Report, as required by domestic and European law on the environmental assessment of plans.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 25 Table 3.1 Summary Requirements of SEA Directive and Compliance of SA Report

Requirements for Environmental Report Component of SA Report

a) An outline of the contents, main objectives of the plan or programme, Section 2.11 and 2.12 and relationship with other relevant plans and programmes; b) The relevant aspects of the current state of the environment and the Table 4.1, Annex B likely evolution thereof without implementation of the plan or and Annex C programme;

c) The environmental characteristics of areas likely to be significantly Section 4.3 and affected; Annex F.

d) Any existing environmental problems which are relevant to the plan Section 4.4 or programme including, in particular, those relating to any areas of particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC;

e) The environmental protection objectives, established at international, Section 4.1, Section 5 Community or national level, which are relevant to the plan or and Annex A programme and the way those objectives and any environmental, considerations have been taken into account during its preparation;

f) The likely significant effects on the environment, including on issues Sections 6 to 9 and such as biodiversity, population, human health, fauna, flora, soil, water, Annexes D to G air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors;

g) The measures envisaged to prevent, reduce and as fully as possible Annex F offset any significant adverse effects on the environment of implementing the plan or programme;

h) An outline of the reasons for selecting the alternatives dealt with, and Section 7, Section 3.1 a description of how the assessment was undertaken including any and Section 3.2 difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information;

i) a description of measures envisaged concerning monitoring in Section 10 accordance with Art. 10;

j) a non-technical summary of the information provided under the Section 1.1 above headings

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 26 4 SUSTAINABILITY CONTEXT AND ISSUES

4.1 REVIEW

The first part of Stage A of the SA process involved establishing the evidence base for the appraisal. It involved a review of plans, policies, and programmes and the collection of baseline information.

A review was undertaken of plans, policies and programmes that are relevant to sustainable development in the Plan Area and to the management of waste and minerals. This sets the policy context for the Plan. The review identified the key sustainable development policy objectives and relevant targets which have fed into the identification of sustainability issues. The findings of this review are set out in Annex A.

The collection of baseline information helped to provide a basis for predicting and monitoring effects of the WMSP, and has also helped in identifying sustainability issues and problems. The full baseline data table and maps are set out in Annex B and Annex C of this report.

4.2 SUSTAINABILITY ISSUES AND PROBLEMS

Sustainability issues and problems have been identified with reference to the baseline information, the policy review, technical studies and assessments undertaken to support the WMSP, and in-house knowledge. They focus on the key issues for sustainable development in the Plan Area that are relevant to the management of waste and minerals as set out in Table 4.1.

Table 4.1 also describes how the sustainability conditions in East Sussex and Brighton & Hove might be expected to evolve without implementation of the WMSP.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 27 Table 4.1 Sustainability Issues and Potential Problems

SA Framework Summary of Issue/Problem Likely future evolution without the WMSP Objective 1. To avoid Health inequalities negative effects Health and health inequalities are likely to improve without and enhance, Major health inequalities exist within the Plan Area, and health deprivation is a implementation of the WMSP, due to other initiatives to where possible, significant problem in some parts. promote good health and address inequalities such as positive effects measures set out within the various local authority Core on health Life expectancy varies throughout the area. The lowest for both men and women is Strategies and Community Strategies and national policy in Hastings. Male life expectancy is below the national average in Brighton and initiatives such as the 2010 Health White Paper. Hove, Eastbourne and Hastings, and female is below the national average only in Hastings. All areas have shown a slight improvement over the last five years.

A disproportionately high percentage of SOA in the Plan Area are ranked within the most deprived among the 20% with high health deprivation nationally. Hastings remains the most health-deprived authority in the Plan Area. Health deprivation is also a significant problem in Brighton & Hove, a situation which has deteriorated in recent years. Only Rother and Wealden have a better health deprivation ranking than the national average.

Pollution incidents It is likely that the existing trend towards less damage to the Pollution incidents relating to waste management facilities have decreased environment than in the past will continue and provide an considerably since 2001 in England. In particular there has been a decrease in non- improvement in public health as a result. This will come inert pollution incidents, household waste site incidents and waste incinerator from implementation of development management policies incidents. Composting facility incidents have increased. The national trend is in the WMP and permitting and inspection of sites by the reflected in East Sussex where the number of pollution incidents (from all types of Environment Agency and Environmental Health facility) has improved. This trend is also apparent in Brighton & Hove. No separate departments. data was found for waste facilities.

2. To protect the High quality community environment amenity of It is possible that the high quality environment within the residents and Communities within the Plan Area generally experience a high quality environment Plan Area could become eroded without implementation of neighbouring as indicated by residential surveys and data on public open spaces. However, East the WMSP, due to the lack of control that the Authorities land uses Sussex and Brighton & Hove is a well-populated county and city with a strongly would have on the location of development. It is possible humanized landscape and it is difficult to get very far from buildings, roads and that proposals could come forward for development in areas vehicles and there is no real wilderness landscape, hence the County as a whole with a rural character. Through policy in the WMP adverse cannot be noted for its remoteness. For this reason where remote landscapes and impacts on residents and neighbours should continue to be

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 28 SA Framework Summary of Issue/Problem Likely future evolution without the WMSP Objective open, green space exist in East Sussex and Brighton & Hove they are highly valued protected without implementation of the WMSP. for the sense of 'getting away from it all', tranquillity, recreation and sense of wellbeing they can provide.

3. To improve Unequal access to waste services equality and It is possible that kerbside collection of recyclables may not access to Coverage of household kerbside collection of recyclables varies across the Plan Area, improve without implementation of the WMSP, as sufficient sustainable reflecting the difficulties of providing services to rural areas. Coverage is high in appropriate facilities may not be provided to enable more waste urban authorities, with Hastings and Eastbourne providing 100% coverage. In rural materials to be collected and processed. management authorities coverage has been lower, although no recent data is available. Access to household waste recycling sites is unlikely to be There are six household waste recycling sites in the Plan Area. Three of these are in affected, with or without implementation of the WMSP. Brighton & Hove, one is in Lewes, one is in Eastbourne and one is in Crowborough.

4. To minimise Waste generation waste The WMSP will not affect the amount of waste generated, generation and The amount of Local Authority Collected Waste (LACW) generated in East Sussex and there is no reason to suppose existing trends in waste disposal to land and Brighton & Hove has been decreasing slightly each year, most recently recorded generation will change without its implementation. LACW as a decrease of 1.6% between 2010/11 and 2011/12. This broadly reflects similar is likely to continue to decline. However, for the other waste trends in the South East region and nationally. streams, a lack of reliable data makes it difficult to predict how the amount of waste generated might change in the Estimates for the amount of C&I waste generated in 2006/07 and 2007/08 show future. fluctuating levels. However, this is only an estimate as it is difficult to gain accurate information for this waste stream.

CDEW makes up approximately 51% of waste in the Plan Area.

Hazardous waste arisings in the Plan Area appear to increase in 2007, followed by a decline in 2009, reflecting the position regionally. Hazardous waste makes up approximately 1% of waste in the Plan Area, but again, reliable data is not readily available.

Recycling and recovery The level of recycling and recovery should continue to The percentage of LACW being recycled or composted in East Sussex and Brighton increase without implementation of the WMSP, but it is & Hove is steadily increasing. However it is below the level of recycling and likely to be below the level that could be achieved with the composting for both the South East and England. WMSP because opportunities to develop facilities to recycle or recover waste may be fewer without allocated sites for

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 29 SA Framework Summary of Issue/Problem Likely future evolution without the WMSP Objective The percentage of waste being used to recover energy has been increasing year by those facilities. year. The percentage of the total tonnage of LACW arisings in East Sussex and Brighton & Hove experienced a jump in 2011/12 with the coming on-stream of the Newhaven ERF which means more waste is used to recover energy than in the South East overall and England.

Landfill The amount of waste landfilled should continue to fall The amount of LACW going to landfill in East Sussex and Brighton & Hove has without implementation of the WMSP, but the decline is continued to fall since 2003/04. Although in 2007/08 this was higher than both the likely to be smaller because opportunities to develop regional and national averages, by 2011/12 the percentage is below both the regional facilities to recycle or recover waste and therefore to divert and national figures. waste from landfill may be fewer without allocated sites for those for recycling or recovery facilities. It has been estimated that 29% of C&I waste was landfilled in 2008/09. Data for more recent years are not available.

The current estimate shows a decline in CDEW going to landfill from a previous estimate of approximately 60% of total CDEW waste to 15% in 2008/09.

There is no longer any available landfill capacity within the Plan Area.

5. To ensure the Increase marine-dredged and secondary and recycled aggregates most It is uncertain how future trends in marine dredged sustainable use National policy states that the supply of aggregates should be met from a significant aggregates and marine imports of crushed rock will evolve of mineral increase in secondary and recycled materials, a reduced contribution from land-won without implementation of the WMSP. It is possible that this resources resources and imports and an increase in marine-dredged aggregates. will increase if economic recovery continues, but this is dependent on levels of construction and demand for After rising production of land-won sand and gravel from 2007, there has been a materials. The amount of secondary recycled aggregates is significant drop in supply in 2011. The South East region also saw a drop in 2011, likely to increase through policy in WMP to promote their although not so significant as that experienced in the Plan Area. production, but it is likely to be lower without implementation of the WMSP than it would otherwise be The overall trend for East Sussex is a decrease in landings of marine-dredged sand because new facilities to recycle aggregates will be fewer, as and gravel. In 2012, landings were 38% of the level they were at in 2007. There has without allocated sites the necessary facilities are less likely also been an overall decrease in marine imports of crushed rock in East Sussex and to be developed. the South East.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 30 SA Framework Summary of Issue/Problem Likely future evolution without the WMSP Objective

Commentary from the South East Aggregates Monitoring Report 20111 states that 'the current state of the economy and reduced activity in the construction sector suggests that recycling is likely to be a lesser figure than 6Mt in 2011. Nonetheless, it is likely to contribute some 25% of aggregate consumption in this region.’

6. To maintain Improvements to water quality and improve The quality of surface and groundwater should continue to water quality The Water Framework Directive requires that water bodies should be achieving improve, in part through policy in WMP which protects the ‘good ecological status’ and aims to achieve this for all waters by 2015. Most of the quality of water, but also through the implementation of the Plan Area falls within the South East River Basin district. Local authorities must River Basin Management Plan. The quality of bathing waters ensure that planning policies and spatial planning documents take account of the is likely to be maintained. objectives of the South East River Basin Management Plan (December 2009).

Results from the River Basin Management Plan show that 19% of surface waters have ‘good ecological status’ and 40% are at least ‘good’ biological status. The majority of water bodies are failing on only one area, generally the fish or invertebrate elements of the classification. 43% of groundwater meets ‘good’ quantitative status and 63% meets ‘good’ chemical status.

The River Basin Management Plan sets targets and actions up to 2027 which will require substantial improvement and protection of water quality in the Plan Area.

Regarding bathing waters, the situation is favourable with all beaches in the Plan Area currently meeting the mandatory standards.

Aquifers are classified according to the properties of the rocks and the overlying soils. Areas most vulnerable are where major aquifers lie close to the surface and is covered by only a thin freely-draining soil. The south west coastal area including Brighton & Hove and Eastbourne and the South Downs are the most vulnerable within the Plan Area.

7. To seek the Water deficit and increased water consumption protection of The Plan Area is likely to continue to be a water stressed area and sustainable The Environment Agency considers the South East as a ‘water-stressed area’. and with planned levels of housing growth it may be

(6) South East Aggregates Monitoring Report 2011, published by the South East England Aggregates Working Party, February 2013

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 31 SA Framework Summary of Issue/Problem Likely future evolution without the WMSP Objective use of water Domestic customers of Southern Water have a per capita consumption similar to the increasingly stressed. The quality of groundwater should resources UK average, while South East Water's customers have an above average per capita not be affected as there are policies in place to prevent consumption. pollution from waste and minerals development.

The Plan Area is dependent on groundwater supplies. Source Protection Zones indicate the risk to groundwater supplies from potentially polluting activities and accidental release of pollutants. Zones have been defined for groundwater sources such as wells, boreholes and springs used for public drinking water supplies. The closer the activity the greater the risk. The majority of protection zones are in the south west of the Plan Area within the chalk formations of the South Downs.

8. To reduce Risk of flooding risk and impact The risk of flooding is likely to increase with progressive of flooding Risk of both fluvial and coastal flooding is a significant issue in the Plan Area. climate change and increased levels of development leading to loss of permeable land. There has been a slight increase in the number of properties located within the flood zone in East Sussex in recent years, and as a percentage of all properties is above both the regional and national averages. The number for Brighton & Hove appears to have remained relatively stable.

The nature of risk is likely to increase in severity as the effects of climate change are felt. Increased unseasonal rainfall, more extreme weather events and rising sea levels will elevate risk, particularly along the urbanized coastal strip.

9. To limit the Climate change causes of and Climate change will continue without implementation of the adapt to climate As a result of climate change, the Plan Area is forecast to experience: hotter, drier WMSP. Greenhouse gas emissions in the Plan Area may change. summers; warmer, wetter winters; and increased frequency of extreme weather continue to fall, although if economic recovery continues and events. There are implications for flood risk, water resources, health, biodiversity, planned housing and economic growth is achieved it is soils and the economy. possible that levels of emissions will rise. However, levels of greenhouse gas emissions will be higher without The Climate Change Strategy for East Sussex commits to four main courses of action: implementation of the WMSP because it will be less likely that facilities to reuse, recycle and compost waste and • Mainstreaming – to ensure that the implications of climate change are recover energy will be developed without allocated sites for considered and action taken in all our work and lives; such development. • Engagement – to inform, advise and enable everyone in the community to play their part in reducing emissions and adapting to climate change;

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 32 SA Framework Summary of Issue/Problem Likely future evolution without the WMSP Objective • Mitigation – to reduce greenhouse gas emissions from East Sussex and the share of those released elsewhere as a result of actions here; and • Adaptation – to respond to the risks and opportunities presented by a changing climate in East Sussex.

Government has set a national target of reducing greenhouse gas emissions by 26% by 2020 and by 80% by 2050. It also requires that measures to adapt to climate change should be developed and implemented by local government.

The Environment Strategy for East Sussex has a target for reducing the landfill of household waste by 80% of 2009/10 levels and increasing the percentage reused, recycled and composted to 40% by March 2012. The Brighton & Hove Sustainability Action Plan 2012 sets the following targets: by 2025 no more than 2% of waste by weight will be sent to landfill; and by 2025 70% of domestic waste will be reclaimed, recycled or composted.

The data continue to show an overall general decline in carbon dioxide emissions across the Plan Area, reflecting a similar position in the South East region. Per capita emissions in the Plan Area are low compared to regional and national data.

Methane is a far more potent greenhouse gas than carbon dioxide. The majority of emissions from the waste sector are currently associated with the emission of uncaptured methane from landfills.

10. To protect Air pollution air quality and It is uncertain how air quality will evolve in the Plan Area in reduce air The overall scale and impacts of emissions from waste and minerals facilities on air future. With increased housing and economic growth, traffic pollution quality is relatively small when compared with emissions from other sectors such as levels could increase leading to a reduction in air quality. transport. Nevertheless waste processes must comply with stringent emissions However, if measures to promote sustainable transport standards which are regulated by the Environment Agency. choices are successful the Plan Area may achieve an improvement in air quality. Air quality is generally good in the Plan Area. However, there are a number of locations which exceed air quality thresholds and Air Quality Management Areas (AQMA) have been declared in Brighton & Hove, Lewes and Hastings. In Brighton & Hove, air quality outside the AQMA has improved, however within the AQMA there has been no improvement over the last 10 years. There is a possible increase in AQMA in East Sussex with Newhaven having possible exceedences of nitrogen dioxide.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 33 SA Framework Summary of Issue/Problem Likely future evolution without the WMSP Objective 11. To reduce Road traffic adverse impacts It is uncertain how levels of road traffic will evolve without of transporting National and local policies emphasise the need to manage the transport network and implementation of the WMSP. With increased housing and waste and deliver a modal shift to sustainable forms of transport. economic growth and continued economic recovery, traffic minerals on the levels could increase. However, if measures to promote environment There was a decline in vehicle kilometres in the Plan Area from 2008-2010, since sustainable transport choices are successful the Plan Area when the level has held fairly steady. The same pattern is shown regionally and may enable a sufficient modal shift to reduce road traffic. nationally. Despite this, emissions from road transport have continued to decline steadily, reflecting the position regionally and nationally.

The amount of fuel consumed by road freight traffic in 2011 is slightly lower than it was in 2007 and 2008 in the Plan Area. This is similar to the regional and national pictures. It is not clear whether this is because of a reduction in the volume of freight traffic or an improvement in vehicle fuel efficiency, or both.

The amount of freight handled at Shoreham in 2011 had recovered to the level of five years previously, while the amount through Newhaven has reduced by almost a half, and is well below the level in 2008. Freight through Rye continues to constitute a very minor proportion. 12. To conserve Soil quality and enhance The amount of agricultural land in the Plan Area is likely to important soil Good soil quality is essential to a properly functioning environment and ecosystems fall in the future, due to the levels of planned housing and functions and as well as providing economic benefits. The national soil strategy states that economic growth. The NPPF directs development to poorer types developers and others must play their part in ensuring soils are adequately quality agricultural land and therefore even without protected and soil functions are maintained wherever possible. implementation of the WMSP good quality agricultural land should be preserved. However, opportunities to develop There is a lack of specific soil quality data in the Plan Area. What data does exist composting facilities may be fewer without allocated sites for relates to the quantity and quality of agricultural land. waste development, and therefore the production of compost could be lower than it would otherwise be and therefore the There has been a slight increase in the amount of agricultural land in Brighton and use of compost as a soil improver could be lower without the Hove and Lewes (combined), compared to a fall in both Hastings and Rother WMSP. Similarly, the treatment of contaminated soils is (combined) and Eastbourne and Wealden (combined). Eastbourne and Wealden had likely to be lower without the WMSP as facilities to carry out an 11% fall in the amount of agricultural land between 2007 and 2010. treatment are likely to be fewer without allocated sites.

East Sussex has a low percentage of agricultural land classed as ‘very good’ and ‘excellent’ when compared to the South East region and England.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 34 SA Framework Summary of Issue/Problem Likely future evolution without the WMSP Objective 13. To protect, High quality landscapes conserve and Although without implementation of the WMSP the enhance East Much of the Plan Area is recognised for its high quality landscape character. The Authorities will have less control over where development is Sussex and South Downs National Park and High Weald AONB cover around two thirds of the located, policies in the WMP to protect landscape and Brighton & Plan Area. The Low Weald is also a landscape of considerable historic complexity. historic assets should ensure that the quality of these assets is Hove's The Plan Area also contains the first defined stretch of Heritage Coast in the country, maintained. countryside and between Seaford and Eastbourne. historic and built East Sussex and Brighton & Hove possess highly-valued heritage assets, including environment listed buildings, scheduled monuments, conservation areas, registered parks, gardens and battlefields and wrecks. These formally designated assets make up only some 10% of the heritage assets on the Historic Environment Record (HER). There is also much that has not yet been identified, including below-ground archaeological remains. The HER maps Archaeological Notification Areas which help to predict the archaeological potential around known sites.

Lack of previously developed sites Without the WMSP, it is likely that higher numbers of The reuse of previously developed land is a national policy objective. However, the greenfield sites will be developed for waste management. Plan Area does not possess a significant supply of such land, although no recent data is available to quantify this.

14. To protect, Sites of biodiversity and geodiversity importance conserve and Although without implementation of the WMSP the where The Natural Environment and Rural Communities Act 2006 places a duty on public Authorities will have less control over where development is appropriate bodies to ensure due regard to the conservation of biodiversity. Local authorities located and therefore it is possible that proposals will come enhance East should ensure no net loss of biodiversity and actively pursue opportunities to forward for sites near to or including areas of biodiversity or Sussex and achieve a net gain. geodiversity value, policies in the WMP to conserve and Brighton & enhance international, national and local nature conservation Hove's The Plan Area possesses an array of sites designated as being of international, sites, sites of geodiversity value and other areas including biodiversity and national and local importance for biodiversity. ancient woodland and land in agri-environment schemes geodiversity should ensure that biodiversity and geodiversity are There are six SACs, two SPA and one Ramsar site. These are internationally protected and enhanced. important sites given strict protection by the EU Habitats and Birds Directives.

Sites of Special Scientific Interest (SSSI) cover over 13,000 ha in the Plan Area, important for wildlife or geological interest. There are four National Nature Reserves and 10% of East Sussex is covered by Ancient Woodland.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 35 SA Framework Summary of Issue/Problem Likely future evolution without the WMSP Objective

There are also designations of local importance including nearly 18,000 ha of Local Nature Reserves and 366 Sites of Nature Conservation Importance.

The condition of SSSIs is improving. In each local authority there is a much greater proportion of SSSI units in a favourable or recovering condition than declining. The total for the Plan Area is 98% favourable or recovering, above the target of 95%.

Habitats and Species Action Plans show significant decline in the condition of certain habitats and species, demonstrating the need for action to reverse trends.

15. To increase Energy consumption energy Policy in the WMP supports greater energy efficiency and efficiency and There is a general need to reduce energy consumption as part of measures to reduce use of renewable or low-carbon energy in waste and the proportion the causes of climate change. Current levels of consumption are seen as minerals development. However, without implementation of energy unsustainable and opportunities should be taken to reduce consumption, improve of the WMSP it is less likely that facilities will be developed generated from efficiency and to generate renewable energy. to recover energy from waste without allocated sites for such renewable facilities and therefore overall energy consumption will be sources No data are available specifically on energy consumption by waste and mineral higher without the WMSP. activities. However, commercial and industrial gas consumption figures over the last five years peaked in 2010 in East Sussex and Brighton and Hove and then fell in 2011 nearer levels in earlier years. This reflected a similar position across the South East region, although this was not so marked nationally.

Electricity consumption per commercial and industrial consumer is considerably lower in the Plan Area than in the South East or nationally. This is likely to be because of the lack of heavy industry in the area. Electricity consumption has decreased at every geographical level in 2011, reversing the trend of increasing consumption between 2003 and 2008, although within the Plan Area the decrease is slight.

16. To Population growth contribute to Increases in housing completions in the Plan Area will lead the growth of a All areas have seen an increase in population over the decade between censuses. to continued population growth, with or without sustainable and Brighton & Hove and Eastbourne have seen growth above the national and regional implementation of the WMSP. diversified averages, while other parts of the Plan Area have had a lower growth than economy nationally and regionally.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 36 SA Framework Summary of Issue/Problem Likely future evolution without the WMSP Objective All areas are predicted to experience population growth over the decade to 2021. Lewes and Rother are projected to see growth above the regional and national averages, while other parts of the Plan Area are likely to see below-average growth.

Housing completions in Hastings, Lewes, Rother and Wealden picked up in 2011/12 compared to the previous year, whereas in Brighton & Hove and Eastbourne they fell back somewhat on 2010/11.

Economic growth With the planned levels of housing and economic growth in The East Sussex economy has been underperforming for a number of years. GVA the Plan Area, GVA is likely to grow. The future change in per head in East Sussex remains well below both the national and regional level. In GVA per head is uncertain however, and depends on the contrast in Brighton & Hove, GVA per head is much closer to the national average. type of jobs created. However, East Sussex has increased its GVA over the five years from 2007 to 2011 more in line with the national and regional increase, whereas Brighton & Hove has remained fairly static.

17. To provide Low employment in certain areas employment If other plans and strategies are successful in their aims to opportunities Employment and income deprivation and inequality is a significant problem in some achieve regeneration and growth in some of the more and develop parts of the Plan Area. Hastings has a disproportionate number of SOA in the 20% deprived parts of the Plan Area, then employment rates in and maintain a most deprived within England. It has also seen the largest increase of all the these areas are likely to rise and the level of employment and skilled Authorities of the Plan Area between 2007 and 2010. Only Brighton & Hove has income deprivation is likely to fall. workforce seen a slight decrease in the percentage of SOA among the 20% most deprived in England.

The employment rate in the Plan Area has fluctuated slightly over the last five years, although currently it is at the same rate as nationally. Lewes and Wealden have an employment rate somewhat above the national average, while Hastings and Rother are somewhat below the national rate.

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ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 38 4.3 CHARACTERISTICS OF AREAS LIKELY TO BE SIGNIFICANTLY AFFECTED

4.4 AREAS OF PARTICULAR ENVIRONMENTAL IMPORTANCE

There are five Special Areas of Conservation (SAC), two Special Protection Areas (SPA) and one Ramsar site in the Plan Area, which are strictly protected by the EU Habitats and Birds Directives. A proposed extension to the SPA and Ramsar designation at Dungeness/Rye Harbour is currently being reviewed. Table 4.2 presents the issues and problems that are occurring at these designated sites.

Table 4.2 Issues and Problems at Sites of International Nature Conservation Importance

Site Reason for designation Issues and problems

Ashdown Forest SAC Wet and dry heathland and Insufficient grazing population of great crested Spread of scrub and bracken newt Long-term drying out of site Possible impact of extraction

Ashdown Forest SPA Populations of Dartford Lack of management warbler and nightjar Succession from open heathland to woodland Lack of grazing Spread of invasive species Intense recreational use

Lewes Downs SAC Calcareous grassland Scrub encroachment Leaching and spray drift from surrounding farmland

Castle Hill SAC Calcareous grassland Scrub encroachment Leaching and spray drift from surrounding farmland

Hastings Cliffs SAC Vegetated sea cliffs Erosion by surrounding coastal protection measures and offshore activities Visitor pressure Adjacent farming practices

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 39 Site Reason for designation Issues and problems

Dungeness SAC Driftline vegetation, Disturbance by vehicles and vegetated shingle and walkers population of great crested Illicit gravel extraction newt Invasion of willows Water abstraction Air pollution

Dungeness to Pett Level Breeding common tern, Coastal erosion SPA and proposed Ramsar little tern and Predation of bird populations site Mediterranean gull and for Aircraft disturbance passage/wintering populations of aquatic Recreational and leisure activities warbler, Bewick’s swan and Changing agricultural practices shoveler Heavy grazing Lowering water levels

Dungeness, Romney Wintering bittern Botaurus Unknown, but likely to be as Marsh and Rye Bay stellaris, hen harrier Circus above potential SPA cyaneus, golden plover Pluvialis apricaria, and ruff Philomachus pugnax; Breeding marsh harrier Circus aeruginosus, avocet Recurvirostra avosetta and sandwich tern Sterna sandvicensis; and An assemblage of over 20,000 waterbirds during the non-breeding season, including: Bewick’s swan Cygnus columbianus bewickii, European white-fronted goose Anser albifrons albifrons, wigeon Anas penelope, gadwall Anas strepera, shoveler Anas clypeata, pochard Aythya ferina, little grebe Tachybaptus ruficollis, great crested grebe Podiceps cristatus, cormorant Phalacrocorax carbo, bittern Botaurus stellaris, coot Fulica atra, lapwing Vanellus vanellus, golden plover Pluvialis apricaria, sanderling Calidris alba, whimbrel Numenius phaeopus, ruff Philomachus pugnax and common sandpiper Actitis hypoleucos.

Pevensey Levels Ramsar Populations of aquatic Introduction/invasion of non- site plants and invertebrates native plant species Pollution from domestic sewage

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 40 4.4.1 Habitats Regulations Assessment

As part of the process of developing the WMSP, the Authorities commissioned a Habitats Regulations Assessment (HRA) Screening. A draft report setting out the findings of the screening was produced in April 2014. The draft findings of the screening have been used to inform the SA.

The vast majority of allocated sites lie within 10km of a European nature conservation site, although the screening concluded that for many of the allocated sites, unless an application comes forward for an energy from waste facility, stack emissions (and potential air quality reductions) would not need to be a consideration. For many allocated sites there is no evidence of any other pathway connecting the allocation to any European sites.

However, for some allocated sites the screening concluded that there was a possibility of adverse impacts, as follows:

• twelve allocated sites risk impacts on air quality at Ashdown Forest SPA/SAC due to transport; • eight allocated sites risk adverse effects on Pevensey Levels Site of Community Importance (SCI)1 and Ramsar site due to potential surface water connectivity; • five allocated sites risk adverse effects on Pevensey Levels SCI and Ramsar site due to run-off; • two allocated sites risk adverse effects on Pevensey Levels SCI and Ramsar from dust and nitrogen dioxide emissions; • three allocated sites risk adverse effects on Lewes Downs SAC due to impacts on air quality from transport.

These findings have been incorporated into the SA process.

(7) 1 Sites that have been adopted by the European Commission but not yet formally designated as SAC by the government

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ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 42 5 SUSTAINABILITY APPRAISAL FRAMEWORK

5.1 INTRODUCTION

The SA framework is essentially a set of sustainable development objectives against which the WMSP has been assessed. The sustainability issues and plans, policies, and programmes review have informed the development of the SA framework.

5.2 OBJECTIVES AND DECISION-MAKING CRITERIA

The earlier framework (developed for the WMP) consists of a number of objectives and decision-making criteria that reflect relevant sustainable development policy issues. The objectives were first identified at the scoping phase for the SA of the WMP and were revised in response to consultation. This earlier framework was taken forward in the Scoping stage for the WMSP and published in the Scoping Report in November 2013. Following comments received on the framework, a small number of minor additions were made to the decision-making criteria to add further criteria on biodiversity and landscape impacts. No changes were made to the SA objectives.

The SA objectives for the appraisal of the WMSP are:

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 43 17. To provide employment opportunities and develop and maintain a skilled workforce.

Table 5.1 WMSP SA Framework – Objectives and Decision-Making Criteria

Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

Social

1. To avoid negative • minimise adverse impacts from current and future waste and minerals effects and enhance, sites/developments and associated activities (i.e. transport) on the health where possible, positive of the surrounding communities (including reducing air, noise and waste effects on health pollution) (link with objective 2, 6, 10 and 11) • minimise adverse impacts to health from waste through effective waste management practice • present an opportunity to benefit health or reduce inequalities, in particular in Hastings and East Brighton Assumptions: - That regulatory bodies such as the Environment Agency and Environmental Health will operate to ensure emissions are within safe and acceptable limits. Therefore the WMSP should not duplicate the role of those regimes. - Negative impacts on health may include perceived as well as actual impacts eg stress or anxiety by those who could potentially be affected by new facilities.

2. To protect the amenity • reduce the disturbance to communities from the transportation of waste of residents and and minerals including encouraging waste and minerals proposals to use neighbouring land uses suitable roads at sociable hours (link with objective 11) • minimise noise/odour/dust nuisance of waste and mineral developments on sensitive receptors such as dwellings, hospitals, schools and other community facilities (link with objective 1) • ensure appropriate design of facilities to reduce adverse visual impacts • ensure appropriate restoration of mineral workings and waste sites for community benefit (link with objective 5) • avoid loss of recreational and public open space (link with objective 13) Assumptions: - That Environmental Health will ensure that facilities operate within acceptable limits.

3. To improve equality • increase public access to recycling facilities and access to sustainable • provide appropriate facilities to support Waste Collection Authorities in waste management providing a sustainable and equitable service • promote integrated sustainable waste facilities within new developments • encourage small-scale community-based waste recycling/composting projects • promote and support local strategies and enterprises that involve sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 44 Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

Environmental

4. To minimise waste • reduce total waste arisings generation and disposal to • increase the amount of waste being reused and recycled and actively land promote the waste hierarchy • enable the delivery of facilities to recycle/reuse materials • raise awareness in order to increase levels of participation in sustainable waste management • safeguard sites suitable for location of waste management facilities from other proposed development

5. To ensure the • manage mineral resources efficiently sustainable use of local • reduce need for raw minerals by maximising the use of secondary and mineral resources recycled aggregates • encourage use of secondary materials such as waste clay, chalk and gypsum for example as fill material substitutes • promote sustainable construction and demolition • ensure appropriate and effective restoration and after-use of mineral workings (link with objective 2 and 14) • safeguard local and regionally significant minerals resources, important sites and depots including wharf and rail facilities. (link with objective 11)

6. To maintain and • minimise the pollution of surface water, groundwater (including aquifers) improve water quality and coastal waters including contamination during waste processing and mineral extraction i.e. during access or through blockage • improve chemical and biological water quality Assumptions: - That regulatory bodies such as the Environment Agency will operate to ensure emissions to water are within safe and acceptable limits. Therefore the WMSP should not duplicate the role of those regimes.

7. To seek the protection • conserve and maintain water resources of and sustainable use of • support a reduction in water consumption in waste management and water resources mineral production • maximise re-use of wastewater

8. To reduce risk and • prevent inappropriate development in flood risk areas impact of flooding • ensure development does not increase risk of flooding elsewhere • ensure no unacceptable impact upon tidal or fluvial flood defences • support sustainable construction and management of flood defences maximising the use of secondary materials • promote sustainable drainage where appropriate

9. To limit the causes of (Cross-cutting criteria from Objectives: 8, 10, 11, 15) and adapt to climate • reduce greenhouse gas emissions from the treatment and transport of change waste and minerals • reduce methane emissions to air from landfill sites • ensure all waste and mineral developments/sites take into account the changing climate through location and design • minimise energy use by maximising use of recycled, recyclable and secondary resources

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 45 Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

10. To protect air quality • minimise the causes and levels of air pollution and reduce air pollution • support cleaner technology for waste and minerals management • take account of Air Quality Management Areas Assumptions: - That regulatory bodies such as the Environment Agency and Environmental Health will operate to ensure emissions to air are within safe and acceptable limits. Therefore the WMSP should not duplicate the role of those regimes.

11. To reduce adverse • encourage disposal/treatment of waste in the nearest appropriate impacts of transporting installation to the source of waste. waste and minerals on the • encourage local supplies of minerals where appropriate. environment • encourage modal shift from road freight to rail and water where appropriate and feasible • encourage integration of complementary activities within minerals and waste sites such as processing, storage and recovery. • safeguard wharves/rail heads to support bulk transport of minerals/waste (link with objective 5)

12. To conserve and • protect rare soil types and important soil functions and where appropriate enhance important soil and practicable improve soil quality functions and types • safeguard high quality agricultural land (1,2 and 3a) from development • encourage the de-contamination of contaminated soils • encourage composting of biodegradable waste that can be used as a soil improver • avoid development on greenfield sites through encouraging use of previously developed land

13. To protect, conserve • protect designated areas such as Areas of Outstanding Natural Beauty and and enhance East Sussex South Downs National Park from inappropriate development and Brighton & Hove’s • minimise the landscape and visual impact of development countryside and historic • and built environment conserve the historic environment and its setting including listed buildings, archaeological remains, historic parks and gardens, conservation areas, and scheduled ancient monuments • limit adverse impacts on features of local historic or architectural interest and value • ensure appropriate protection of archaeological remains discovered • ensure appropriate design of facilities to reduce adverse visual impacts and protect local character and distinctiveness • ensure appropriate screening of mineral workings and waste facilities in environmentally sensitive areas and tourist areas • optimise use of previously developed land and existing buildings over greenfield sites • ensure restoration of mineral workings maximise enhancement to the countryside (link with objective 5)

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 46 Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

14. To protect, conserve • protect designated areas from inappropriate development – Special and where appropriate Protection Areas, Special Areas of Conservation, Ramsar sites, Sites of enhance East Sussex and Special Scientific Interest, National Nature Reserves, Ancient Woodland, Brighton & Hove’s Local Nature Reserves, Sites of Nature Conservation Importance biodiversity and • protect ecological networks and ensure no adverse impacts on protected geodiversity species • protect designated areas from adverse environmental impacts, including air quality impacts arising from waste management activities and waste transport • provide appropriate mitigation measures to protect biodiversity and geodiversity especially in designated areas • ensure appropriate and effective restoration and after-use of mineral workings to maximise environmental and nature conservation benefits (link with objective 5) • maximise waste/mineral sites biodiversity potential during as well as after their use

15. To increase energy • promote generation and use of low and zero carbon technology efficiency and the • where landfill gas is generated maximise the energy recovered proportion of energy • generated from renewable encourage energy conservation and energy-efficient design in new waste sources and mineral developments/workings in line with the energy hierarchy (reduce, improve efficiency, generate renewables) • encourage development of local supply chains, in particular biomass

Economic

16. To contribute to the • contribute to increase in gross value added per head, particularly in coastal growth of a sustainable sub-region and diversified economy • ensure provision of sufficient raw and recycled minerals to support sustainable economic growth including meeting the demand for the construction of housing and infrastructure • ensure appropriate waste facilities in East Sussex and Brighton & Hove to meet society’s needs and support sustainable economic growth including supporting the local tourism industry • support the development of businesses involved in the reduction, reuse and recycling of waste • support technologies which will lead to cost effectiveness within waste and minerals industries • maximise the recovery value of waste • consider impact of waste/mineral facilities on other local businesses e.g. adjoining sites or those competing for sites

17. To provide • increase the level and range of employment opportunities within the employment mineral and waste industries and especially in rural and deprived areas opportunities and develop • contribute to a reduction in unemployment in the most deprived SOAs by and maintain a skilled encouraging use of the local labour market in waste and mineral industries workforce • encourage the development of training opportunities, especially in deprived areas, to give people the necessary skills to work in the waste and mineral industries

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ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 48 6 OPTIONS APPRAISAL

6.1 INTRODUCTION

The SA is required to appraise the impacts of the WMSP and of reasonable alternatives to it. In developing the WMSP, a single type of option has been considered, that of the number of waste sites to be allocated. Three options have been developed and each of these has been appraised against the SA objectives of the appraisal framework. A description of the options, the reasons for selecting the alternatives dealt with and the findings of the appraisal are set out in the following sections.

Minerals occur where they lie and there is no option but to work those sites that are viable. However there are choices to be made in allocated sites for waste management uses and consequently these are the options that have been assessed.

A ‘do nothing’ option has been considered and rejected from appraisal because it is not an option to do nothing. A Site Allocations Plan must be produced.

6.2 DESCRIPTION OF OPTIONS

The following options have been developed for the number of sites to be allocated:

Allocating sites based on suitability rather than need would provide the most flexibility for the waste industry. It would allow the WMSP to be more responsive to technological innovation, because more specialised waste processing facilities could be needed in future to manage narrower waste streams. The more the total waste stream is divided, the more facilities are potentially needed. However, there would be considerable uncertainty and possible planning blight for local communities, with many sites that are allocated being unlikely to come forward due to the number allocated being in excess of the need. It could also result in inappropriate spatial concentration of facilities in one part of the Plan Area and a danger of over-provision of capacity, although both of these impacts would be controlled by market forces to some extent.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 49 Allocating the minimum number of sites would provide the greatest level of certainty for local communities. However it would also be very inflexible for the waste industry and leave the WMSP unable to accommodate any changes of circumstance which could affect the deliverability of identified sites. The inflexibility would also mean it would be hard to accommodate future changes in waste management methods which may result in further separation of waste streams requiring a higher number of specialist facilities.

The final option would be to reduce the number of potentially suitable sites to a determined quantity for inclusion on the shortlist. This approach would allocate those sites that have the greatest sustainability benefits, and the number allocated could be set to ensure sufficient flexibility, but also to manage community knowledge or certainty of where such development would be likely to occur. Sites potentially suitable but not taken forward could still come forward using criteria based policies.

6.3 APPRAISAL RESULTS

The three options have been appraised against the appraisal framework and the detailed results are set out in Annex E. The findings are summarised in the following paragraphs.

Allocating the minimum number of sites (option A2) increases the possibility that insufficient sites will be developed, as the Plan would not have any flexibility should any of the required sites become unavailable for waste development. This would reduce the treatment capacity in the Plan area and result in more emissions of greenhouse gases through reduced recovery capacity and increased transport of waste out of the Plan Area. It is likely also to result in more waste being landfilled. It would reduce the economic contribution of new jobs in the waste industry within the Plan Area. However, the fewest number of people would be affected by waste development and perceptions of adverse impacts on health could be fewer than if more sites were allocated.

Allocating the maximum number of sites (option A1) will increase the possibility that a site may be developed that has potentially viable sustainable transport modes and will increase the options for locating close to large centres of population and therefore reduce the contribution of waste transport to poor air quality and climate change. Allocating the minimum number of sites will reduce the possibility of this. By allocating the maximum number of sites, the largest number of people are likely to perceive their health could be affected by waste development, and this could lead to stress. Allocating the bare minimum number of sites will minimise the number of people so affected. Effects are likely to reduce over time as development proceeds.

Allocating more sites than the minimum but not all (option A3) has similar effects to option A1 in some cases, particularly on economic criteria and

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 50 promoting sustainable waste and minerals management. However, on environmental criteria it performs slightly better than option A2 but not as well as option A1. Option A3 performs slightly better than option A1 on social criteria.

6.4 PREFERRED OPTION

Option A3 has been selected as the preferred option. This will enable the allocation of sites with the greatest sustainability benefits, and that have a realistic chance of being developed to be allocated, whilst retaining significant flexibility for the waste industry. The SA indicates that this option has similar effects to option A1 in some cases but on environmental criteria it does not perform as well. However, the conclusion that option A1 performs better on these criteria is based on option A1 increasing the options for locating sites close to centres of population. As all the sites proposed to be allocated are in fact close to the larger population centres, the identified negative sustainability implications associated with option A3 are considered to be unlikely to be realised. Overall, given the location of the sites to be short- listed, option A3 is considered to provide the greatest sustainability benefits.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 51

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 52 7 APPRAISAL OF SITES

7.1 METHODOLOGY

The waste sites that have been identified and proposed to be allocated in the WMSP have been subject to SA. The sites have been appraised against the SA objectives in the appraisal framework and an assessment made of the likely significant effects of development at each site. In doing this the SA has made reference to the site assessment work carried out in-house by Council officers and set out in the ‘East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan - Detailed Site Assessment Document’ which will be published in due course. In undertaking the SA of sites, reference has also been made to publicly available data on local conditions in the vicinity of sites. Recommendations have been made for each site for ways in which the predicted negative effects could be mitigated and for capitalising on opportunities for benefits.

The SA of sites has been an iterative process. East Sussex County Council officers provided a list of potential sites in March 2014 and these were appraised against the appraisal framework. A paper was prepared in April 2014 setting out the results of the appraisal and making mitigation recommendations where possible. Following this, the in-house site assessment work done by East Sussex was amended and the amended site information provided to the SA team along with comments on the first SA of sites. The SA team then made amendments to the SA of sites to reflect this amended site information and comments and the revised findings of the SA of sites is now provided in Annex F.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 53

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 54 8 APPRAISAL OF WMSP POLICIES AND OBJECTIVES

8.1 METHODOLOGY

The appraisal determined the likely effects arising from the WMSP. This applied to the strategic objectives, policies and to a series of options. This was done by assessing each element of the WMSP against the appraisal objectives in turn and making a largely qualitative assessment, with reference also to the baseline data from the Scoping Report.

In reporting the results of the appraisal, the following symbols have been used to indicate the broad nature of the predicted effect:

+ effect likely to be positive - effect likely to be negative 0 no significant effect ? effect unknown

If the appraisal objective was not relevant to the element of the WMSP being appraised, no symbol is given.

Multiple symbols have been used (e.g. ++) to indicate a different scale of impact over time, or where the impacts of an option are substantially better or worse than others.

The assessment of significance is indicated in the tables in this report by colour:

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 55 Not relevant No significance Medium significance High significance

8.2 APPRAISAL OF POLICIES

The findings of the appraisal are set out in detail in Annex D. The table below summarises those findings for the WMSP’s policies.

Table 8.1 Summary of Policy Appraisal Results

SA Objectives WMSP1 WMSP2 WMSP3 WMSP4 WMSP5 WMSP6 WMSP7 WMSP8 WMSP9 WMSP10

1. To avoid negative effects and + 0 0 0 0 0 + + enhance, where possible, positive effects on health. 2. To protect the amenity of residents + +/- +/- +/- +/- 0 + + + and neighbouring land uses. 3. To improve equality and access to + 0 0 0 0 0 + sustainable waste management. 4. To minimise waste generation and + + + + + + + disposal to land. 5. To ensure the sustainable use of + ? ? ? ? ? + + + + local mineral resources. 6. To maintain and improve water 0/? 0/? 0 0 0 quality. 7. To seek the protection of and sustainable use of water resources. 8. To reduce risk and impact of 0/- 0/- 0 0 0 flooding. 9. To limit the causes of and adapt to + + + + + + + + climate change. 10. To protect air quality and reduce + 0/- 0/- 0 0 0 + + air pollution. 11. To reduce adverse impacts of + +/0 +/0 +/0 +/0 + + + + transporting waste and minerals on the environment. 12. To conserve and enhance + +/- +/- -/? -/? 0/? + important soil functions and types. /? /? 13. To protect, conserve and enhance + +/- +/- -/? -/? 0/? + East Sussex and Brighton & Hove’s countryside and historic and built environment. 14. To protect, conserve and where + - - - - - + + appropriate enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity. 15. To increase energy efficiency and + ?/+ ?/+ ?/+ ? ? + the proportion of energy generated from renewable sources.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 56 16. To contribute to the growth of a + +/? +/? +/? +/? +/? + + + + sustainable and diversified economy. 17. To provide employment + + + + + + + + opportunities and develop and maintain a skilled workforce.

8.2.1 Summary of Findings of Policy Appraisal

By safeguarding existing waste sites and allocating new sites, the WSMP will help to ensure sufficient facilities within the Plan Area to deal with waste arisings, maximising the recovery of value from waste and minimising disposal to landfill. This will minimise waste transport distances and promote waste recycling and energy recovery, leading to reduced energy use and reduced greenhouse gas emissions. It will also help to reduce waste transport distances and contribute to avoiding adverse impacts on air quality from waste transport. By seeking to prevent existing waste facilities from being prejudiced from development proposals, the WMSP will indirectly help to ensure that adverse impacts on health and amenity from waste facilities on surrounding uses are prevented.

The WMSP will support businesses involved in sustainable waste management activities, and ensure the supply of recycled minerals to support sustainable construction.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 57 likelihood of effects on flood risk is uncertain. Some sites are close to the SDNP, AONB and historic assets and adverse impacts are possible. Development should be of high quality design to reduce the likelihood of impacts on landscape and historic assets and to protect residential amenity. For some sites, opportunities to co-locate waste facilities and use sustainable modes of transport have been identified, and this could help to further reduce road transport of waste. Some sites have potential for connection to heat networks, which would help to increase energy efficiency and reduce greenhouse gas emissions. Some sites are close to an AQMA and vehicles could add to poor air quality, but in many cases effective routing of vehicles could avoid adverse impacts. Although many sites are on previously developed land, some are greenfield and soil and open space will be lost if these are developed.

8.3 COMPATIBILITY CHECK OF STRATEGIC OBJECTIVES

The WMP developed a number of Strategic Objectives which set the framework for the plan policies. These same Spatial Objectives are used in the WMSP and are set out in .

Table 8.2 WMSP Strategic Objectives

SO1 To achieve declining rates of growth of all wastes, to reduce the amount of waste produced, and to drive the management of waste up the hierarchy by reusing and recycling waste material into new products and recovering energy from materials that cannot effectively be recycled. SO2 To achieve prudent and efficient use of minerals, having regard to the market demand and supply restrictions in the Plan Area, and to recognise waste as a resource in order to reduce local demands on water, energy, land, and primary raw materials including soil and minerals. SO3 To make timely provision for sufficient facilities for the sustainable management of waste (including waste water) and production of minerals to meet forecast requirements for the Plan Area, in order to contribute as far as practicable to regional and national requirements for waste management and support the production of nationally and regionally important minerals. SO4 To protect and enhance the environment, communities and human health through minimising harmful emissions to air (including greenhouse gases), water and land; minimising the use of natural resources (including greenfield sites); minimising impacts on protected habitats, designated landscapes, geological sites and heritage sites; and areas which have landscape character and quality which is sensitive to development including the South Downs National Park; and through ensuring high quality mitigation, compensation and restoration to appropriate after-uses. Account will be taken of local landscape character and distinctiveness. SO5 To manage waste and minerals at an appropriate scale, taking account of the distribution of waste sources and the limitations on the availability of suitable land in the Plan Area, as close to the sources as practicable in order to encourage communities to take more responsibility for the waste they create and to minimise the transport of waste and minerals whilst still moving up the waste hierarchy. Use the most sustainable and practicable mode where it is necessary to transport waste or minerals. SO6 To ensure that sustainable waste management objectives are considered in all plans, strategies and proposals in the Plan Area, and that the design, construction and operation of all new development promotes sustainable waste management. SO7 In recognition of limited capacity for disposal to land in the Plan Area, to dispose of waste to land as a last resort and seek appropriate after-use of land disposal sites to achieve conservation and enhancement of the environment.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 58 SO8 To ensure facilities are designed, located and operated in a manner that takes the implications of climate change, and in particular rising sea levels, into account.

Government guidance recommends that the SA should undertake a compatibility analysis between the objectives of the WMSP and the SA appraisal objectives. This has been done and the results are set out in below.

The purpose of this exercise is to determine whether the objectives of the WMSP will contribute to sustainable development, and to identify any potential incompatibilities between the objectives of the WMSP and sustainable development policy objectives. To do this, the WMSP Strategic Objectives have been compared with each of the SA appraisal objectives and an assessment made of the likelihood that the WMSP will contribute to the achievement of each objective for sustainable development. In most cases where there is a link between the WMSP Strategic Objective and the SA Objective, they are mutually compatible, although in some instances there is a degree of uncertainty and these are explained below the table.

Table 8.3 Compatibility of WMSP Strategic Objectives with SA Objectives

WMSP Strategic Objectives

SA Objectives SO1 SO2 SO3 SO4 SO5 SO6 SO7 SO8

1. To avoid negative effects and    enhance, where possible, positive effects on health. 2. To protect the amenity of residents    and neighbouring land uses. 3. To improve equality and access to  sustainable waste management. 4. To minimise waste generation and      disposal to land. 5. To ensure the sustainable use of     local mineral resources. 6. To maintain and improve water     quality. 7. To seek the protection of and   sustainable use of water resources. 8. To reduce risk and impact of  flooding. 9. To limit the causes of and adapt to        climate change. 10. To protect air quality and reduce ? ?   air pollution. 11. To reduce adverse impacts of ? ?   transporting waste and minerals on the environment. 12. To conserve and enhance     important soil functions and types. 13. To protect, conserve and enhance   East Sussex and Brighton & Hove’s countryside and historic and built environment.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 59 WMSP Strategic Objectives

SA Objectives SO1 SO2 SO3 SO4 SO5 SO6 SO7 SO8

14. To protect, conserve and where  ? appropriate enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity. 15. To increase energy efficiency and       the proportion of energy generated from renewable sources. 16. To contribute to the growth of a    sustainable and diversified economy. 17. To provide employment    opportunities and develop and maintain a skilled workforce.

The following paragraphs describe the source of the uncertainty in the compatibilities identified in the table above by a ‘?’:

• SO1 – By reducing the amount of waste generated, the WMSP will reduce the need for waste transport, although increasing levels of recycling and recovery is likely to increase the need for waste transport by requiring multiple handling of waste streams, including recyclables and by-products of processing. This could have adverse effects on air quality, although the likelihood and significance of effects are uncertain as this will depend in part on where developments are located and what catchment areas they serve.

• SO2 – In order to promote the use of waste as a resource the WMSP will support increased levels of recycling and recovery which may lead to increased waste transport with potential adverse effects on air quality, although the likelihood and significance of effects are uncertain as this will depend in part on where developments are located and what catchment areas they serve.

• SO7 – By supporting appropriate after-use of landfill sites, this objective may promote increased biodiversity value of closed landfill sites, although this will depend on any specific restoration conditions imposed at particular sites. However, no new landfill sites are proposed in the WMSP, and therefore the capacity of the WMSP to influence the achievement of this is extremely limited.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 60 9 CUMULATIVE EFFECTS AND INTERRELATIONSHIP BETWEEN EFFECTS

9.1 CUMULATIVE EFFECTS

The SEA Directive requires assessment of an additional level of impacts in addition to straightforward direct impacts. These are specified as “secondary, cumulative, synergistic, short, medium and long-term permanent and temporary, positive and negative”. The following approach has been taken to identifying such impacts.

A number of different types of impact are set out in European Commission guidance:

• separate developments causing the same impact – cumulative; • different impacts acting together on a receptor e.g. air pollution and land take – cumulative; • plan impacts which give rise to other indirect impacts – secondary; and • different impacts which together give rise to yet another impact – cumulative and secondary.

There is therefore a need to consider both secondary and cumulative impacts in the appraisal. Secondary impacts were considered as an integral part of the main appraisal work, and this is indicated in the appraisal matrices in Annexes D to F where impacts are either direct or indirect i.e. secondary. Certain other attributes are common to all types of impact: these are timescales (i.e. short, medium and long-term impacts), reversibility (i.e. permanent or temporary impacts) and whether the impacts are positive or negative. These attributes were also all considered as integral aspects of impact assessment, and this is similarly indicated in the appraisal matrices in Annexes D to F. Cumulative impacts are discussed in this section of the SA Report.

There are two types of situation that could give rise to cumulative impacts:

• the same effect arising from two or more different sources; and • different effects where there is a relationship between the effects and potentially an interaction.

Synergistic effects are a type of cumulative impact. These are effects where the cumulative impact may be greater or smaller than the sum of the separate effects.

Cumulative impacts were considered in the appraisal in two ways:

• the potential for different developments to give rise to the same type of effect; and • the potential for interaction between different types of effect.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 61 In order to assess the cumulative impacts arising from all potential developments under the WMSP, the appraisal considered the overall effect of the WMSP as a whole on each of the SA objectives. The results of this are set out above in Section 6.2.

The appraisal then assessed the potential for the development of multiple waste sites to give rise to cumulative effects. The appraisal finally considered the potential for effects arising from other plans and programmes which in combination with effects arising from the WMSP may give rise to significant impacts. The results of the review of other plans and programmes and their potential to give rise to cumulative effects is set out in Annex G.

9.1.1 Cumulative Impact of Development of Multiple Waste Sites

Newhaven

Most of the Newhaven sites are constrained in some way by features of biodiversity value. If more than one site is developed within the area, this may lead to adverse cumulative impacts on biodiversity, including from reduced air quality, disturbance, direct land-take, predation and litter, depending on the risks at individual sites. Several of the Newhaven sites are also within flood risk areas, which could lead to increased flood risk from development of more than one site within a catchment, although development could also present an opportunity for works to reduce the risk and impact of flooding and therefore the likelihood of effects on flood risk is uncertain. Development of several sites within the Newhaven/Seaford area could lead to adverse cumulative visual impacts on the South Downs National Park. The impacts of facilities and waste traffic could contribute to reduced air quality in Newhaven, although this is also dependent on measures at specific sites to address poor air quality and therefore the significance of effects is uncertain.

Eastbourne

Many of the sites assessed in Eastbourne are constrained in terms of their biodiversity value and flood risk. If more than one site is developed, this may lead to cumulative impacts on biodiversity depending on the constraints at the particular sites, but these could include adverse impacts from reduced air quality, direct land take, disturbance and predation. It may also lead to increased flood risk, although development could also present an opportunity for works to reduce the risk and impact of flooding and therefore the likelihood of effects on flood risk is uncertain.

Brighton & Hove

Several of the Brighton & Hove sites are in or near to areas of poor air quality. If more than one site is near to an AQMA, this may lead to adverse cumulative impacts on air quality, with the risk of adverse effects on human health and on

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 62 biodiversity. Effects are also possible on biodiversity from predation, depending on the risks at individual sites.

Hastings

All of the Hastings sites are constrained in some way by features of biodiversity value. If more than one site is developed within a particular area, this may lead to adverse cumulative impacts on biodiversity, including from reduced air quality, direct land-take, disturbance, predation and litter, depending on the risks at individual sites. Several of the sites are also within flood risk areas and several are greenfield sites or contain areas of greenfield land, which could lead to increased flood risk from development of more than one site within a catchment, although development could also present an opportunity for works to reduce the risk and impact of flooding and therefore the likelihood of effects on flood risk is uncertain. Development of several sites within Hastings could lead to adverse cumulative visual impacts on the AONB. A small number of sites risk adverse impacts on the setting of listed buildings, and therefore cumulative adverse effects on heritage assets are possible.

Bexhill

All of the Bexhill sites are constrained in some way by features of biodiversity value. If more than one site is developed within a particular area, this may lead to adverse cumulative impacts on biodiversity, including from reduced air quality, disturbance and litter, depending on the risks at individual sites. Several of the sites are also within flood risk areas, which could lead to increased flood risk from development of more than one site within a catchment, although development could also present an opportunity for works to reduce the risk and impact of flooding and therefore the likelihood of effects on flood risk is uncertain. Development of several sites within the Bexhill area could lead to adverse cumulative visual impacts on the local landscape and countryside.

Wealden

All of the Wealden sites are constrained in some way by features of biodiversity value. If more than one site is developed within a particular area, this may lead to adverse cumulative impacts on biodiversity, including from reduced air quality, direct land-take, disturbance and predation, depending on the risks at individual sites. Several of the sites are also within flood risk areas, which could lead to increased flood risk from development of more than one site within a catchment, although development could also present an opportunity for works to reduce the risk and impact of flooding and therefore the likelihood of effects on flood risk is uncertain. Development of more than one site at Crowborough could lead to adverse cumulative visual impacts on the AONB.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 63 9.1.2 Cumulative Effects of Other Plans and Strategies in Combination with the WMSP

The key plans and strategies that could give rise to significant cumulative impacts together with the WMSP are:

• Eastbourne Core Strategy Local Plan, February 2013; • Eastbourne Proposed Draft Employment Land Local Plan, December 2013 • Brighton and Hove Submission City Plan Part One, February 2013; • Wealden Core Strategy Local Plan, February 2013; • Wealden Submission Strategic Sites Local Plan, March 2014; • The Hastings Planning Strategy 2011-2028, February 2014; • Rother District Council Proposed Submission Core Strategy, August 2011 and Schedule of Main Modifications, August 2013; • Lewes Joint Core Strategy – Proposed Submission Document, January 2013; • Shoreham Harbour Joint Area Action Plan: Draft for Consultation, February 2014; • East Sussex Local Transport Plan 2011-2026, June 2011; • South East LEP Growth Deal and Strategic Economic Plan, March 2014; • Coast to Capital Strategic Economic Plan, March 2014.

Each of these is summarised in Annex G, and an assessment made of the potential contribution to significant cumulative effects in combination with the WMSP.

Many of the plans and strategies reviewed will promote housing growth and increased economic activity in the Plan Area. This is likely to increase the demand for road space, which could lead to increased congestion and a deterioration in air quality with potential negative effects on human health and biodiversity. However, plans and strategies generally have a strong emphasis on reducing traffic and promoting sustainable modes of travel and some seek to enhance digital connectivity. These factors will help to ease congestion and may offset to some extent the adverse effects on air quality, although the extent to which this will apply is uncertain. A shift to more sustainable transport choices will also help to limit greenhouse gas emissions.

The promotion of economic activity will benefit the local population through increased access to employment and should help to reduce deprivation in key parts of the Plan Area such as Brighton & Hove, Hastings and Newhaven. Upgrading of port services will help to encourage the transport of waste by water. Improvements to flood defences at Newhaven and Shoreham are likely to contribute to reduced flood risk for a number of sites. Opportunities for decentralised, low carbon energy systems will be promoted, helping to increase energy efficiency and reduce greenhouse gas emissions.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 64 9.2 INTERRELATIONSHIP BETWEEN EFFECTS

The SEA Directive requires the appraisal to consider the interrelationship between the significant effects of the WMSP. This has been done as an integral part of the appraisal of the policies and options, and examples of this can be found throughout Sections 6 and 7 and Annexes D to F of this report. The main interrelationships found through the appraisal are highlighted below.

The WMSP will help to ensure sufficient capacity within the Plan Area to deal with waste arisings, reducing the landfill of waste. This will minimise waste transport distances and promote waste recycling and energy recovery, leading to reduced energy use and reduced greenhouse gas emissions. It may also indirectly reduce adverse impacts of poor air quality on biodiversity.

There is the potential for adverse effects on biodiversity and ecosystems from poor air quality although the significance of effects is uncertain. This could act in combination with effects from the direct land-take of sites of nature conservation value, from disturbance from waste management activities, predation by vermin and fragmentation of ecological networks, leading to pressure on biodiversity and potential adverse impacts.

Protecting the amenity of nearby residents and other neighbouring land uses will help to avoid adverse impacts on human health from waste facilities, including from reduced air quality, noise, odours and visual impacts. Mitigating the visual impacts of development will help to protect the quality of local landscapes and townscapes, the countryside and the AONB and SDNP, as will promoting the use of secondary and recycled aggregates.

By increasing energy efficiency and energy recovery, the WMSP will help to reduce greenhouse gas emissions and contribute to improved air quality, which again will lead to benefits for human health and ecosystems.

The WMSP gives support to the waste industry, which will contribute to economic growth in the Plan Area and may help to reduce deprivation in a small way. By ensuring the sustainable use of mineral resources, promoting the production of secondary and recycled aggregates and promoting sustainable transport of waste and minerals, and the WMSP will contribute to improved air quality which will have benefits for improved human health and protection and enhancement of ecosystems and biodiversity.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 65

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 66 10 MONITORING

10.1 PROPOSALS FOR MONITORING

As required by the SEA Directive, a number of recommendations are made for indicators to monitor the likely significant impacts of the WMSP. These are set out in Table 10.1 corresponding to the relevant impacts identified and summarised in the preceding chapters of this report.

One of the aims of monitoring as specified by the SEA Directive is to identify unforeseen adverse effects in order to be able to take appropriate remedial action. To enable this to be done, recommendations are also made in Table 10.1 for monitoring potential sustainability impacts that are not expected to occur as foreseen by the appraisal.

An Annual Monitoring Report will be produced to monitor the implementation of the WMP and WMSP, and the recommendations given below for monitoring should be incorporated within this.

Table 10.1 Monitoring Recommendations

SA Objectives Recommended Indicators 1. To avoid negative effects and Number of complaints about health impacts of waste enhance, where possible, positive and minerals developments effects on health. 2. To protect the amenity of residents Number of complaints about amenity impacts of and neighbouring land uses. waste and minerals developments Number of enforcement cases regarding amenity impacts 3. To improve equality and access to Number of waste management businesses operating sustainable waste management. in Plan Area 4. To minimise waste generation and Tonnage of waste arisings, by waste stream disposal to land. Capacity in Plan Area for: reuse; recycling; composting; other recovery Tonnage of waste sent to landfill, by waste stream 5. To ensure the sustainable use of Capacity for secondary and recycled minerals local mineral resources. production in Plan Area 6. To maintain and improve water Number of facilities breaching permit conditions quality. 7. To seek the protection of and None recommended sustainable use of water resources. 8. To reduce risk and impact of Planning permissions granted contrary to flooding. Environment Agency advice 9. To limit the causes of and adapt to MW of energy generated by waste facilities climate change. Tonnage of waste and minerals transported by rail and water Capacity in Plan Area for: reuse; recycling; composting; other recovery

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 67 SA Objectives Recommended Indicators 10. To protect air quality and reduce Number of facilities breaching permit conditions air pollution. 11. To reduce adverse impacts of Number of enforcement cases regarding traffc transporting waste and minerals on impacts the environment. Tonnage of waste and minerals transported by rail and water 12. To conserve and enhance Hectarage of greenfield sites lost to waste and important soil functions and types. minerals development 13. To protect, conserve and enhance Number of enforcement cases regarding landscape East Sussex and Brighton & Hove’s impacts countryside and historic and built Number of enforcement cases regarding impacts on environment. historic assets 14. To protect, conserve and where Number of sites of biodiversity or geodiversity value appropriate enhance East Sussex and lost to waste and minerals development Brighton & Hove’s biodiversity and Number of enforcement cases regarding impacts on geodiversity. biodiversity 15. To increase energy efficiency and MW of energy generated by waste facilities the proportion of energy generated Number of developments incorporating CHP from renewable sources. 16. To contribute to the growth of a Capacity in Plan Area for: reuse; recycling; sustainable and diversified economy. composting; other recovery Number of waste management businesses operating in Plan Area Number of minerals businesses operating in Plan Area Tonnage of raw minerals extracted Tonnage of secondary and recycled minerals produced 17. To provide employment Number of waste management businesses operating opportunities and develop and in Plan Area maintain a skilled workforce. Number of minerals businesses operating in Plan Area

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL 68 11 NEXT STEPS

11.1 CONSULTATION

This first SA Report has been published for consultation alongside the draft WMSP of 2014. All representations received from consultees will be considered and where necessary, amendments and/or additions to the information contained in the SA Report will be undertaken.

11.2 PROPOSED SUBMISSION WMSP

Following the close of consultation on the draft WMSP and SA Report, all representations will be considered and any required amendments will be made to the WMSP to produce the Proposed Submission WMSP. This will be subject to further SA and both the Proposed Submission WMSP and the accompanying SA Report will be published for comment. It is currently expected that this will be published in late summer 2015.

Following consultation on the Proposed Submission WMSP and SA, the WMSP will be submitted to the Secretary of State in late 2015. The Examination in Public is expected to be held in early 2016, with adoption and publication of the WMSP in mid-2016.

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Annex A

Review of Policies, Plans and Programmes

LIST OF REVIEWED POLICIES, PLANS AND PROGRAMMES

Crosscutting Plans, Policies and Programmes. National Planning Policy Framework DCLG, March 2012) National Infrastructure Plan (Treasury, Oct 2010) Decentralisation & Localism Bill (CLG, Dec 2010) Local Planning Regulations (DCLG July 2011) East Sussex Environment Strategy (East Sussex Environment Strategy Group, 2011) UK Government Sustainable Development Strategy: Securing the Future (TSO, March 2005) The South East Regional Sustainability Framework: Towards a Better Quality of Life. (SEERA, et al, 2008) Best Value Review of Sustainable Communities Report by Project Board (ESCC, 2005) Pride of Place: Working Towards a Better Future for Local People and Local Communities. A Sustainable Community Strategy for East Sussex (East Sussex Strategic Partnership et al, 2008) East Sussex Statement of Community Involvement, (ESCC, Dec 2006) Brighton & Hove Statement of Community Involvement (BHCC, Sept 2006) Brighton and Hove Sustainable Community Strategy: Creating the City of Opportunities (LSP, 2010)

Brighton & Hove Sustainability Action Plan (BHCC 2012) Brighton & Hove Local Plan (BHCC, 2005) Brighton & Hove City Plan Part 1 (Submission) 2013 Eastbourne Core Strategy Local Plan (EBC Feb 2013) adopted Hastings Local Plan, (HBC, 2004) Hastings Development Management Plan Proposed Submission (HBC, Nov 2012) Lewes District Local Plan, (LDC, March 2003) Lewes District and South Downs National Park Authority Proposed Submission Core Strategy (2013) Rother District Local Plan, (RDC, July 2006) Rother Core Strategy, Proposed Submission (RBC, August 2011) Wealden District Local Plan (non statutory) (WDC, December 2005) Wealden District Core Strategy (WDC, November 2012) adopted Sustainability Objective 1 – To improve the health of people living and working in East Sussex and Brighton and Hove White Paper - Healthy Lives, Healthy People (Department of Health, November 2010) Choosing Health: Making Healthy Choices Easier (Department of Health, 2004) Review of Environmental and Health Effects of Waste Management: Municipal solid waste and similar wastes (DEFRA, 2004) The South East England Health Strategy (Regional Public Health Group, 2008) Brighton and Hove 2020 Community Strategy: Healthy City Partnership & The Health Inequalities Strategy (2008) Sustainability Objective 2 – To protect the amenity of residents and neighbouring land uses. Noise Policy Statement for England (Defra 2010) Noise Action Plan Brighton Agglomeration (Defra 2010)

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Sustainability Objective 3 – To improve equality and access to sustainable waste management, and; Sustainability Objective 4 – To minimise waste generation and disposal to land. Waste Framework Directive (2008/98/EEC)

Hazardous Waste Directive (1975, amended 1991/689/EEC)

Waste Incineration Directive (2000/76/EC)

Waste Electrical and Electronic Equipment (WEEE) Directive 2002/96/EC (European Commission, 2002) EU Thematic Paper: Taking sustainable use of resources forward: A Thematic Strategy on the prevention and recycling of Waste (EU Commission, 2005) PPS10: Planning For Sustainable Waste Management (ODPM, 2005) PPS10: Companion Guide (DCLG, 2006) Update to PPS10 – waste Hierarchy (March 2011) Waste Strategy for England 2007 (DEFRA) Waste Regulations 2011 (England and Wales) Feb 2011 NPS Waste Water (DEFRA, 2012) National Waste Strategy (2011) Municipal Waste Management Strategy (County Council and all District Councils in East Sussex, Brigh ton & Hove Municipal Waste Management Strategy (BHCC, 2010) East Sussex and Brighton & Hove Waste Local Plan (ESCC and BHCC 2006) (saved policies East Sussex, South Downs and Brighton & Hove Waste & Minerals Local Plan (2013) Sustainability Objective 5 – To ensure the most sustainable use of minerals resources. Planning and Minerals: Practice Guide (DCLG, 2006) MMG 1 – Guidance on the Extraction by Dredging of Sand, Gravel and Other Minerals from the English Seabed (ODPM, 2002) MPG8 Interim Development Order Permissions – Statutory Provisions and Procedures (DoE, MPG9 Interim Development Order Permissions – Conditions (DoE, 1991) National and Regional Guidance for Aggregate Provision in England 2001-2016, (ODPM, 2003) National and Regional Guidelines for Aggregates Provision in England 2005 -2020, (CLG, June 2009). English Nature Policy Position Statement: Aggregate Extraction and Nature Conservation (English Nature, 2002) English Nature Policy Statement: Non-aggregate Mineral Extraction (English Nature, 1997) Mineral Safeguarding in England: Good practice advice (BGS/The Coal Authority, 2011) Partial Review of the Regional Spatial Strategy for the South East (Review of Policy M3 – Primary land-won aggregates and sub-regional apportionment (Consultation March 2009) See Also, East Sussex, South Downs and Brighton & Hove Waste & Minerals Local Plan (2013) Sustainability Objective 6 – To maintain and improve water quality. Urban Waste Water Treatment Directive (1991/271/EEC) Water for Life (White Paper) (Defra 2011) Underground, Under threat – Groundwater Protection: Policy and Practice Groundwater protection: policy and practice (Environment Agency, 2006) Future Water: The Government’s Water Strategy for England (DEFRA, 2008) River Basin Management Plan South East River Basin District (Environment Agency, Dec 2009) Sustainability Objective 7 – To seek the protection of and sustainable use of water resources, and; Sustainability Objective 8 – To reduce risk and impact of flooding. The Flood and Water Management Act 2010 (HMSO, 2010) Water for people and the environment: Water Resources Strategy for England and Wales (EA 2009)

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Shoreline Management Plan South Foreland to Beachy Head, First Review, Final Report (SDGE, 2006) Shoreline Management Plan. Beachy Head to Selsey Bill (First Review – 2006)

Rother and Romney Catchment Flood Management Plan, (CFMP) (Environment Agency, August 2008) Medway CFMP (Environment Agency September 2008) Cuckmere and Sussex Havens CFMP (Environment Agency September 2008) River Ouse CFMP (Environment Agency September 2008) Adur CFMP (Environment Agency September 2008) Draft Water Resources Management (South East Water, May 2013) Draft Water Resources Management (Southern Water, May 2013) Waste and Minerals Development Framework Strategic Flood Risk Assessment, East Sussex Brighton and Hove Council Strategic Flood Risk Assessment, January 2012 Technical Guidance to the National Planning Policy Framework, DCLG, March 2012 Sustainability Objective 9 – To limit the causes of and adapt to climate change. Kyoto Climate Change Protocol (1997) The UK Low Carbon Transition Plan (2009)

Carbon Plan: Delivering Our Low Carbon Future (2011)

Beyond Copenhagen: The UK Government’s International Climate Change Action Plan (DECC - 2010) The Planning Response to Climate Change: advice on better practice (ODPM, 2004) Climate Change: The UK Programme (DEFRA, 2006) Climate Change Act 2008 (DEFRA, November 2008) Climate Change Strategy (East Sussex County Council, 2009) Climate Change Strategy 2011-2015 (BHCC 2011)

Sustainability Objective 10 – To protect air quality and reduce air pollution. Air Quality Directive (2008/50/EC) The Environment Act 1995 (Part iv) Air Quality Strategy for England, Scotland, Wales and Northern Ireland (DEFRA, July 2007) Hastings Borough Council AQMA (HBC, 2004) Lewes District Council AQMA (LDC, 2005) Brighton & Hove City Council AQMA 2013 Adur District Council AQMA (ADC, 2005) Sustainability Objective 11 – To reduce adverse impacts of transporting waste and minerals by road on the environment. Towards a Sustainable Transport System (DfT 2007) Delivering a Sustainable Transport System (DaSTS, 2008) Low Carbon Transport: A Greener Future, (DFT, 2009) Active Travel Strategy (DFT 2010) Towards a Sustainable Transport System: Supporting Economic Growth in a Low Carbon Economy (TSO - 2007). East Sussex Freight Strategy (ESCC, 2010) East Sussex Local Transport Plan 3 2011-26 (ESCC, 2011) Brighton & Hove Local Transport Plan 2011-2026 (BHCC, 2011) National Policy Statement (NPS) Ports (DFT, 2012) White Paper: Creating Growth, Cutting Carbon – (DfT January 2011) Sustainability Objective 12 – To conserve and enhance important soil functions and types. European Thematic Strategy for Soil Protection (EU, 2006) First Soil Action Plan for England 2004 -2006 (DEFRA, 2004) Safeguarding our Soils: A Strategy for England (Defra, 2009)

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Sustainability Objective 13 – To protect, conserve and enhance East Sussex and Brighton and Hove’s countryside and historic and built environment. National Parks & Countryside Act 1949 and Environment Act 1990 (HMSO 1949, 1990) English National Parks and the Broads UK Government Vision and Circular 2010 Heritage Counts 2006: The State of the South East’s Historic Environment (English Heritage A Strategy for Archaeology in East Sussex (ESCC 1993) The High Weald AONB Management Plans (High Wield JAC 2004) Management Plan for the South Downs (South Downs Joint Committee, 2009) nd The High Weald AONB Management Plan 2004 2 edition, (High Weald AONB Joint Advisory Committee, March 2009) Marine Policy Statement, (Defra, March 2011) Sustainability Objective 14 – To protect, conserve and enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity. The Natural Environment and Rural Communities Act 2006 (Commencement No. 2 Order 2006) The Conservation of Habitats and Species Regulations 2010 Chapter 8 covers Land Use Plans (April 2010) Natural Environment White Paper (DEFRA 2011) Biodiversity 2020: A Strategy for England’s Wildlife and Ecosystem Services (DEFRA 2011) A Strategy for England’s Trees Woods and Forests (2007) A Biodiversity Action Plan for Sussex (Sussex Biodiversity Partnership, 1997) South East Biodiversity Strategy (South East Biodiversity Forum – 2009) Brighton & Hove Biodiversity Action Plan (BHCC Feb 2013) Sustainability Objective 15 – To increase energy efficiency and the proportion of energy generated from renewable sources. Energy Act 2008 (DEFRA) Energy White Paper, Meeting the Energy Challenge (DTI, 2007) The Energy Challenge - DTI Energy Review: A Report (DTI, 2006) National Policy Statement (EN1) – Overarching National Policy Statement for Energy (DECC, July, 2011) National Policy Statement (EN2) – Fuel Electricity Generating Infrastructure e.g. gas, oil and coal fired power stations (DECC, July, 2011) National Policy Statement (EN3) – Renewable Energy generation, including wind farms, energy from waste and biomass plant fossil (DECC, July, 2011) Renewable Energy Strategy (DECC, 2009) The UK Low Carbon Transition Plan: National Strategy for Climate and Energy (TSO - 2009) Sustainability Objective 16 – To contribute to the growth of a sustainable and diversified economy, and; Sustainability Objective 17 – To provide employment opportunities and develop and maintain a skilled workforce. Strategy for Sustainable Farming and Food (DEFRA 2004) Regional Economic Strategy for the South East of England 2006-2016 (SEEDA, 2006) East Sussex Economic Strategy 2003-2013 (ESCC, 2003) Brighton & Hove Economic Strategy 2008-2016 (BHCC, 2008) Local growth white paper (BIS, Oct 2010) Employment Land Study for Brighton & Hove (NLP for BHCC 2012)

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Crosscutting Plans, Policies and Programmes. National National Planning Policy The National Planning Policy Framework (NPPF) sets out the Government’s Plan should contribute to the SA Objectives should reflect Framework (DCLG, March planning policies for England and how these are expected to be applied. The objective of achieving sustainable the core planning principles 2012) NPPF must be taken into account in the preparation of local and neighbourhood development (social, economic and and policies set out in the plans, and is a material consideration in planning decisions. environmental). NPPF. At the heart of the NPPF is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking. For plan-making this means that: ● local planning authorities should positively seek opportunities to meet the development needs of their area; ● Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless: • any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or –– specific policies in this Framework indicate development should be restricted.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA National Infrastructure Plan The Government’s vision for major infrastructure investment in the UK: The Waste and Minerals Sites Plan The SA should reflect aims (Treasury, October 2010) • maximising the potential of existing road and rail networks; (WMSP) should aim to reflect of the plan where relevant. • transforming energy and transport systems to deliver a low vision objectives and help carbon economy; address issues and needs raised • transforming the UK’s strategic rail infrastructure; in the plan. • meeting future challenges in providing sustainable access to water for everyone; • protecting the economy from the current and growing risk of floods and • coastal erosion; • reducing waste and improving the way it is treated; • providing the best superfast broadband in Europe; and • ensuring that the UK remains a world leader in science, research and innovation.

Looking forwards, trends all point towards a need for a step change in both the level and type of investment. There are a number of drivers that will have a long term impact on the infrastructure need across all sectors, including:

• Obsolescence (updating of existing infrastructure) • Globalisation (competition from overseas) • Growing demand (population growth) • Climate change (less carbon intensive infrastructure needed) • Interdependence (increase between systems i.e. technology and digital networks)

The delivery of effective, timely and high value for money infrastructure projects requires a transparent planning and consents regime which is able to respond quickly to the need for new infrastructure at both the national and local level. An efficient planning regime is vital to encourage private sector investment.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Localism Act CLG, 2011) The overall effect of the Act Bill The WMSP should take account SA should take account of of the reforms brought about by reforms brought about by New freedoms and flexibilities for local government the Act. the Act. The Act will: • give local authorities everywhere the formal legal ability and greater confidence to get on with the job of responding to what local people want; • cut red tape to enable councillors everywhere to play a full and active part in local life without fear of legal challenge; and • encourage a new generation of powerful leaders with the potential to raise the profile of English cities, strengthen local democracy and boost economic growth.

New rights and powers for local communities The Act will:

• make it easier for local people to take over the amenities they love and keep them part of local life; • ensure that local social enterprises, volunteers and community groups with a bright idea for improving local services get a chance to change how things are done; • give people a new way to voice their opinions on any local issue close to their heart; and • enable local residents to call local authorities to account for the careful management of taxpayers’ money.

Reform to make the planning system clearer, more democratic and more effective The Act will:

• place significantly more influence in the hands of local people over issues that make a big difference to their lives; • provide appropriate support and recognition to communities who welcome new development

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA the job of working with local people to draw up a vision for their area’s future; and • reinforce the democratic nature of the planning system - passing power from bodies not directly answerable to the public, to democratically accountable ministers.

Reform to ensure that decisions about housing are taken locally The Act will:

• enable local authorities to make their own decisions to adapt housing provision to local needs, and make the system fairer and more effective Local Planning Regulations, The changes in summary: The WMSP should ensure that all The SA should ensure that DCLG regulations are complied with, all regulations are complied • Existing requirements are streamlined and a list of the public and provide sufficient evidence of with, and provide sufficient bodies to whom the new ‘duty to co-operate’ applies, is public consultation that has been evidence of public provided. LEPs should be accounted for. undertaken. consultation that has been • The definition of development plan documents is simplified, without referring to complex ‘local development frameworks’. undertaken. This allows councils to decide what they want to include in their development plan documents and review policy more quickly. • Local development schemes now only need to be reported to local people. • Secretary of State’s powers for intervention are set out and the need to seek compliance with regional strategies for areas • outside London has been removed. The detailed prescription for public participation in the preparation of the statement of community involvement has also been removed. • The need to prepare a monitoring report for the Secretary of State has been removed. Councils are instead required to make the report for local people.

What’s not changing?

The basic process of plan preparation is largely unchanged in order to meet EU requirements. The process for preparing development plan documents consists of an engagement stage and one formal consultation stage before submission to the Secretary of State for examination in public. See revised regulations 19, 20 and 21

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA East Sussex Environment The priority of the strategy is to: protect and enhance our natural and built The WMSP should be The SA should ensure that Strategy (East Sussex environment for current and future generations, and enable individuals and underpinned by a commitment to the objectives reflect the Environment Strategy Group, organisations to tackle and adapt to climate change. help deliver the tasks in the priorities and tasks being 2011) Environment Strategy. undertaken by the strategy. The key tasks of the strategy are to: • Develop high quality environments in our towns and villages; • Reduce traffic, increase alternative sustainable travel choices and improve air quality; • Increase green spaces, leisure opportunities and visitor facilities, and make best use of our natural assets; • Prepare for the effects of climate change, manage the risks and make the most of the opportunities; • Encourage individuals and organisations to minimise their water consumption, CO2 emissions and overall environmental impact; • Reduce, reuse and recycle more household, business and industrial waste; • Ensure climate change is a strategic consideration of Local Development Frameworks and other planning policies; and • Improve streets and green spaces so that places are safer.

UK Government Sustainable The Strategy aims to enable all people throughout the world to satisfy their basic WMSP to include commitments Priorities and principles Development Strategy: needs and enjoy a better quality of life without compromising the quality of life to, and promote, sustainable should act as pointers for Securing the Future (2005) of future generations. Priorities: development principles and the SA objectives and • Sustainable consumption and production. priorities by: indicators. • Natural resource protection. • Reducing • Sustainable Communities. resource • Climate change and energy. consumption. Principles: • Reducing waste • Living within environmental limits. transportation • Ensuring a strong, healthy and just society. (proximityprinci • Achieving a sustainable economy. ple). • Promoting good governance. • Reducing • Using sound science responsibly. environmental degradation. • Encouraging community involvement in waste. t

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Regional The South East Regional Updates the Integrated Regional Framework 2004. It sets a common vision, WMSP should address the The SA Framework should Sustainability Framework priorities and 25 objectives. Vision: relevant sustainability objectives, be based on and incorporate (RSF): Towards a Better • A socially and economically strong, healthy and just South East that regional indicators and targets the RSF objectives as Quality of Life. (SEERA, et respects the limits of the global environment. included in the framework. appropriate. al, 2008) Priorities: • Achieving sustainable levels of resource use. • Reducing greenhouse gas emissions associated with the region. • Ensuring that the South East is prepared for the inevitable impacts of climate change. • Ensuring that the most deprived people also have an equal opportunity to benefit from and contribute to a better quality of life. It sets an overarching framework that the regions plans should be reviewed against to enable sustainable development objectives to be integrated into the policy development process.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Unitary/County/Sub-Regional Best Value Review of The Best Value Review investigated 4 key areas including ‘Environment, WMSP to reflect the Project Boards SA to reflect the Boards Sustainable Communities particularly domestic waste and recycling’. sustainability objectives and take on sustainability definition and Report by Project Board board the recommendations. develop indicators related to (ESCC, 2005) Sustainable Development definition for East Sussex: “Sustainable the Boards sustainability Development is the simple idea of ensuring a better quality of life and objectives. successful communities for everyone, now and for generations to come. This means that we in ESCC together with partners should: Include objectives such as: • Encourage a thriving and improving local economy supported by • To promote education and training. development • Promote better transport facilities. that is socially, • Use natural resources wisely and encourage conservation. economically • Protect and enhance the environment. and • Care for and protect people. environmentall • Promote affordable housing.” y sustainable; and A number of recommendations were made in regard to waste including: • Minimise waste • Exploration of the creation of a single waste collection and generation disposal authority with a view to remove the disincentives to o recycling. • Investigation of further possibilities for increasing the amount of green waste collected for composting in East Sussex, with a view to reducing the demands on landfill and producing a marketable compost product. • Urge Government to be more proactive in supporting LA actions in promoting and sustaining viable waste disposal. Pride of Place: Working Developed by the six Local Strategic Partnerships in East Sussex to create one WMSP should be fully aligned SA framework should reflect Towards a Better Future for integrated strategy. with the priorities identified in strategy and include Local People and Local Environment & Climate Change Pride of Place. Climate change objectives to: Communities. A Sustainable Priority is to protect and enhance our natural and built environment for issues should be fully considered • protect and Community Strategy for East current and future generations, and enable individuals and organisations to when developing policies. enhance the Sussex (East Sussex Strategic tackle and adapt to climate change. natural and built Partnership et al., 2008) environment; Key Tasks include: • tackle and adapt to climate change;

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA • Reuse, reduce and recycle more household, business and industrial • increase waste. sustainable • Reduce traffic, increase alternative sustainable travel choices and travel; and improve air quality. • minimise • Prepare for the effects of climate change; manage the risks and resource make the most of the opportunities. consumption • Encourage individuals and organisations to minimise their water and CO2 consumption, CO2 emissions and overall environmental impact. emissions • Ensure climate change is a strategic consideration of Local Development Frameworks and other planning policies. East Sussex Statement of The SCI sets out how and when Local Authorities will engage communities in The WMSP must meet and try to Consultations on the SA Community Involvement the preparation of Local Development Documents and Planning Applications. exceed the requirements for should fulfil community (SCI), (ESCC, Dec 2006) formal consultation set out in the involvement requirements in “The County Council will exceed these minimum requirements for community Town and Country Planning the SCI. involvement where appropriate.” (Local Development) (England) Regulations 2004.

Brighton & Hove The overarching goal of the Action Plan is to ensure that the city can live within The WMSP should build on the key The SA Framework should Sustainability Action Plan its ecological means. Ecological Footprint is used as the headline sustainability objectives of the Action Plan, reflect the priorities identified (BHCC 2012) indicator for the city. particularly the targets relating to and the One Planet approach. The Action Plan builds upon the One Planet Framework and sets specific waste reduction. objectives and targets for each of the following themes: Zero Carbon, Zero Waste, Sustainable Transport, Sustainable Materials, Local and Sustainable Food, Sustainable Water, Land Use and Wildlife, Culture and Community, Equity and Local Economy, and Health & Happiness. Targets relating to waste reduction include: • By 2025, 70% of domestic waste by weight will be reclaimed, recycled or composted. • Residual household waste will reduce by 10% per household. • By 2025, no more 2% of waste will be sent to landfill. • To develop the infrastructure to enable recycling of commercial waste.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Brighton & Hove The SCI sets out the minimum requirements for community involvement and The WMSP must meet the Consultations on the SA Statement of consultation on the planning documents that form the new Local Development requirements for formal should fulfil community Community Framework; to enable the local community to say what sort of place they want to consultation set out in the Town involvement requirements in Involvement (SCI) live in at a stage when this can make a significant difference. and Country Planning (Local the SCI. (BHCC, Sept 2006) Development) (England) States that ESCC will be preparing an SCI for involving interested parties in Regulations 2004. the WMSP and where joint consultation is undertaken the city council will work with the County to ensure consistency of approach.

Brighton and Hove Aims to improve the economic, social and environmental well-being of Brighton The WMSP need to take into The SA Framework should Sustainable Community and Hove. Eight priority themes: account the priority themes reflect those priorities Strategy: Creating the City of • Promoting enterprise and learning; identified in the Community identified. Opportunities (LSP, 2010) • Reducing Crime and Improving Safety; Strategy. • Improving health and well-being; • Strengthening communities and involving people; • Improving housing and affordability; • Living within environmental limits and enhancing the environment; • Promoting sustainable transport;and • Providing quality advice and information services.

Includes various targets including: • From a 2005 baseline, achieve a 12% reduction in city CO2 direct emissions by 2012/13, a 42% reduction by 2020 and an 80% reduction by 2050. • Promote and require sustainable practices, such as: reaching very good or excellent in the BREEAM or ecohome standard; using the construction phase to develop local skills and businesses; incorporating a high proportion ofAffordable housing and ensuring housing is accessible. • Use section 106 agreements to increase the number of apprenticeship and local employment opportunities. • Improve the physical environment, infrastructure and quality of life of residents. • Reducing the amount of waste produced per head. • Increasing the number of cycle trips in the city. • Increasing the number of passenger journeys made on local buses. • Narrowing the gap in life expectancy in the city. • Reducing the rise in obesity.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Brighton and Hove Local Vision: A cosmopolitan, successful city by the sea where people have a high Wider environmental benefits of Should take into account Plan quality of life in a decent environment. renewable energy installations need policies on sustainability and (BHCC, 2005) to be balanced against local impacts. environmental issues which Key Objectives: elaborate on national • Make the link between land use and transport, reducing need to Consider environmental impacts guidance. travel. of waste and minerals • Minimise environmental impacts and conserve, sustain and transportation. SA could include objectives enhance environmental assets and resources. on protecting and enhancing • Minimise the use of non-renewable resources and the production of the environment as well as waste, whilst maximising energy efficiency and promoting renewable achieving economic sources of energy. prosperity and social equity. • Maintain and enhance the natural environment, the Sussex Downs AONB and built heritage.

Relevant Policies TR16 Potential rail freight depot A potential site adjacent to Hove Station has been identified for transfer of waste onto the rail system. Planning permission will only be granted for developments that will not affect the use of this site, which will be protected until it has been appraised.

SU2 Efficiency of development in the use of energy, water and materials Planning permission will be granted for proposals which demonstrate a high standard of efficiency in the use of energy, water and materials. Proposals will be required to demonstrate that they incorporate the facilitation of the use of renewable energy resources and pay particular regard to provision of space and general facilities for refuse, waste recycling and composting.

SU13 Minimisation and re-use of construction industry waste Planning permission will be granted for developments which reduce the amount of construction waste. Proposals should show regard has been given to minimisation and reuse of construction waste by:

• Site selection and design, minimising excavation; • Re-use of buildings, increasing life-span of development; • Sustainable construction methods that minimise raw materials and maximise recyclable usage, incorporating waste material into development design.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA

Applicants will be expected to provide temporary on-site facilities for recovery, separation and processing of waste. Planning permission on developments not demonstrating effective waste minimisation to be refused.

SU14 Waste Management Large-scale developments are required to provide facilities for recycling or reuse of waste that staff and customers generate. Substantial new housing developments will need to include recycling facilities, in safe and convenient areas, for household waste.

SU16 Production of renewable energy Renewable energy installations will be permitted if they do not have a detrimental impact on the environment, nearby amenities and general character of the area.

EM12 Shoreham Harbour – mixed uses Planning permission will be granted for temporary Port related development and buildings for existing industrial users prior to the construction of a transport link provided they do not add to the environmental disadvantages suffered as a result of Heavy Goods Vehicle (HGV) traffic passing along the roads used for Port access.

Nature Conservation Policies NC1-4+6 Planning permission will not be granted for proposals within or in the setting of an existing or proposed site of international/ European/national importance/Local Nature Reserves (LNR)s/Site of Nature Conservation Interest (SNCI)s/Regionally Important Geological Sites (RIGS)/countryside/ downland where it is likely to have an adverse impact, directly or indirectly, on the nature conservation features of the site. Exceptions will be made in certain circumstances.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA

NC5 Urban Fringe Proposals within the urban fringe that comply with Policy NC6 will only be granted where they: • Make a positive contribution to the overall enjoyment of the countryside and integrate and enhance nature conservation features and secure environmental improvements; • Provide a sense of being in the countryside, improve landscape character and use materials in keeping with the special character of the area; and • Facilitate leisure, recreational use and public access to the countryside without increasing private motor vehicle traffic.

NC7 Areas of Outstanding Natural Beauty (AONB)s Development will not be permitted within or adjacent to the Sussex Downs AONB. Exceptions will be made where the proposal conserves and enhances the visual and landscape quality and character of the AONB and complies with Policy NC6; or it can be demonstrated that the development is in the public interest and that there are no alternative sites. Development will be required to keep adverse effects to a minimum and demonstrate positive environmental enhancements.

NC12 High grade agricultural land Development would not be permitted if it would result in the loss of best and most versatile agricultural land (grades 1, 2 and 3a) unless it can meet all of the following criteria: • An overriding need for the development • A lack of development opportunity in already developed areas • Little lower grade land with no environmental value.

PPS7 (2004) calls for consideration of other sustainability factors when determining planning applications including: accessibility to infrastructure; protection of natural resources; biodiversity; quality and character of landscape.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Brighton & Hove City Plan Part 1 The City Plan Part 1 sets out 23 strategic objectives in the following four themes: The City Plan should inform the SA objectives should reflect Submission (BHCC, 2013) • Strong and Prosperous City. WMSP in producing sustainable and not be in conflict with • A Sustainable City. aims and policies. the plans objectives. • An Attractive City. • Healthy and Balanced Communities.

The City Plan Part 1 aims to achieve the strategic objectives through delivery of the spatial strategy and the Development Area, Special Area and Citywide policies set out in the Plan.

The vision is summarized as follows: By 2030 Brighton & Hove will have sustainable, resilient low carbon economy with jobs at all levels. Local residents will have the skills to enable them to progress and live successfully in the city. New housing will be provided. The city will have made significant progress to becoming a resource efficient One Planet, Zero Carbon city, and be a city adapting well to climate change. The city will remain a safe and healthy place for residents, business and visitors alike with a high quality built environment and protected natural environment. Everyone has a right to a decent home, a good education, a job that pays a decent standard of living, good healthcare and to feel safe in their community. No one should be disadvantaged due to the neighbourhood they are born into.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Local Eastbourne Core Strategy The Vision: The Eastbourne Core Strategy SA objectives should reflect Local Plan (adopted) Feb should inform the WMSP in and not be in conflict with By 2027 Eastbourne will be a premier seaside destination within an enhanced 2013) producing sustainable aims and the plans spatial objectives. green setting. To meet everyone’s needs Eastbourne will be a safe, thriving, policies. healthy and vibrant community with excellent housing, education and employment choices, actively responding to the effects of climate change.

There are 10 Key Spatial Objectives which support the vision. These are based around the following themes:

1. Sustainable Development 2. Sustainable Growth 3. Town centre Regeneration 4. Local Economy 5. Tourism 6. Community Health 7. Green Space and Biodiversity 8. Sustainable Travel 9. Quality of the Built Environment 10. Sustainable Neighbourhoods

Hastings Local Plan, The Hastings Local Plan focuses on Economic Regeneration, Environmental The WMSP should encourage the As with all of the local plans, (Hastings Borough Council, Regeneration, and Integrated Transport objectives. re-use of redundant buildings, sustainability is the key driver 2004) maintain the amenity of High behind the aims and Most of the Local Plan policies are derived from county, regional and Weald AONB and seek objectives of the Hastings national policy so do not need to be repeated. Their objectives and opportunities for improvement to Local Plan. These should implications for the WMSP are covered elsewhere. the primary road and rail network. therefore be a key source for identifying SA objectives and There are no specific minerals or waste policies, objectives or aims. The Hastings Local Plan should possible indicators. inform the WMSP in producing sustainable aims and policies. Additional indicators: • The Green Network • Preserved woodland

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Hastings Development The vision for Hasting states that ‘By 2026 Hastings will be a safe and thriving place The WMSP should take account of The SA framework should Management Plan (DPD) to live in, that offers a high quality of life, and has a strong economy and sustainable the objectives outlined in the DPD reflect the relevant plan Proposed Submission (Nov future, founded upon our unique heritage and seaside location, and supported by social, i.e. using previously developed objectives. 2012) economic, cultural and environmental regeneration.’ land and promoting cultural heritage, historic buildings and To achieve the vision a number of strategic objectives (which are natural landscape. accompanied by ‘critical success factors’) including; • increased business activity, • identifying land that will support the needs and opportunities of businesses, • use previously developed land, • improvements in strategic transport infrastructure at a local, county and national level, • promote sustainable alternatives to the car, • improve the health and wellbeing of the population, and • promote, enhance and manage the town’s unique cultural heritage, historic buildings and natural landscape.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Lewes District Local Plan, The Plan aims to: reduce pollution, prevent loss of natural resources and create a The WMSP should incorporate the As with all of the local plans, (Lewes District Council, healthy, safe, and secure environment. sustainable development aims of sustainability is the key driver March 2003) the Lewes Local Plan. behind the aims and • To improve the range of employment opportunities and promote objectives of the Lewes local commerce and industry. The WMSP should consider District Local Plan. These • To reduce the growth in the number and distance of journeys made by maintaining the facility for should therefore be a key private car and encourage the use of more energy efficient and less receiving and processing sea source for identifying SA polluting modes of public and private transport. borne imported aggregates. objectives and possible indicators. The WMSP should clarify the Relevant Policies: situation with the Beddingham and SA framework should The Lewes Local Plan contains sustainable development policies on transport Glynde sites. include waste minimisation and accessibility, protecting and enhancing the environment and protection of objectives open space. As these policies are derived from county, regional and national planning policy, they do not need to be repeated. Indicators: • Employment Policy NH 24: • Distance and North Quay is identified in the adopted Minerals Local Plan as an area where number of journeys the retention and further development of facilities for receiving and of W&M vehicles processing sea borne imported aggregates would be supported. North Quay • Public transport use is also identified as a Minerals Consultation Area (MCA) where consultation • Areas of with the County Council is required on applications for development which established would sterilise important mineral facilities. character • Historic battlefields Beddingham and Glynde BG1 Land at Balcombe Pit • Archaeological Sites Allocated for development for: • Conservation Areas a) Business Uses (Use Class B1) b) General Industry (Use Class B2) Balcombe Pit is currently operational for the extraction of chalk, the Minerals Local Plan identifies the potential for an extension where it is not within the Sussex Downs AONB and has satisfactory access. If the chalk extraction is implemented it would not prejudice the business and industrial uses proposed in the District Local Plan.

Chailey Parish (Brickworks) Chailey Brickworks is an important established employer within the area.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Lewes District and South The vision for the Lewes District for the next 20 years is: The DPD should inform the SA objectives should reflect Downs National Park Authority • To enhance and maintain the District’s nationally and internationally WMSP in producing sustainable and not be in conflict with Proposed Submission (2013) important landscape, natural and historic environment. aims and policies. the plans objectives. • To ensure all communities are getting healthier and more prosperous by working to achieve vibrant, diverse, distinctive, safe and sustainable places to live.

• To minimise the impact of growth on the countryside and to prioritise development in urban areas. • To address the lack of access to facilities (for young people), the needs of an aging population, access to affordable housing, and deprivation on the coast.

The objectives that will deliver the vision are based around the following: • Maintain and enhance vibrancy, distinctiveness and diversity, ensuring high quality and well designed developments. • Promote and enhance natural and manmade environments. • Seek efficient and sustainable use of resources in development proposals. • Allow new development in the most sustainable locations. • Balance the need for housing and employment land and other development. • Provide an environment that stimulates sustainable economic growth. • Supply social and cultural infrastructure throughout the district to meet community needs. • Improve accessibility by public transport, walking and cycling. • Work with a range of housing providers and allocate sufficient land to create well designed housing (with appropriate size, type and tenure) to meet local housing needs. • Avoid development that would increase risk of flooding, coastal erosion, noise or pollution.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Rother District Local Plan, Vision: To provide a high quality of life based on vibrant and inclusive The WMSP should encourage As with all of the local plans, (Rother District Council, July communities, access to a wide range of jobs and respect for the built and renewable energy schemes and sustainability is the key 2006) natural environment. sustainable transport driver behind the aims and opportunities as well as the objectives of the Rother Relevant Policies: sustainable development criteria. District Local Plan. These The Rother Local Plan contains policies on encouraging renewable energy and should therefore be a key sustainable transport as well as a locally relevant set of criteria to promote Potential for increasing mineral source for identifying SA sustainable development. As these policies emanate from county, regional and landing and processing at Rye objectives and possible national planning policy, they do not need to be repeated. Harbour. indicators.

Rye Harbour Road Employment Area RY7 The vacant sites at Harbour Road, Rye represent a significant potential for further job creation. Proposals (Use Classes B1-B8) will be supported subject to improvements to the Harbour Road/A259 junction and implementation of the Tidal Walls Embankments flood alleviation scheme. Rother Core Strategy, Objectives: The WMSP should support Targets include no loss of Proposed Submission 1. Build more sustainable communities with a better balance regeneration and growth within semi-natural ancient (August 2011) between homes and jobs. the Plan Area. woodland, maintain air 2. Maintain character of settlements, their relationship between them quality within UK Strategy and with their landscape settings. for Air Quality targets, and 3. Promote economic regeneration and growth for the Hastings / recycle or compost 50% of Bexhill area. all waste by 2010. 4. Support the ‘market town roles and environmental qualities of Battle and Rye 5. Meet local need and promote vital, viable and mixed communities in the rural areas, whilst giving particular attention to the economic, ecological, public enjoyment and intrinsic value of the countryside.

Wealden District Local Key aims include: W&M development must not As with all of the local plans, Plan (non statutory) (Wealden Pursuing sustainable development looking to improve the quality of life and adversely affect the sustainability is the key driver District Council, December equality of opportunities for Wealden’s existing and future communities; environmental quality and behind the aims and 2005) character of the area. objectives of the Wealden • To recognise the need for development in the District to be balanced Local Plan. with the conservation and enhancement of the District’s These should therefore be a environmental quality and character. key source for identifying SA objectives and possible indicators.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Wealden District Core The vision: The Wealden DPD should inform SA objectives should reflect Strategy (Wealden District the WMSP in producing and not be in conflict with “By 2030 Wealden will have successfully accommodated growth to meet the Council, adopted November sustainable aims and policies. the plans objectives. future needs whilst protecting and enhancing its essential rural character and 2012) high quality environment and promoting the countryside as a resource for recreation and tourism. Its market towns will have been regenerated providing opportunities for residents to access suitable housing, local jobs, services, facilities and recreational opportunities and a number of its villages and rural settlements will have enhanced their sustainability through successful growth including provision of affordable housing.”

There are 15 Spatial Planning objectives which support the vision. These are based around the following themes: • Countryside resources and development of the rural economy whilst protecting biodiversity and geodiversity. • Protection of historic environment, heritage and cultural assets and encourage sustainable tourism. • Housing need and economic prosperity. • Viability of the 5 principle towns improving retail and service functions. • Learning needs and skills • Economic prosperity and employment opportunities. • Reduce the need to travel by car by centralising development. • Village networks. • Climate Change. • Flooding. • Open space, leisure and recreation facilities creating a network of green infrastructure. • Safety and levels of crime. • High quality, safe and attractive living environments • Maximise the use of previously developed land. • Identifying infrastructure requirements.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Sustainability Appraisal Objective 1 – To improve the health of people living and working in East Sussex and Brighton and Hove. National White Paper – Healthy This White Paper sets out a new public health system where responsibilities, Improving health must be a key The White Paper strengthens Lives, Healthy People. freedoms and funding will be devolved locally wherever possible, but consideration in the work of local the need for SA framework to (Department of Health, recognising that central government needs to lead on certain aspects including government and therefore must consider health improvement November 2010) serious unavoidable threats and emergencies, and ensuring that air, food and be embedded in other areas and protection. water meet safety standards. The new public health system will aim to including planning. protect and improve the public’s health, improving the health of the poorest, The future publication of fastest. the new Public Health

Policies within the WMSP must Outcomes Framework, The core elements of the new system will be set out in the forthcoming Health seek to protect and improve which will set high level and Social Care Bill. Subject to passage of this Bill, plans are to: health, including tackling health outcomes and indicators, • create Public Health England, taking on responsibilities from 2012, inequalities and promoting may be useful for including functions of Health Protection Agency, which will lead equality. monitoring purposes. health protection and public health work;

• transfer local health improvement functions to local governments and incentivise local governments to improve health and reduce health inequalities, in line with local needs; upper tier and unitary authorities will have a duty to take steps to improve health;

• give local government new functions to increase local accountability and support partnership working across other public sectors.

The plan recognises that health considerations are an important part of planning policy and that DCLG will consider how to take health forward in the new National Planning Policy Framework. It also supports planning policy that aligns social, economic, environmental and health priorities in one place.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Choosing Health: Making Main Objectives The White Paper builds upon the The White Paper provides a Healthy Choices Easier This delivery plan highlights how the DH and the NHS, within the framework Saving Lives Document and rationale as to why and how (Department of Health (DH), of government policies, will help more people make more healthy choices and further reiterates the requirement health may be integrated 2004) reduce health inequalities. It outlines clearly the priorities for delivery at to consult with individuals into wider decision making national, regional and local levels and what will be done by whom and when. responsible for the health and and also provides a HIA It brings into one place all of the actions on the White Paper commitments, wellbeing of local communities, target for NHS staff. As such alongside related Public Service Agreements and local targets to improve i.e. the relevant Primary Care there is both a requirement health. Trusts. and additional driver for NHS staff to participate and Broad Relevant Aims The White Paper further support the SA. The White Paper builds upon a number of UK Health policies including establishes the benefit of integrating elements of Health • Saving Lives: our healthier nation; Impact Assessment (HIA) into the • Independent Inquiry into Inequalities in Health (Acheson development and assessment of report); the WMSP to achieve the • The NHS Plan: a plan for investment, a plan for reform overarching goal of good health (Department of Health); for all. • Cross cutting Review on Health Inequalities (Department of Health); • Tackling Inequalities: a programme of action (Department of Health); • the Wanless Report: securing good health for the whole population (Wanless); and • the health and social care standards and planning framework: National Standards, Local Action (Department of Health).

Broad aims relevant to the WMSP reflect the requirement of local government, the NHS and wider partners to work together in facilitating healthier communities coupled with including health as a component in regulatory impact assessment through processes such as Health Impact Assessment.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Review of Environmental The Prime Minister's Strategy Unit, in its report "Waste not, Want not", The review provides a summary The SA is to provide and Health Effects of Waste recommended that an independent body should bring together the literature of the available evidence base and environmental criteria to Management: Municipal and evidence on the relative health and environmental effects of all the details the regulatory framework both meet the needs of Solid Waste and Similar different waste management options. governing the design and communities and protect Wastes (DEFRA, 2004) operation of waste management health. The subsequent review examines the waste management options for treating facilities currently in practice in municipal solid and similar waste. It focuses on the principal types of facilities the UK and Europe. Where appropriate, the SA that are currently used for dealing with such waste in the UK and in Europe will identify projects that and on what the currently available scientific evidence can tell us about their The overall conclusion is that well may require further environmental and health effects. run facilities, run to strict investigation as to both environmental standards do not perceived and actual risk to Main Objectives constitute a significant risk to health. The report’s conclusion is that on the evidence from studies so far, the health. treatment of municipal solid waste has at most a minor effect on health

particularly when compared with other health risks associated with ordinary The WMSP will follow the waste day to day living. management hierarchy of reduce,

Among the other conclusions to be drawn, the report shows that risks to reuse and recycle and where human health from incineration are small in comparison with other known appropriate apply the evidence risks, and acknowledges the role of incineration with energy recovery as a base encapsulated in the review to sustainable waste management option although the priority must be waste inform strategic decision making. minimisation, reuse and recycling. Where appropriate, the WMSP team will consult with the UK Broad Relevant Aims Health Protection Agency or The report provides local authorities with a summary of the current refer to current position evidence base to guide and support the task of approving planning statements on waste applications for new waste management facilities. management. Regional The South East England The South East Regional Health Strategy is part of a suite of regional strategies The strategy highlights the The SA should incorporate Health Strategy (Regional that make up the South East Regional Sustainability Framework. It builds requirement to investigate and elements of HIA and ensure Public Health Group, 2008) upon national and regional policies for improving health and reducing address existing health inequalities that inequality, sensitive inequalities. and sensitive receptors, coupled receptors and local Main Objectives with the benefits of establishing a circumstance are The core objective of the strategy is to ensure that other regional close,

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA policies and plans take account of health and health inequalities by addressing long lasting and mutually inclusive in the appraisal the following 5 key themes: beneficial partnership with local criteria supplemented with • reducing health inequalities; Primary Care Trust (PCT)s. PCT engagement. • promoting a sustainable region; • promoting safer communities; • increasing the positive relationship between employment and health; • improving outcomes for children and young people; and • improving outcomes in later life.

In each case, the strategy acknowledges the role and influence of the wider determinants of health in achieving good health and sustainable communities, and encourages the creation of an on-going dialogue among regional partners to create an environment which fosters innovative thinking and coordinated action to improve health and wellbeing in the South East.

Broad Relevant Aims Broad aims relevant to the WMSP include: • reduce health inequalities and raise life expectancy of the most social disadvantaged; • promote a vibrant healthy, safe and sustainable region to maximise peoples health; • increase the opportunities for a healthier and productive workforce; • promote physical activity and mental health and wellbeing of children and implement effective programmes to protect those most vulnerable to adverse health outcomes and hazards; and • improve the healthy life expectancy of older people and reduce inequalities.

The broad aims are followed by a number of specific objectives geared to prevent harm, maximise benefits and remove barriers to good socio economic and mental health.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Local Brighton and Hove 2020 In July 2004 Brighton & Hove was designated as a ‘Healthy City’ by the World The programme makes a local The SA should incorporate Community Strategy: Healthy Health Organisation, acknowledging the city’s strong political and partnership requirement to further investigate elements of HIA in the City Partnership & The commitment to reduce health inequalities and improve health for everyone. potential health outcomes and development of: Health Inequalities Strategy where possible to minimise risk • baseline information; Main Objectives and inequality and maximise • appropriate health benefits through processes appraisal criteria; The core objectives of the programme are to: such as HIA. and • improve and develop services that: provide high quality treatment and • engagement standards of care; The WMSP should integrate with relevant • focus on prevention and promoting health and well-being; elements of HIA at the earliest PCT. • deliver care in more local settings; and stage and ensure that local health • are flexible, integrated and responsive to people’s needs and issues and local circumstance are wishes. considered.

The programme recognises that achieving health for all is not just about Such a requirement should healthcare and that health depends upon a range of wider factors, including extend to all of the Plan Area. the quality of the environment, employment, housing, transport, crime, education and poverty.

Brighton & Hove's designation as a World Health Organisation Healthy City has established strong networks between the Council and PCT and has led to the integration of a local requirement for HIA through the Local Development Framework.

Broad Relevant Aims Broad relevant aims largely reflect the application of healthy urban planning principles to foster healthy and sustainable communities in Brighton & Hove.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Sustainability Appraisal Objective 2 – To protect the amenity of residents and neighbouring land uses.

Noise Policy Statement for Aims include: Ensure that noise implications are Noise impacts should be England (Defra 2010) Through the effective management and control of environmental, neighbour and taken into account when siting new considered in the SA and could neighbourhood noise within the context of Government policy on sustainable development. The cumulative be included within an objective development: impact of noise should also be taken relating to health. SA should into consideration. This should include a noise indicator. To avoid significant adverse impacts on health and quality of life; to mitigate and consider not only the existing sources minimise adverse impacts on health and quality of life; and where possible, to of noise but any combined impact contribute to the improvement of health and quality of life. sourced from a number of proposed sites in one area. The application of the Noise Policy Statement should mean that noise is properly Also, noise as a secondary impact taken into account at the appropriate time. The application of the NPS should (e.g. from increased traffic) should also ensure that noise is considered in alongside other issues and not in isolation. also be considered. Health policy Also, see Natural Environment White Paper – re: designation of space as “quiet should ensure assessment of noise open space”. takes place as part of any major scheme.

Noise Action Plan Brighton Identifies priority areas for action, based on the Defra Noise Mapping exercise. Relevant policies should reflect the The SA should ensure that the Agglomeration (2010) Predicts that households most effected by traffic noise are those closest to findings of the study. impacts of noise are considered London Road, Lewes Road and the seafront. under the health objective.

Sustainability Appraisal Objective 3 – To improve equality and access to sustainable waste management, and; Sustainability Appraisal Objective 4 – To minimise waste generation and disposal to land. Waste Framework Directive Aims to reduce landfill and associated greenhouse gas emissions through WMSP should reflect the SA should consider (2008/98/EEC) increasing waste prevention and recycling rates and encouraging use as a hierarchy set out in the objectives relating to secondary resource. Directive. provision of adequate Targets for recycling include: supply of suitable waste • 50% household waste recycled by 2020; and WMSP should ensure sufficient facilities, to reduce waste • 70% construction & demolition waste recycled by 2020. facilities are provided so targets and to reduce waste sent to can be met. landfill.

Hazardous Waste Directive Aims to safeguard to the environment through high levels of protection. The WMSP should adhere to Objectives should reflect (1975, amended 1991/689/EEC) differentiation it introduces between hazardous and non hazardous waste is requirements of the Directive as requirements of Directive. laid down in the Waste Framework Directive. appropriate. No specific targets as such.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Waste Incineration Directive To prevent or to limit as far as practicable, negative effects on the Appropriate pollution SA should consider (2000/76/EC) environment, in particular pollution by emissions into air, soil, surface water prevention criteria should be including objectives that and groundwater and the resulting risks to human health, from the adopted by the WMSP to assess protect the environment, incineration and co-incineration of waste. potential locations for new soil, air and water from the waste incineration facilities. impacts of development. The Directive sets out limit values for emissions to atmosphere and technical operating requirements. Waste Electrical and Electronic • This Directive compliments other European Union measures on landfill Plan will need to consider the SA objectives should Equipment (WEEE) Directive and incineration of waste, aims to reduce the quantity of waste from potential requirements for consider the need to increase 2002/96/EC electrical and electronic equipment and increase its reuse, recovery collection, storage, and re-use, recycling and (European Commission, 2002) and recycling. Relevant equipment includes household appliances, IT processing of WEEE waste. recovery of WEEE waste. and telecoms equipment, audiovisual equipment (TV, hi-fi, video), lighting, electrical and electronic tools, toys, leisure and sports Plan will need to provide criteria equipment. for determining the suitability of • Producers of electrical equipment will be responsible for taking back potential locations for and recycling electrical and electronic equipment. This will provide management of WEEE waste. incentives to design electrical and electronic equipment in an environmentally more efficient way. Consumers will be able to return their equipment free of charge. In order to prevent the generation of hazardous waste. • Sets conditions for pollution prevention and control at waste treatment facilities. • UK target of an average rate of collection of 4kg per householder per year. • Site for managing WEEE waste must have appropriate permits.

• Linked to the WEEE Directive is Directive 2002/95/EC which aims to limit the environmental impact of electrical and electronic equipment when it reaches the end of its life. It requires the substitution of various heavy metals (lead, mercury, cadmium, and hexavalent chromium) and brominated flame retardants (polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE)) in new electrical and electronic equipment put on the market from 1 July 2006.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA EU Thematic Paper: Taking Main elements of the proposed new strategy: WMSP should consider potential SA objectives should sustainable use of resources of waste as a resource. It should include waste minimisation, forward: A Thematic Strategy • Life-cycle approach: The strategy proposes to look beyond the support waste minimisation and recycling and recovery. on the prevention and pollution caused by waste to consider its potential contribution to a maximising recycling. recycling of Waste (EU more sustainable use of natural resources and raw materials. This Commission, 2005) aspect is dealt with in a separate strategy on the sustainable use of natural resources. • Prevention: Member states will be required to develop waste prevention policies that will "reach out to the individuals and businesses" responsible for waste generated in the first place. These will have to be adopted within three years following the adoption of the revised waste framework directive. Follow-up reports will have to be submitted every three years afterwards. • Recycling: EU-wide environmental standards on recycling will be adopted to "support the development of an EU market for secondary (recycled) materials." • Simplifying existing legislation: This is also a major priority which will apply along the principles of the Commission's 'better regulation' initiative.

Targets: The new strategy does not impose specific waste recycling or prevention targets. The Commission therefore says it is "not expected to result in any quantifiable financial costs" on member states and businesses.

• Incineration: A revision of the IPPC Directive (Integrated Pollution Prevention and Control) will be tabled that will set "an ambitious benchmark" to improve energy recovery from municipal incinerators. The Commission says the new energy efficiency benchmark "will determine whether an incinerator can be identified as a recovery facility instead of a disposal facility.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA PPS 10: Planning For • Gives emphasis to the principles of: driving waste management Plan should promote reduction, SA should include Sustainable Waste up the waste hierarchy; self-sufficiency; and the proximity reuse and recovery of waste in objectives that: Management principle. accordance with the waste • support increasing (ODPM, 2005) hierarchy, as well as providing the reduction, reuse, • Places requirement on regional bodies to collate data on certain facilities for disposal. recycling and waste streams. recovery of waste. • Requires Regional Planning Bodies to account for the waste Plan should identify sites for • seek to protect management needs of an area and the number/type of facilities that waste management to enable net the will be needed to provide a treatment and disposal options for regional self-sufficiency, and to environment waste Implement waste strategies to guide waste management meet the needs of local from solutions for an area. communities. development. • Development of facilities for the recovery or disposal of waste should • protect and enhancing not harm human health or the environment. Brings in the requirement of SA biodiversity. • Is focused on working with communities and informing on waste instead of BPEO for assessing the solutions for their area. suitability of sites and waste management options.

PPS 10 Companion Guide Setting PPS 10 in wider spatial planning context Guidance on issues at local level, Provides an overview of the (DCLG, 2006) • Delivery of key principles of PPS10; including the content of core principles of sustainability • Gives guidance on how RSS and LDD need to work together; strategy and the allocation of sites appraisal in waste planning • Gives guidance on the collection and use of data, its sources and and areas for waste management and approaches to methods of data collection and forecasting future trends; facilities. stakeholder involvement • Decision making supported by SA, gives guidance on the role and the and participation approach to monitoring and regular review to ensure the content of RSS and LDD; and • Planning for waste management on regional level; planning for facilities of national, regional or sub-regional significance. Update to PPS10 – Waste The changes to PPS10 are to paragraph 1 and Annex C. It will ensure that local WMSP should incorporate the SA objectives should reflect Hierarchy (March 2011) authorities have regard to the hierarchy in the preparation of their waste plans. changes made to PPS10, and the change made to PPS10. The revised Directive seeks to increase the use of waste as a resource (e.g. for continue to support the aims of fuel) and to place greater emphasis on the prevention and recycling of waste, moving management of waste up while protecting human health and the environment. It includes a new waste the hierarchy. hierarchy which differs from the existing hierarchy in how it defines re-use of materials and in how it distinguishes between recycling and other recovery.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Waste Strategy for England Aims to move waste up the waste hierarchy. Targets for WMSP should support strategy SA framework should reflect 2007 (Defra) municipal waste: aims to move waste up the waste the priorities identified in By 2010 = 40% recycling & composting By 2015 hierarchy and reducing waste sent the Strategy for reducing = 45% to landfill. waste sent to landfill, and for By 2020 = 50% increasing recycling/composting rates. For commercial and industrial waste, target to reduce waste sent to landfill by 20% by 2010 (compared to 2004 levels). For construction and demolition waste, target to halve waste going to landfill by 2012.

• Identifies energy from waste as essential component of a well- balanced energy policy. • Waste infrastructure delivery programme – will provide support to LPAs through PFI and other sources.

• Prefers anaerobic digestion for food waste. • Highlights need for culture change and consumer and producer responsibility.

Draft Waste Regulations 2011 The draft regulations is based around the following chapters: WMSP should ensure that the The SA framework should (England and Wales) February proposed regulations are ensure it meets with the • Waste Prevention Programmes; 2011 complied with in full. proposed regulations. • Waste Management Plans; • Duties in relation to waste management and improved use of waste as a resource.; • Duties of planning authorities; • Deposits in the sea; • Registration of carriers, brokers and dealers; • Transfer of waste; • Enforcement; and • Final Provisions.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA National Policy Statement The Government’s vision for the water sector and some of the steps required WMSP should support SA framework should (NPS) Waste Water (DEFRA) to achieve this vision by 2030 are set out in the Future Water strategy paper statement in relation of waste reflect the priorities Feb 2012 which was published in February 2008. The government plans the following water. identified in the statement. for the water industry:

Sustainable Development – to seek waste water infrastructure that allows us to live within environmental limits and that helps ensure a strong, healthy and just society;

Public health and environmental improvement – to continue to meet our obligations under the Urban Waste Water Treatment Directive15 by providing suitable collection and treatment systems to limit pollution of the environment;

To improve water quality in the natural environment and meet our obligations under related European Directives, such as the Habitats Directive16, the Water Framework Directive17 and its Daughter Directives;

To reduce water consumption by households and industry which will have the knock on effect of reducing waste water production and therefore demand for waste water treatment infrastructure;

To reduce demand for waste water infrastructure capacity by diverting surface water drainage away from the sewer system by using Sustainable Drainage Systems (SuDS);

Climate change mitigation and adaptation – in line with the objectives of Defra’s mitigation and adaptation plans to help deliver the UK’s obligation to reduce greenhouse gas emissions by 80% by 2050 and work to carbon budgets stemming from the Climate Change Act 2008, within the context of the EU Emissions Trading System. Also to ensure that climate change adaptation is adequately included in waste water infrastructure planning; and

Waste Hierarchy – to apply the waste hierarchy in terms of seeking to first reduce waste water production, to seek opportunities to re-use and recycle resources and to recover energy and raw materials where possible.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA National Waste Strategy Principal Challenges to realise long term vision of a green, zero waste WMSP should support strategy SA framework should reflect (Defra, 2011) economy include: aims to move waste up the waste the priorities identified in the hierarchy and reducing waste sent review for reducing waste • Preventing waste wherever it occurs to landfill. sent to landfill, and for • Helping the community to develop and deliver local solutions for increasing collecting and dealing with waste from households and businesses. recycling/composting rates.

• Increase of recycling of waste from households and businesses.

• Approach to extracting recyclables from waste, generates high quality material to meet needs of reprocessors.

• Interface between EFW policies, RE targets, and delivering on climate and broader environmental needs.

• Reduce landfill (especially biodegradable waste).

• Effective approach reducing waste crime, reducing harm to the environment, human health, local communities and businesses.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Municipal Waste There are a number of broad objectives. These can be summarised as: The WMSP provides the planning MWMS and WMSP SAs Management Strategy • Moving management of waste up the waste hierarchy by framework by which the facilities should be consistent and (County Council and all reducing and reusing more and disposing of less. to manage Municipal Solid Waste objectives should not be in District Councils in East • Avoiding endangering human health and harm to the environment. (MSW) are delivered. As such conflict. The MWMS SA Sussex, 2006) • Promoting the proximity and self sufficiency principles. there needs to be consistency provides potential sources • Avoiding disposal of waste to landfill. between the WMSP and the of information for the • Improving waste services by meeting waste legislation, MWMS where relevant. WMSP SA baseline data. requirements, technologies and opportunities.

Targets: 1. Reduce growth in household waste from 2.7% per year in April 2005 to 2.4% per year by April 2009. 2. Amount of household waste arising per head. 3. Each council will aim to achieve, and where possible exceed, the statutory standards set by government for recycling household waste in financial year 2007/ 2008. These are: • Eastbourne 20% • Hastings 20% • Lewes 27% • Rother 24% • Wealden 24% • East Sussex County Council 27% 4. The councils will collectively achieve a minimum 30% recycling of household waste by 2008/09, aiming for 33% by 2010 in line with the Waste Local Plan. 5. Together, the councils will aspire to be in the top quarter of English authorities for recycling / composting by 2010. 6. individual boroughs and districts will aspire to collect the following numbers of recyclables from householders by 2010: • Eastbourne – 6 • Hastings – 3 • Lewes – 6

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA • Rother – 3 • Wealden – 4 7. Conduct surveys of public participation in recycling services. 8. The councils will collectively aim to achieve at least: • 45% recovery of waste (recycling and energy recovery) by March 2009, • 50% by March 2011 • 67% by March 2016 9. The councils aim to reduce the amount of biodegradable waste we landfill to meet the yearly allowances set by Government and allocated to East Sussex County Council. Key targets are to reduce the amount of biodegradable waste we landfill to: •  102,000 tonnes by 2009/10 •  68,000 tonnes by 2012/13 •  47,500 tonnes by 2019/20

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Brighton & Hove Municipal Sets out a strategy focusing on how performance can be improved. The WMSP needs to reflect the SA including objectives Waste Management Strategy objectives and aims set out within should reflect the strategy. (Brighton & Hove, 2010), Objectives: the strategy. • reduce the overall volume of household waste generated and maximise re-use, recycling and recovery of the waste that is produced; • send as little waste as possible to landfill; • ensure compliance with all legal requirements relevant to waste management, and enforce these fairly and consistently; • protect the environment and enhance its quality locally; and • improve our service to residents and our engagement with residents and businesses while ensuring services continue to improve and represent value for money for council tax payers.

Policies: 1. Service quality and engagement with residents, businesses and communities 2. Waste minimisation and prevention 3. Increasing rates of re-use 4. Increasing recycling rates 5. Increasing composting rates 6. Residual waste 7. Waste from businesses and other organisations

Strategy Targets: Recycling and Composting: 2007/08 = 28.5%, 2020/21 = 45% Energy Recovery 2007/08 = 11%, 2020/21 = 53% Landfill 2007/08 = 60.6%, 2020/21 = 2%

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA East Sussex and Brighton Now mainly superseded by the Waste & Minerals Local Plan 2013, however These policies will be No impact. & Hove Waste Local Plan the following policies are saved until adoption of the Site Allocations DPD: reviewedduring the Site (East Sussex and Brighton & • WLP7 – Site Specific Allocation for Road to Rail Transfers, which Allocations DPD preparation Hove, Adopted 2006) Saved identifies Sackville Coalyard, Hove. process. Policies Only • WLP8 – Site Specific Allocation for Material Recovery Facilities / Waste Transfer Stations, which identifies sites at: o -Hangleton Bottom; o -Hollingdean Depot; o -Bellbrook Industrial Estate; o -Land at Tutts Barn; and o –Pebsham. • WLP9 – Site Specific Allocation for Energy from Waste and Materials Recovery Facilities at North Quay. East Sussex, South Downs and Sets out planning policies for the sustainable management and disposal of all Site Allocations DPD must ensure SA objectives should consider Brighton & Hove Waste and types of waste generated in the Plan Area up to 2030. Sets the policy that the aims and objectives of the the need to increase reuse, Minerals Local Plan (2013) framework to enable the Authorities to judge the acceptability of applications Local Plan can be met, through recycling and recovery of for planning permission. provision of sufficient types of waste, and the types of facilities to meet the need facilities that will enable these Overall, the vision for the Plan Area is to reduce the environmental footprint, identified in the Plan, in particular types of waste management. particularly greenhouse gas emission associated with the production and facilities associated with reusing, SA objectives should also management of waste and minerals. recycling and recovering energy consider the need to protect from waste. communities, the natural and The Plan seeks to reduce waste arisings, and to reuse, recycle or recover historic built environment from energy from waste, and dispose of the least possible amount of waste. development. Sustainability Appraisal Objective 5 – To ensure the most sustainable use of minerals resources. Planning and Minerals: To be read alongside MPS1. Provides examples and principles of good practice This advice needs to be Further indicators for the SA Practice Guide (DCLG, and background information to assist MPAs in preparing WMSP and considered and reflected in the may come to light once the 2006) determining planning applications. WMSP where appropriate. advice is considered further.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA MMG 1 – Guidance on the MMG1 sets out the Government’s policies and procedures on the extraction of The WMSP should acknowledge SA should include objective Extraction by Dredging of minerals by dredging from the seabed in English marine waters. the contribution of marine sand to increase marine dredging Sand, Gravel and Other Marine sand and gravel makes an important contribution to meeting the and gravel and contain policies in where environmentally Minerals from the English nation’s demand for construction aggregate materials. It is particularly respect of wharves and other acceptable to reduce need Seabed important in London and the South East of England, where it accounts for associated shore based facilities. for land won aggregates. (ODPM, 2002) almost a third of the total regional demand for sand and gravel. Using marine sources reduces the pressure to work minerals on land where resources are constrained in areas of agricultural, environmental or development value. As dredged material can often be landed close to the point of demand, this can also secure an environmental advantage by reducing the need for onward transport on the road network. The extraction of marine minerals has the potential to impact unacceptably on the coastal environment, commercial fisheries, marine ecosystems, navigational routes, wrecks and other archaeological remains and other uses of the sea. It is therefore important that dredging is only undertaken at locations and in ways that do not have unacceptable impacts. MPG8 Interim Development MPG8 provides advice on the implications of the Planning and Compensation The registration process Objectives and indicators to Order Permissions – Statutory Act 1991 for the regularisation of old minerals permissions. It outlines the legal envisaged by the 1991 Act has in reflect the guidance. Provisions and Procedures requirements for registration of old permissions in order to secure their many cases progressed. (DoE, 1991) continuing validity, and the criteria applicable. Further advice on the Nevertheless consider making conditions which might be imposed on such continued permissions, to ensure references to the legislation in the that the operational standards are brought up to modern environmental WMSP. requirements, are contained in MPG9.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA MPG9 Interim Development MPG9 provides advice on the considerations when setting conditions on old The registration process Objectives and indicators to Order Permissions – minerals permissions to provide proper environmental protection, and to envisaged by the 1991 Act has in reflect the guidance. Conditions (DoE, 1991) ensure that future working is carried out to an acceptable environmental many cases progressed. standard. Nevertheless consider making references to the legislation in the In all cases, it will be necessary, to identify sensitive property and areas which WMSP. are, or could be, adversely affected by the development and to seek ways in which the impact can be mitigated or avoided - for example, through the provision of buffer zones and/or baffle mounds, or restrictions on working hours and/or appropriate noise limits. Particular attention should be given to areas of environmental or ecological importance such as National Parks, AONBs, National Nature Reserves, SSSIs, features of archaeological interest and the built heritage; and, to the proximity of residential or other sensitive property such as schools and hospitals. Consideration should also be given to the need to avoid adverse effects on the quality or quantity of groundwater resources where these are particularly vulnerable or in short supply. 'National and Regional The guidelines set out figures for land-won aggregate provision, making The Plan will need to assess how Objectives will need to Guidance for Aggregate assumptions on the expected level of supply from marine sand and gravel, the apportionment figure for reflect the requirement Provision in England 2001- alternatives and net imports. They are to be used in the preparation of Local land-won aggregates (arising of the MPA to provide 2016, ODPM (2003)' Development Frameworks. from the guidelines) can be for the apportionment provided for in the Plan Area. If figure for land-won Following their publication the regional guidelines have now been new extraction sites appear sand and gravel. apportioned by the Regional Planning Bodies (RPBs) to mineral planning necessary then their acceptability Though this may authority areas, taking into account the advice of the Regional Aggregate will need to be tested through the conflict with other Working Parties (RAWPs) and the likely environmental impacts of the preparation of the Minerals sites objectives. implied extraction. DPD. The SA will help to test MPAs are to take account of the relevant sub-regional apportionment in The expectations on the level of the feasibility of development documents within draft Minerals Development Frameworks aggregate supply from other meeting the (MDFs). sources, including marine and apportionment recycled materials, also need to be particularly within The guidance states that the development plan (and RSS) process(es) will examined in the local context acceptable provide full opportunity for public participation in the testing of the regional during the DPD preparation environmental means. and sub-regional guidelines. process.

The guidelines will be monitored nationally by the Government.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA National and Regional Changes between the guidelines for England published in 2003 and the new The WMSP will need to reflect the Objectives and indicators to Guidelines for Aggregates guidelines show an overall fall in national demand for aggregates and an changes in aggregates provision reflect the guidance and Provision in England 2005 – increase in use of alternatives to primary aggregates, notably construction and as per the revised guidelines. principles. 2020, demolition waste. In the guidelines published in June 2003 the target for use of CLG (2009), secondary/recycled materials in England was 60 million tonnes per annum by 2011. The guidelines in the present paper assume the revision of the target to 65 million tonnes per annum by 2015. English Nature Policy English Nature, guided by the principles of sustainable development, will Ensure all possible Objectives and indicators to Position Statement: Aggregate work with MPAs to ensure that the country’s terrestrial and marine aggregate environmental implications of reflect the guidance and Extraction and Nature resources are won in a way that does not diminish the quality and diversity of mineral extraction are taken into principles. Conservation (English England’s natural environment. English Nature: account and their impact Nature, 2002) • Acknowledges the vital role of the aggregates industry in supplying mitigated as far as is feasible. minerals needed by local and national economies. • Will work in partnership with Government, the aggregates industry, MPAs and conservation groups, to ensure that demand for aggregates is minimised so far as possible and that aggregates are won with least harm to the natural environment. • Believe that industry and planners must, in the location, working and after use of extraction sites, take full account of important areas for nature conservation and seek measures to minimise the adverse environmental impacts of extraction. Impacts include the loss or disturbance of important wildlife habitats or geological features, pollution, noise, infrastructure impacts, and changes in water systems. English Nature Policy English Nature recognises the benefits of non-aggregate rocks and minerals Ensure restoration and Objectives and indicators to Statement: Non- aggregate to the national chemical, energy and construction industries. However, remediation of sites is carried reflect the guidance and Mineral Extraction mineral extraction to provide these needs can and often does have serious out to achieve the maximum principles. (English Nature, 1997) impacts on the natural environment; English Nature: environmental and nature • aims to work with MPAs to minimise the impacts and maximise the conservation benefits. nature conservation benefits which can arise from mineral extraction. • considers that mineral deposits should be worked within the principles of sustainability, integrating extraction with care for the natural environment. Mineral extraction should operate within wider efforts to maintain the natural environment and should look to ensure wise use of the finite minerals resource.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Mineral Safeguarding in In the past there have been many instances where mineral resources have been The Sites DPD will need to take on SA objectives should England (Good Practice Advice needlessly sterilised by non-mineral development. MPAs must now set out board the guidance to ensure that include the effective (BGS/Coal Authority) 2011 Mineral Safeguarding Areas and Mineral Consultation Areas. resources are safeguarded and safeguarding of mineral sterilization is avoided. resources. The guidance puts forward a methodology for determining MSAs, together with policies through which they would have effect. In particular the sites DPD will SA indicators should Steps set out as follows: need to consider the steps include an assessment of the 1. - Assess what is the best geological and resource information for suggested for identifying MSAs impact on mineral the authority area (and MCAs) and include them resources. 2. - Decide which minerals in the area need to be safeguarded where relevant. and decide the physical extent of the the safeguarded area 3. – Consult on proposed MSA 4. Decide on approach to safeguarding for Core Strategy / Local Plan 5. Include mineral assessments in local lists of information requirements 6. Include safeguarding at district level DPDs 7. – Include development management policies in a DPD

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Partial Review of the Partial aggregate review: The WMSP should plan to meet The objectives and Regional Spatial Strategy for Current apportionment in the South East Plan Policy is based solely on the the revised apportionment. indicators within the SA the South East (Review of historic production (sales) of materials. Revised apportionment is based on should reflect those Policy M3 – Primary land- where future demand and where aggregate resources are located, and are within the partial review won aggregates and sub- relatively unconstrained by national conservation or heritage designations. of policy M3. regional apportionment (Consultation March 2009) Policy M3 (Primary Aggregates) within the South East Plan proposes that the region’s MPA’s should plan to provide for a smaller amount of aggregates in the future. It should be noted that the South East total apportionment has decreased by 4.26 million tonnes per annum (mtpa) from 13.25 to 9.01 mtpa. With the exception of 3 mineral planning authority areas, all apportionment has decreased. East Sussex / Brighton & Hove (along with the Isle of White and Milton Keynes, although neither as much as East Sussex and Brighton & Hove) has increased.

The policy previously required that East Sussex / Brighton & Hove to provide 0.01 mtpa. This is now proposed to increase to 0.06 mtpa making the total 0.07mtpa.

The sub-regional apportionments for both sand and gravel, and for crushed rock, will be subject to testing of deliverability in the preparation of minerals development documents, including through sustainability appraisal.

The County Council supports the sub-regional allocation of 0.07 mtpa and would object to any changes to this allocation. The proposed separate split for soft sand and is also not supported. (Note that the examination in public is due to take place in October 2009). East Sussex and Brighton The majority of the policies have been replaced by the 2013 Waste & Minerals The Site DPD should ensure review of SA should include & Hove Minerals Local Plan Local Plan, however the following policies have been saved until they are these policies. in view of current consideration of impacts on (November 1999) replaced by the Site DPD: local needs and in respect of all environmental Policy 3 – Sites for provision of sand and gravel changes in local constraints. designations and sensitive SAVED POLICIES ONLY Policy 4 – Preferred Areas of search uses within the Plan Area. Policy 32 – Safeguarding Policy 36 – Review of sites

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Sustainability Appraisal Objective 6 – To maintain and improve water quality. Urban Waste Water Treatment Main objective is to protect the environment from the adverse effects of WMSP must adhere to the SA should consider Directive (1991/271/EEC) urban waste water discharges and discharges from certain industrial sectors requirements of the Directive objectives relating to and concerns the collection, treatment and discharge of waste water. and ensure effective water quality. management of urban waste water treatment. Water for Life (Defra 2011) The proposals set out in the White Paper introduce a new approach to water Plan should seek to protect SA framework management, with the aim of stabilising consumer bills, protecting water water resources and reduce should seek to protect resources, and ensuring water companies are as efficient as possible. The water consumption. water quality and white paper aims to: promote reduction of Explains how the government will improve the condition of rivers by water consumption. encouraging local organisations to improve water quality and make sure water is extracted from the environment in the least harmful way; Announces plans to reform the water industry and deregulate water markets to drive economic growth; Enables business and public sector customers to negotiate better services from suppliers and cut their costs; Removes barriers that have discouraged new entrants from competing in the water market; Asks water companies to consider where water trading and inter-connecting pipelines could help ensure secure water supplies at a price customers can afford; Enables water companies to introduce new social tariffs for people struggling to pay their bills and seeks to tackle bad debt.

Underground/underthreatGro The Environment Agencies Core Groundwater Policy is: The discharge of waste and SA should include undwater protection: policy “To protect and manage groundwater resources for present and future generations in wastewater into the ground is an objective to protect ways that are appropriate for the risks that we identify.” and practice, (Environment activity that the WMSP should ground water. “prevent” or “limit” in East Agency, 2006) “Preventing pollution (the “prevent or limit” approach) is by far the most Sussex and B&H. sustainable and cost-effective way of maintaining good groundwater quality.”

Activities that put groundwater at risk: • Discharge of waste and wastewater onto or into the ground. • Civil engineering, mining, urban development and quarrying.

The demand for water from industry has fallen. Increasing urban development threatens groundwater resources by increasing the rate at which water enters river systems. This can lead to flooding problems.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Future Water: The The strategy sets out government’s overall vision and key priorities for water. WMSP should include measures SA should incorporate Government’s Water Strategy The vision includes: which support and contribute to priorities into SA • achieving the strategy’s vision for England (DEFRA, 2008) improved quality of our water environment; framework. • sustainably managed risks from flooding and coastal erosion; and key priorities. • sustainable use of water resources; • cutting greenhouse gas emissions; and • continuous adaptation to climate change. River Basin Management The Plan has been prepared under the Water Framework Directive. It WMSP should take into account The SA framework should Plan South East River Basin describes the river basin district and the pressures the water environment the objectives of the River Basin seek to maintain and District. Environment Agency faces. Under the Water Framework Directive all EU countries are required to Management Plan and therefore improve water quality. Dec 2009 manage the water environment to consistent standards, namely, to; include measures which support Indicators of water quality • prevent deterioration in the status of aquatic ecosystems, protect and contribute to halting the should be linked to the River them and improve the ecological condition of waters deterioration of aquatic Basin Management Plan’s • aim to achieve at least good status for all waters by 2015. ecosystems, and ensures no targets. • Where this is not possible, good status should be achieved by 2021 or deterioration in the status of 2027 Water Framework Directive • promote sustainable use of water as a natural resource water bodies and contributes to the achievement of good status. • conserve habitats and species that depend directly on water • progressively reduce or phase out the release of individual pollutants or groups of pollutants that present a significant threat to the aquatic environment • progressively reduce the pollution of groundwater and prevent or limit the entry of pollutants • contribute to mitigating the effects of floods and droughts.

The current status classification of the water environment has been updated since the draft plan to: • 19% of surface waters at good or better ecological status • 40% of assessed surface waters at good or better biological status • 88% of assessed surface waters at good chemical status • 19% of surface waters at good overall status • 43% of groundwater bodies are at good quantitative status • 63% of groundwater bodies are at good chemical status • 33% of groundwater bodies are at good overall status The Plan includes section on the responsibilities of local authorities, specifically relating to spatial planning.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA River Basin Management Under the Water Framework Directive all EU countries are required to WMSP should include measures The SA framework should Plan: South East River Basin manage the water environment to consistent standards, namely, to; which support and contribute to seek to maintain and • halting the deterioration of District (Environment prevent deterioration in the status of aquatic ecosystems, protect them improve water quality. aquatic ecosystems, and Agency, December 2008) and improve the ecological condition of waters. • aim to achieve at least good status for all waters by 2015, where this is improvement in the status of not possible, good status should be achieved by 2021 or 2027. water bodies. • promote sustainable use of water as a natural resource. • conserve habitats and species that depend directly on water. • progressively reduce or phase out the release of individual pollutants or groups of pollutants that present a significant threat to the aquatic environment. • progressively reduce the pollution of groundwater and prevent or limit the entry of pollutants. • contribute to mitigating the effects of floods and droughts.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Sustainability Appraisal Objective 7 – To seek the protection of and sustainable use of water resources, and; Sustainability Appraisal Objective 8 – To reduce risk and impact of flooding. Flood & Water Management The Act takes forward a number of recommendations from the Pitt Review The WMSP should include The SA Framework should Act 2010 into the 2007 floods and places new responsibilities on the Environment measures to reduce flood risk and include objectives that seek HMSO 2010 Agency and local authorities (among others) to manage the risk of flooding. must take into account the to reduce flood risk. Environment Agency’s National The Environment Agency will be required to develop a national strategy for Strategy, once produced. the management of coastal erosion and all sources of flood risk for England.

Lead local flood authorities (unitary and county councils) will be required to develop, maintain, apply and monitor a strategy for local flood risk management in its area. Local flood risk includes surface runoff, groundwater, and ordinary watercourses (including lakes and ponds).

Lead local flood authorities will also have a duty to investigate flooding incidents in its area and to maintain a register of structures or features which they consider to have a significant effect on flood risk in their area.

The Act places a duty on a relevant authority to co-operate with other relevant authorities in the exercise of their flood and coastal erosion risk management functions.

The Act establishes a SuDS Approving Body (the “SAB”) at county or unitary local authority levels. The SAB would have responsibility for the approval of proposed drainage systems in new developments and redevelopments. Approval must be given before the developer can commence construction and the proposed drainage system would have to meet new national standards for sustainable drainage.

The Act will need to be commenced by ministerial order before it comes into effect.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Water for people and the The strategy sets out the pressures facing the water environment and advocates Brighton & Hove and East Sussex The SA Framework should environment: Water numerous actions which will help to ensure that the aims and vision of the are located within an area where include objectives which Resources Strategy for strategy will be met. The overall strategy aim being: “A better place for people water resources are under pressure. seek to maintain and England and Wales. Env and wildlife for present and future generations”, within this the vision being for The WMSP should include improve water quality, and Agency 2009 there to be enough water for people and the environment, meeting legitimate measures which will help achieve protect water resources. needs. the strategy’s aims. Development There are four key aims: Management policies should • Adapting to & mitigating climate change – to manage water include measures to reduce water resources and protect the environment in the face of climate change. usage in new development to levels • A better water environment – species and habitats that above those required by Building depend on water are restored, protected, improved and valued. Standards, aspiring to water • Sustainable planning and management of water resources – good neutrality in addition to requiring water management contributes to sustainable development by SuDS. supporting people and the economy in an improved environment. • Water and the water environment are valued – people value water Wastewater should be recognised and enjoy their water environment and understand how it contributes as an important resource of water, to their quality of life. which can be used to support the water environment and sustain downstream abstractions. The Key actions for local authorities to consider include: location of the point of discharge • Require sustainable drainage schemes in all new is key to the ability to re-use this developments; resource and may be a • In areas where water resources are under pressure: include consideration in site searches. measures that support water neutrality in new development and require developers to produce water cycle studies; and • Adopt water efficiency standards in planning conditions that are tighter than buildings regulations.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Shoreline Management Plan Non-statutory policy document for coastal defence management planning. Hold the line policy will maintain SA to include coastal South Foreland to Beachy nd Promotes management policies for a coastline into the 22 century, to achieve existing buildings, landscape and protection related objectives. Head, First Review, Final long-term objectives, while being technically sustainable, environmentally land-use.

Report (SDGE, 2006) acceptable and economically viable. Any additional facilities or Objectives: change in extraction levels in • To define the flooding and erosion risks to people and the these areas should take into account environmental and traffic developed, historic and natural environment within the SMP area impacts. over the next century. • To inform planners, developers and others of the risks identified within Rye - Storm beach gravel the SMP and preferred SMP policies when considering future deposits. development of the shoreline and land use changes.

Policy Unit 4c17: River Rother Hold the Line Provide continued flood protection and ensure ongoing operability of Rye Harbour. Relates to Port of Rye 15A Newhaven Harbour Hold the line to protect existing port development.

9B Shoreham Harbour Mouth to Aldrington Hold the Line to protect existing port infrastructure and development.

Shoreline Management Plan The review was commissioned to take account of : Hold the line policy will maintain SA to include coastal Beachy Head to Selsey Bill existing buildings, landscape and protection related objectives. • Latest coastal studies and monitoring information; (First review 2006) land-use. • Issues identified by most recent defence planning (i.e. coastal defence

strategy plans which have now been produced to cover most of the Any additional facilities or SMP area); change in extraction levels in • Changes in legislation (e.g. European Union Habitats these areas should take into Directive); account environmental and traffic • Changes in national food and coastal defence planning policy impacts. requirements (e.g. the need to consider a timeframe of at least100 years rather than the original 50 years).

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Catchment Flood Management Plans Rother and Romney Catchment objectives: The WMSP policies should SA to consider CFMP’s aims Catchment Flood Management • Reduce the cost of flooding to a sustainable level. consider the impact upon the and objectives. Plan (CFMP) (August 2008) – • Reduce the risk of flooding to people. CFMP. Environment Agency • Reduce the risk of flooding to key infrastructure. • Conserve and enhance internationally and nationally designated nature conservation sites, and promote opportunities to create freshwater habitat when managing flood risk. • • Protect the character of the landscape and designated heritage features within it.

Medway CFMP Catchment wide objectives have been identified based on specificissues, The WMSP policies should SA to consider CFMP’s aims (September 2008) – features or problems that relate to flooding. These were formed from consider the impact upon the and objectives. Environment Agency opportunities and constraints identified by consultation undertaken at the CFMP. Pilot Stage (2001 – 2004) and can be seen in Section 5.2 of the plan. A number of objectives have been created that relate to flood risk to people, properties and the environment.

These reflect a future vision for the Medway and classify what exactly is to be measured when considering the best way forward for flood risk management. Seven objectives have been agreed during the Medway update process. These have been used to appraise the CFMP policies for flood risk management.

The following are the final set of objectives that we have developed and refined: • Ensure the impact on people, property and the built environment does not increase due to future changes • Reduce the flood risk to people where it is unacceptability high • Maintain critical infrastructure • Reduce the cost of flooding where it is unacceptability high • Protect and improve geomorphology • Protect and improve habitats and species • Protect and improve cultural heritage and landscape

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Cuckmere and Sussex We have set objectives for the catchments based on specific issues, The WMSP policies should SA to consider CFMP’s aims Havens CFMP (September features or problems that relate to flooding, taking into account the consider the impact upon the and objectives. 2008) – Environment Agency opportunities and constraints identified above. The objectives for the CFMP. catchments are: • Ensure the harm to life caused by flooding does not increase. • Reduce disruption to critical infrastructure caused by flooding. • Ensure disruption to people and properties caused by flooding does not increase. • Reduce the number of properties affected by surface water or urban drainage flooding. • Sustain and protect sites of cultural, archaeological and historical value from flooding. • Sustain and protect the landscape character, amenity and recreational values of the catchment. • Ensure the cost of damages caused by flooding does not increase significantly due to future changes. • Protect and enhance nationally and internationally designated sites. Protect and enhance Biodiversity Action Plan habitats through flood risk management. • Protect and enhance where possible naturally functioning rivers and floodplains. • Prevent a decline in water quality resulting from flood risk management activities.

River Ouse CFMP Catchment Objectives: The WMSP policies should SA to consider CFMP’s aims (September 2008) – • Reduce the number of properties affected by flooding. consider the impact upon the and objectives. Environment Agency • Reduce disruption caused by flooding to transport and critical CFMP. infrastructure. • Ensure the impact of flooding on people and communities does not increase (for example due to climate change). • Reduce the risk of harm to life caused by flooding. • Restore rivers and floodplains to a naturally functioning state. • Protect and enhance nationally and internationally important species and habitats. • Reduce the cost of flood damages. • Ensure flood damages do not increase (for example due to climate change).

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Adur CFMP (September Catchment Objectives: The WMSP policies should SA to consider CFMP’s aims 2008) – Environment Agency • Restore rivers and floodplains to a naturally functioning state consider the impact upon the and objectives. where feasible. CFMP. • Protect and enhance nationally and internationally important species and habitats. • Ensure the impact of flooding on people and property does not significantly increase in the future (for example due to climate change). • Ensure the disruption caused by flooding to transport and critical infrastructure does not significantly increase in the future (for example due to climate change). • Reduce the impact of muddy flooding. • Ensure flood damages do not significantly increase in the future (for example due to climate change). • Ensure that river channel and flood defence maintenance expenditure is appropriate to the economic damage of flooding. Draft Water Resources Describes the challenges for water resources to 2030 in the region and The WMSP policies should The SA should ensure that Management Plan – Southern proposes solutions to both reduce demand for water, and increase supply of consider the impact upon water water resource issues are Water (May 2013) water. resources, should be aware of the covered by the SA challenges regarding water framework. Southern Water intends to re-open a borehole in the East Sussex area by 2031 resources and seek to reduce to help increase supply, and build pipelines to help move water around. IN consumption of water where addition, it is proposing catchments management schemes to help reduce the possible. Site Allocations DPD amount of nitrates in the water abstracted, and reduce leakages, particular in should be aware of proposals for the Hastings area. new water resources and consider impact of development on potential new resources.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Draft Water Resources Describes the challenges for water resources to 2030 in the region and The WMSP policies should The SA should ensure that Management Plan – South proposes solutions to both reduce demand for water, and increase supply of consider the impact upon water water resource issues are East Water (May 2013) water. The area is predicted to be in water deficit, where demand surpasses resources, should be aware of the covered by the SA supply by the end of the period, unless measures are taken to increase supply. challenges regarding water framework. South East Water proposing to increase supply through methods such as resources and seek to reduce desalination; increasing groundwater resources, with new resources proposed consumption of water where at Forest Row, Coggins Mills and Cowbeach; improving existing water possible. Site Allocations DPD treatment works at Barcombe; water re-use schemes and increasing the should be aware of proposals for capacity at Arlington Reservoir. new water resources and consider impact of development on potential new resources.

Waste and Minerals Provides information on the areas within the Plan Area that are at risk of The SFRAs provide the basis The SFRA informs the SA of Development Framework flooding, taking into account other sources of flooding and climate change as from which to apply the areas at risk of flooding so Strategic Flood Risk well as information on the Flood Map. Sequential Test and Exception that an assessment can be Test where development might made of the likely impact of Assessment, East Sussex be located in areas of flood risk. the WMSP on flood risk. County Council and Brighton and Hove City Council, November 2009 Brighton and Hove Council Contains information on flood zones and an assessment of risks from all The SFRAs provide the basis from The SFRA informs the SA of Strategic Flood Risk sources of flooding and also contains more detailed information on the nature which to apply the Sequential areas at risk of flooding so Assessment, January 2012 of flood hazards that exist in areas that do flood. In addition, the strategic Test and Exception Test where that an assessment can be responses that should be considered to address the effect of proposed development might be located in made of the likely impact of development allocations are described to address conditions as they are now areas of flood risk. the WMSP on flood risk. and as they will be in the future. Technical Guidance to the The aims of the PPS on development and flood risk are to ensure that flood risk The WMSP should take account of The SA should include an National Planning Policy is taken into account at all stages in the planning process to avoid inappropriate flood risk and direct development objective about climate Framework, DCLG, March 2012 development in areas at risk of flooding, and to direct development away from away from areas at higher risk. change and reducing the areas at higher risk. Where new development is, exceptionally, necessary in Flood risk should not be increased risk of flooding will be an such areas, policy aims to make it safe without increasing flood risk elsewhere and where possible should be important consideration. and where possible, reducing flood risk overall. reduced. Sustainability Appraisal Objective 9 – To limit the causes of and adapt to climate change.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Kyoto Climate Change - To negotiate binding limitations on greenhouse gases for the developed Plan should support reduction in Consider inclusion of Protocol (1997) nations, pursuant to the objectives of the Framework Convention on Climate greenhouse gas emissions. objectives to support Change of 1992. reduction in greenhouse gas - To limit the emissions of six greenhouse gases (carbon dioxide, methane, emissions. nitrous oxide, hydrofluorocarbons, perfluorocarbons, sulphur hexafluoride). - The UK has a Kyoto target to reduce emissions by 12.5% below base year levels (1990 for the 3 major gases – CO2, methane and NOx) by 2008-2012. The UK Low Carbon Plan plots how the UK will meet the 34% cut in emissions on 1990 levels by 2020. Plan should contribute towards SA objectives should Transition Plan (2009) The Plan shows how the reductions in the power sector and heavy industry; achieving lower carbon consider the impact of transport; homes and communities; workplaces and jobs; and farming, land and emissions. policies on whether they waste sectors could enable carbon budgets to 2022 to be met. contribute towards reducing carbon emissions. Carbon Plan: Delivering Our The Carbon Plan is a government wide plan of action on climate change, Plan should contribute towards SA objectives should Low Carbon Future (2011) including domestic and international activity. achieving lower carbon support achieving lower It sets a range of plans and targets for: emissions. carbon emissions. • low carbon buildings; • low carbon transport; • low carbon industry; • low carbon electricity; and • agriculture, land use, forestry and waste.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Beyond Copenhagen: The UK Priorities for 2010: The WMSP should support the The SA should ensure that Governments International At home: priorities set out within the climate change is covered by Climate Change Action Plan Continue with long term plans to reduce emissions by at least 80% by 2050 on Action Plan. the framework, and that the (DECC-2010) 1990 levels, with investment in low carbon technologies. Within the EU: SA supports the priorities Support action to invest in low-carbon jobs and growth through the EU 2020 set out within the action strategy. EU should development low carbon infrastructure, and see budget plan. focus on tackling key challenges such as climate change. Internationally: Support practical measure to support countries around the world in delivering action on reducing emissions and adapting to the impacts of climate change, including:

• Agree design principles of new green fund for dispersing climate finance at scale. • Substantial progress in rolling out fast start funding (to provide finance approaching $30 billion over 3 years to 2012.

• Recommendations from high-level advisory group on sources of climate finance. • To launch a new REDD+ mechanism which will provide a package of finance and technical support to help developing countries tackle deforestation. • To strengthen dialogue between countries in the process of establishing emissions trading systems. • Agreement on implementing the Copenhagen Accord commitment to establish a technology mechanism to support the development and deployment of low-carbon technologies. • Release of adaptation funds quickly for poor and vulnerable countries.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Sustainability Appraisal Objective 9 – To limit the causes of and adapt to climate change. The Planning Response to This advice sets out the range of topics that planning authorities and WMSP to support use of Life- SA to include indicators Climate Change: advice on developers will need to take into consideration with reference to climate cycle assessment tools (WRATE) relating to: better practice (ODPM, 2004) change. It describes the issues that must be addressed in response to the to assess greenhouse gas • Reduction in CO2 impacts of climate change in order to mitigate greenhouse gas emissions and emissions for different waste emissions promotes climate adaptation planning policies. management options. • Reduction in Key issue for the Waste Planning Authority is to reduce reliance on landfill sites energy by applying the Waste Hierarchy. WMSP provides an opportunity for consumption minimising greenhouse gas emissions resulting from waste, by restricting development of new landfill sites and identifying sites for new alternative facilities. • Building design that includes space for building users to separate and store materials for recycling prior to collection. • Identifying sites for local recycling centres for the public to take recyclable materials with minimal transport impacts. • Identifying sites for sorting and bulking depots; and encouraging the development of, processing facilities for recyclable materials such as in- vessel composting of biodegradable waste. • Positively encouraging the development of facilities that manufacture products from recycled materials and the use of recycled and secondary materials in construction Climate Change: The UK Outlines the UK Government climate change programme which is designed Reflect objectives and targets Contribution to reduction Programme to ensure that UK emissions remain on a downward path and to prepare the identified in the UK Climate in emissions should form (DEFRA, 2006) UK for making bigger cuts in the future. Includes details of the Governments Change programme. part of the SA/SEA strategic approach to tackling emissions for each sector. monitoring regime for Promote reduction of greenhouse plans. The review assesses the impact of existing policies and potential contribution of gases. new policy options to achieve the domestic goal of reducing carbon dioxide Inclusion of objective and emissions by 20% below 1990 levels by 2010 and 60% by 2050. WMSP should help to meet indicator relating to the UK’s target to cut reduction of CO2 emissions. Includes information and details of European and national targets, on energy greenhouse emission and these from waste and waste management. factors should be taken into consideration when appraising potential sites.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Climate Change Act 2008 The Act introduces a long term framework for reducing greenhouse gas The WMSP should contribute to SA framework and appraisal (DEFRA, November 2008) (GHG) emissions and adapting to the impacts of climate change. achieving the UK’s carbon targets should reflect the UK’s and address the need to adapt to priorities to reduce The key elements of the Act are: the impacts of climate change. greenhouse gas emissions • Setting targets and providing a system of carbon budgeting. and to adapt to the impacts • Creating a committee on climate change. of climate change. • Placing a duty on the government to assess the risk to the UK from the impacts of climate change.

• Providing powers to establish trading schemes for the purpose of limiting GHG emissions. • Powers to create waste reduction pilot schemes.

Carbon Targets: 80% reduction in targeted GHG emissions by 2050 against 1990 baseline. At least 26% reduction of targeted GHG emissions by 2020 against 1990 baseline.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Climate Change Strategy The overall aim for this strategy is “to promote the prosperity and wellbeing The WMSP should comply with Aim and objectives will help (East Sussex County Council, of our community by reducing greenhouse gas emissions and adapting to the local objectives, and deliver shape the sustainability 2009) climate change, and to enable individuals and organisations to tackle and policies which support the issues and problems and adapt to climate change”. strategy’s vision and the principles framework.

guiding the aim. Guiding the aim are the following principles: SA framework and • Climate change, above and beyond that which can be explained by The WMSP should contribute to appraisal should reflect the natural variation, is happening, and the impact of this change poses achieving the UK’s carbon targets Strategy’s aim and significant risks for our local community. and address the need to adapt to objectives to address climate • Addressing climate change requires both immediate work and long- the impacts of climate change. change. term effort. • Addressing climate change requires action at local, national and international levels. • Addressing climate change will require resources, but the costs of not taking action will be far greater. • We should all be exemplars of good practice in making positive progress towards tackling climate change. • Climate change considerations must inform decision making, investment and policy development. • As organisations and businesses, we need to work together to address climate change. • As individuals, we all need to play our part in rising to the challenges of climate change.

The aim will be achieved by addressing these four themes:

1. Bring climate change into the mainstream of all that we do; Objectives: • MA 1. Establish widespread local commitment to action on climate change. • MA 2. Take account of climate change implications in all policy development. • MA 3. Monitor and report progress, highlighting success as well as areas for further action and review the strategy.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA 2. Engage with new and existing partner organisations and the public; Objectives: • EN 1. Ensure that residents and organisations are well informed about climate change, including how they can play their part in mitigation and adaptation. • EN 2. Ensure that programmes of support for action on mitigation and adaptation are available and suitable for individuals and organisations in East Sussex. 3. Reduce our greenhouse gas emissions (‘mitigate’); Objectives: • MI 1. Understand current and forecast levels of greenhouse gas emissions from East Sussex. • MI 2. Set the scale of appropriate local mitigation, at least in line with national government targets. • MI 3. Determine the options available for the reduction of greenhouse gases. • MI 4. Take action to reduce greenhouse gas emissions from East Sussex. 4. Create a community which can adapt to the changing climate. Objectives: • AD 1. Consider the nature of likely future climatic conditions in East Sussex. • AD 2. Understand local vulnerabilities to a changing climate, including extreme weather events, as well as the opportunities presented by change. • AD 3. Assess the likely risks to services, structures, business processes and the lives of residents and workers, and prioritise responses to risks. • AD 4. Make adaptations to climate change, revise policies and procedures, and implement changes to facilities and infrastructure.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Climate Change Strategy The Strategy focuses efforts towards reducing greenhouse gas emissions and The WMSP should contribute SA framework and appraisal 2011-2015 (BHCC 2011) adapting to a changing climate. It brings together work that is already being towards achieving the outcomes should reflect the Strategy’s done in the city from existing work programmes, such as the LTP, Food Strategy set out in the strategy. aim and objectives to and City Plan. It has five high level outcomes and sets out steps on how to address climate change achieve them: • A low carbon economy. • Low carbon homes and buildings. • Low carbon transport. • Renewable and Sustainable energy resources. • A city adapting well to climate change. Sustainability Appraisal Objective 10 – To protect air quality and reduce air pollution. Air Quality Strategy for The Strategy sets out air quality objectives and policy options to further There is no legal requirement to SA should reflect the new England, Scotland, Wales and improve air quality in the UK from today into the long term. meet the policy targets/intentions approach of reducing air Northern Ireland (DEFRA, in the strategy. However, many of pollution levels across the July 2007) The primary objective is to ensure that all citizens should have access to them mirror European obligations whole population of an outdoor air without significant risk to their health, where this is economically which are legally binding. urban area or region. This is and technically feasible. because there is no The Environment Agency is recognised safe level for The objectives in the strategy are policy targets/intentions that are expressed responsible for regulating exposure to fine particles as a maximum ambient concentration not to be exceeded. emissions from waste and (PM2.5). minerals processes. However, the Have now adopted an “exposure reduction” approach for PM2.5 This is based WMSP should have regard to the on the principle that levels of pollutants with a low or zero threshold for objectives set out in the strategy adverse effects should be reduced across the whole population of an urban to ensure that waste and minerals area or region rather than in a small area or “hotspot”. policy does not lead to • This is to be delivered by setting air quality objectives/limit values to development that exceeds the ensure some basic level or quality of air which all citizens should maximum ambient experience; and concentrations of air pollutants • An objective based on reducing average exposures across the most (Table 2 of the strategy). heavily populated areas of the country.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Hastings Borough Council Air “On a small part of Bexhill Road, levels of Particulate Matter (PM) are above Minerals and Waste proposals AQMAs can be used as a Quality Management Area the permitted level…The dust probably originates from the waste handling should not be permitted on sites measure of areas where air (AQMA) (2004) and disposal facilities next to Bexhill Road.” where they will further the pollution exceeds the already exceeded air pollution permitted levels set by “Since Spring 2004 PM10 levels have fallen significantly. It’s possible that levels of AQMAs. The WMSP government. increased road cleaning and improved wheel washing at the landfill have should have regard to AQMAs contributed to this significant improvement. “ when assessing the suitability of Air quality should be Minerals and Waste sites. included in the sustainability Measures considered in the Action Plan include investigations into objectives. improved dust controls at the local waste handling facilities and working It is also important to assess with the Environment Agency to use existing licence conditions on relevant frequency and route of HGVs to sites to minimise levels of dust leaving each ensure that where possible they site. do not use roads within AQMAs. “…the closure of the landfill operation at Freshfields, expected in 2008, will reduce the amount of material available for resuspension as road dust. It’s anticipated that this will also reduce levels of PM10.”

“…there are currently areas of uncertainty within the draft plan, which arise from the current monitoring results and the lack of available knowledge relating to the resuspension process.” Lewes District Council The Detailed Assessment (Sept 2004) concluded that pollution levels in Fisher The WMSP should consider The SA should consider the AQMA (June 2005) Street (Lewes town centre) were likely to exceed the annual mean air quality impacts and avoid developments location of the AQMAs and objective for nitrogen dioxide and an AQMA for nitrogen dioxide was and activities which would whether the transportation declared. further the already exceeded air of waste and minerals pollution levels. would have a negative A Draft Air Quality Action Plan was produced in September 2007 setting out impact on the surrounding measures to improve air quality particularly in Lewes Town Centre by air quality. reducing pollution emitted from vehicles and the amount of traffic on the roads.

Newhaven has been identified as having possible exceedences of nitrogen dioxide. Further monitoring is being carried out. (Local Air Quality Management Progress Report 2008)

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Brighton & Hove City Council The council declared a new AQMA in August 2013, which is quarter of the The WMSP should consider The SA should consider the AQMA 2013 size of the previous one which encompassed much of southern central impacts and avoid developments location of the AQMAs and Brighton & Hove. Broadly speaking, the AQMA covers much of the seafront, and activities which would whether the transportation some key roads heading back from the seafront into the city and part of the further the already exceeded air of waste and minerals city centre. The council is developing a renewed 2014 air quality action plan pollution levels. would have a negative targeting this area. Levels of nitrogen dioxide exceed Air Quality Objectives impact on the surrounding in the AQMA, and this is associated mainly with road traffic. air quality.

Adur District Council AQMA There are two proposed AQMAs: Both AQMAs are close to the plan The SA should consider the (December 2005) • Southwick AQMA between Kingston Lane and 24 Southview Close, boundary. Therefore the WMSP location of the AQMAs and Southwick Boundaries defined by north side of A270 and rear of should consider impacts and whether the transportation properties facing onto south side of A270. avoid developments and activities of waste and minerals • Shoreham-by-Sea AQMA between Norfolk Bridge and Surry Street, which would further the already would have a negative Shoreham-by-Sea Boundaries defined by Mean High Water Tide exceeded air pollution levels. impact on the surrounding Level and rear of properties facing onto A259. air quality. The Council are to develop an Action Plan aimed at reducing levels of nitrogen dioxide in these areas.

Sustainability Appraisal Objective 11 – To reduce adverse impacts of transporting waste and minerals by road on the environment. Towards a Sustainable Aims to improve transport’s contribution to economic growth and WMSP should contribute to SA objectives should reflect Transport System (DfT, productivity while reducing CO2 emissions. reducing transport’s CO2 government transport goals 2007) Goals emissions and minimise the on economic growth, CO2 • Maximising the overall competitiveness and productivity of the negative impacts of transport emissions, health and the national economy. on people’s health and the environment. • Reducing transport’s emissions of CO2 and other green house gases. environment. • Contributing to better health and longer life-expectancy. • Improving quality of life for transport users and non-transport users. • Promoting greater equality of transport opportunity for all citizens.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Delivering a Sustainable This document demonstrates how the Government requires local authorities The WMSP should take note of Include a transport Transport System (DaSTS) to deliver the national goals for transport and describes the associated the 5 national goals. objective considering the 5 November 2008 challenges. national goals.

Following consultation on TaSTS the five national goals were revised as follows:-

• Support economic growth and competitiveness • Tackle climate change • Contribute to better safety, security and health • Promote equality of opportunity • Improve quality of life

The key requirement of the goals is that they should capture both the positive and negative range of impacts of transport. Each goal includes related challenges; these are included to provide more detail for practitioners in transport or land use planning where progress will be required under each goal. It is expected that packages of measures or interventions are developed to support overarching goals rather than targeting individual challenges.

Low Carbon Transport: A This document is a key component of The UK Low Carbon Transition Plan, WMSP can assist in contributing The SA will need to include Greener Future, 2009 and sets out the actions that the Government is taking to deliver cuts in to the overarching aim of this a specific objective to:- emissions to meet with the obligations under carbon budgets to 2022, and the strategy to reduce carbon • address the causes longer term change required for the period up to 2050. emissions through improving of climate change. locating waste facilities close to The strategy is based on 3 themes:- where it arises. • reduce air pollution and ensure air • Supporting a shift to new technologies and fuels quality. • Promoting lower carbon transport choices • Using market based measures to encourage a shift to lower carbon transport

Government is committed to reducing greenhouse gas emissions across the economy by at least 34% by 2020 and by at least 80% in comparison to 1990 levels by 2050. (Transport accounts for 21% of UK domestic greenhouse gas emissions).

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA At a European level, targets are in place to reduce greenhouse gas emissions across the EU by 20% by 2020, and delivering 20% of energy from renewable sources by 2020.

The transport sector will contribute to these targets by:-

• Subjecting CO2 emissions from aviation to a legally binding, tightening cap from 2012 through the EU Emissions Trading System (Pricing on goods and services that reflect the costs that they impose on society, incentives for development and quicker adoption of new technologies.)

• Sourcing 10% of transport’s energy from renewable energy sources by 2020.

16% reduction in greenhouse gases by 2020 (on 2005 levels) across those sectors not covered by trading scheme, i.e. domestic transport, heat, agriculture and waste.

Active Travel Strategy (DFT The strategy aims to: The WMSP should consider The SA framework should 2010) public health and well-being, ensure objectives cover the • Promote better public health and well-being by increasing levels before, during and after any waste subject of health and of physical activity, particularly among the most inactive people or minerals development has wellbeing. in our society; taken place. • Increase accessibility and reduce congestion; and • Improve air quality and reduce carbon emissions.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Towards a Sustainable TaSTS sets out the Government’s new transport investment and policy plans in The WMSP should take note of SA objectives should Transport System, 2007 order to implement the recommendations of the Eddington Transport Study the 5 national goals. cover the 5 national (TaSTS) and reflect the Stern Review of the economics of climate change. goals where relevant.

TaSTS identifies five national goals for transport policy:

• climate change

• competitiveness and productivity

• equality of opportunity

• health, safety and security

• quality of life East Sussex Freight Strategy The vision for the Freight Strategy is: WMSP should take account of the Objectives should relate to (ESCC, 2010) To encourage the safe and sustainable distribution of freight into, out of and Strategy and aim to minimise the minimisation of waste around East Sussex, which supports our economy and provides a service to road based vehicle kilometers transported by road. businesses and customers, whilst mitigating its impacts on communities and the and the environmental impact of environment. road haulage, and encourage transportation of freight by rail To help achieve the vision outlined above, a series of objectives in the Freight wherever possible. Strategy have been identified: · To provide for the efficient, safe and sustainable distribution of freight to industries and The Site Allocations DPD should consumers into, out of, and around, East Sussex, assess suitability of sites in relation to proximity to to rail, · To protect communities and the environment from negative impacts arising from freight and suitable road network. distribution, in terms of emissions, noise, visual intrusion and physical damage, · To reduce the use of inappropriate routes to reach destinations, · To improve education and awareness of freight issues in East Sussex for both the freight industry and local communities, and · To promote and encourage sustainable transportation of freight on rail where opportunities arise.

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA East Sussex Local Transport Vision: The WMSP needs to reflect the SA framework should Plan 3 2011- To make East Sussex a prosperous county where an effective, well managed plan objectives. include objectives that seek 2026 (ESCC, June 2011) transport infrastructure and improved travel choices help businesses to thrive to reduce the harmful effects and deliver better access to jobs and services, safer, healthier, sustainable and of waste and minerals traffic inclusive communities and a high quality environment. on the environment and communities including noise High Level Objectives: and greenhouse gas • Improve economic competitiveness and growth emissions. • Improve safety, health and security • Tackle climate change • Improve accessibility and enhance social inclusion • Improve quality of life

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Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Transport Plan 20011-2026 Vision statement The WMSP needs to reflect the • SA framework (BHCC, 2011) “To deliver an integrated, accessible and balanced transport system that supports LTP’s objectives. should include economic growth and enables people to travel around and access services as objectives that safely and freely as possible while minimising damage to the environment and seek to reduce contributing to a safer, cleaner, quieter and healthier city.” the harmful effects Strategic transport objectives to deliver wider policy goals transport can Supporting economic growth: have on the To ensure the local transport system operates efficiently, is well maintained and economy, can cope with extreme occurrences. society and the To improve access to job opportunities, shopping areas and cultural and visitor environment. attractions. To help inform travel decisions and improve reliability of journey times for all road users. To deliver transport improvements required to support sustainable housing growth.

Reducing carbon emissions Increase the use of low-emission forms of transport and support the use of associated technologies. To reduce the need to travel for some journeys and enable people to travel more sustainably.

Promoting equality and opportunity To increase the availability and accessibility of travel choices for everyone, particularly disadvantaged people, and those living outside the central area. To improve streets and the wider transport system to assist in the regeneration of deprived areas and communities.

Contributing to safety, security and health To reduce fear of danger and the risk of personal injury as a result of transport collisions. To minimise the impacts of transport-related air and noise pollution on people, and the natural and built environments. To encourage and enable greater levels of active and healthy travel, such as cycling and walking, especially for shorter journeys.

ENVIRONMENTAL RESOURCES MANAGEMENT E AST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A68

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA National Policy Statement The NPS for ports sets out the Government’s policy for new port development. The WMSP should support the The SA should support the (NPS) – Ports (DFT, 2012) It outlines what the Department considers to be the potential economic, key components of the NPS, and key components of the NPS, environmental and social impacts of port development, defining the consider the key issues which it and ensure that the policies acceptable limits of adverse impacts and explaining the levels of mitigation raises. developed within the likely to be required depending on local circumstances. In doing so, it WMSP consider the key integrates planning policy from relevant Planning Policy Guidance and issues that have been raised. Planning Policy Statements produced by the Department for Communities and Local Government.

Key Components to within the NPS:

• Transport and the economy: the essential role of ports • The need for additional capacity • An uncertain future • A successful and competitive market-led sector • Connecting ports to the rest of the transport network • Transport that works for everyone • Supporting economic growth • Reducing greenhouse gases • Contributing to better safety, security and health • Promoting equality of opportunity • Improving quality of life, and promoting a healthy natural environment • Key considerations for decision making

White Paper: Creating Growth, The Government is also making a number of specific national The WMSP needs to support the SA objectives should reflect Cutting Carbon – (DFT January commitments to enhance the sustainability of local transport. These commitments made by the the government’s 2011) government through the White commitments. include: Paper. • reviewing the way in which investment decisions are made to ensure that the carbon implications are fully recognised; and • setting out in a road safety strategy, by spring 2011, how to ensure that Britain’s roads are among the world’s safest.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A69

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Sustainability Appraisal Objective 12 – To conserve and enhance important soil functions and types. European Thematic Strategy The strategy is seeking to: Consider impact on soil when SA framework should for Soil Protection (EU, 2006) • Establish common principles for the protection and sustainable use developing policies. Protect soil include objectives to of soils. functions and prevent conserve and enhance • Prevent threats to soils, and mitigate the affects of those threats. contamination to soils. Where important soil functions and • Preserve soil functions within the context of sustainable use. possible restore contaminated restore contaminated soils. • Restore degraded and contaminated soils to approved levels of soils. functionality.

Strategy includes proposals for a EU Soil Framework Directive the main draft elements include: • A requirement to consider the impact that new policy will have on soils while they are being developed.

• A requirement to reduce the risks relating to soil erosion, organic matter decline, compaction, salinisation and landslides. • A requirement to prevent soil contamination.

(Note: There is no detailed UK position on the proposed directive, until the results of public consultation due to close on 19 October 2007 are known.) First Soil Action Plan for Actions are listed under eight headings: WMSP should consider impacts SA should include an England 2004-2006 • Protecting soils in the Planning System. on soils and ensure a more objective on soil quality. (DEFRA, 2004) • Minimising contamination of soils. sustainable use and protection of • Predicting and adapting to the impacts of climate change on soil. soils. • Soils for Agriculture and Forestry. • Interactions between soils, air and water. • Soils and Biodiversity. • Soils, the landscape and cultural heritage. • Soils in minerals extraction, construction and the built environment.

All actions included in the plan work towards more sustainable use and protection of soil.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A70

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Safeguarding our Soils: A The vision: Consider impact on soil when SA framework should Strategy for England (Defra, By 2030, all England’s soils will be managed sustainably and degradation developing policies. Ensuring include objectives to 2009) threats tackled successfully. This will improve the quality of England’s soils that there is protection of soil conserve and enhance and safeguard their ability to provide essential services for future generations. functions and policies which important soil functions. minimise the risk posed by Three main threats: contaminants when recycling • Soil erosion by wind and rain. Erosion affects both the organic materials to soil/land. productivity of soils but also water quality and aquatic ecosystems. Consider soil in terms of • Compaction of soil reduces agricultural productivity and water hazardous waste. infiltration, and increases flood risk through higher levels of run off. • Organic matter decline. The loss of soil organic matter reduces soil quality, affecting the supply of nutrients and making it more difficult for plants to grow, and increases emissions to the atmosphere.

Summary of key new actions: • A review of the need for future options under Environmental Stewardship to improve soil protection. • A new goal to significantly reduce the rate of loss of stored soil carbon by 2020.

• A commitment to developing a new framework for action for peat protection, including on horticultural peat use post 2010. • Reviewing thresholds for pollutants entering soil through recycling materials to land. • Publishing a new code of practice for soil use on construction sites and a new toolkit for planners in 2010 on how to take account of soil functions through the planning system. • Reviewing the effectiveness of the existing planning policy to protect important soils and whether there is a need to update it. • Publishing new best practice guidance on decision making for contaminated land.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A71

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Sustainability Appraisal Objective 13 – To protect, conserve and enhance East Sussex and Brighton and Hove’s countryside and historic and built environment.

National Parks and The 1949 Act makes provision for National Parks. Section 11A, sub-section (2) Plan should protect the National Ensure SA framework Countryside Act 1949 and places specific duty on Local Authorities and other public bodies to have regard Park and have regard to the includes protection of the Environment Act 1990 (HMSO to the purposes of the National Park. The Act also specifically states “if it appears purposes of the National Park. National Park 1949,1990) that there is a conflict between those purposes, (the local authority) shall attach Sites DPD should consider the greater weight to the purpose of conserving and enhancing the natural beauty, impact on development within or wildlife and cultural heritage of the area comprised in the National Park.” adjacent to the National Park, The Environment Act 1990 section 62 amends section 11A of the 1949 Act, including impacts of the setting of however the above duty still remains. the National Park, and views from or of the National Park. English National Parks and the Sets a vision for National Parks, and that by 2030, English National Parks will be Plan should support the vision SA objectives should reflect Broads UK Government Vision places where: for the SDNP. Key considerations the aims set in the SDNP and Circular 2010 -there are thriving, living, working landscapes; include conservation and Strategy and Action Plan. - they inspire visitors and inhabitants to live within environmental limits; enhancement of natural beauty, -the range of services they provide are valued; wildlife and cultural heritage of - Sustainable development can be seen in action; SDNP and promotion of - Wildlife flourishes and habitats are maintained, restored, and expanded; and opportunities of understanding and enjoyment of the SDNP by - Everyone can discover the rich variety of England’s natural and historic the public. environment.

A Strategy for Archaeology in To protect, conserve, record and interpret the archaeological heritage of East Plan should protect and recognise Consider including East Sussex Sussex; the importance of the historic protection of the historic East Sussex County Council 1993 To ensure the preservation and conservation of the county's heritage through the environment. environment as an SA planning process and other appropriate means; and objective. To take measures to safeguard the important maritime archaeological heritage which lies off the coast of East Sussex.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A72

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA The High Weald AONB 20 year vision: ‘Envisages environmental, social and economic developments WMSP to ensure that new SA framework to consider Management Plans (High in the High Weald that support the primary purpose of designation: the developments are sympathetic to policies from the AONB Wield JAC 2004) conservation and enhancement of natural beauty. Environmental the landscape character of the management plans. (ADOPTION) sustainability is at the heart of this vision. This means maintaining the locality and ensure no

capacity of natural systems; minimising resource consumption; and unacceptable adverse effects on Include objectives such as: protecting and improving the quality of the natural and historic surrounding area and • To protect, enhance environment.’ community. and conserve the diversity, heritage, Objectives include: WMSP should include policies to quality, and natural

• To enhance the architectural quality of the High Weald and to re- mitigate impacts including: beauty of the

establish the use of local materials as a means of protecting the • Aftercare and afteruse AONBs. environment and adding to this distinctiveness. conditions; • To secure agriculturally productive use of the fields of the High • To provide Weald AONB, especially for local markets, as part of sustainable • Restoration of opportunities to

land management. mineral workings source materials

at sites of locally. Management Plan for the 20 year vision: ‘A landscape of the highest quality where the diversity of geological interest. South Downs landscape character enjoyed at the turn of the 21st century has been retained • Consideration of noise (South Downs Joint and enriched, offering people the experience of natural beauty at its very best.’ and air quality. Include targets relating to Committee, 2008) (REVIEW) • Consideration of local use of renewable energy Main Aims: character and and waste minimisation. • The protection, conservation and enhancement of the natural distinctiveness in the beauty of the South Downs. design, scale and setting of • The promotion of opportunities for the understanding and new development. quiet enjoyment of the area’s special qualities. WMSP to reflect relevant principles from the Plans, balancing protection and

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A73

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA • The encouragement of sustainable forms of economic and enhancement of the countryside and protection of future community development in ways that help support the first two aims. resources with sustainable economic growth. Stressed that minimising the damage caused by change is not enough and that positive enhancement is required. WMSP to encourage: The High Weald AONB • Local production and use nd Management Plan 2004 2 Ambitions with associated targets including: of traditional building Edition, (High Weald AONB • A high quality and diverse landscape. materials. Joint Advisory Committee, • Conserved historic and cultural heritage. • Extraction of minerals March 2009) (RE- • Tranquil landscape. on a scale sensitive to ADOPTION) • Sustainable management of the land. the landscape. • Unpolluted air, soil and water. • All new developments • Buoyant local economy. to meet the highest standards of energy Ambitions refer to issues including: and water • Larger scale development pressures. conservation • Ongoing damage to archaeological sites, historic landscapes and • Use of renewable features. energy sources, • Traffic growth. where possible. • Loss of local vernacular craft skills and locally sourced materials. • Reducing greenhouse gas emissions and the consumption of natural resources.

Marine Policy Statement, The UK vision for the marine environment is for ‘clean, healthy, safe, Impact upon the marine SA framework to consider (Defra March 2011) productive and biologically diverse oceans and seas’. environment should be taken into objectives around marine consideration when developing issues. The high level marine objectives: development plan policies.

Achieving a sustainable marine economy: • Infrastructure is in place to support and promote safe, profitable and efficient marine businesses. • The marine environment and its resources are used to maximise

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A74

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA sustainable activity, prosperity and opportunities for all, now and in the future. • Marine businesses are taking long-term strategic decisions and managing risks effectively.

• They are competitive and operating efficiently. • Marine businesses are acting in a way which respects environmental limits and is socially responsible. This is rewarded in the marketplace.

Ensuring a strong, healthy and just society: • People appreciate the diversity of the marine environment, its seascapes, its natural and cultural heritage and its resources and act responsibly. • The use of the marine environment is benefiting society as a whole, contributing to resilient and cohesive communities that can adapt to coastal erosion and flood risk, as well as contributing to physical and mental wellbeing. • The coast, seas, oceans and their resources are safe to use. • The marine environment plays an important role in mitigating climate change. • There is equitable access for those who want to use and enjoy the coast, seas and their wide range of resources and assets and recognition that for some island and peripheral communities the sea plays a significant role in their community. • Use of the marine environment will recognise, and integrate with, defence priorities, including the strengthening of international peace and stability and the defence of the UK and its interests.

Living within environmental limits • Biodiversity is protected, conserved and where appropriate recovered and loss has been halted. • Healthy marine and coastal habitats occur across their natural

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A75

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA communities and the functioning of healthy, resilient and adaptable marine ecosystems. • Our oceans support viable populations of representative, rare, vulnerable, and valued species.

Promoting good governance • All those who have a stake in the marine environment have an input into associated decision-making. • Marine, land and water management mechanisms are responsive and work effectively together, for example through integrated coastal zone management and river basin management plans. • Marine management in the UK takes account of different management systems that are in place because of administrative, political or international boundaries. • Marine businesses are subject to clear, timely, proportionate and, where appropriate, plan led regulation. • The use of the marine environment is spatially planned where appropriate and based on an ecosystems approach which takes account of climate change and recognises the protection and management needs of marine cultural heritage according to its significance.

Using sound science responsibly • Our understanding of the marine environment continues to develop through new scientific and socio-economic research and data collection. • Sound evidence and monitoring underpins effective marine management and policy development. • The precautionary principle is applied consistently in accordance with the UK Government and Devolved Administrations’ sustainable

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A76

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Sustainability Appraisal Objective 14 – To protect, conserve and enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity. The Natural Environment and Key Elements: Impact upon biodiversity should Biodiversity included as part Rural Communities Act 2006 • Establishment of Natural England, responsible for enhancing be taken into account when of SA objectives. (Commencement No. 2) Order biodiversity and landscape. developing all policies. 2006 • Formal establishment of Commission for Rural Communities which acts as an independent advocate, advisor and watchdog for rural people. • Extension of the CROW Biodiversity Duty to public bodies and statutory undertakers to ensure due regard to the conservation of biodiversity.

Section 40: “Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity”.

The purpose of the duty is to raise the profile of biodiversity in England and Wales, and to stimulate a cultural change in all parts of the public sector with the intended result being that biodiversity issues become second nature for public bodies when developing policies and making decisions.

The Conservation of Habitats The objective of the Habitats Directive is to protect biodiversity The WMSP should recognise the Biodiversity included as part and Species Regulations 2010 through the conservation of natural habitats and species of wild fauna and contribution the regulations have of SA objectives. Chapter 8 covers Land Use flora. The Directive lays down rules for the protection, management and on habitats and species, and Plans (April 2010) exploitation of such habitats and species. should support it through policy development. Including Chapter 8 of the regulations covers Land Use Planning, including assessment of undertaking Appropriate implications for European sites and European offshore marine sites, Assessments where there is likely considerations of overriding public interest, co-ordination for land use plan to be an impact on European prepared by more than one authority, compensatory measures designated sites.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A77

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Natural Environment Published as a response to the Nagoya Summit (2010) which aims: “by 2050 Plan should promote protection Consider inclusion of White Paper (DEFRA biodiversity is valued, conserved, restored and wisely used, maintaining and enhancement of biodiversity objectives to protect and, 2011) ecosystem services, sustaining a healthy planet and delivering benefits essential and should consider the where possible, enhance for all people”. promotion of biodiversity at a biodiversity The White Paper promotes landscape scale approach to biodiversity conservation landscape scale. and emphasizes the value of ecosystem services, public engagement and the integration of biodiversity goals with economic development. Also establishes mechanisms for formally identifying and protecting urban Quiet Areas, so that people living in cities can benefit from access to areas of relative quiet for relaxation and contemplation.

Biodiversity 2020: A Strategy Main aims are to: Plan should promote protection and Consider inclusion of for England’s Wildlife and Halt overall biodiversity loss, enhancement of biodiversity. objectives to protect and, Ecosystem Services (Defra Support healthy well-functioning ecosystems, and where possible, enhance 2011) Establish coherent ecological networks with more and better places for nature biodiversity. for the benefit of wildlife and people A Strategy for England’s Trees To provide a resource of trees, woods and forests in places where they can Plan should promote sustainable Consider objective or Woods and Forests (2007) contribute most in terms of environmental, economic and social benefits now management of woods and indicator that protects and for the future. forests. Plan should seek steady existing and promotes new Strategy includes some indicators including: expansion of woodland areas. woodland areas. • Proportion if SSSI in favourable condition Site Allocations DPD should • Woodland bird indicators consider impact on trees and • Access to and use of woodland woodlands. • Trends in plants and ancient woodland indicator plants A Biodiversity Action Plan Key objectives are: The WMSP should acknowledge SA should include objectives (BAP) for Sussex (1998) and support this action plan by to protect and enhance • To maintain, and where practicable enhance, the wildlife and integrating its objectives and biodiversity. habitats that give Sussex its character and natural diversity. policies. This primarily includes • To identify priority habitats and species which are important to us in ensuring that priority habitats and Indicators Sussex and/or where we have a special responsibility to care for species are not adversely affected. • Local habitats something, which is important on a national or international scale. • Threatened species • Designated Areas e.g.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A78

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA • To set realistic, but ambitious, targets and timescales for priority Quality of SSSIs habitats and species and to monitor progress of action plans against those targets.

• To ensure that biodiversity action continues as a joint initiative, evolving a dynamic framework for nature conservation. •

The action plan has been intermittently undated since 1997, however the South East Biodiversity The South Eas t Biodiv ersi ty Strat egy is a web based resource The WMSP should acknowledge SA should ensure Strategy (South East which aims to: the strategy as a resource and Biodiversity Opportunity Biodiversity Forum) - 2009 support the overall aims. Areas have been • Be a clear, coherent and inspiring vision for the South East; acknowledged by the • Provide a framework for the delivery of biodiversity targets that guide WMSP. and support all those who have an impact on biodiversity in the region ; • Embed a landscape scale approach to restoring whole ecosystems in the working practices and policies of all partners;

• Create the space needed for wildlife to respond to climate change; • Enable all organisations in the South East to support and improve biodiversity across the region; and • Be a core element within the strategies and delivery plans of organisations across the South East region.

The strategy consists of three core elements: • Working in partnership – agreed responsibility for partners; • A regional Biodiversity Opportunity Areas Map; and • Biodiversity Action Plan targets – agreed regional targets for habitats and species.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A79

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Brighton & Hove The LBAP addresses the species and the habitats or particular importance in The Plan should acknowledge Consider inclusion of Biodiversity Action Plan Brighton & Hove. It includes action plans covering 18 species or groups of and support the aims of this objectives to protect and (BHCC 2012) species which are considered to have specialist requirements which can be action plan. enhance biodiversity. addressed locally and which cannot be adequately addressed through local The Site Allocations DPD should Indicators and targets habitat action plans and 15 actions plans covering habitats of greatest take into account the species and relating to biodiversity importance locally. The LBAP sets of 5 principles which take into account the habitats for which there are should be linked to the goals on Biological Diversity Strategic Plan 2011-2020 and outcomes of the 2011 action plans when assessing targets set in the local BAP. England Biodiversity Strategy: suitability of sites.

1) Mainstream Biodiversity in Society. 2) Integrate the conservation of biodiversity across other land uses. 3) Conserve important habitats and species on a landscape scale. 4) Share the benefits of biodiversity and ecosystem services. 5) Establish a strong evidence base.

Sustainability Appraisal Objective 15 – To increase energy efficiency and the proportion of energy generated from renewable sources. Energy White Paper: Meeting Sets out the Government’s long term strategic vision for energy policy. WMSP should: SA framework should the Energy Challenge, (DTI • To put ourselves on a path to cutting CO2 emissions by 60% by 2050 • maximise reflect the priorities 2007) with real progress by 2020. production of identified in the Strategy • To maintain the reliability of energy supplies. energy from waste for tackling CO2 emissions • To promote competitive markets in the UK and abroad. • reduce emissions and maximising renewable • To ensure that every home is adequately and affordably heated. from transport energy sources. • be energy efficient Emphasis on: • support supply and • microgeneration (including CHP) and the role of renewable energy. use of biomass

• reducing emissions from transport e.g. use of cleaner fuels, and vehicle efficiency. • maximising the supply & use of biomass, including from waste, in the production of sustainable energy (details are published in UK Biomass Strategy).

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A80

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA The Energy Challenge - DTI A programme of action to make further progress towards our energy goals to WMSP should ensure that SA Framework should Energy Review: A Report 2020 and beyond. This work aims to put the UK in a position to meet the two guidance is in place to encourage include objectives and (DTI, 2006) major long-term challenges in energy policy: to tackle climate change by a reduction in carbon dioxide indicators relating to a reducing carbon dioxide emissions; and to deliver secure, clean energy at emissions whilst promoting reduction in greenhouse gas affordable prices. sustainable economic growth, and emissions. identify sites for generating The review sets out key proposals to tackle these issues including: energy by capturing landfill gas • Increasing energy efficiency by influencing individual and and incineration. commercial behaviour. • Increasing small-scale power generation at a local level. WMSP should emphasis a • Building a new generation of nuclear power stations and reduction in waste of high carbon increased investment in UK power stations. and energy products • Finding alternatives to oil as an energy source. • Reforming the planning system in relation to energy projects. • Commissioning of a cross-governmental study on the adoption of a personal carbon allowance policy.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A81

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA National Policy Statement Summary of the Government’s Energy and Climate Change Objectives for WMSP should ensure its policies SA framework should reflect (EN1) – Overarching National the Power Sector : help to deliver the UK’s the objectives identified in Policy Statement for Energy obligations in terms of reducing the NPS, especially in terms (July, 2011) • To help deliver the UK’s obligation to reduce greenhouse gas emissions green house gas emissions and of assessing the contribution by 80% by 2050 and work to carbon budgets stemming from the cutting carbon through renewable of renewable energy within Climate Change Act 2008, within the context of the EU Emissions energy production. the County. Trading System. WMSP should contribute • To ensure that investment provides security of energy supply through a towards sustainable development diverse and reliable mix of fuels and low carbon technologies – by encouraging energy renewables, nuclear and fossil fuel plants fitted with carbon capture and infrastructure (but only where storage. there is an identified need).

• To further ensure that investment delivers an electricity grid with greater capacity and the ability to manage larger fluctuations in supply and demand.

• To support the elimination of fuel poverty and protect the vulnerable through ensuring energy infrastructure is delivered in a cost effective way that keeps energy bills as low as possible.

• To contribute to sustainable development by seeking energy infrastructure development that helps reduce climate change while also minimising negative impacts on the local environment.

There is a significant need for new major energy infrastructure. Government is confident that industry can deliver what is required subject to the right framework, including quick and effective planning decisions which recognise the national need for new energy infrastructure.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A82

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA National Policy Statement Government policy criteria for fossil fuel generating Stations WMSP should ensure its policies SA framework should reflect (EN2) – Fuel Electricity help to deliver the UK’s the objectives identified in Generating Infrastructure The following criteria must be met before consent for a new fossil fuel obligations in terms of reducing the NPS, especially in terms e.g. gas, oil and coal fired generating station can be given: green house gas emissions and of assessing the contribution power stations (July, 2011) • Combined Heat and Power. cutting carbon through renewable of renewable energy within • Carbon Capture Readiness. energy production. the County.

• Carbon Capture and Storage for coal-fired generating stations. WMSP should contribute • Climate change adaptation. towards sustainable • Consideration of “good design” for energy infrastructure. development by encouraging energy infrastructure (but only This NPS has additional policy on: where there is an identified • Air emissions; need). • Landscape and visual; • Noise and vibration; • Release of dust by coal-fired generating stations; • Residue management for coal-fired generating stations; and

• Water quality and resources

National Policy Statement This NPS does not seek to repeat the material set out in EN-1, which applies to WMSP should ensure its policies SA framework should reflect (EN3) – Renewable Energy all applications covered by this NPS unless stated otherwise. The reasons for help to deliver the UK’s the objectives identified in Generation, including Wind policy that is specific to the energy infrastructure covered by this NPS are obligations in terms of reducing the NPS, especially in terms Farms, energy from waste and given, but where EN-1 sets out the reasons for general policy these are not green house gas emissions and of assessing the contribution biomass plant fossil (July, Repeated. cutting carbon through renewable of renewable energy within 2011) energy production. the County.

WMSP should contribute towards sustainable development by encouraging energy infrastructure (but only where there is an identified need).

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A83

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Renewable Energy Strategy Target to ensure 15% of our energy comes from renewable sources by 2020: The WMSP should ensure that its SA Framework should (DECC, 2009) almost a seven-fold increase in the share of renewables in just over a decade. policies work toward the 2020 include objectives and renewable energy target. indicators relating to Lead scenario suggests that we could see: renewable energy.

• More than 30% of our electricity generated from renewables, up from about 5.5% today. Much of this will be from wind power, on and offshore, but biomass, hydro and wave and tidal will also play an important role. • 12% of our heat generated from renewables, up from very low levels today. We expect this to come from a range of sources including biomass, biogas, solar and heat pump sources in homes, businesses and communities across the UK.

• 10% of transport energy from renewables, up from the current level of 2.6% of road transport consumption. The Government will also act to support electric vehicles and pursue the case for further electrification of the rail network.

The UK Low Carbon The UK Government has a five point plan to tackle climate change. The WMSP should ensure SA Framework should Transition Plan: policies create a low carbon include objectives and NationalStrategy for Climate 1. Protecting the public from immediate risk. environment. , which promote a indicators relating to carbon Change and Energy (TSO 2. Preparing for the future. decrease in emissions. reduction. – 2009) 3. Limiting the severity of future climate change through a new international climate agreement. WMSP should emphasis a 4. Building a low carbon UK. reduction in waste of high carbon 5. Supporting individuals, communities and businesses and energy products to play their part.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A84

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Sustainability Appraisal Objective 16 – To contribute to the growth of a sustainable and diversified economy, and; Sustainability Appraisal Objective 17 – To provide employment opportunities and develop and maintain a skilled workforce. Strategy for Sustainable Farming • To produce safe, healthy products in response to market demands, Plan should take into the account SA Framework should and Food - Facing the Future and ensure that all consumers have access to nutritious food, and the resource available for consider protection of soil (DEFRA 2004) to accurate information about food products; growing food and to ensure as a resource. • To support the viability and diversity of rural and urban protection of soil from pollution. economies and communities; • To enable viable livelihoods to be made from sustainable land management, both through the market and through payments for public benefits; • To respect and operate within the biological limits of natural resources (especially soil, water and biodiversity); • To achieve consistently high standards of environmental performance by reducing energy consumption, by minimising resource inputs, and use renewable energy wherever possible; • To ensure a safe and hygienic working environment and high social welfare and training for all employees involved in the food chain; • To achieve consistently high standards of animal health and welfare; • To sustain the resource available for growing food and supplying other public benefits over time, except where alternative land uses are essential to meet other needs of society.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A85

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Regional Economic Strategy for The Strategy sets the vision, priorities and key actions for taking forward the RES objectives have synergy with SA to include economic the South East of England 2006- sustainable economic development of the region. It sits within the overall aims of WMSP in terms of objectives relating to: 2016 (SEEDA, 2006) context of the Integrated Regional Framework for sustainable development infrastructure and market Increasing the value and alongside the South East Plan the regional spatial strategy. support in order to mitigate ofwaste. effects of waste on climate Creating employment Identifies 3 key challenges and provides objectives and values which relate to change and to enhance economic opportunities. them: competitiveness of the region. Sustainable use of • The global challenge – investing in success and building on resource. excellence. The WMSP should encourage: • • Waste Including increasing • Smart growth – investing in potential to lift the minimisation and technologies and business prospects of underperforming areas, communities. recycling. opportunities associated • Sustainable prosperity – investing in and safeguarding • Markets for with sustainable waste quality of life. recyclable and management. recycled products. Also supporting the market 3 headline targets: • Development of sector of recycled materials • Achieve an annual average increase in Gross Value Added new technologies and and increasing skills in per capita of at least 3%. business opportunities waste and minerals • Increase productivity per worker by an average 2.4% annually. associated with employment. • Reduce rate of increase in regions ecological footprint, stabilise reducing, reusing and it and seek to reduce it by 2016. recycling waste. With indicators such as: • Reduction in water and energy consumption. • Diversification opportunities.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A86

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Identifies areas for: • Opportunities to increase • No. employed in • Regional transport hubs which will be centres of economic economic activity and to minerals and waste activity (Brighton & Hove and Hastings.); and enable more people to • Diamonds for investment and growth which will act as a benefit from the regions • No of new catalyst to stimulate prosperity (Brighton & Hove). prosperity. businesses creating/selling 8 transformational actions include: products from Global Leadership in Environmental Technologies – to exploit the recycled/recyclable business opportunities created by reducing carbon emissions and waste materials. generation.

Strategy recognises that a more sustainable approach to consumption and production leads to a different view of waste where: • Waste has significant resource value and coupled with resource reduction and resource efficiency can benefit the economy and environment, and • More productive uses for discarded material need to be found – including reuse, remanufacturing and recycling and the development of associated markets.

Most relevant objective is: Sustainable Prosperity Target 12 – Sustainable consumption and production. Achieve 30% increase over the 2003 baseline in Gross Value Added (GVA) generated per tonne of materials entering the waste stream by 2016.

Actions that relate specially to waste and minerals include: supporting and facilitating the creation of projects in waste minimisation, re-use or resource swapping and which extract maximum value from waste. Also supports sustainable construction.

Other targets acknowledge the need for reducing CO2, increasing renewable energy reducing water consumption, and improving the quality, biodiversity and accessibility of green and open space.

Targets to increase economic activity and to enable more people to benefit from the regions prosperity are covered under the objectives Smart Growth and Sustainable Prosperity.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A87

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA East Sussex Economic Three cornerstone or 'flagship' projects are seen as the ultimate goals of WMSP - reflect priorities by: SA Objectives and indicators Strategy 2003-2013 (ESCC) economic strategy and vision for East Sussex over the next five to ten years. • development of to reflect the vision. • Integrated Transport Initiatives; infrastructure to ensure • Knowledge and skills based economy; and sustainable W&M • Rural and urban revival. transportation; • encouraging markets These 3 cornerstones reflect the Regional Economic Strategy priorities. for recycled and recyclable materials; and • promoting increases in skills in related sectors.

Brighton & Hove Economic The Strategy places emphasis on: WMSP should provide a robust SA should check that Strategy 2008- • Dynamic, ambitious, open and effective leadership by individuals in the planning policy framework to WMSP supports economic 2013 public and private sectors; enable adequate new waste growth via the provision of • Increasing the standards of our schools and FE colleges; management facilities and sufficient capacity minerals • Harnessing the talent and innovation of the Universities; minerals extraction/processing to and waste management • Increasing the value of the jobs in the city at both ends of the salary scale; come forward to support facilities. • The determination to embrace change in the cityscape to a high quality of economic growth as defined by design; the B&H Economic Strategy, SA should check that site • The encouragement of distinctive site development to provide jobs and whilst also aiming to protect allocation criteria aim to homes; existing businesses in the City protect the amenity of • Investment in a distinctive and characteristic cultural offer for the city; from potential negative impacts of existing businesses. • Investment in a world-class conference offer for the city; and waste and minerals management. • Developing a mixed housing stock suitable for the needs of the population A significant reduction in congestion and improved transport to keep the city moving.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A88

Title Key objectives, targets and indicators relevant to Plan and SA Implications for Plan Implications for SA Local Growth White Paper The Government has outlines a new approach to local growth, shifting power The WMSP should reflect the SA should ensure that policies (BIS, October 2010) away from central government to local communities, citizens and independent priorities of the white paper, within the WMSP tackle providers. This means recognising that where drivers of growth are local, including ensuring that local barriers to growth. decisions should be made locally. drivers of growth decisions are The Government will therefore: made by local people where • shift power to local communities and business, appropriate. enabling places to tailor their approach to local circumstances; • promote efficient and dynamic markets, in particular in the supply of land; • provide real and significant incentives for places that go for growth; and • support investment in places and people to tackle the barriers to growth.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL A89

Annex B

Baseline Data

Indicator Brighton & Hove and East Sussex Comparators

Social

1. To avoid negative effects and enhance, where possible, positive effects on health.

Life expectancy at birth 2006-08 2007-09 2008-10 2009-11 2010-12 2006-08 2007-09 2008-10 2009-11 2010-12 Male Male Brighton & Hove 76.6 77.2 77.8 78.5 78.7 England & Wales 77.8 78.1 78.4 78.8 79.1 Eastbourne 78.5 78.7 78.2 78.5 78.7 Hastings 76.3 76.6 77.2 76.7 77.5 Lewes 80.3 80.6 80.6 80.7 80.9 Rother 79.4 79.6 79.7 79.9 80.1 Wealden 80.5 80.8 80.4 80.6 81.0

Female Female Brighton & Hove 82.2 82.2 82.8 82.6 83.0 England & Wales 81.9 82.2 82.4 82.8 82.9 Eastbourne 82.7 83.3 83.4 83.6 83.5 Hastings 80.5 80.7 80.8 81.0 81.2 Lewes 83.8 84.2 84.4 84.9 84.8 Rother 83.3 83.5 83.8 83.6 83.9 Wealden 83.7 84.3 84.1 84.5 84.2

Health deprivation - 2007 2010 Not available proportion of population Brighton & Hove 25.2% 43.5% living in 20% most deprived East Sussex 11.8% 38.5% Super Output Areas Eastbourne 16.9% 35.1% nationally (health domain) Hastings 42.0% 58.7% (see map 2) Lewes 0.0% 31.0% Rother 6.8% 15.5% Wealden 0.9% 0.0%

Pollution incidents 2009 2010 2011 2012 2013 (air, land and water) Brighton & Hove 1 2 1 0 0 Eastbourne 0 1 0 0 0 Hastings 0 0 0 0 0 Lewes 1 0 4 2 0 Rother 0 0 0 0 0 Wealden 1 4 4 1 1

2. To protect the amenity of residents and neighbouring land uses.

Areas of Remoteness East Sussex is a well-populated county with a strongly humanized landscape. It is difficult to get very far from buildings, roads and vehicles and there is no (see map 9) real wilderness landscape, hence the county as a whole cannot be noted for its remoteness. For this reason where remote landscapes exist in the County they are highly valued for the sense of 'getting away from it all' and tranquillity they can provide.

Public open space Hectares No. of sites Brighton & Hove 362 282 Note: Public Open Spaces include: provision for children and young people, parks & gardens, outdoor sports facilities (Open Space, Sports and Recreation Study 2008) Eastbourne 224 153 Note: Public Open Spaces include: parks, recreation grounds, play areas and public sports pitches Hastings 161 76 (last update July 2009) Lewes 144 169 Rother 4844 175 (last update April 2010) Wealden 683 159

3. To improve equality and access to sustainable waste management.

Percentage of 2005/06 2006/07 2008/09 2006/07 2007/08 households served by Brighton & Hove 87% 92% 97% Average for all 95.0% 97.6% kerbside collection of East Sussex English district recyclable materials Eastbourne 94% 92% 100% councils Hastings 93% 100% 100% Lewes 88% 90% 93% Rother 63% 61% 88% Wealden 60% 60% 65%

Number of waste management 103 waste management facilities are permitted in the Plan area, of which 6 facilities are household waste amenity sites. Three of these are in Brighton and Hove, one is in Lewes, one is in Eastbourne and one is in Crowborough.

Environment

4. To minimise waste generation and disposal to land.

Total tonnage of municipal 2007/08 2008/09 2009/10 2010/11 2011/12 2007/08 2008/09 2009/10 2010/11 2011/12 waste Plan area 381,614 371,145 366,744 365,740 359,991 England 28,506 27,334 26,541 26,200 25,419 (Comprises household South East 4,563 4,328 4,230 4,230 4,146 waste plus some trade (thousand tonnes) waste, street sweepings, parks & gardens waste collected by LAs)

1 Indicator Brighton & Hove and East Sussex Comparators

Total tonnage of household 2007/08 2008/09 2009/10 2010/11 2011/12 2007/08 2008/09 2009/10 2010/11 2011/12 waste Plan area 362,993 352,731 348,214 348,589 342,382 England 25,287 24,334 23,666 23,454 22,900 South East 4,242 4,038 3,937 3,920 3,852 (thousand tonnes)

% of municipal waste being 2007/08 2008/09 2009/10 2010/11 2011/12 2007/08 2008/09 2009/10 2010/11 2011/12 reused, recycled or composted Plan area 33% 34% 35% 35% 36% England 34.0% 36.8% 38.6% 40.2% 41.8% South East 36.7% 39.1% 40.6% 41.9% 44.2%

% of household waste being 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 reused, recycled or composted Plan area 32% 33% 34% 35% 36% England 43% (Does not include waste composted at home by householders)

Percentage of municipal waste 2007/08 2008/09 2009/10 2010/11 2011/12 2007/08 2008/09 2009/10 2010/11 2011/12 arisings used to recover heat, Plan area 10% 20% 26% 25% 43% England 11.1% 12.1% 13.6% 15.1% 19.1% pwer or other energy South East 12.1% 15.3% 21.5% 25.6% 30.6%

Percentage of household waste 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 arisings used to recover heat, Plan area 10% 21% 28% 26% 45% England 22% power or other energy

% of municipal waste going 2007/08 2008/09 2009/10 2010/11 2011/12 2007/08 2008/09 2009/10 2010/11 2011/12 to landfill Plan area 57% 46% 39% 40% 21% England 54.4% 50.3% 46.9% 43.3% 37.4% South East 51.2% 45.6% 37.9% 32.7% 25.1%

% of household waste 2007/08 2008/09 2009/10 2010/11 2011/12 Not monitored at higher levels. going to landfill Plan area 58% 46% 39% 39% 19%

Commercial and industrial Brighton & Hove No data available South East waste 2002/03 (% of total East Sussex Chemicals 10.2% waste) Chemicals 8.1% Metallic 4.2% Metallic 3.6% Non Metallic 24.0% Non Metallic 25.1% Discarded Equip 0.7% Discarded Equip 0.8% Animal and Plant 8.6% Animal and Plant 9.4% Mixed 38.6% Mixed 45.3% Common Sludges 1.1% Common Sludges 1.0% Mineral Wastes 12.5% Mineral Wastes 6.6% (estimate) (estimate) Total commercial and industrial 1998/99 2002/03 2006/07 2008/09 1998/99 2002/03 waste Brighton & Hove n/a n/a n/a n/a South East (tonnes) East Sussex Ind 3,988 3,581 Ind 187,000 175,000 Com 5,013 5,271 Comm 380,000 415,000 Total 9,001 8,852 Total 567,000 590,000 367,000 475,000 (thousand tonnes)

Commercial and industrial 2011/12 waste as a % of total waste Plan area 27%

% of commercial and industrial 2008/09 waste reused, recycled or Plan area 71% composted

% of commercial and industrial 2008/09 arisings used to recover heat, Plan area 0% power or other energy

% of construction and demolition 2008/09 waste being recycled Plan area 45%

% of construction and 2008/09 demolition waste going to Plan area 15% landfill

Total hazardous waste 2006 2007 2009 South East 2006 2007 2009 (tonnes) Plan area 21,853 22,740 19,286 477,042 532,116 505,870

2 Indicator Brighton & Hove and East Sussex Comparators

5. To ensure the most sustainable use of mineral resources.

Supply of land-won sand and 2007 2008 2009 2010 2011 2007 2008 2009 2010 2011 gravel (tonnes) Plan area 311,797 312,118 359,745 359,250 199,032 South East 8,502 7299 6007 6180 5824 (thousand tonnes)

Landings of marine dredged 2008 2009 2010 2011 2012 2007 2008 2009 2010 2011 sand and gravel (thousand Plan area 205 106 155 n/a 78 South East 6,507 5,828 4,800 4,825 5,599 tonnes)

Marine imports of crushed 2008 2009 2010 2011 2012 2007 2008 2009 2010 2011 rock (thousand tonnes) Plan area 145 145 129 n/a n/a South East 3,000 2,305 1,500 1881 1,945

Annual production (tonnes) 2011/12 2011 of secondary and recycled Plan area South East aggregates (estimate) Recycled aggregates 240,000 Recycled aggregates2,500,000 Secondary aggregates 68,000 Secondary aggregates300,000 Total 308,000 Total 2,800,000 Figures are from incomplete returns and should therefore be treated with caution and not as a precise figure.

Extractors' sales of clay 2004 2005 2006 2007 2003 2004 2005 2006 2007 and shale (thousand tonnes) East Sussex 163 119 126 127 South East 910 1156 951 1,018 920

6. To maintain and improve water quality. 2011 Percentage of beaches In 2013 Brighton & Hove achieved 100% 2013 Southern 13% meeting the EU mandatory compliance with the EU mandatory standards. 100% standards of bathing water In 2013 all four bathing waters quality achieved the more stringent EU guideline standards. 2011 In 2013 East Sussex achieved 100% 2011 2013 National 13% compliance with the EU mandatory standards. 21% 100% Of the 11 designated bathing waters, 9 achieved the more stringent EU guideline standards.

Groundwater quality Results from the South East River Basin District Management Plan published in December 2009 show that 43% of groundwater in the South East River Basin District meets good quantitative status and 63% meets good chemical status.

Surface water quality Results from the South East River Basin District Management Plan published in December 2009 show that 19% of surface waters have ‘good ecological status’ and 40% are at least ‘good’ biological status. The majority of water bodies are failing on only one area, generally the fish or invertebrate elements of the classification.

Chemical Water Quality - There are no classified river stretches in Brighton & Hove 2002 2003 2004 2005 2006 Percentage of river length administrative area. South East 57.6 58.9 54.8 61.3 65.0 assessed as good/very 2002 2003 2004 2005 2006 England 75.3 73.1 72.2 73.4 74.4 good chemical quality East Sussex 38.2 45.7 37.2 49.7 58.1

Biological water quality - There are no classified river stretches in Brighton & Hove 2002 2003 2004 2005 2006 percentage of river length administrative area South East 76.7 76.4 78.2 78.2 77.3 assessed as good/very 2002 2003 2004 2005 2006 England 69.8 70.6 71.1 71.5 72.1 good biological quality East Sussex 77.1 79.4 80.6 82.6 79.5

Groundwater Indicates areas where groundwater resources are vulnerable to pollution. Aquifers are classified according to the properties of the rocks and the overlying soils. Areas most vulnerable are where major aquifers vulnerability (see map 8) lie close to the surface and is covered by only a thin freely-draining soil. The south west coastal area including Brighton & Hove and Eastbourne and the South Downs are the most vulnerable within the plan area.

7. To seek the protection of and sustainable use of water resources.

Water consumption from Water is provided in the plan area by South East Water and Southern Water. The environment Agency considers the South East as a 'water stressed commercial and industrial Southern Water area'. customers Sussex Coast area - includes Brighton &Hove and part of Lewes. The South East of England experienced a prolonged period of below average Area was in surplus in 2006/07 and remained in surplus in 2007/08. rainfall between October 2004 and August 2006. The drought affected customers with restrictions on water use such as hosepipe and sprinkler Sussex Hastings - including Hastings and part of Rother. bans. So far, the actions of water companies and their customers has Area had deficit against target headroom in 2003/04 this has continued and minimised the risk of serious supply problems in the South East. the area was still in deficit in 2007/08.

South East Water Resource zones 2 and 3 covers most of East Sussex Large deficit in 2002/03 improved to ‘marginal deficit in 2004/05 as a result of the completion of the Bewl/Darwell/Hazards Green transfer pipeline. Both zones were is surplus during 2007/2008.

3 Indicator Brighton & Hove and East Sussex Comparators

Water efficiency (target) (litres per person per day) 2013 2040 2012 Southern Water 152 130 UK 150 South East Water 160 149

Groundwater Source Source Protection Zones indicate the risk to groundwater supplies from potentially polluting activities and accidental release of pollutants. Zones have been defined for groundwater sources such as wells, Protection Zones boreholes and springs used for public drinking water supplies. The closer the activity the greater the risk. The maps show three main zones (inner, outer and total catchment. The majority of protection zones (see map 17) are in the south west of the plan area within the chalk formations of the South Downs.

8. To reduce risk and impact of flooding

Properties in the extreme 2006 2009 2010 (% of all properties) 2006 2009 2010 flood outline (1 in 1000 year Brighton & Hove 932 934 n/a England 9.0% flood or 0.1% probability) East Sussex 27,093 27136 27,661 South East 3.7% 4.3% East Sussex 11.6% 11.5% 11.6%

England & Wales 2.3m estimated (9% of all properties lie in areas at risk of flooding)

Flood risk areas This map depicts the probability of sea and river (main rivers) flooding only, ignoring the presence of existing defences. (see map 7) It is only indicative of flood zones 3 and 2, flood zone 1 being all the land falling outside zones 3 and 2. It does not show all forms of flood risk in the Plan area. Other forms of flooding include; flooding from land, groundwater, sewers and other artificial sources (e.g. reservoirs, canals, lakes)

The Strategic Flood Risk Assessment provides more detailed information, covers all forms of flooding and including allowances for climate change.

9. To limit the causes of and adapt to climate change.

Carbon dioxide emissions 2007 2008 2009 2010 2011 2007 2008 2009 2010 2011 Total emissions in kilotonnes Brighton and Hove 1359.9 1336.2 1218.0 1274.6 1151.0 South East 64913.5 63128.5 57498.6 59670.5 54633.9 Eastbourne 488.3 475.5 432.9 452.9 412.2 Hastings 414.2 404.5 367.3 385.3 348.8 Lewes 569.1 559.5 512.1 527.8 488.0 Rother 627.2 601.9 543.2 566.5 520.5 Wealden 966.8 944.4 874.3 898.9 840.3 Total 6432 6330 5957 6116 5772

Carbon dioxide emissions 2007 2008 2009 2010 2011 2007 2008 2009 2010 2011 Total emissions per capita Brighton and Hove 5.3 5.1 4.6 4.7 4.2 England 8.2 8.0 7.1 7.3 6.7 (tonnes) Eastbourne 5.0 4.8 4.4 4.6 4.2 South East 7.8 7.5 6.8 7.0 6.3 Hastings 4.7 4.6 4.1 4.3 3.9 Lewes 6.0 5.9 5.3 5.4 5.0 Rother 7.0 6.7 6.0 6.3 5.7 Wealden 6.6 6.4 6.0 6.1 5.6

Carbon dioxide emissions Plan area 2007 2008 2009 2010 2011 England 2007 2008 2009 2010 2011 by end user (kilotonnes) Industry and commercial 31% 30% 29% 30% 29% Industry and commercial 43% 43% 41% 41% 41% Domestic 41% 42% 41% 43% 41% Domestic 29% 30% 30% 31% 29% Transport 29% 29% 31% 29% 31% Transport 27% 27% 29% 27% 29% Land use, land use change-1% and forestry-1% -1% -1% -1% Land use, land use change 1%and forestry1% 1% 1% 1% change and forestry change and forestry

10. To protect air quality and reduce air pollution

Air Quality Management In 2005 Brighton & Hove City Council declared an (AQMA) Not available Areas (AQMA) related to exceedences of the annual average objective (see maps 4a and 4b) for nitrogen dioxide (NO2). The area was increased in 2008 but in 2013 the boundary was redrawn which reduced the AQMA to a quarter of its previous size. Broadly speaking, the AQMA covers much of the seafront, key roads heading from the seafront into the city, and part of the city centre. Within the AQMA, nitrogen dioxide exceeds Air Quality Objectives, a pollutant usually associated with road traffic.

In 2004 Hastings Borough Council declared and AQMA related to exceedences of PM10. The area encompasses properties between the junction of the A259 (Bexhill Road) and Harley Shute Road, and number 576 Bexhill Road on its northern side, and numbers 211 to 585 Bexhill Road on its southern side.

Lewes District Council declared an (AQMA) in Lewes in 2005 due to exceedence of the air quality objective for nitrogen dioxide (NO2 of 40 ug/m3 in 2005). The area focuses on the Station Road, Fisher Street, West Street area of Lewes. Newhaven has been identified as having possible exceedences of nitrogen dioxide. Further monitoring is being carried out.

Carbon dioxide emissions Crosscutting - See objective 9 by end user.

4 Indicator Brighton & Hove and East Sussex Comparators

11. To reduce adverse impacts of transporting waste and minerals on the environment

Total freight traffic per 2007 2008 2009 2010 2011 2007 2008 2009 2010 2011 annum - ports (thousand Shoreham (B&H) 1,871 1,677 1,587 1,685 1,889 All UK ports 581,504 562,166 500,881 511,855 519,495 tonnes) Newhaven (ES) 684 850 554 464 352 Rye (ES) 52 47 45 72 41

Shoreham (B&H) 81% of the freight was dry bulk in 2011. Newhaven (ES) Ro-ro (roll-on roll-off) traffic formed the main types of traffic in 2011. There were also 329000 passenger movements through the port. Rye (ES) The current wharf is well-used by a steady inflow of imported aggregates, although navigational constraints restrict the type and size of vessel and therefore the volumes that can be handled. NB. Rye Wharf Ltd is said to have expansion plans.

Estimated traffic flows for all 2008 2009 2010 2011 2012 2008 2009 2010 2011 2012 motor vehicles (million Brighton & Hove 1,376 1,356 1,329 1,329 1,339 South East 85,035 84,121 82,906 83,303 82,980 vehicle kms) East Sussex 4,274 4,208 4,135 4,125 4,100 England 428,494 424,402 417,767 418,866 417,051 (see map 1)

Carbon dioxide emissions from 2007 2008 2009 2010 2011 2007 2008 2009 2010 2011 road transport (thousand tonnes) Brighton and Hove 331.4 318.6 309.2 302.6 299.0 South East 20,836.0 19,855.6 19,183.8 18,948.1 18,728.5 Eastbourne 93.7 90.8 87.8 86.8 84.5 England 110,088.0 105,608.4 102,228.9 101,024.6 99,598.6 Hastings 81.0 78.5 76.0 75.3 73.9 Lewes 191.0 189.5 183.5 176.6 172.8 Rother 187.6 182.4 175.6 171.5 168.8 Wealden 394.8 376.2 361.1 355.7 349.3 Total 1,279.5 1,235.9 1,193.2 1,168.4 1,148.4

Road transport energy 2007 2008 2009 2010 2011 2007 2008 2009 2010 2011 consumption - freight traffic Brighton and Hove 22.1 23.1 22.4 22.9 22.5 South East 1,925.3 1,919.4 1,803.8 1,838.4 1,820.5 (kt of fuel) Eastbourne 5.1 5.3 5.1 5.1 5.0 England 10,809.4 10,840.2 10,201.9 10,321.8 10,198.6 Hastings 4.6 4.9 4.6 4.7 4.7 Lewes 15.2 16.2 15.5 14.8 14.6 Rother 15.0 15.2 14.2 14.3 14.1 Wealden 31.1 31.5 29.9 30.5 30.0 Total 93.1 96.2 91.8 92.3 90.9

12. To conserve and enhance important soil functions and types

Agricultural land (hectares) 2007 2010 % change 2007 2010 % change Brighton & Hove and Lewes 25 261 25 778 2% South East 1 208 460 1 140 878 -6% Hastings and Rother 35 881 34 222 -5% 9 291 357 8 887 289 -4% Eastbourne and Wealden 58 737 52 083 -11%

Agricultural land quality 2002 Grade Area % of land Grade Area % of land (see map 6) Brighton & Hove South East Excellent (1) 0 0.0 Excellent (1) 48,347 2.5 Very Good (2) 0 0.0 Very Good (2) 198,851 10.4 Good/Mod (3) 2,700 32.8 Good/Mod (3) 998,587 52.4 Poor (4) 869 10.5 Poor (4) 307,979 16.1 Very poor (5) 0 0.0 Very poor (5) 25,379 1.3 Non Agricultural 809 9.8 Non Agricultural 182,208 9.6 Urban 3,865 46.9 Urban 145,963 7.7 Total 8,243 100.0 Total 1,907,314 100.0

East Sussex Excellent (1) 136 0.1 Very Good (2) 4,450 2.6 Good/Mod (3) 104,140 60.9 Poor (4) 37,618 22.0 Very poor (5) 802 0.5 Non Agricultural 15,437 9.0 Urban 8,373 4.9 Total 170,956 100.0

13. To protect, conserve and enhance East Sussex and Brighton & Hove's countryside and historic and built environment.

Amount of available previously Of which percentage Of which percentage developed land (PDL) in 2007 Total already committed Total already committed hectares for development hectares for development Brighton & Hove 75 18.7% South East 8,990 52.7% East Sussex 311 62.2% England 62,120 28.6%

Eastbourne 29 77.9% Hastings 24 33.3% Lewes 159 88.6% Rother 30 11.6% Wealden 69 26.2%

National Park and The High Weald AONB reaches from Horsham in the west to Hastings in the East, crosses 4 counties (West & East Sussex, Kent Areas of Outstanding and a corner of Surrey), covers a total of 1457 sq km of countryside, 11 district authorities are within the High Weald and 99 Natural Beauty parishes have some or all of their area in the AONB, which has a population of over 120,000 one of the most populated AONB's in the (see map 10) country. The South Downs National Park came into existence on 1 April 2010. It covers an area of land along the coastal strip, encompassing Brighton and Hove in the west and stretching to the outskirts of Eastbourne in the east, and inland just north of Lewes. It covers an area of over 1,600 km2 and is home to more than 110,400 people. Recognised as an area of outstanding beauty, the South Downs is also home to a multitude of vibrant working communities steeped in history and traditional English culture. The Sussex Downs AONB was revoked on 31 March 2010 when the South Downs National Park came into existence.

Heritage Coast Heritage Coasts are a non-statutory landscape definition defined by agreement between the relevant maritime local authorities and (see map 19) Natural England. The coast between Seaford and Eastbourne (inland as far as the A27) forms the Sussex Downs Heritage Coast and includes Beachy Head and the Seven Sisters. It is 6 miles long and was the first to be defined in 1973. Sussex Heritage Coast has a non-statutory designation, however, the Sussex Downs AONB extends to the base of the coastal cliffs. The purpose of both designations have strong similarities and the AONB designation provides statutory protection for many features of the East Sussex Heritage Coast.

5 Indicator Brighton & Hove and East Sussex Comparators

Statutory designated 2013 Listed Scheduled WrecksAncient MonumentsRegistered RegisteredConservation historic environment assets buildings monuments parks/gdns battlefield areas Brighton & Hove 1222 15 1 6 0 34 Eastbourne 128 39 0 2 0 12 Hastings 562 6 1 2 0 2 Lewes 1262 116 0 5 1 35 Rother 2134 45 0 7 1 10 Wealden 2212 104 0 20 0 34 Total 7520 325 2 42 2 127

Non-statutory designated As at 15/11/13 there were 14,103 entries on the East Sussex Historic Not available historic environment assets Environment Record, covering East Sussex and Brighton and Hove. The HER is a record of the known archaeology of the county and city. The Historic Environment Record (HER) is continually having records added and being refined as more archaeological work is carried out.

Historic Landscape HLC & EUS map time depth and change in the landscape. Characterisation (HLC) HLC covers all East Sussex and Brighton and Hove. Extensive Urban Surveys (EUS) Extensive Urban Surveys cover approximately 20 historic towns in East Sussex and Brighton and Hove.

East Sussex County East Sussex is covered by four regional character areas: Landscape Assessment The High Weald: This is distinct and diverse landscape with a broken and dissected landform of ridges, ghylls and streams and east-west valleys. This is formed of small, irregular fields, abundantwoods, hedges, ridge top villages, scattered settlements and sunken lanes. It is a classic patchwork countryside which has remained essentially the same since medieval times. It rises to the north of the Low Weald and is the largest East Sussex landscape region occupying the northern half of the county. The Low weald: This broad low lying, gently undulating clay vale underlies a small-scale landscape with a mix of copses and shaws, a patchwork of fields and hedgerows. In the east, this gives way to a more open and sometimes prairie - like landscape. It lies between the High Weald and the Downs, and is between 5 - 8 kms wide. The Downs: The north facing scarp line of chalk hills provides a dramatic backdrop to the Low Weald. These are Kipling's 'blunt, bow-headed, whale-backed Downs'. The northern slopes or scarp are characterised by close cropped turf and woodland, with the dipslope supports arable farming. This is the distinct upland area between the sea and the Low Weald. Most but not all of the area is coincident with the AONB. The East Sussex Downs run from the western edge of the county to Eastbourne. The Levels: This is an open and expansive landscape of grazed wet meadows, criss-crossed by reed filled ditches.There are few trees and hedgerows, but has a backdrop of the South Downs, and the High Weald. The landscape area is not contineous but occurs in two separate units: the Eastbourne and the Pevensey levels, and the Rye - Winchelsea area.

14. To protect, conserve and where appropriate enhance East Sussex and Brighton & Hove's biodiversity and geodiversity.

SSSI area by condition FavourableUnfavourableUnfavourable, recoveringUnfavourable no changePart declining destroyed (hectares) Brighton & Hove 188.36 0 0 0 0 (see map 13) Eastbourne 109.46 150.24 0 0 0 Hastings 432.17 50.96 0 31.55 0 Lewes 1422.79 977.73 9.73 26.5 0 Rother 558.97 1467.39 8.92 0.15 17.84 0.982122869 Wealden 907.79 6623.55 114.44 25.49 0 Total 3619.54 9269.87 133.09 83.69 17.84 13124.03

Ancient woodland cover 2001 2011 % increase in area of AW (Area recorded in Ancient Brighton & Hove 95 94 -1 Woodland Inventory) Eastbourne n/a n/a n/a (hectares) Hastings 128 145 13.3 (see map 16) Lewes 1,019 1,156 13.4 Rother 7,595 8,055 6.1 Wealden 9,754 11710 20.1

Special Protection Areas Ashdown Forest (see map 11) Site Area (ha) 3,207 General site character 50% heath scrub 40% mixed woodland 10% bog marsh Quality and importance Regularly supports 1% of GB breeding population of Nightjars 1.30% of Dartford Warbler population

Dungeness to Pett Level (also a proposed Ramsar site) Site Area (ha) 1,474 General site character 35% improved grassland 15% total river, estuaries, mud and sand flats 15% shingle, sea cliff 12% inland water bodies Quality and importance Regularly supports 9% of GB breeding population of Mediterranean Gull 1.50% of little Terns 2.25% of Common Terns 2.50% of Berwick's Swans 1.00% of population of Northern Shovelers

Special Areas of Site Area (ha) Conservation Ashdown Forest 2729 (see map 11) Castle Hill 115 Dungeness (partially in East Sussex) 3224 Hastings Cliffs 184 Lewes Down 147 Total 6399

Ramsar Wetlands Pevensey Levels (also National Nature Reserve) (see map 11) Site Area (ha) 3578 General site character One of largest and least-fragmented lowland wet grassland systems in South East Quality and importance Site supports an outstanding collection of wetland plants and invertebrates. It supports 68% of vascular plant species in Great Britain that can be described as aquatic. It is best site in Britain for freshwater molluscs. Many types of flowering water plant grow here, some of which are nationally rare. There are high numbers of dragonflies and damselflies present and the site is among the top five locations in Great Britain for aquatic beetles. Dungeness to Pett Level also a proposed Ramsar site ( See Special Protection Areas above)

National Nature Reserves Site Area (ha) (see map 20) Castle Hill 47 Lewes Downs 49 Lullington Heath 62 Pevensey Levels 182

6 Indicator Brighton & Hove and East Sussex Comparators

Area of land designated a 2000 2006 2000 2006 local nature reserve Brighton & Hove n/a 359.3 South East 7,713 8,976 (hectares) East Sussex 993 1,412 (see map 20) Total 1771.3

Sites of Nature Brighton & Hove has 62 SNCIs covering 612.3 hectares or Conservation Importance 7.3% of total administrative area of city. (SNCIs) (see map 21) Number of SNCIs in East Sussex: Eastbourne 19 Hastings 30 Lewes 98 Rother 60 Wealden 97

15. To increase energy efficiency and the proportion of energy generated from renewable sources

Gas consumption per 2005 2006 2007 2010 2011 2005 2006 2007 2010 2011 commercial/industrial Brighton & Hove 312,636 312,148 320,373 388,228 334,437 South East 506,024 422,413 443,648 513,391 447,641 consumer (K/Wh) East Sussex 350,292 362,944 369,149 374,729 364,967 England 659,026 655,549 Eastbourne 371,324 358,117 Hastings 292,781 265,213 Lewes 314,354 305,502 Rother 775,491 758,860 Wealden 222,352 223,794

Electricity consumption per 2007 2008 2009 2010 2011 2007 2008 2009 2010 2011 commercial/industrial Brighton & Hove 41,355 41,795 41,078 41,246 39,821 South East 71,499 71,984 70,434 71,429 68,765 consumer (K/Wh) Eastbourne 45,345 45,724 45,433 45,063 45,081 England 78,068 78,535 74,934 76,393 72,416 Hastings 39,196 39,300 39,572 40,908 39,963 Lewes 39,430 39,525 38,432 38,962 38,542 Rother 37,075 35,451 33,509 35,059 34,146 Wealden 32,272 32,719 32,843 33,306 33,427

Economic

16. To contribute to the growth of a sustainable and diversified economy.

Population growth 2001 2011 increase 2001 2011 increase (persons) Brighton & Hove 248,073 273,369 10.2% South East 8,023,449 8,634,750 7.6% East Sussex 493,130 526,671 6.8% England 49,138,831 53,012,456 7.9% Eastbourne 89,836 99,412 10.7% Hastings 85,392 90,254 5.7% Lewes 92,247 97,502 5.7% Rother 85,471 90,588 6.0% Wealden 140,184 148,915 6.2% Total 1,236,334 800,040

Population projections 2011 2021 increase 2011 2021 increase Brighton & Hove 273,369 289,902 6.0% South East 8,634,750 9,453,452 9.5% East Sussex 526,671 568,291 7.9% England 53,012,456 57,687,784 8.8% Eastbourne 99,412 107,293 7.9% Hastings 90,254 95,459 5.8% Lewes 97,502 109,514 12.3% Rother 90,588 99,822 10.2% Wealden 148,915 156,203 4.9%

Housing completions (total) 2007/08 2008/09 2009/10 2010/11 2011/12 Brighton & Hove 567 721 380 283 309 Eastbourne 280 387 222 121 217 Hastings 283 241 155 77 209 Lewes 416 257 175 161 204 Rother 177 222 95 200 426 Wealden 415 349 337 709 619 Total 2138 2177 1364 1551 1984

Future housing provision per year total (2009 baseline) (annual average) Brighton & Hove 565 11,300 to 2030 570 East Sussex 1,265 23,147 1,500 Eastbourne 239 5,022 to 2027 240 Hastings 200 3,400 to 2028 210 Lewes 225 4,500 to 2030 220 Rother 335 5,700 to 2028 280 Wealden 266 4,525 to 2027 550

Gross value added per head 2007 2008 2009 2010 2011 2007 2008 2009 2010 2011 at current basic prices Brighton & Hove 20,874 21,030 20,301 20,703 20,914 South East 21,636 21,877 21,266 21,898 22,369 (£) East Sussex 13,999 14,047 13,573 14,063 14,371 England 20,681 20,992 20,531 21,054 21,349

17. To provide employment opportunities and develop and maintain a skilled workforce.

Employment deprivation 2007 2010 Not available (% of SOAs in 20% most Brighton & Hove 20% 18% deprived in England) Eastbourne 15% 22% (see map 18) Hastings 42% 49% Lewes 0% 2% Rother 12% 16% Wealden 1% 2%

Employment rate 2008/09 2009/10 2010/11 2011/12 2012/13 2008/09 2009/10 2010/11 2011/12 2012/13 (% of working age population Brighton & Hove 78% 78% 75% 77% 77% England 77% 77% 76% 77% 77% in employment) Eastbourne 76% 80% 85% 80% 78% South East 80% 80% 79% 79% 79% Hastings 76% 79% 75% 73% 72% Lewes 80% 79% 79% 78% 80% Rother 76% 75% 78% 74% 73% Wealden 80% 82% 75% 78% 80% Total 78% 79% 77% 77% 77%

7 Indicator Brighton & Hove and East Sussex Comparators

Number of persons employed 2004 2005 2006 2007 2011 2004 2005 2006 2007 2011 directly and indirectly in the Brighton & Hove n/a n/a n/a n/a n/a South East - 1016 3483 3002 1839 minerals industry who were East Sussex 22 23 32 45 46 England 20204 subject to the provisions of the Mines and Quarries Acts 1954 and 1969.

Employment in the waste 2003 2004 2005 2006 2007 2003 2004 2005 2006 2007 industry Brighton & Hove 100 100 500 600 600 Great Britain 102,100 106,000 108,300 115,500 119,600 (estimated number of jobs) East Sussex 500 700 700 700 800 South East 11,500 11,400 13,300 14,300 16,200

Employment in the waste 2003 2004 2005 2006 2007 2003 2004 2005 2006 2007 industry (estimate) Brighton & Hove 0.1% 0.1% 0.4% 0.4% 0.4% Great Britain 0.3% 0.3% 0.3% 0.4% 0.4% (percentage of all jobs) East Sussex 0.3% 0.5% 0.3% 0.3% 0.4% South East 0.3% 0.3% 0.3% 0.4% 0.4%

Workforce skills Plan area 2008 2009 2010 2011 2012 England 2008 2009 2010 2011 2012 (percentage of working age No qualifications 10% 8% 8% 9% 8% No qualifications 13% 12% 11% 10% 9% population by qualification NVQ 1 14% 12% 13% 13% 12% NVQ 1 14% 14% 13% 13% 12% level) NVQ 2 16% 17% 17% 16% 16% NVQ 2 16% 16% 16% 17% 17% (see map 15) Trade apprenticeships 4% 4% 4% 3% 3% Trade apprenticeships 4% 4% 4% 3% 3% NVQ 3 18% 17% 16% 18% 18% NVQ 3 15% 15% 16% 16% 17% NVQ 4+ 31% 34% 37% 37% 36% NVQ 4+ 28% 30% 31% 33% 34% Other 8% 8% 6% 5% 6% Other 9% 9% 9% 7% 6%

2012 2012 Percentage of working age Brighton & Hove 6.1% England 9.5% population with no qualifications Eastbourne 13.0% Hastings 11.8% Lewes 6.9% Rother 7.2%

8 Annex C

Maps

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C1

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C2

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C3

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C4

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C5

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C6

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C7

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C8

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C9 ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C10 ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C11 ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C12 ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C13 ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C14 ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C15 ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C16 ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C17 ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C18 ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C19

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL C20 Annex D

Appraisal of Policies

Key: Impacts Significance Probability of effects Direct or indirect effects Reversibility + positive impact Low significance L low probability D direct effect  reversible effect - negative impact Medium significance M medium probability I indirect effect  not reversible ie permanent effect 0 no significant impact High significance H high probability

? impact unknown Ø not relevant Multiple symbols are used to indicate differential scale of effects over time

Table D.1 Policy WMSP1 Safeguarding Waste Sites

Objectives Short Med Long Comments Prob Dir/Ind Rev? 1. To avoid negative effects and enhance, where + + ? By seeking to prevent existing waste facilities from H I  possible, positive effects on health. being prejudiced from development proposals, the policy will indirectly help to ensure that adverse impacts on health from waste facilities on surrounding uses are prevented. 2. To protect the amenity of residents and + + ? By seeking to prevent existing waste facilities from H I  neighbouring land uses. being prejudiced from development proposals, the policy will indirectly help to ensure that adverse impacts on amenity from waste facilities on surrounding uses are prevented. 3. To improve equality and access to sustainable + + ? By safeguarding existing waste facilities the policy H D  waste management. will help to support enterprises involved in sustainable waste management. 4. To minimise waste generation and disposal to + + ? By safeguarding existing waste facilities the policy H D  land. will help to provide facilities to minimise disposal of waste to land.

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5. To ensure the sustainable use of local mineral + + ? By safeguarding recycled and secondary aggregates H D/I  resources. facilities, the policy will help to encourage and maximise the use of these materials and in so doing enable efficient management of mineral resources. It will also indirectly support sustainable construction and demolition. 6. To maintain and improve water quality. Not relevant 7. To seek the protection of and sustainable use of Not relevant water resources. 8. To reduce risk and impact of flooding. Not relevant 9. To limit the causes of and adapt to climate + + ? By safeguarding existing waste sites, the policy will M I  change. help to ensure sufficient facilities within the Plan Area to deal with waste arisings. This will minimise waste transport distances and promote waste recycling and energy recovery, leading to reduced energy use and reduced greenhouse gas emissions. 10. To protect air quality and reduce air pollution. + + ? By safeguarding existing waste sites, the policy will L I  help to ensure sufficient facilities within the Plan Area to deal with waste arisings. This will minimise waste transport distances and will contribute to avoiding adverse impacts on air quality from waste transport. 11. To reduce adverse impacts of transporting waste + + ? By safeguarding existing waste sites, the policy will H I  and minerals on the environment. help to ensure sufficient facilities within the Plan Area to deal with waste arisings. This will minimise waste transport distances and reduce adverse impacts of waste transport on the environment. It may also help to promote local supplies of recycled minerals. 12. To conserve and enhance important soil + + ? By safeguarding recycling facilities, the policy will L I  functions and types. indirectly help to ensure the supply of compost which can be used as a soil improver.

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13. To protect, conserve and enhance East Sussex + + ? By safeguarding secondary and recycled aggregates M/H I  and Brighton & Hove’s countryside and historic and facilities, the policy will indirectly help to reduce built environment. adverse impacts of mining on landscape and countryside, including on the SDNP and AONB. It will also help to optimise the use of previously developed land. 14. To protect, conserve and where appropriate + + ? By safeguarding secondary and recycled aggregates M/L I  enhance East Sussex and Brighton & Hove’s facilities, the policy will indirectly help to conserve biodiversity and geodiversity. geological resources in the Plan Area. It will also help to ensure sufficient facilities to deal with the Plan Area’s waste, which will help to reduce waste transport and may indirectly reduce adverse impacts of poor air quality on biodiversity, although this is much more strongly dependent on other policies and strategies. 15. To increase energy efficiency and the proportion + + ? By safeguarding existing waste facilities, the policy H/M D/I  of energy generated from renewable sources. will encourage recovery of energy from waste and indirectly help to encourage local supply chains in recycled materials and compost. 16. To contribute to the growth of a sustainable and + + ? By safeguarding existing waste facilities, the policy H D  diversified economy. will support businesses involved in sustainable waste management activities, and ensure the supply of recycled minerals to support sustainable construction. It will maximise the recovery of value from waste. The policy also seeks to minimise adverse impacts on neighbouring sites which may be used by local businesses. 17. To provide employment opportunities and Not relevant develop and maintain a skilled workforce.

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Table D.2 Policy WMSP2 Waste Site Allocations

Objectives Short Med Long Comments Prob Dir/Ind Rev? 1. To avoid negative effects and enhance, where 0 0 0 There are unlikely to be significant impacts on health, H I  possible, positive effects on health. although there may be a perception of negative impacts with development being close to residential areas.

2. To protect the amenity of residents and +/- +/- +/- A high quality design could improve the visual H I  neighbouring land uses. amenity for neighbouring residential areas around some sites. However, some sites are overlooked by residential areas and buffers and additional screening are required to reduce the likelihood of adverse impacts.

3. To improve equality and access to sustainable 0 0 0 No impacts identified. waste management. 4. To minimise waste generation and disposal to + ++ ++ Sites would provide opportunities for facilities to be H D  land. developed which will reduce the amount of waste landfilled and actively promote the waste hierarchy. It may also increase reuse or recycling depending on the type of facility developed.

5. To ensure the sustainable use of local mineral ? ? ? Development of sites may help to encourage the L I  resources. increased use of recycled aggregates if the site handles CDE waste, but this is unknown.

6. To maintain and improve water quality. 0/? 0 0 Mixed impacts. Some sites are unlikely to affect L D  water quality, while others require a risk assessment to demonstrate no risk to groundwater or surface water quality.

7. To seek the protection of and sustainable use of Not relevant to selection of sites. water resources. 8. To reduce risk and impact of flooding. 0/- 0/- 0 Most of the sites are located in flood zone 1, although M D  two contain areas of flood zone 3 and adverse impacts on flood risk are possible.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL D4

9. To limit the causes of and adapt to climate + + + The site provides an opportunity to develop a facility M I  change. to reduce the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton, some sites will help to reduce emissions from waste transport.

10. To protect air quality and reduce air pollution. 0/- 0 0 Some sites are close to an AQMA and vehicles could L I  add to poor air quality, but effective routing of vehicles could avoid adverse impacts.

11. To reduce adverse impacts of transporting waste +/0 +/0 +/0 Mixed impacts. Some sites are located in the urban H I  and minerals on the environment. area, which will help to reduce waste transport. For some sites, opportunities have been identified for co- location of waste facilities and for the use of sustainable modes of transport.

12. To conserve and enhance important soil +/-/? +/-/? ? Mixed impacts. Some sites are previously developed L I  functions and types. land and some are greenfield. Development may help to encourage the composting of biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and enhance East Sussex +/- +/- +/- Mixed impacts. Some sites are close to the SDNP and M/H I  and Brighton & Hove’s countryside and historic and historic assets and adverse impacts are possible. built environment. Development should be of high quality design to reduce the likelihood of impacts on landscape and historic assets. Some sites have the potential for archaeology to have survived and an assessment of archaeological value should be undertaken.

14. To protect, conserve and where appropriate - - - Several of the sites are close to sites of nature M/L I  enhance East Sussex and Brighton & Hove’s conservation importance and adverse effects are biodiversity and geodiversity. possible, including from reduced air quality, disturbance and predation.

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15. To increase energy efficiency and the proportion ?/+ ?/+ ?/+ Development of sites could create an opportunity to H/M D/I  of energy generated from renewable sources. recover energy from waste, depending on the type of facility developed. Some sites have potential for connection to heat network, which would help to increase energy efficiency.

16. To contribute to the growth of a sustainable and +/? +/? +/? Development of sites will contribute to providing H D  diversified economy. waste facilities to meet society’s needs, recover value from waste and support sustainable economic growth. It may support the development of business in reduction, reuse and recycling, or in supply of recycled minerals, but this will depend on the type of facility developed, which is unknown at this stage.

17. To provide employment opportunities and + + + Development of some sites will create job M I  develop and maintain a skilled workforce. opportunities close to some very deprived areas of Brighton, although on its own it is not likely to significantly improve overall employment prospects for deprived areas.

Table D.3 Policy WMSP3 Areas of Opportunity on Previously Developed or Allocated Land

3. To improve equality and access to sustainable 0 0 0 No impacts identified. waste management.

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4. To minimise waste generation and disposal to + ++ ++ Sites would provide opportunities for facilities to be H D  land. developed which will reduce the amount of waste landfilled and actively promote the waste hierarchy. It may also increase reuse or recycling depending on the type of facility developed.

7. To seek the protection of and sustainable use of Not relevant to selection of sites. water resources. 8. To reduce risk and impact of flooding. 0/- 0/- 0 Most of the sites are located in flood zone 1, although M D  one contains areas of flood zone 2 and 3 and adverse impacts on flood risk are possible.

9. To limit the causes of and adapt to climate + + + The site provides an opportunity to develop a facility M I  change. to reduce the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to centres of population, some sites will help to reduce emissions from waste transport.

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13. To protect, conserve and enhance East Sussex +/- +/- +/- Mixed impacts. Some sites are close to the AONB and M/H I  and Brighton & Hove’s countryside and historic and the SDNP and adverse impacts are possible. built environment. Development should be of high quality design to reduce the likelihood of impacts on landscape and historic assets. Some sites have the potential for archaeology to have survived and an assessment of archaeological value should be undertaken.

14. To protect, conserve and where appropriate - - - Several of the sites are close to sites of nature M/L I  enhance East Sussex and Brighton & Hove’s conservation importance, including nationally and biodiversity and geodiversity. internationally designated sites, and adverse effects are possible, including from reduced air quality, direct land-take, disturbance and predation. Fragmentation of habitats is also likely at three sites. One site partially overlaps an LGS.

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17. To provide employment opportunities and + + + Development of some sites will create job M I  develop and maintain a skilled workforce. opportunities close to some deprived areas, although on its own it is not likely to significantly improve overall employment prospects for deprived areas.

Table D.4 Policy WMSP4 Areas of Search

6. To maintain and improve water quality. 0 0 0 Significant adverse impacts on water quality are unlikely.

7. To seek the protection of and sustainable use of Not relevant to selection of sites. water resources.

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8. To reduce risk and impact of flooding. - - - Two of the sites contain small areas of flood zone 3, L D  but adverse impacts on flood risk are unlikely.

9. To limit the causes of and adapt to climate + + + The site provides an opportunity to develop a facility M I  change. to reduce the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to centres of population, some sites will help to reduce emissions from waste transport.

10. To protect air quality and reduce air pollution. 0 0 0 Significant adverse impacts on air quality are unlikely.

11. To reduce adverse impacts of transporting waste +/0 +/0 +/0 Mixed impacts. Some sites are located close to centres H I  and minerals on the environment. of population, which will help to reduce waste transport. No opportunities have been identified for co-location of waste facilities or for the use of sustainable modes of transport.

12. To conserve and enhance important soil -/? -/? ? All sites are greenfield and soil will be lost to L I  functions and types. development. Development may help to encourage the composting of biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and enhance East Sussex -/? -/? -/? One site is within the AONB and one adjacent to the M/H I  and Brighton & Hove’s countryside and historic and AONB and adverse impacts are likely. Several sites built environment. are open greenfield land and so adverse impacts on the local landscape and countryside are inevitable, although for sites within masterplan areas impacts will be inevitable in any event. Some sites are close to heritage assets and adverse impacts on their setting are possible. Development should be of high quality design and well-screened to reduce the likelihood of impacts on landscape and historic assets. Some sites have the potential for archaeology to have survived and an assessment of archaeological value should be undertaken.

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14. To protect, conserve and where appropriate - - - Several of the sites are close to sites of nature M/L I  enhance East Sussex and Brighton & Hove’s conservation importance, including some which are biodiversity and geodiversity. close to nationally and internationally designated sites, and adverse effects are possible, including from reduced air quality, direct land-take, disturbance and predation. Fragmentation of habitats is also likely at one site.

15. To increase energy efficiency and the proportion ?/+ ?/+ ?/+ Development of sites could create an opportunity to H/M D/I  of energy generated from renewable sources. recover energy from waste, depending on the type of facility developed. Some sites have potential for connection to a heat network, which would help to increase energy efficiency.

Table D.5 Policy WMSP5 Physical Expansion of Existing Waste Sites

2. To protect the amenity of residents and +/- +/- +/- One site is close to a residential property and buffers H I  neighbouring land uses. and additional screening are required to reduce the likelihood of adverse impacts.

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6. To maintain and improve water quality. 0 0 0 Significant adverse impacts on water quality are unlikely.

7. To seek the protection of and sustainable use of Not relevant to selection of sites. water resources. 8. To reduce risk and impact of flooding. 0 0 0 Significant adverse impacts on flood risk are unlikely.

9. To limit the causes of and adapt to climate + + + The sites provide an opportunity to develop a facility M I  change. to reduce the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to centres of population, the sites will help to reduce emissions from waste transport.

10. To protect air quality and reduce air pollution. 0 0 0 Significant adverse impacts on air quality are L I unlikely.

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12. To conserve and enhance important soil -/? -/? ? Part of one site is greenfield and grade 3 agricultural L I  functions and types. land and soil will be lost to development. Development may help to encourage the composting of biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and enhance East Sussex -/? -/? -/? One site is in a rural area and adverse visual impacts M/H I  and Brighton & Hove’s countryside and historic and on countryside are possible. Additional screening built environment. should be provided to minimise the visual impacts. Both sites have the potential for archaeology to have survived and an assessment of archaeological value should be undertaken.

15. To increase energy efficiency and the proportion ? ? ? Development of sites could create an opportunity to H/M D/I  of energy generated from renewable sources. recover energy from waste, depending on the type of facility developed.

Table D.6 Policy WMSP6 Existing Industrial Estates

Objectives Short Med Long Comments Prob Dir/Ind Rev?

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1. To avoid negative effects and enhance, where 0 0 0 There are unlikely to be significant impacts on health, H I  possible, positive effects on health. although there may be a perception of negative impacts with one site being close to residential areas.

2. To protect the amenity of residents and 0 0 ? The amenity of residents and neighbouring land uses M D  neighbouring land uses. will be protected through policies WMP25 and WMP26.

5. To ensure the sustainable use of local mineral ? ? ? Development of sites may help to encourage the L I  resources. increased use of recycled aggregates if a site handles CDE waste, but this is unknown.

6. To maintain and improve water quality. 0 0 ? Significant adverse impacts on water quality are unlikely.

7. To seek the protection of and sustainable use of Not relevant to selection of sites. water resources. 8. To reduce risk and impact of flooding. 0 0 ? Significant adverse impacts on flood risk are unlikely.

9. To limit the causes of and adapt to climate + + + The sites provide an opportunity to develop a facility M D  change. to reduce the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to centres of population, some sites will help to reduce emissions from waste transport.

10. To protect air quality and reduce air pollution. 0 0 0 Significant adverse impacts on air quality are unlikely through implementation of policy WMP25.

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11. To reduce adverse impacts of transporting waste + + + Some sites are located close to centres of population, H I  and minerals on the environment. which will help to reduce waste transport. Some opportunities have been identified for co-location of waste facilities or for the use of sustainable modes of transport.

12. To conserve and enhance important soil 0/? 0/? ? As existing industrial estates, loss of soil is unlikely to H/L I  functions and types. be significant. Development may help to encourage the composting of biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and enhance East Sussex 0/? 0/? 0/? As existing industrial estates, impacts on landscape M I  and Brighton & Hove’s countryside and historic and and countryside are unlikely to be significant and built environment. development could provide opportunities to improve landscape impacts. A number of sites have the potential for archaeology to have survived and an assessment of archaeological value should be undertaken.

14. To protect, conserve and where appropriate - - ? Several of the sites are close to sites of nature M I  enhance East Sussex and Brighton & Hove’s conservation importance and adverse effects are biodiversity and geodiversity. possible, including from reduced air quality, direct land-take, disturbance and predation.

15. To increase energy efficiency and the proportion ? ? ? Development of sites could create an opportunity to M D  of energy generated from renewable sources. recover energy from waste, depending on the type of facility developed.

16. To contribute to the growth of a sustainable and +/? +/? +/? Development of sites will contribute to providing H/M D  diversified economy. waste facilities to meet society’s needs, recover value from waste and support sustainable economic growth. It may support the development of business in reduction, reuse and recycling, or in supply of recycled minerals, but this will depend on the type of facility developed, which is unknown at this stage.

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Table D.7 Policy WMSP7 Waste Consultation Areas

Objectives Short Med Long Comments Prob Dir/Ind Rev? 1. To avoid negative effects and enhance, where + + ? By seeking to prevent non-waste development from H I  possible, positive effects on health. constraining waste facilities, the policy will indirectly help to ensure that adverse impacts on health from waste facilities on surrounding uses are prevented. 2. To protect the amenity of residents and + + ? By seeking to prevent existing waste facilities from H I  neighbouring land uses. being prejudiced from development proposals, the policy will indirectly help to ensure that adverse impacts on amenity from waste facilities on surrounding uses are prevented. 3. To improve equality and access to sustainable + + ? By seeking to prevent non-waste development from H D  waste management. constraining waste facilities, the policy will help to support enterprises involved in sustainable waste management. 4. To minimise waste generation and disposal to + + ? By seeking to prevent non-waste development from H D  land. constraining waste facilities the policy will help to provide capacity to minimise disposal of waste to land. 5. To ensure the sustainable use of local mineral + + ? By seeking to prevent non-waste development from H D/I  resources. constraining waste facilities, the policy will help to encourage and maximise the use of recycled and secondary aggregates and in so doing enable efficient management of mineral resources. It will also indirectly support sustainable construction and demolition. 6. To maintain and improve water quality. Not relevant

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL D16

7. To seek the protection of and sustainable use of Not relevant water resources. 8. To reduce risk and impact of flooding. Not relevant 9. To limit the causes of and adapt to climate + + ? By seeking to prevent non-waste development from M I  change. constraining waste facilities, the policy will help to ensure sufficient capacity within the Plan Area to deal with waste arisings. This will minimise waste transport distances and promote waste recycling and energy recovery, leading to reduced energy use and reduced greenhouse gas emissions. 10. To protect air quality and reduce air pollution. + + ? By seeking to prevent non-waste development from L I  constraining waste facilities, the policy will help to ensure sufficient capacity within the Plan Area to deal with waste arisings. This will minimise waste transport distances and will contribute to avoiding adverse impacts on air quality from waste transport. 11. To reduce adverse impacts of transporting waste + + ? By seeking to prevent non-waste development from H I  and minerals on the environment. constraining waste facilities, the policy will help to ensure sufficient capacity within the Plan Area to deal with waste arisings. This will minimise waste transport distances and reduce adverse impacts of waste transport on the environment. It may also help to promote local supplies of recycled minerals. 12. To conserve and enhance important soil + + ? By seeking to prevent non-waste development from L I  functions and types. constraining waste facilities, the policy will indirectly help to ensure the supply of compost which can be used as a soil improver. 13. To protect, conserve and enhance East Sussex + + ? By seeking to prevent non-waste development from M/H I  and Brighton & Hove’s countryside and historic and constraining waste facilities, the policy will indirectly built environment. help to maximise the supply of secondary and recycled aggregates which will reduce adverse impacts of mining on landscape and countryside, including on the SDNP and AONB. It will also help to optimise the use of previously developed land.

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14. To protect, conserve and where appropriate + + ? By seeking to prevent non-waste development from M/L I  enhance East Sussex and Brighton & Hove’s constraining waste facilities, the policy will indirectly biodiversity and geodiversity. help to maximise the supply of secondary and recycled aggregates facilities which will conserve geological resources in the Plan Area. It will also help to ensure sufficient facilities to deal with the Plan Area’s waste, which will help to reduce waste transport and may indirectly reduce adverse impacts of poor air quality on biodiversity, although this is much more strongly dependent on other policies and strategies. 15. To increase energy efficiency and the proportion + + ? By seeking to prevent non-waste development from H/M D/I  of energy generated from renewable sources. constraining waste facilities, the policy will encourage recovery of energy from waste and indirectly help to encourage local supply chains in recycled materials and compost. 16. To contribute to the growth of a sustainable and + + ? By seeking to prevent non-waste development from H D  diversified economy. constraining waste facilities, the policy will support businesses involved in sustainable waste management activities, and ensure the supply of recycled minerals to support sustainable construction. It will maximise the recovery of value from waste. The policy will also help to minimise adverse impacts on neighbouring sites which may be used by local businesses. 17. To provide employment opportunities and Not relevant develop and maintain a skilled workforce.

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Table D.8 Policy WMSP8 Mineral Safeguarding Areas and Mineral Consultation Areas for land-won minerals resources within the Plan Area

Note: This policy relates to existing permissions and therefore any adverse impacts are assumed to have been assessed as acceptable at planning application stage.

Objectives Short Med Long Comments Prob Dir/Ind Rev? 1. To avoid negative effects and enhance, where Not relevant possible, positive effects on health. 2. To protect the amenity of residents and Not relevant neighbouring land uses. 3. To improve equality and access to sustainable Not relevant waste management. 4. To minimise waste generation and disposal to Not relevant land. 5. To ensure the sustainable use of local mineral + + ? The policy directly seeks to safeguard mineral sites to H D  resources. safeguard mineral resources and manage them efficiently. 6. To maintain and improve water quality. Not relevant 7. To seek the protection of and sustainable use of Not relevant water resources. 8. To reduce risk and impact of flooding. Not relevant 9. To limit the causes of and adapt to climate Not relevant change. 10. To protect air quality and reduce air pollution. Not relevant 11. To reduce adverse impacts of transporting waste + + ? By safeguarding mineral resources, the policy will H D  and minerals on the environment. help to encourage local supplies of minerals. 12. To conserve and enhance important soil Not relevant functions and types. 13. To protect, conserve and enhance East Sussex Not relevant and Brighton & Hove’s countryside and historic and built environment. 14. To protect, conserve and where appropriate Not relevant enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity. 15. To increase energy efficiency and the proportion Not relevant of energy generated from renewable sources.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL D19

16. To contribute to the growth of a sustainable and + + ? By safeguarding mineral resources, the policy will H D  diversified economy. help to ensure sufficient minerals are available to support construction of housing and infrastructure to support economic growth. 17. To provide employment opportunities and + + ? The policy will indirectly support the provision of H I  develop and maintain a skilled workforce. jobs in some rural and deprived areas.

Table D.9 Policy WMSP9 Safeguarding wharves and railheads within the Plan Area

Objectives Short Med Long Comments Prob Dir/Ind Rev? 1. To avoid negative effects and enhance, where Not relevant possible, positive effects on health. 2. To protect the amenity of residents and + + ? By safeguarding wharves and railheads, the policy M D  neighbouring land uses. will help to reduce the likelihood of adverse impacts on amenity from road transport of minerals. 3. To improve equality and access to sustainable waste management. 4. To minimise waste generation and disposal to land. 5. To ensure the sustainable use of local mineral + + ? The policy directly seeks to safeguard wharves and H D  resources. rail facilities. 6. To maintain and improve water quality. Not relevant 7. To seek the protection of and sustainable use of Not relevant water resources. 8. To reduce risk and impact of flooding. Not relevant 9. To limit the causes of and adapt to climate + + ? By safeguarding wharves and rail facilities, the policy H D  change. will help to reduce greenhouse gas emissions from minerals transport. 10. To protect air quality and reduce air pollution. + + ? By safeguarding wharves and rail facilities, the policy L I  will help to reduce emissions from road transport of minerals, which may have benefits in improved air quality.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL D20

11. To reduce adverse impacts of transporting waste + + ? By safeguarding wharves and rail facilities, the policy H D  and minerals on the environment. will help to encourage a modal shift to rail and water. 12. To conserve and enhance important soil Not relevant functions and types. 13. To protect, conserve and enhance East Sussex Not relevant and Brighton & Hove’s countryside and historic and built environment. 14. To protect, conserve and where appropriate + + ? By safeguarding wharves and rail facilities, the policy L I  enhance East Sussex and Brighton & Hove’s will help to reduce road transport of minerals which biodiversity and geodiversity. may indirectly reduce adverse impacts of poor air quality on biodiversity, although this is much more strongly dependent on other policies and strategies. 15. To increase energy efficiency and the proportion Not relevant of energy generated from renewable sources. 16. To contribute to the growth of a sustainable and + + ? By safeguarding wharves and rail facilities, the policy M D  diversified economy. will help to ensure sufficient raw minerals are available to support construction of housing and infrastructure to support economic growth. It will also support the economy in the coastal sub-region. 17. To provide employment opportunities and + + ? The policy will support the preservation of jobs in H I  develop and maintain a skilled workforce. some deprived coastal areas.

Table D.10 Policy WMSP10 Safeguarding facilities for concrete batching, coated materials manufacture and other concrete products within the Plan Area

Objectives Short Med Long Comments Prob Dir/Ind Rev? 1. To avoid negative effects and enhance, where + + ? By seeking to prevent incompatible development, the H I  possible, positive effects on health. policy will indirectly help to ensure that adverse impacts on health from concrete batching and similar facilities on surrounding uses are prevented. 2. To protect the amenity of residents and + + ? By seeking to prevent incompatible development, the H I  neighbouring land uses. policy will indirectly help to ensure that adverse impacts on amenity from concrete batching and similar facilities on surrounding uses are prevented.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL D21

3. To improve equality and access to sustainable waste management. 4. To minimise waste generation and disposal to land. 5. To ensure the sustainable use of local mineral + + ? The policy directly seeks to safeguard sites for H D  resources. concrete batching facilities and similar facilities, helping to ensure efficient management of resources. 6. To maintain and improve water quality. Not relevant 7. To seek the protection of and sustainable use of Not relevant water resources. 8. To reduce risk and impact of flooding. Not relevant 9. To limit the causes of and adapt to climate Not relevant change. 10. To protect air quality and reduce air pollution. Not relevant 11. To reduce adverse impacts of transporting waste Not relevant and minerals on the environment. 12. To conserve and enhance important soil Not relevant functions and types. 13. To protect, conserve and enhance East Sussex Not relevant and Brighton & Hove’s countryside and historic and built environment. 14. To protect, conserve and where appropriate Not relevant enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity. 15. To increase energy efficiency and the proportion Not relevant of energy generated from renewable sources. 16. To contribute to the growth of a sustainable and + + ? By safeguarding mineral facilities, the policy will help M D  diversified economy. to ensure sufficient minerals are available to support construction of housing and infrastructure to support economic growth. 17. To provide employment opportunities and + + ? The policy will indirectly support the provision of H I  develop and maintain a skilled workforce. jobs in some rural and deprived areas.

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Annex E

Options Appraisal

Key Impacts Significance + positive impact Low significance - negative impact Medium significance 0 no significant impact High significance

? impact unknown

Table 1.1 Site Allocation Options

Objective A1 A2 A3 Assessment comments

Social

1. To avoid negative effects ------By allocating all sites, the largest number of and enhance, where people are likely to perceive their health possible, positive effects on could be affected by waste development, health and this could lead to stress. Allocating the bare minimum number of sites will minimise the number of people so affected. Effects are likely to reduce over time as development proceeds and in the long term there are unlikely to be significant impacts on health as people become accustomed to waste facilities near their homes.

2. To protect the amenity of ? ? ? Waste development has the potential to residents and neighbouring affect residential amenity and to have land uses visual impacts. Mitigation is proposed for sites where adverse effects are possible, but there may be residual impacts. However, the number of sites which are allocated will not have a differential effect on residential amenity.

3. To improve equality and No impacts identified. access to sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL E1 Objective A1 A2 A3 Assessment comments

Environmental

4. To minimise waste ++ + ++ Allocating the minimum number of sites generation and disposal to increases the possibility that insufficient land sites will be developed as the Plan would not have any flexibility should any of the required sites become unavailable for waste development. This would reduce the treatment capacity in the Plan area and result in more waste for landfill.

5. To ensure the sustainable ++ + ++ Allocating the minimum number of sites use of local mineral increases the possibility that insufficient resources sites will be developed as the Plan would not have any flexibility should any of the required sites become unavailable for waste development. This may reduce the capacity for recycling CD&E waste in the Plan area and result in more waste for landfill. However, the likelihood of this effect is uncertain as the type of facilities that would come forward is unknown.

6. To maintain and improve 0 0 0 Unlikely to have a differential impact on water quality water quality.

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact Impact on flood risk is dependent on of flooding management of individual sites, rather than numbers allocated.

9. To limit the causes of and +++ + ++ Allocating the minimum number of sites adapt to climate change increases the possibility that insufficient sites will be developed as the Plan would not have any flexibility should any of the required sites become unavailable for waste development. This would reduce the treatment capacity in the Plan area and result in more emissions of greenhouse gases through reduced recovery capacity. Allocating all sites will increase the opportunities for locating near to large centres of population and therefore reduce the contribution of waste transport to climate change.

10. To protect air quality +++ + ++ Allocating all sites will increase the and reduce air pollution opportunities for locating near to large centres of population and therefore reduce the contribution of waste transport to poor air quality.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL E2 Objective A1 A2 A3 Assessment comments

11. To reduce adverse +++ + ++ Allocating all sites will increase the impacts of transporting possibility that a site may be developed waste and minerals on the that has potentially viable sustainable environment transport modes and will increase the options for locating close to large centres of population. Allocating the minimum number of sites will reduce the possibility of this.

12. To conserve and enhance Dependent on sites that are developed important soil functions rather than number allocated. and types

13. To protect, conserve and Dependent on sites that are developed enhance East Sussex and rather than number allocated. Brighton & Hove’s countryside and historic and built environment

14. To protect, conserve and Dependent on sites that are developed where appropriate enhance rather than number allocated. East Sussex and Brighton & Hove’s biodiversity and geodiversity

15. To increase energy Not relevant to number of sites allocated. efficiency and the proportion of energy generated from renewable sources

Economic

16. To contribute to the ++ + ++ Allocating the minimum number of sites growth of a sustainable and increases the possibility that insufficient diversified economy sites will be developed as the Plan would not have any flexibility should any of the required sites become unavailable for waste development. This would reduce the e conomic contribution of new jobs in the waste industry.

17. To provide employment ++ + ++ Allocating the minimum number of sites opportunities and develop increases the possibility that insufficient and maintain a skilled sites will be developed as the Plan would workforce not have any flexibility should any of the required sites become unavailable for waste development. This would reduce the number of new jobs in the waste industry.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL E3

Annex F

Appraisal of Sites

Key Impacts Significance + positive impact Low significance - negative impact Medium significance 0 no significant impact High significance

? impact unknown

Table F.1 WMSP-A/A Beach Road (Land west of), Beach Rd / Railway Rd, Newhaven

Objective Assessment comments

Social

1. To avoid negative effects 0 There are unlikely to be significant impacts on health, although and enhance, where there may be a perception of negative impacts with possible, positive effects on development being close to residential areas. health

2. To protect the amenity of - There are residential properties adjacent to the site and adverse residents and neighbouring impacts are possible from waste development, from visual land uses impact and from vehicles accessing the site. If well-designed, development could improve the visual impact of the site. Mitigation: Development should be well-designed and have appropriate landscaping to minimise visual impact.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

4. To minimise waste + Site would provide opportunities for facilities to be developed generation and disposal to which will reduce the amount of waste landfilled and actively land promote the waste hierarchy. It may also increase reuse or recycling depending on the type of facility developed.

5. To ensure the sustainable ? Development of the site may help to encourage the increased use of local mineral use of recycled aggregates if the site handles CDE waste, but resources this is unknown.

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - The entire site is within flood zone 3. of flooding Mitigation: Any planning application should be accompanied by a flood risk assessment and should demonstrate no adverse impact on flood risk and improvement of flood risk where possible. Development in the functional flood plain should be avoided.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The location between Brighton and Eastbourne will make a contribution to reducing waste transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F1 Objective Assessment comments

10. To protect air quality - There are concerns over air quality in Newhaven, particularly and reduce air pollution around the gyratory system. Waste-related development has the potential to add to poor air quality through emissions from a waste facility and from the associated traffic. Mitigation: Any planning application should be accompanied by an assessment of the impact on air quality. A routing strategy should be adopted which routes traffic along the A26.

11. To reduce adverse +/- Being situated between Brighton and Eastbourne, the site will impacts of transporting make a contribution to reducing the adverse impacts of waste waste and minerals on the transport. No opportunities have been identified to co-locate environment waste facilities. The site is adjacent to the port and railway line, which may present opportunities to use sustainable modes of transport. There are capacity constraints on the local road network Mitigation: Any planning application should be accompanied by a transport assessment which should demonstrate adequate capacity on the local road network.

12. To conserve and enhance +/? The site is previously developed land. Development may help important soil functions to encourage the composting of biodegradable waste, but this and types depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and 0/? The site is 470m from the National Park. However, the site is in enhance East Sussex and existing industrial use and therefore any waste development is Brighton & Hove’s unlikely to have a significant additional adverse effect on the countryside and historic Park. There is the potential for historic remains to have and built environment survived below ground. Mitigation: Any planning application should be accompanied by an assessment of historic assets.

14. To protect, conserve and - There are several local nature conservation sites within 1km and where appropriate enhance records of protected species in the vicinity. Adverse impacts are East Sussex and Brighton & possible from reduced air quality due to facility emissions and Hove’s biodiversity and vehicle emissions, from disturbance and predation. geodiversity Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation with particular focus on the impacts on biodiversity. An ecological assessment should examine the existence of protected species on site and in the vicinity and appropriate mitigation put in place.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy There may be opportunities to connect to heat users in the generated from renewable vicinity. sources

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F2 Objective Assessment comments

Economic

16. To contribute to the +/? Development of the site will contribute to providing waste growth of a sustainable and facilities to meet society’s needs, recover value from waste and diversified economy support sustainable economic growth. It may support the development of business in reduction, reuse and recycling, or in supply of recycled minerals, but this will depend on the type of facility developed, which is unknown at this stage.

17. To provide employment + Development of the site will create job opportunities near to opportunities and develop some fairly deprived communities, although on its own it is not and maintain a skilled likely to significantly improve overall employment prospects. workforce

Table F.2 WMSP-A/B Coal Yard adjacent to Sackville Trading Estate, Hove

Objective Assessment comments

Social

2. To protect the amenity of ? There are residential areas adjacent to the site, but the site is residents and neighbouring well-screened from these areas. Adverse impacts on residential land uses amenity are possible from waste transport. Mitigation: Any waste development should be of high quality design and be well-screened by vegetation. Existing vegetation should be retained where possible. An appropriate routing strategy should be adopted to divert waste vehicles away from residential areas.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Part of the site is within a groundwater source protection zone 3. water quality However, adverse impacts on groundwater are unlikely.

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F3 Objective Assessment comments

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Brighton, the site will help to reduce emissions from waste transport.

10. To protect air quality ? Sackville Road and parts of Old Shoreham Road are in an and reduce air pollution AQMA. Adverse effects on air quality are possible from a waste management facility and associated waste transport, although the impacts may not be significantly different from existing site uses. Mitigation: Any planning application should be accompanied by an assessment of the impacts on air quality and should demonstrate no reduction of air quality in the AQMA.

11. To reduce adverse +/0 By locating near to Brighton, the site will contribute to a impacts of transporting /? reduction in waste transport. No opportunities have been waste and minerals on the identified to co-locate waste facilities. There is a railway line environment adjacent to the site and sidings could be reinstated, although this may not be viable.

13. To protect, conserve and 0 No impacts have been identified on landscape and countryside. enhance East Sussex and The site is separated from the Hove Station conservation area Brighton & Hove’s and listed buildings by a railway line and impacts are unlikely countryside and historic to be significant. and built environment

14. To protect, conserve and - There is a possibility of protected species on site, and adverse where appropriate enhance impacts are possible from land take and disturbance. East Sussex and Brighton & Mitigation: Any planning application should be accompanied by Hove’s biodiversity and an assessment of impacts on protected species and appropriate geodiversity mitigation put in place.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy The site is close to a heat cluster and therefore presents generated from renewable opportunities to connect to major heat users. sources

Economic

17. To provide employment + Development of the site will create job opportunities near to opportunities and develop deprived communities, although and on its own it is not likely and maintain a skilled to significantly improve overall employment prospects. workforce

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F4 Table F.3 WMSP-A/C Former Gasworks, Roedean Road, Brighton

Objective Assessment comments

Social

2. To protect the amenity of +/- A high quality design could improve the visual amenity for residents and neighbouring neighbouring residential areas. However, the site is a gateway land uses for two conservation areas in Brighton and waste development is unlikely to be compatible in terms of visual impact.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Development of site is unlikely to affect water quality. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality - The site is close to the edge of an AQMA, but effective routing and reduce air pollution of vehicles could avoid adverse impacts. Mitigation: Planning application should be accompanied by a Transport Assessment and routing strategy.

11. To reduce adverse +/0 The site is located in the urban area, which will help to reduce impacts of transporting waste transport. However, no opportunities have been waste and minerals on the identified for co-location of waste facilities or use of sustainable environment modes of transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F5 Objective Assessment comments

12. To conserve and enhance +/? The site is previously developed and understood to contain important soil functions some contamination. Development may help to encourage the and types composting of biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and +/- Development of the site would provide an opportunity to enhance East Sussex and replace gasometers which would enhance views from the Brighton & Hove’s National Park if development is high quality. The site is countryside and historic previously developed and would avoid greenfield development. and built environment The site /is close to a listed building and conservation area but significant adverse effects are unlikely. Mitigation: Any development should be required to enhance current views from the SDNP and be of appropriate design to minimise adverse impacts on the listed building.

14. To protect, conserve and 0 Significant impacts on biodiversity or geodiversity are unlikely. where appropriate enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy There is potential for connection to heat network linked to generated from renewable comprehensive development of City Plan DA2 Development sources Area, which would help to increase energy efficiency.

Economic

17. To provide employment + Development of the site will create job opportunities close to opportunities and develop some very deprived areas of Brighton, although on its own it is and maintain a skilled not likely to significantly improve overall employment workforce prospects for deprived areas.

Table F.4 WMSP-A/D Hangleton Bottom, Hangleton Link Road, North Portslade

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F6 Objective Assessment comments

2. To protect the amenity of ? There are residential areas adjoining the site and any residents and neighbouring development of the site may have adverse visual impacts land uses depending on the height of any buildings or the existence of a stack. Mitigation: Development should provide screening from residential areas through appropriate screening and tree planting.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The location near to Brighton could make a contribution to reducing waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located near to Brighton, which will help to reduce impacts of transporting the impacts of waste transport. The site is large enough to co- waste and minerals on the locate waste facilities. No opportunities have been identified for environment the use of sustainable modes of transport.

12. To conserve and enhance -/? The site is greenfield land. Development may help to encourage important soil functions the composting of biodegradable waste, but this depends on the and types type of facility that is developed, which is unknown at this stage.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F7 Objective Assessment comments

13. To protect, conserve and -/? The site is adjacent to the SDNP and is visible from one enhance East Sussex and viewpoint. Development of the site could have adverse impacts Brighton & Hove’s on the SDNP depending on the height of any buildings and the countryside and historic existence of a stack. There is the potential for archaeological and built environment remains to have survived below ground. Mitigation: Any planning application should be accompanied by an assessment of historic assets. Development should incorporate screening and buffer zones to mitigate impact on residential areas and the SDNP. The type and scale of buildings should be designed to minimise adverse impacts on the SDNP.

14. To protect, conserve and - The site is adjacent to two local nature conservation sites and where appropriate enhance there are several more within 1 km. It is 120m from an area of East Sussex and Brighton & BAP priority habitat and there are several patches of ancient Hove’s biodiversity and woodland within 1 km. Adverse impacts are possible from geodiversity reduced air quality due to facility emissions and vehicle emissions, disturbance and predation. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation with particular focus on the impacts on biodiversity.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy The site is within 2km of a heat cluster and there may be generated from renewable opportunities to connect to heat users. sources

Economic

17. To provide employment + Development of the site will create job opportunities near to opportunities and develop some deprived communities, although on its own it is not likely and maintain a skilled to significantly improve overall employment prospects. workforce

Table F.5 WMSP–A/E Hollingdean Industrial Estate, Brighton

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F8 Objective Assessment comments

2. To protect the amenity of -/+ There are residential areas surrounding the site with residents and neighbouring considerable overlooking. The existing site is in a dilapidated land uses state and there is the potential for new development to improve the townscape if designed to a high specification. Mitigation: New development should be designed to a high specification to improve visual amenity. A buffer should be provided to residential areas and trees should be incorporated into the design.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve ? The site is within a groundwater source protection zone 1. water quality Mitigation: Any planning application should be accompanied by a risk assessment which demonstrates no risk to groundwater quality.

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality - There is an AQMA along Hollingdean Road to the east of the and reduce air pollution site and along Lewes Road. Vehicles accessing the site could add to poor air quality. Mitigation: Any planning application should be accompanied by a Transport Assessment and an assessment of impacts on air quality.

11. To reduce adverse +/0 The site is located in the urban area, which will help to reduce impacts of transporting waste transport, and there is an existing MRF and WTS already waste and minerals on the on part of the site, which presents opportunities to co-locate environment waste facilities to reduce transport. However, no opportunities have been identified for the use of sustainable modes of transport.

12. To conserve and enhance +/? The site is previously developed. Development may help to important soil functions encourage the composting of biodegradable waste, but this and types depends on the type of facility that is developed, which is unknown at this stage.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F9 Objective Assessment comments

13. To protect, conserve and 0/- Significant impacts are unlikely on landscape. The site is 50m enhance East Sussex and from two conservation areas and several listed buildings are Brighton & Hove’s immediately adjacent to the site or within 100m. There is also countryside and historic the potential for archaeology to have survived on site and there and built environment are a number of undesignated heritage assets within a few hundred metres. There is potential for adverse impacts on heritage assets from waste-related development. Mitigation: Any planning application should be accompanied by an assessment of the archaeological value of the site. Development should be of a high quality design that takes into account the nearby heritage assets and enhances their setting where possible.

14. To protect, conserve and - The site is within 400 m of an area of BAP Priority Habitat and where appropriate enhance within 1km of several sites of local nature conservation East Sussex and Brighton & imiportance. Adverse impacts are possible from reduced air Hove’s biodiversity and quality from transport and emissions from a facility. geodiversity Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity.

15. To increase energy ?/0 Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy The site is within 2km of a heat user cluster, but the cost of generated from renewable implementing a heat network are likely to be high. sources

Economic

17. To provide employment + Development of the site will create job opportunities close to opportunities and develop some deprived areas of Brighton and Hove, although on its own and maintain a skilled it is not likely to significantly improve overall employment workforce prospects for deprived areas.

Table F.6 WMSP-A/F Old Factory, West of A22, A271 and A267 Roundabout, Lower Dicker

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F10 Objective Assessment comments

2. To protect the amenity of - There are residential areas and a cemetery and chapel adjoining residents and neighbouring the site and any development of the site may have adverse land uses impacts on the amenity of these neighbouring uses. Visual impacts are unlikely to be significantly worse than existing uses, depending on the scale of development and the existence of a stack. Mitigation: Development should provide screening from residential areas and the chapel and cemetery through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no adverse impact on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The location about 15km from Eastbourne could make a contribution to reducing waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located about 15km from Eastbourne and so will help impacts of transporting to reduce the impacts of waste transport. No opportunities have waste and minerals on the been identified for the co-location of waste facilities or for the environment use of sustainable modes of transport.

13. To protect, conserve and 0/? No impacts on landscape and countryside. There is the enhance East Sussex and potential for historic remains to have survived below ground. Brighton & Hove’s countryside and historic Mitigation: Any planning application should be accompanied by and built environment an assessment of historic assets.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F11 Objective Assessment comments

14. To protect, conserve and - There are several patches of ancient woodland within 1km and where appropriate enhance there is BAP priority habitat 300m from the site. Adverse East Sussex and Brighton & impacts are possible from disturbance and reduced air quality Hove’s biodiversity and due to facility emissions and vehicle emissions. geodiversity Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity.

Economic

17. To provide employment + Development of the site will create job opportunities near to opportunities and develop deprived communities, although on its own it is not likely to and maintain a skilled significantly improve overall employment prospects. workforce

Table F.7 WMSP-A/G Pumping Station, A271, nr Amberstone Bridge, Hailsham

Objective Assessment comments

Social

2. To protect the amenity of - There are residential areas in close proximity to the site and any residents and neighbouring development of the site may have adverse impacts on the land uses amenity of these neighbouring uses. Development of the site is likely to have visual impacts as it is in an open, flat, rural area. Significance of visual impacts will vary depending on the scale of development and the existence of a stack. Mitigation: Existing trees should be retained and development should provide screening from residential areas and surrounding countryside. Any planning application should be required to demonstrate that there will be no impact on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F12 Objective Assessment comments

Environmental

6. To maintain and improve ? A small watercourse runs along the boundary of the site and water quality adverse impacts on water quality are possible. Mitigation: Any planning application should be accompanied by an assessment of impacts on water quality and appropriate mitigation put in place to ensure no adverse effects.

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - Half of the site is within flood zone 1 and half within flood zone of flooding 3. Mitigation: Any planning application should be accompanied by a flood risk assessment which demonstrates no adverse impacts on flood risk and a reduction of flood risk where possible. Development should avoid the functional flood plain.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The location about 18km from Eastbourne could make a contribution to reducing waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located about 18km from Eastbourne which will help impacts of transporting to reduce the impacts of waste transport. No opportunities have waste and minerals on the been identified for the co-location of waste facilities or for the environment use of sustainable modes of transport.

13. To protect, conserve and -/? The site is in an open, flat, rural location and development of the enhance East Sussex and site will have impacts on views from the countryside. The Brighton & Hove’s potential for historic remains to have survived below ground is countryside and historic unknown. and built environment Mitigation: Existing trees should be retained and additional screening provided to limit visual impacts on the countryside. Any planning application should be accompanied by an assessment of historic assets.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F13 Objective Assessment comments

14. To protect, conserve and - There are several patches of ancient woodland within 1km and where appropriate enhance there is BAP priority habitat adjacent to the site. There is a SSSI East Sussex and Brighton & 750m from the site. Adverse impacts are possible from Hove’s biodiversity and disturbance and reduced air quality due to facility emissions geodiversity and vehicle emissions, from disturbance and from litter and predation. The site is 700m from Pevensey Levels SCI and Ramsar site and adverse impacts on water quality are possible from surface run-off. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity, and impacts from disturbance. Waste uses which attract vermin should be prohibited. An Appropriate Assessment may be required.

Economic

Table F.8 WMSP-O/A Hoyle Road, Peacehaven

Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F14 Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

2. To protect the amenity of - There are residential areas adjoining the site and a school in residents and neighbouring close proximity. Any development of the site is likely to have land uses adverse visual impacts and may have amenity impacts. There may be adverse impacts on residential environments from HGV traffic on residential roads. Mitigation: Development should provide screening from residential areas through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no impact from noise and odours on neighbouring land uses. Any planning application should be accompanied by a transport assessment which demonstrates that vehicle movements will be at acceptable levels. Site is an existing industrial estate and use of a unit may be acceptable if there are no additional vehicle movements compared to existing non-waste uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating between Brighton and Eastbourne the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located between Brighton and Eastbourne, which will impacts of transporting help to reduce waste transport. However, no opportunities waste and minerals on the have been identified for co-location of waste facilities or use of environment sustainable modes of transport.

12. To conserve and enhance -/? The site is a greenfield site. Development may help to important soil functions encourage the composting of biodegradable waste, but this and types depends on the type of facility that is developed, which is unknown at this stage.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F15 Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

13. To protect, conserve and 0/? No impacts on landscape and countryside. There is the enhance East Sussex and potential for archaeological remains on the site. Brighton & Hove’s Mitigation: Any planning application should be accompanied by countryside and historic an assessment of the site archaeology. and built environment

14. To protect, conserve and - The site is 590 m from a SSSI and about 900m from an SNCI. where appropriate enhance There are records of Great Crested Newts and other reptiles East Sussex and Brighton & within 500m. Adverse impacts are possible from reduced air Hove’s biodiversity and quality due to facility emissions and vehicle emissions, from geodiversity disturbance and potentially land-take, and from predation by vermin. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation with particular focus on the impacts on biodiversity, and an assessment of potential impacts on protected species. Development which attracts vermin should not be permitted unless appropriate mitigation is put in place.

Economic

17. To provide employment + Development of the site will create job opportunities close to opportunities and develop some deprived areas of Peacehaven and fairly close to deprived and maintain a skilled areas of Brighton, although on its own it is not likely to workforce significantly improve overall employment prospects for deprived areas.

Table F.9 WMSP-O/B Maresfield Camp, Maresfield (Ashdown Business Park)

Objective Assessment comments

Social

2. To protect the amenity of 0 There are residential areas 160m from the site but these are residents and neighbouring screened by trees and other buildings, therefore impacts on land uses amenity are unlikely.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F16 Objective Assessment comments

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is in flood zone 1. of flooding

10. To protect air quality 0 There are no air quality issues near the site and impacts are and reduce air pollution unlikely.

11. To reduce adverse +/0 The site is next to a household waste site and so presents an impacts of transporting opportunity to co-locate waste facilities. No opportunities have waste and minerals on the been identified for the use of sustainable modes of transport. environment

13. To protect, conserve and 0/? The sites is on the edge of Maresfield, but significant impacts on enhance East Sussex and countryside are not likely. The site is close to known areas of Brighton & Hove’s Roman activity and there is potential for remains to exist below countryside and historic ground. and built environment Mitigation: Any planning application should be accompanied by an assessment of historic assets.

14. To protect, conserve and - There is a local nature conservation site within 1km, ancient where appropriate enhance woodland adjacent to the site, BAP priority habitats on site and East Sussex and Brighton & there are records of protected species in the vicinity. Adverse Hove’s biodiversity and impacts are possible from reduced air quality due to facility geodiversity emissions and vehicle emissions, disturbance and predation. The site is 2.6km from Ashdown Forest SAC/SPA and adverse impacts on air quality are possible from facilities and vehicles. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation with particular focus on the impacts on biodiversity. An Appropriate Assessment may be required.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F17 Objective Assessment comments

Economic

17. To provide employment + Development of the site will create job opportunities, although opportunities and develop these will not be near to deprived communities and on its own it and maintain a skilled is not likely to significantly improve overall employment workforce prospects.

Table F.10 WMSP-O/C North Quay, Newhaven

Objective Assessment comments

Social

2. To protect the amenity of 0 There are residential properties about 100m from the site, but residents and neighbouring these are separated from the site by the existing industrial estate land uses and therefore adverse effects on residential amenity are unlikely. New development could improve the visual impact of the site.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F18 Objective Assessment comments

8. To reduce risk and impact - The site has land within flood zones 1, 2 and 3. of flooding Mitigation: Any planning application should be accompanied by a flood risk assessment and should demonstrate no adverse impact on flood risk and improvement of flood risk where possible. Development in flood zone 3 should be avoided.

11. To reduce adverse +/- Being situated between Brighton and Eastbourne, the site will impacts of transporting make a contribution to reducing the adverse impacts of waste waste and minerals on the transport. There are several waste uses on site and therefore the environment site presents an opportunity to co-locate waste facilities. The river is navigable and wharves are in use. Railway sidings have recently been constructed to export incinerator bottom ash. Adverse impacts are likely on the local road network by additional HGVs. Mitigation: Any planning application should be accompanied by a transport assessment which should demonstrate adequate capacity on the local road network.

13. To protect, conserve and 0/? The northern boundary of the site adjoins the National Park. enhance East Sussex and However, the site is in existing industrial use and therefore any Brighton & Hove’s waste development is unlikely to have a significant additional countryside and historic adverse effect on the Park. There is the potential for historic and built environment remains to have survived below ground. Mitigation: Development should be of an appropriate scale and design to minimise adverse impacts on the SDNP. Any planning application should be accompanied by an assessment of historic assets.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F19 Objective Assessment comments

14. To protect, conserve and - There are several local nature conservation sites within 1km of where appropriate enhance the site. There are BAP priority habitats adjacent to the site and East Sussex and Brighton & records of protected species in the vicinity. Adverse impacts are Hove’s biodiversity and possible from reduced air quality due to facility emissions and geodiversity vehicle emissions, from land-take and from disturbance and predation. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation with particular focus on the impacts on biodiversity. An ecological assessment should examine the existence of protected species on site and in the vicinity and appropriate mitigation put in place.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy There are a number of industrial buildings and facilities within generated from renewable the estate and therefore opportunities to connect to major heat sources users.

Economic

Table F.11 WMSP-O/D Queensway (Land west of), Hastings

Objective Assessment comments

Social

2. To protect the amenity of - There are residential areas adjoining the site with views to the residents and neighbouring site and any development of the site is likely to have adverse land uses visual impacts. Mitigation: Development should provide screening from residential areas through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no impact from noise and odours on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F20 Objective Assessment comments

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Hastings the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

12. To conserve and enhance -/? Part of the site is a greenfield site. Development may help to important soil functions encourage the composting of biodegradable waste, but this and types depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and 0/? Although development of the site would result in the loss of enhance East Sussex and greenfield land, the impacts on the countryside of East Sussex Brighton & Hove’s will be limited. There is the potential for archaeological remains countryside and historic on the site. and built environment Mitigation: Any planning application should be accompanied by an assessment of the site archaeology.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F21 Objective Assessment comments

14. To protect, conserve and - The site is adjacent to several areas of BAP priority habitat, a where appropriate enhance SSSI, ancient woodland and a Local Nature Reserve. Part of the East Sussex and Brighton & SSSI falls within the site allocation. Adverse impacts are Hove’s biodiversity and possible from reduced air quality due to facility emissions and geodiversity vehicle emissions and from predation by vermin. The site partially overlaps Marline Park Woods LGS. Mitigation: Any planning application should be accompanied by an assessment of impacts on air and water quality with particular focus on the impacts on biodiversity. Development which attracts vermin should not be permitted unless appropriate mitigation is put in place. Development should avoid the SSSI and appropriate mitigation put in place to ensure no adverse effect. A 15m buffer should be provided to the ancient woodland. A 15m buffer should be provided for the LGS.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy There are some limited opportunities to provide heat to generated from renewable potential users nearby. sources

Economic

17. To provide employment + Development of the site will create job opportunities fairly close opportunities and develop to some deprived areas of Hastings, although on its own it is not and maintain a skilled likely to significantly improve overall employment prospects for workforce deprived areas.

Table F.12 WMSP-O/E Station Road / Old Swan Lane Industrial Estate, Hailsham

Objective Assessment comments

Social

2. To protect the amenity of - There are residential properties close to the site and therefore residents and neighbouring there may be adverse impacts on amenity and visual impacts, land uses depending on the scale of development and the existence of a stack. Mitigation: Development should provide screening from residential buildings through appropriate screening and tree planting. Large scale development is unlikely to be acceptable in this location. Any planning application should be required to demonstrate that there will be no impact from noise and odours on residential areas.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F22 Objective Assessment comments

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 No adverse impacts on water quality are likely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Eastbourne, the site will contribute towards reducing emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located near Eastbourne, which will help to reduce impacts of transporting waste transport. There is an existing waste facility on site which waste and minerals on the presents an opportunity to co-locate facilities. No opportunities environment have been identified for the use of sustainable modes of transport.

12. To conserve and enhance - Part of the site is greenfield land and part previously developed. important soil functions /+/ The site contains grade 3 agricultural land. Development may and types ? help to encourage the composting of biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and ? No significant impacts on landscape and countryside. There is enhance East Sussex and potential for there to be archaeological remains on the site. Brighton & Hove’s Mitigation: Any planning application should be accompanied by countryside and historic an assessment of the site archaeology. and built environment

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F23 Objective Assessment comments

14. To protect, conserve and - The site is 400m from a SSSI. It is adjacent to BAP priority where appropriate enhance habitat and there are records of protected species in the vicinity. East Sussex and Brighton & Development of wooded area is likely to reduce the connectivity Hove’s biodiversity and of ecological networks. Adverse impacts are possible from air geodiversity emissions from facilities and transport and from disturbance and predation. The site is 400m from Pevensey Levels SCI and Ramsar site and adverse impacts are possible on water quality from surface run-off. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with a particular focus on effects on biodiversity. Development which attracts vermin should not be permitted unless appropriate mitigation is put in place. An ecological assessment should be undertaken to assess the existence of protected species and appropriate mitigation put in place. An Appropriate Assessment may be required.

Economic

Table F.13 WMSP-O/F Station Road Industrial Estate, Hailsham

Objective Assessment comments

Social

2. To protect the amenity of - There are residential properties adjacent to the site and therefore residents and neighbouring there may be adverse impacts on amenity and visual impacts, land uses depending on the scale of development and the existence of a stack. Mitigation: Development should provide screening from residential buildings through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no adverse impact from noise and odours on residential areas.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F24 Objective Assessment comments

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 No adverse impacts on water quality are likely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Eastbourne, the site will contribute towards reducing emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located near Eastbourne, which will help to reduce impacts of transporting waste transport. No opportunities have been identified for the waste and minerals on the co-location of waste facilities or the use of sustainable modes of environment transport.

12. To conserve and enhance - Part of the site is greenfield land and part previously developed. important soil functions /+/ Development may help to encourage the composting of and types ? biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and ? The site borders countryside to the south. There is potential for enhance East Sussex and there to be archaeological remains on the site. Brighton & Hove’s Mitigation: Any planning application should be accompanied by countryside and historic an assessment of the site archaeology. Development should be and built environment of an appropriate type, scale and design to minimise adverse visual impacts on the countryside.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F25 Objective Assessment comments

14. To protect, conserve and - The site is 800m from a SSSI. It is adjacent to BAP priority where appropriate enhance habitat and there are records of protected species in the vicinity. East Sussex and Brighton & Development of wooded area is likely to reduce the connectivity Hove’s biodiversity and of ecological networks. Adverse impacts are possible from air geodiversity emissions from facilities and transport, from disturbance and land-take. The site is 830m from Pevensey Levels SCI and Ramsar site and adverse impacts on water quality are possible from surface run-off. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with a particular focus on effects on biodiversity. Development should avoid the wooded area. An ecological assessment should be undertaken to assess the existence of protected species and appropriate mitigation put in place. An Appropriate Assessment may be required.

Economic

Table F.14 WMSP-S/A Burgess Road, Hastings

Objective Assessment comments

Social

2. To protect the amenity of - There is a caravan site to the south east which is well screened residents and neighbouring from the site by trees. The site is in informal recreational use land uses and development would result in loss of this. Mitigation: Existing screening woodland should be retained.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F26 Objective Assessment comments

Environmental

6. To maintain and improve 0 No adverse impacts on water quality are likely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Hastings, the site will contribute towards reducing emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located near Hastings, which will help to reduce impacts of transporting waste transport. There is an existing waste facility on site which waste and minerals on the presents an opportunity to co-locate facilities. No opportunities environment have been identified for the use of sustainable modes of transport.

13. To protect, conserve and -/? The site is within the AONB and is wooded. Development of enhance East Sussex and the site would erode the AONB. There is potential for there to Brighton & Hove’s be archaeological remains on the site. countryside and historic Mitigation: Development should be of an appropriate scale, and built environment design and well-screened to minimise adverse effects on the AONB. Any planning application should be accompanied by an assessment of the site archaeology.

14. To protect, conserve and - There are several local nature conservation sites within 1km. where appropriate enhance The site contains BAP priority habitat. There are several patches East Sussex and Brighton & of ancient woodland within 1km and development of the site is Hove’s biodiversity and likely to reduce the connectivity of ecological networks. geodiversity Adverse impacts are possible from air emissions from facilities and transport. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with a particular focus on effects on biodiversity.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F27 Objective Assessment comments

Economic

Table F.15 WMSP-S/B Ivyhouse Lane Extension, Hastings

Objective Assessment comments

Social

2. To protect the amenity of - There are residential areas within 250 m of the site and any residents and neighbouring development of the site is likely to have adverse visual impacts. land uses A waste facility could adversely impact the caravan site although it is close to existing industrial areas and a railway line. Mitigation: Development should provide screening from residential areas and the caravan site through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no adverse impact from noise and odours on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F28 Objective Assessment comments

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Hastings the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

13. To protect, conserve and - The site is within the High Weald AONB and is undeveloped. enhance East Sussex and Any development will have an adverse impact on the AONB. Brighton & Hove’s There are several undesignated heritage assets within 1 km and countryside and historic there is the potential for archaeological remains to exist on site. and built environment Mitigation: Significant screening of the site should be required, and any planning application should be accompanied by an assessment of the site archaeology.

14. To protect, conserve and - There is a SSSI 3km to the south and air quality impacts are where appropriate enhance possible. The site is adjacent to several areas of BAP priority East Sussex and Brighton & habitat and there are several local nature conservation sites Hove’s biodiversity and within 1 km including one adjacent to the site. There are several geodiversity patches of ancient woodland within 1 km, including one 175m distant. Adverse impacts are possible from reduced air quality due to facility emissions and vehicle emissions and litter. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality and litter with particular focus on the impacts on biodiversity.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F29 Objective Assessment comments

Economic

Table F.16 WMSP-S/C Land north of Sidley, Bexhill

Objective Assessment comments

Social

2. To protect the amenity of - There are residential areas within 100m of the site and any residents and neighbouring development of the site is likely to have adverse visual impacts land uses depending on the height of any buildings or the existence of a stack. It is unlikely to be possible to fully mitigate the visual impacts. The existing road network is unsuitable for additional HGV traffic and residents are likely to experience a loss of amenity until new roads can be built. Public footpaths and bridleway cross the site area, which is adjacent to public open spaces and Levetts Wood. Mitigation: Development should provide screening from residential areas and public open spaces through buffers and appropriate screening and tree planting. Public footpaths and bridleways should be retained and enhanced as green infrastructure.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F30 Objective Assessment comments

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The location close to Bexhill will make some contribution to reducing waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 Located close to Bexhill the site will make a contribution to impacts of transporting reducing the adverse impacts of waste transport. As an waste and minerals on the undeveloped site there are good opportunities to co-locate environment waste facilities. No opportunities have been identified for the use of sustainable modes of transport.

13. To protect, conserve and -/+ The site is open greenfield land and so development will have a enhance East Sussex and significant adverse impact on the local landscape and Brighton & Hove’s countryside, although the site is within a master plan area and countryside and historic therefore the land is highly likely to be developed in any event. and built environment The setting of Preston Hall listed buildings will be adversely affected. There is high potential for important historic remains to have survived below ground. Mitigation: Any planning application should be accompanied by an assessment of visual impact on the listed buildings and appropriate mitigation put in place if necessary. Any planning application should be accompanied by an assessment of historic assets.

14. To protect, conserve and - The site is adjacent to two areas of ancient woodland and there where appropriate enhance are more close to the site. There is an SSSI and BAP priority East Sussex and Brighton & habitat 1km from the site. There are several SNCIs within 1km Hove’s biodiversity and of the site. Adverse impacts are possible from reduced air geodiversity quality due to facility emissions and vehicle emissions, from disturbance and litter and potentially from leachate. Mitigation: Any planning application should be accompanied by an assessment of impacts on air and water quality, disturbance and litter with particular focus on the impacts on biodiversity.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy As an undeveloped site there is good potential to connect to generated from renewable heat users. sources

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F31 Objective Assessment comments

Economic

Table F.17 WMSP-S/D Land at West Uckfield, Uckfield

Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

Social

2. To protect the amenity of - The site has been allocated for mixed uses including residential, residents and neighbouring education and employment. There is the potential for impacts land uses on residential amenity and visual impacts depending on the location of any development, its scale and its proximity to residential areas or schools. Mitigation: Any planning application should be accompanied by an assessment of impacts on residential amenity and appropriate mitigation put in place. Development should be well-designed and well-screened. Existing vegetation should be retained where possible.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F32 Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

8. To reduce risk and impact ? Most of the site is in flood zone 1, but there are small areas of of flooding flood zones 2 and 3 on the site. Impacts on flood risk are dependent on the location of any waste development within the site, which is unknown.

9. To limit the causes of and +/0 The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating north of Uckfield, the site will not make a significant contribution to reducing emissions from waste transport.

10. To protect air quality 0 There are no air quality issues near the site and impacts are and reduce air pollution unlikely.

11. To reduce adverse 0/+ By locating north of Uckfield, the site is away from centres of impacts of transporting population and will not help significantly to reduce waste waste and minerals on the transport. No opportunities have been identified for the co- environment location of waste facilities or the use of sustainable modes of transport.

13. To protect, conserve and -/? There will be significant impacts on countryside from the enhance East Sussex and development of the site through loss of countryside, although Brighton & Hove’s the impacts relating to waste development will be relatively countryside and historic minor. The site is close to known areas of Roman activity and and built environment there is potential for remains to exist below ground. Mitigation: Any planning application should be accompanied by an assessment of historic assets.

14. To protect, conserve and ? There are three areas of ancient woodland within the site and where appropriate enhance two areas of BAP priority habitat. Any impacts are dependent East Sussex and Brighton & on the location of waste development which is unknown. The Hove’s biodiversity and sites is 5.2km from Ashdown Forest SAC/SPA and adverse geodiversity impacts on air quality are possible from facilities and vehicles. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, with particular focus on the impacts on biodiversity. An Appropriate Assessment may be required.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy With a large mixed use development there are likely to be generated from renewable opportunities to develop CHP. sources

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F33 Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

Economic

Table F.18 WMSP-S/E Whitworth Rd, Hastings

Objective Assessment comments

Social

2. To protect the amenity of - There are residential properties adjacent to the site and therefore residents and neighbouring there are likely to be adverse impacts on amenity and visual land uses impacts, depending on the scale of development and the existence of a stack. The site has recreational potential. It is a greenfield site in a prominent location with long views into the site. Mitigation: Development should provide screening from residential buildings and surrounding green space through appropriate screening and tree planting. Large scale development is unlikely to be acceptable in this location due to visual impact. Any planning application should be required to demonstrate that there will be no impact from noise and odours on residential areas.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 No adverse impacts on water quality are likely. water quality

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F34 Objective Assessment comments

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - The site is mostly flood zone 1 but there is a small area of flood of flooding zone 3. Mitigation: Any planning application should be accompanied by a flood risk assessment which demonstrates no adverse impact on flood risk and improvement of risk where possible. Development should avoid the functional flood plain.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Hastings, the site will contribute towards reducing emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located near Hastings, which will help to reduce impacts of transporting waste transport. There is an existing waste facility nearby waste and minerals on the which presents an opportunity to co-locate facilities. No environment opportunities have been identified for the use of sustainable modes of transport.

13. To protect, conserve and - The site is adjacent to the AONB but separated by landform. enhance East Sussex and There are long views into the site and it is located at a Brighton & Hove’s prominent location. The are three listed buildings in close countryside and historic proximity to the site and development is likely to adversely and built environment affect their setting. There is potential for there to be archaeological remains on the site. Mitigation: Development should be of an appropriate scale, design and well-screened to minimise adverse effects on the AONB and the setting of listed buildings. Any planning application should be accompanied by an assessment of the site archaeology.

14. To protect, conserve and - The site is approximately 750m from a SSSI and 800m from an where appropriate enhance LNR and a second SSSI. The site is adjacent to BAP priority East Sussex and Brighton & habitat and there are records of protected species in the vicinity. Hove’s biodiversity and There are several local nature conservation sites within 1km, geodiversity including one adjacent to the site and one on site. The site is adjacent to a patch of ancient woodland and several more within 1km and development of the site is likely to reduce the connectivity of ecological networks. Adverse impacts are possible from air emissions from facilities and transport and land-take, from leachate, from disturbance and predation. Mitigation: Any planning application should be accompanied by an assessment of impacts on air and water quality with a particular focus on effects on biodiversity. Development which attracts vermin should not be permitted unless appropriate mitigation is put in place. A 15m buffer should be provided to ancient woodland.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F35 Objective Assessment comments

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Industrial units and a food superstore nearby present generated from renewable opportunities to connect to major heat users. sources

Economic

Table F.19 WMSP-E/A Cophall Wood Waste Transfer Station (Land North of), A22, Polegate

Objective Assessment comments

Social

1. To avoid negative effects 0 There are unlikely to be significant impacts on health. and enhance, where possible, positive effects on health

2. To protect the amenity of 0 Site is in an isolated rural area and negative impacts on amenity residents and neighbouring are unlikely. land uses

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 No adverse impacts on water quality are likely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F36 Objective Assessment comments

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Eastbourne, the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located near Eastbourne, which will help to reduce impacts of transporting waste transport. There is an existing waste facility to the south waste and minerals on the of the site which presents an opportunity to co-locate waste environment facilities. No opportunities have been identified for the use of sustainable modes of transport.

12. To conserve and enhance - Part of the site is greenfield and there is grade 3 agricultural important soil functions /+/ land within the site. Development may help to encourage the and types ? composting of biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and ? The site is in a rural area and visual impacts on the countryside enhance East Sussex and are possible, depending on the scale of the development and the Brighton & Hove’s existence of a stack. The potential for there to be archaeological countryside and historic remains on the site is unknown. and built environment Mitigation: Existing vegetation should be retailed and development should be screened from the surrounding countryside. Large-scale development is unlikely to be acceptable in this location. Any planning application should be accompanied by an assessment of the site archaeology.

14. To protect, conserve and - The site is adjacent to ancient woodland and an SNCI. There are where appropriate enhance BAP priority habitats within the site and records of a protected East Sussex and Brighton & species in the vicinity. Adverse impacts are possible from air Hove’s biodiversity and emissions from facilities and transport, from disturbance, land- geodiversity take, litter and from predation. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with a particular focus on effects on biodiversity. Development which attracts vermin should not be permitted unless appropriate mitigation is put in place. An ecological assessment should be undertaken to assess the existence of protected species and appropriate mitigation put in place.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F37 Objective Assessment comments

Economic

Table F.20 WMSP-E/B Woodside Depot, A22, Polegate

Objective Assessment comments

Social

2. To protect the amenity of ? There is a residential property adjoining the site and any residents and neighbouring development of the site may have adverse impacts on land uses residential amenity depending on the nature of operations. There is the possibility of adverse visual impacts on the surrounding rural character. Mitigation: Development should provide screening from residential areas through appropriate screening and tree planting. Existing vegetation should be retained.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is in flood zone 1. of flooding

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F38 Objective Assessment comments

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The location near to Eastbourne could make a contribution to reducing waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located near to Eastbourne, which will help to reduce impacts of transporting the impacts of waste transport. No opportunities have been waste and minerals on the identified for the co-location of waste facilities or the use of environment sustainable modes of transport.

13. To protect, conserve and 0/? No impacts on countryside and landscape. There are two listed enhance East Sussex and buildings 300m to the east although there are trees between Brighton & Hove’s these and the site which should screen development. There is countryside and historic the possibility of historic remains to have survived below and built environment ground. Mitigation: Any planning application should be accompanied by an assessment of historic assets.

14. To protect, conserve and - There are several areas of BAP priority habitats, ancient where appropriate enhance woodlands and a local nature conservation site within 1km and East Sussex and Brighton & records of protected species in the vicinity. Adverse impacts are Hove’s biodiversity and possible from reduced air quality due to facility emissions and geodiversity vehicle emissions. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity. An ecological assessment should be undertaken to determine the presence of protected species and appropriate mitigation put in place.

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F39 Table F.21 IND/A Alder Close and Hawthorn Road Industrial Estate, Lottbridge Drove, Eastbourne

Objective Assessment comments

Social

1. To avoid negative effects 0 There are unlikely to be significant impacts on health from and enhance, where development on the site. possible, positive effects on health

2. To protect the amenity of 0 The nearest residential properties are 300m away but are residents and neighbouring separated from the site by an industrial area and therefore there land uses are unlikely to be significant impacts on residential amenity from waste development.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - The site is located almost entirely in flood zone 3. of flooding Mitigation: Any planning application should be accompanied by a flood risk assessment which should demonstrate no adverse impact on flood risk and an improvement in flood risk where possible. Development should be avoided in the functional flood plain.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Eastbourne the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F40 Objective Assessment comments

11. To reduce adverse +/- The site is located near to Eastbourne, which will help to reduce impacts of transporting waste transport. No opportunities have been identified for co- waste and minerals on the location of waste facilities or the use of sustainable modes of environment transport. There are capacity issues on the local road network that a waste facility could add to, particularly a large-scale one. Mitigation: Any planning application should be accompanied by a transport assessment which demonstrates that vehicle movements will be at acceptable levels

12. To conserve and enhance +/? The site is on previously developed land. Development may important soil functions help to encourage the composting of biodegradable waste, but and types this depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and 0/? No impacts on landscape and countryside. There is the enhance East Sussex and potential for there to be archaeological remains on the site. Brighton & Hove’s Mitigation: Any planning application should be accompanied by countryside and historic an assessment of the site archaeology. and built environment

14. To protect, conserve and - There are several local nature conservation sites within 1km, where appropriate enhance including 1 adjacent to the site. BAP priority habitat is adjacent East Sussex and Brighton & to the site and there are records of a protected species in the Hove’s biodiversity and vicinity. Adverse impacts are possible from reduced air quality geodiversity due to facility emissions and vehicle emissions, from disturbance, and predation. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation, with particular focus on the impacts on biodiversity. An ecological assessment should be undertaken to determine the presence of protected species and appropriate mitigation put in place.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Nearby industrial estates and residential areas may present an generated from renewable opportunity to connect to heat users. sources

Economic

17. To provide employment + Development of the site will create job opportunities close to opportunities and develop deprived communities, although on its own it is not likely to and maintain a skilled significantly improve overall employment prospects for workforce deprived areas.

Table F.22 IND/B Avis Way/New Road Industrial Estates, Newhaven

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F41 Objective Assessment comments

2. To protect the amenity of ? There are residential properties about 130m from the site and residents and neighbouring there are views into the site from residences. However, a waste land uses development is unlikely to have a significantly greater impact on residential amenity than existing industrial uses. There are footpaths within the site and a recreation ground adjacent, which could be affected by waste development depending on its location within the site. Mitigation: Development should be of a high quality design and provide screening from residential areas. Existing footpaths should be retained. Any planning application should be required to demonstrate that there will be no impact from noise and odours on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 The eastern part of the site is within groundwater source water quality protection zone 3. However, adverse impacts on water quality are unlikely.

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - The site is almost entirely within flood zone 3. of flooding Mitigation: Any planning application should be accompanied by a flood risk assessment and should demonstrate no adverse impact on flood risk and improvement of flood risk where possible. Development in the functional flood plain should be avoided.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F42 Objective Assessment comments

11. To reduce adverse +/- Being situated between Brighton and Eastbourne, the site will impacts of transporting make a contribution to reducing the adverse impacts of waste waste and minerals on the transport. There are several waste uses on site and therefore the environment site presents an opportunity to co-locate waste facilities. No opportunities have been identified for the use of sustainable modes of transport. Adverse impacts are likely on the local road network by additional HGVs. Mitigation: Any planning application should be accompanied by a transport assessment which should demonstrate adequate capacity on the local road network.

14. To protect, conserve and - There are several local nature conservation sites within 1km of where appropriate enhance the site, including one 20m away. There are BAP priority East Sussex and Brighton & habitats adjacent to the site and records of protected species in Hove’s biodiversity and the vicinity. Adverse impacts are possible from reduced air geodiversity quality due to facility emissions and vehicle emissions, from accidental discharge to the intertidal area, from land-take and from disturbance and predation. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, water quality, disturbance and predation with particular focus on the impacts on biodiversity. An ecological assessment should examine the existence of protected species on site and in the vicinity and appropriate mitigation put in place.

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F43

Table F.23 IND/C Beeching Road Industrial Estate, Bexhill

Objective Assessment comments

Social

2. To protect the amenity of - There are residential areas adjacent to the site although residents and neighbouring development of the site is unlikely to have significantly worse land uses visual impacts than existing uses. Impacts are possible on residential amenity from waste development. A footpath crosses the site. Mitigation: Development should provide screening from residential areas through buffers and appropriate screening and tree planting. Any planning application should be accompanied by an assessment of impacts on residential amenity and appropriate mitigation put in place to mitigate adverse impacts on neighbouring land uses. The footpath should be retained.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - Much of the site is within flood zone 1, but there are also areas of flooding of flood zones 2 and 3 within the site. Mitigation: Any planning application should be accompanied by a flood risk assessment which demonstrates no adverse impact on flood risk and a reduction in flood risk where possible. Development should avoid the functional flood plain.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The location close to Bexhill will make some contribution to reducing waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F44 Objective Assessment comments

11. To reduce adverse +/0 Located close to Bexhill the site will make a contribution to impacts of transporting reducing the adverse impacts of waste transport. No waste and minerals on the opportunities have been identified for the co-location of waste environment facilities or for the use of sustainable modes of transport.

13. To protect, conserve and 0/- No adverse impacts on landscape and countryside. There are enhance East Sussex and non-designated but potentially important buildings and Brighton & Hove’s structures on the site and development may have significant countryside and historic adverse effects depending on its location within the site. and built environment Mitigation: Any planning application should be accompanied by an assessment of historic assets.

14. To protect, conserve and - There is a patch of ancient woodland which is also an SNCI where appropriate enhance 700m from the site and BAP priority habitat 250m from the site. East Sussex and Brighton & There is the potential for adverse impacts from reduced air Hove’s biodiversity and quality due to facility emissions and vehicle emissions. geodiversity Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity.

Economic

Table F.24 IND/D Bellbrook Industrial Estate, Uckfield

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F45 Objective Assessment comments

2. To protect the amenity of - The site is adjacent to residential areas and there is the potential residents and neighbouring for impacts on residential amenity and visual impacts land uses depending on the location of any development, its scale and its proximity to residential areas. A footpath abuts the site but adverse impacts are unlikely. Mitigation: Any planning application should be accompanied by an assessment of impacts on residential amenity and appropriate mitigation put in place. Development should be well-designed and well-screened. Existing vegetation should be retained where possible.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact ? Some of the site is in flood zone 1, but there are also areas of of flooding flood zones 2 and 3 on the site. Impacts on flood risk are dependent on the location of any waste development within the site, which is unknown.

9. To limit the causes of and +/0 The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Uckfield, the site will not make a significant contribution to reducing emissions from waste transport.

10. To protect air quality 0 There are no air quality issues near the site and impacts are and reduce air pollution unlikely.

11. To reduce adverse 0/+ By locating near to Uckfield, the site is away from centres of impacts of transporting population and will not help significantly to reduce waste waste and minerals on the transport. There is an existing waste facility on site which environment presents an opportunity to co-locate waste facilities. No opportunities have been identified for the use of sustainable modes of transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F46 Objective Assessment comments

13. To protect, conserve and 0 No impacts on landscape and countryside or on historic assets. enhance East Sussex and Brighton & Hove’s countryside and historic and built environment

14. To protect, conserve and - There are several areas of ancient woodland and several local where appropriate enhance nature conservation within 1km, including one SNCI within East Sussex and Brighton & 20m. Adverse impacts are possible due to emissions to air from Hove’s biodiversity and a facility and associated transport, and from predation. The site geodiversity is 5.4km from Ashdown Forest SAC/SPA and adverse impacts on air quality are possible. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, with particular focus on the impacts on biodiversity. Development which attracts vermin should not be permitted unless appropriate mitigation is put in place. An Appropriate Assessment may be required.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy With a large mixed use development there are likely to be generated from renewable opportunities to develop CHP. A hospital and retail superstore sources nearby present opportunities to connect to major heat users.

Economic

Table F.25 IND/E Brampton Road Industrial Estate, Willingdon Drive, Eastbourne

Objective Assessment comments

Social

2. To protect the amenity of - There are residential properties adjacent to the site and therefore residents and neighbouring there may be adverse impacts on amenity, depending on the land uses scale of facility and the existence of a stack. Visual impacts are not likely to be significantly different than existing uses. Mitigation: Development should provide screening from residential buildings through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no impact from noise and odours on neighbouring land uses.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F47 Objective Assessment comments

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - The site is contains areas of flood zones 2 and 3. of flooding Mitigation: Any planning application should be accompanied by a flood risk assessment which should demonstrate no adverse impact on flood risk and an improvement in flood risk where possible. Development should be avoided in the functional flood plain.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Eastbourne the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located near to Eastbourne, which will help to reduce impacts of transporting waste transport. No opportunities have been identified for co- waste and minerals on the location of waste facilities or the use of sustainable modes of environment transport.

14. To protect, conserve and 0 There are three SNCIs within 1km and BAP priority habitats where appropriate enhance adjacent to the site. There are unlikely to be significant impacts. East Sussex and Brighton & Hove’s biodiversity and geodiversity

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F48 Objective Assessment comments

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Nearby industrial estates, large retail units, a school and generated from renewable residential areas may present an opportunity to connect to heat sources users.

Economic

Table F.26 IND/F Brett Drive Industrial Estate, Bexhill

Objective Assessment comments

Social

2. To protect the amenity of - There are residential areas adjacent to the site although residents and neighbouring development of the site is unlikely to have significantly worse land uses visual impacts than existing uses. Impacts are possible on residential amenity from waste development. Mitigation: Development should provide screening from residential areas through buffers and appropriate screening and tree planting. Any planning application should be accompanied by an assessment of impacts on residential amenity and appropriate mitigation put in place to mitigate adverse impacts on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F49 Objective Assessment comments

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The location close to Bexhill will make some contribution to reducing waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

13. To protect, conserve and 0/? No adverse impacts on landscape and countryside. The enhance East Sussex and potential for historic remains to have survived below ground is Brighton & Hove’s unknown. countryside and historic Mitigation: Any planning application should be accompanied by and built environment an assessment of historic assets.

14. To protect, conserve and - There is a patch of ancient woodland and several local nature where appropriate enhance conservation sites within 1km. There is the potential for adverse East Sussex and Brighton & impacts from reduced air quality due to facility emissions and Hove’s biodiversity and vehicle emissions. geodiversity Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity.

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F50 Table F.27 IND/G Bulverhythe Depot, Bulverhythe, St Leonards-on-Sea

Objective Assessment comments

Social

2. To protect the amenity of - There are residential areas adjacent to the site, but waste residents and neighbouring development is unlikely to be significantly different in land uses residential amenity terms than existing site uses. Residential roads could be adversely affected by additional waste traffic. Mitigation: Any development should be well screened from residential areas. Any planning application should be accompanied by an assessment of impacts on residential amenity including from traffic and appropriate mitigation put in place.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - The site is almost entirely within flood zone 3. of flooding Mitigation: Any planning application should be accompanied by a flood risk assessment and demonstrate no adverse impact on flood risk and reduction of risk where possible. Development should be prohibited within flood zone 3B.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The location between Bexhill and Hastings is likely to make a contribution to reducing waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity and adverse and reduce air pollution impacts are unlikely.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F51 Objective Assessment comments

11. To reduce adverse +/- Being situated between Bexhill and Hastings, the site is likely to impacts of transporting make a contribution to reducing the adverse impacts of waste waste and minerals on the transport. There are existing waste operations on and adjacent environment to the site and therefore the site presents an opportunity to co- locate waste facilities. There is a railway line with sidings to the south of the site. Access constraints make the site unviable until a new road is constructed.

13. To protect, conserve and 0/? No impacts on landscape and countryside. There is the enhance East Sussex and potential for historic remains to have survived below ground. Brighton & Hove’s Mitigation: Any planning application should be accompanied countryside and historic and built environment by an assessment of below-ground historic assets.

14. To protect, conserve and - There are several local nature conservation sites within 1km, where appropriate enhance including one adjacent to the site. There is the potential for East Sussex and Brighton & adverse impacts on biodiversity from emissions from a facility Hove’s biodiversity and and associated transport and from litter. geodiversity Mitigation: Any planning application should be accompanied by an assessment of the impacts on biodiversity from emissions to air and litter and appropriate mitigation put in place.

Economic

17. To provide employment + Development of the site will create job opportunities near to opportunities and develop deprived communities in Hastings, although on its own it is not and maintain a skilled likely to significantly improve overall employment prospects. workforce

Table F.28 IND/H Castleham Industrial Estate, St Leonards-on-Sea

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F52 Objective Assessment comments

2. To protect the amenity of 0/+ There are residential areas adjacent to the site, although it is in residents and neighbouring /- existing industrial use and therefore any negative visual impacts land uses are unlikely to be significantly worse than current uses, and development presents an opportunity to improve visual impacts. Adverse effects on residential amenity are possible. Mitigation: Development should provide screening from residential areas and existing vegetation should be retained. Any planning application should be required to demonstrate that there will be no adverse impact from noise and odours on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Hastings the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located in the urban area of Hastings, which will help impacts of transporting to reduce waste transport. No opportunities have been waste and minerals on the identified to co-locate waste facilities or for the use of environment sustainable modes of transport.

12. To conserve and enhance +/- The site is previously developed land although it contains some important soil functions /? small areas of greenfield land. Development may help to and types encourage the composting of biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and 0/? No impacts on landscape and countryside. There is the enhance East Sussex and potential for archaeological remains to exist on site. Brighton & Hove’s Mitigation: Any planning application should be accompanied by countryside and historic an assessment of the site archaeology. and built environment

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F53 Objective Assessment comments

14. To protect, conserve and - There are several patches of ancient woodland and local nature where appropriate enhance conservation sites within 1km, including one site within 40m East Sussex and Brighton & which is also a SSSI. There are BAP priority habitats adjacent to Hove’s biodiversity and the site and records of protected species in the vicinity. Adverse geodiversity impacts are possible from reduced air quality due to facility emissions and vehicle emissions, leachate and likely fragmentation of ecological networks if trees on the site are lost. Adverse impacts are also possible from litter. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality and litter with particular focus on the impacts on biodiversity. Existing vegetation on site should be retained. A 15m buffer should be provided to ancient woodland.

Economic

Table F.29 IND/I Centenary Industrial Estate, Brighton

Objective Assessment comments

Social

2. To protect the amenity of 0 Significant impacts are unlikely on neighbouring land uses, but residents and neighbouring existing trees are important for screening the site. land uses Mitigation: Any development should retain existing trees.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F54 Objective Assessment comments

Environmental

6. To maintain and improve 0 Significant impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality - The site is close to an AQMA and air quality could be adversely and reduce air pollution affected by vehicles accessing the site. Mitigation: Any planning application should be accompanied by a Transport Assessment and an assessment of impacts on air quality.

11. To reduce adverse +/0 The site is located in the urban area, which will help to reduce impacts of transporting waste transport. The site is near to several sites with potential to waste and minerals on the use heat generated by the facility. However, no opportunities environment have been identified for co-location of waste facilities or use of sustainable modes of transport.

13. To protect, conserve and 0/- No impacts on landscape and countryside identified. enhance East Sussex and The site is adjacent to the Roundhill conservation area. If Brighton & Hove’s screening is provided, impacts should not be major. Railway countryside and historic archaeology survives. and built environment Mitigation: Trees should be planted to add to the existing screening. Any archaeological assets should be investigated and assessed and appropriate mitigation put in place.

14. To protect, conserve and 0 There are five local wildlife sites within 1km and there is where appropriate enhance potential for adverse air quality impacts at four of these. East Sussex and Brighton & Mitigation: Any planning application should be accompanied by Hove’s biodiversity and an assessment of impacts on air quality and suitable mitigation geodiversity included within the development.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F55 Objective Assessment comments

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Existing and future development sites nearby may present generated from renewable opportunities to connect to heat network. sources

Economic

Table F.30 IND/J Chaucer Industrial Estate, Polegate

Objective Assessment comments

Social

2. To protect the amenity of ? There are residential areas adjoining the site and any residents and neighbouring development of the site may have adverse visual impacts land uses depending on the height of any buildings or the existence of a stack. Some existing uses of the estate may not be compatible with some types of waste-related development. Mitigation: Development should provide screening from residential areas through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no impact on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F56 Objective Assessment comments

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The location near to Eastbourne could make a contribution to reducing waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located near to Eastbourne, which will help to reduce impacts of transporting the impacts of waste transport. There are existing waste waste and minerals on the facilities on the estate providing an opportunity to co-locate environment waste operations. However, no opportunity has been identified for the use of sustainable modes of transport.

13. To protect, conserve and 0/? No impacts on countryside and landscape. There has been enhance East Sussex and prehistoric, Roman and medieval activity in the vicinity and a Brighton & Hove’s major Roman road passes through the site. There is the countryside and historic potential for remains to have survived below ground. and built environment Mitigation: Any planning application should be accompanied by an assessment of historic assets.

14. To protect, conserve and - The site is 250m from BAP priority habitats and there are several where appropriate enhance patches of ancient woodland within 1 km. Adverse impacts are East Sussex and Brighton & possible from reduced air quality due to facility emissions and Hove’s biodiversity and vehicle emissions. geodiversity Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Other industrial units within the estate and neighbouring generated from renewable residential areas may provide opportunities to connect to heat sources users.

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F57

Table F.31 IND/K Churchfields Industrial Estate, St Leonards-on-Sea

Objective Assessment comments

Social

2. To protect the amenity of 0/+ There are residential areas adjacent to the site, although it is in residents and neighbouring /- existing industrial use and therefore any negative visual impacts land uses are unlikely to be significantly worse than current uses, and development presents an opportunity to improve visual impacts. Adverse effects on residential amenity are possible. Some undeveloped parts of the site have recreational potential. Mitigation: Development should provide screening from residential areas and existing vegetation should be retained. Any planning application should be required to demonstrate that there will be no adverse impact from noise and odours on neighbouring land uses. Currently undeveloped areas should be retained as green infrastructure for recreation.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - Site is mostly located in flood zone 1 although there is a small of flooding part within flood zones 2 and 3. Mitigation: Any planning application should be accompanied by a flood risk assessment that demonstrates no adverse impact on flood risk and an improvement in flood risk where possible. The functional flood plain should be avoided.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Hastings the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F58 Objective Assessment comments

12. To conserve and enhance +/- Most of the site is previously developed land although it important soil functions /? contains some areas of semin-natural green space. Development and types may help to encourage the composting of biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

14. To protect, conserve and - There are several patches of ancient woodland, areas of BAP where appropriate enhance priority habitat and part of a LNR within the site. There is a East Sussex and Brighton & SSSI within 20m and another within 600m. There are several Hove’s biodiversity and more local nature conservation sites within 1km and areas of geodiversity BAP priority habitat adjacent to the site and records of protected species in the vicinity. Adverse impacts are possible from reduced air quality due to facility emissions and vehicle emissions. Adverse impacts are also possible from direct land- take, disturbance, predation and litter. There may be fragmentation of ecological networks if habitat on the site is lost. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity. The LNR and areas of BAP priority habitat should be retained. Existing vegetation on site should be retained. An ecological assessment should be undertaken to determine the presence of protected species on site and appropriate mitigation put in place. A 15m buffer should be provided to ancient woodland.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Existing occupants of the estate may provide potential for generated from renewable connection to heat users. sources

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F59 Table F.32 IND/L Diplocks Way, Hailsham

Objective Assessment comments

Social

2. To protect the amenity of ? There are residential areas adjoining the site and any residents and neighbouring development of the site may have adverse visual impacts land uses depending on the height of any buildings or the existence of a stack. Some existing uses of the estate may not be compatible with some types of waste-related development. Mitigation: Development should provide screening from residential areas through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no adverse impact on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - The northern part of the site contains areas of flood risk in zones of flooding 2 and 3. Mitigation: Development should avoid flood zone 3 and should be accompanied by a Flood Risk Assessment to demonstrate how flood risk will be reduced.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. As the site is about 15km from Eastbourne, it could make a contribution to reducing waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F60 Objective Assessment comments

11. To reduce adverse +/0 As the site is about 15km from Eastbourne, it could make a impacts of transporting contribution to reducing the impacts of waste transport. There waste and minerals on the are existing waste facilities on the estate providing an environment opportunity to co-locate waste operations. However, no opportunity has been identified for the use of sustainable modes of transport.

13. To protect, conserve and 0/? No impacts on countryside and landscape. There are historic enhance East Sussex and buildngs on the industrial estate, and there is the potential for Brighton & Hove’s remains to have survived below ground. countryside and historic Mitigation: Any planning application should be accompanied by and built environment an assessment of historic assets. Development should protect the rope factory buildings and contribute to their enhancement where possible.

14. To protect, conserve and - The site is 700m from an SNCI and 80m from a patch of ancient where appropriate enhance woodland, and there are records of great crested newts and East Sussex and Brighton & water voles in the vicinity. Adverse impacts are possible from Hove’s biodiversity and disturbance and reduced air quality due to facility emissions geodiversity and vehicle emissions. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity. Ecological surveys should be undertaken to determine the presence of protected species.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Other industrial units within the estate and neighbouring generated from renewable residential areas may provide opportunities to connect to heat sources users.

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F61 Table F.33 IND/M Dittons Business Park, Dittons Road, Polegate

Objective Assessment comments

Social

2. To protect the amenity of ? There are residential areas in close proximity to the site and any residents and neighbouring development of the site may have adverse visual impacts land uses depending on the height of any buildings or the existence of a stack. Mitigation: Development should provide screening from residential areas through appropriate screening and tree planting. Existing vegetation should be retained.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The location near to Eastbourne could make a contribution to reducing waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F62 Objective Assessment comments

13. To protect, conserve and 0/? No impacts on countryside and landscape. There is the enhance East Sussex and possibility of historic remains to have survived below ground. Brighton & Hove’s countryside and historic Mitigation: Any planning application should be accompanied by and built environment an assessment of historic assets.

14. To protect, conserve and - There are several areas of ancient woodland within 1km of the where appropriate enhance site and records of protected species in the vicinity. Adverse East Sussex and Brighton & impacts are possible from reduced air quality due to facility Hove’s biodiversity and emissions and vehicle emissions and from disturbance and geodiversity predation. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity. An ecological assessment should be undertaken to determine the presence of protected species and appropriate mitigation put in place.

Economic

Table F.34 IND/N English Close Industrial Area, Brighton

Objective Assessment comments

Social

2. To protect the amenity of - There is the potential for adverse impacts on residential amenity residents and neighbouring as some properties are adjacent to the site with no screening. land uses Mitigation: Any development should retain existing trees and provide additional screening for residential properties.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F63 Objective Assessment comments

Environmental

6. To maintain and improve ? The site is located within groundwater source protection zone 2 water quality and there is the potential for adverse impacts. Mitigation: A planning application should be accompanied by measures to ensure no risk to groundwater in accordance with Environment Agency standing advice.

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality - The site is within half a kilometre of an AQMA and air quality and reduce air pollution may be adversely affected by vehicles accessing the site, although this may not be significantly different from the impact of the existing site use. Mitigation: Any planning application should be accompanied by a Transport Assessment and an assessment of impacts on air quality. A vehicle routing strategy should be put in place.

13. To protect, conserve and 0 No impacts on landscape and countryside or historic built enhance East Sussex and environment identified. Brighton & Hove’s countryside and historic and built environment

14. To protect, conserve and 0 No impacts on biodiversity or geodiversity identified. where appropriate enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F64 Objective Assessment comments

15. To increase energy ?/0 Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy It is within 2 km of the Hove Park heat cluster, although the cost generated from renewable of implementing a heat network through the built-up area is sources likely to be high therefore impacts on energy efficiency are unlikely.

Economic

Table F.35 IND/O Farringham Road, Crowborough

Objective Assessment comments

Social

2. To protect the amenity of ? There are residential areas adjoining the site and any residents and neighbouring development of the site may have adverse visual impacts land uses depending on the height of any buildings or the existence of a stack. Some existing uses of the estate may not be compatible with some types of waste-related development. Mitigation: Development should provide screening from residential areas through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no adverse impact on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F65 Objective Assessment comments

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is in flood zone 1. of flooding

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 There are existing waste facilities on the estate providing an impacts of transporting opportunity to co-locate waste operations. However, no waste and minerals on the opportunity has been identified for the use of sustainable modes environment of transport.

13. To protect, conserve and ?/? The site is 300m from the AONB, and adverse visual impacts are enhance East Sussex and possible depending on the height of buildings and the existence Brighton & Hove’s of a stack. There is the potential for remains of brick-making countryside and historic activity to have survived below ground. and built environment Mitigation: Development should be of an appropriate scale and design to minimise adverse impacts on the AONB. Any planning application should be accompanied by an assessment of historic assets.

14. To protect, conserve and - The site abuts a Local Nature Reserve, and there are several where appropriate enhance SNCIs and patches of ancient woodland within 1 km. Adverse East Sussex and Brighton & impacts are possible from reduced air quality due to facility Hove’s biodiversity and emissions and vehicle emissions, from disturbance and possibly geodiversity from predation. The site is 2.9km from Ashdown Forest SAC/SPA and adverse impacts are possible from reduced air quality. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation with particular focus on the impacts on biodiversity. An Appropriate Assessment may be required.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Other industrial units within the estate and neighbouring generated from renewable residential areas may provide opportunities to connect to heat sources users.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F66 Objective Assessment comments

Economic

17. To provide employment + Development of the site will create job opportunities, but these opportunities and develop will not be near to deprived communities and on its own it is and maintain a skilled not likely to significantly improve overall employment workforce prospects.

Table F.36 IND/P Finmere Road Industrial Estate, nr Lottbridge Drove, Eastbourne

Objective Assessment comments

Social

2. To protect the amenity of - There are residential properties and a school adjacent to the site residents and neighbouring and therefore there may be adverse impacts on residential land uses amenity and visual impacts, depending on the scale of facility and the existence of a stack. There are also capacity problems on the local road network which could be added to by a waste facility, particularly a large-scale one. Mitigation: Development should provide screening from residential buildings through appropriate screening and tree planting. Large scale development is unlikely to be acceptable in this location. Any planning application should be required to demonstrate that there will be no impact from noise and odours on neighbouring land uses. Any planning application should be accompanied by a transport assessment which demonstrates that vehicle movements will be at acceptable levels.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F67 Objective Assessment comments

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - A large proportion of the site is in flood zone 1, but there are of flooding areas within flood zones 2 and 3. Mitigation: Any planning application should be accompanied by a flood risk assessment which should demonstrate no adverse impact on flood risk and an improvement in flood risk where possible. Development should be avoided in the functional flood plain.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Eastbourne the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

14. To protect, conserve and - There are several local nature conservation sites within 1km, where appropriate enhance including 1 adjacent to the site. The site is close to BAP priority East Sussex and Brighton & habitat and there are records of a protected species in the Hove’s biodiversity and vicinity. Adverse impacts are possible from reduced air quality geodiversity due to facility emissions and vehicle emissions, from disturbance and predation. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation, with particular focus on the impacts on biodiversity. An ecological assessment should be undertaken to determine the presence of protected species and appropriate mitigation put in place.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Nearby industrial estates, large retail units and residential areas generated from renewable may present an opportunity to connect to heat users. sources

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F68 Objective Assessment comments

Economic

Table F.37 IND/Q Hammonds Drive Industrial Estates, Lottbridge Drove, Eastbourne

Objective Assessment comments

Social

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F69 Objective Assessment comments

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - The site is located entirely in flood zone 3. of flooding Mitigation: Any planning application should be accompanied by a flood risk assessment which should demonstrate no adverse impact on flood risk and an improvement in flood risk where possible. Development should be avoided in the functional flood plain.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Eastbourne the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

14. To protect, conserve and - There are several local nature conservation sites within 1km, where appropriate enhance including 1 adjacent to the site. The site is adjacent to BAP East Sussex and Brighton & priority habitat and there are records of a protected species in Hove’s biodiversity and the vicinity. Adverse impacts are possible from reduced air geodiversity quality due to facility emissions and vehicle emissions, from disturbance and predation. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation, with particular focus on the impacts on biodiversity. An ecological assessment should be undertaken to determine the presence of protected species and appropriate mitigation put in place.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Nearby industrial estates and residential areas may present an generated from renewable opportunity to connect to heat users. sources

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F70 Objective Assessment comments

Economic

Table F.38 IND/R Heathfield Industrial Estate (Ghyll Road Site), Heathfield

Objective Assessment comments

Social

2. To protect the amenity of - There are residential areas adjoining the site and any residents and neighbouring development of the site may have adverse visual impacts land uses depending on the height of any buildings or the existence of a stack. The allocation contains wooded areas and development of these would have adverse visual impacts. Some existing uses of the estate may not be compatible with some types of waste- related development. Mitigation: Development should provide screening from residential areas through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no adverse impact on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F71 Objective Assessment comments

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse 0 No opportunities have been identified for the co-location of impacts of transporting waste management facilities or the use of sustainable modes of waste and minerals on the transport. environment

12. To conserve and enhance -/? Part of the site is previously developed and part is greenfield. important soil functions Development may help to encourage the composting of and types biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and -/? The site is adjacent to the AONB, and adverse visual impacts are enhance East Sussex and possible depending on the height of buildings and the existence Brighton & Hove’s of a stack, particularly development of the currently wooded countryside and historic area. There is the potential for historic remains to have survived and built environment below ground. Mitigation: Development should be of an appropriate scale and design to minimise adverse impacts on the AONB. Any planning application should be accompanied by an assessment of historic assets.

14. To protect, conserve and - The site is adjacent to and contains ancient woodland, is 900m where appropriate enhance from a SSSI and there are records of protected species in the East Sussex and Brighton & vicinity. Adverse impacts are possible from reduced air quality Hove’s biodiversity and due to facility emissions and vehicle emissions, from geodiversity disturbance and possibly from predation. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation with particular focus on the impacts on biodiversity. The site boundary should be redrawn to exclude the ancient woodland.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Other industrial units within the estate and neighbouring generated from renewable residential areas may provide opportunities to connect to heat sources users.

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F72

Table F.39 IND/S Highfields Industrial Estate, Willingdon Drove, Eastbourne

Objective Assessment comments

Social

1. To avoid negative effects 0 There are unlikely to be significant impacts on health. and enhance, where possible, positive effects on health

2. To protect the amenity of 0 No impacts on amenity. residents and neighbouring land uses

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - The site is almost entirely covered by flood zone 3. of flooding Mitigation: Any planning application should be accompanied by a flood risk assessment which should demonstrate no adverse impact on flood risk and an improvement in flood risk where possible. Development should be avoided in the functional flood plain.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Eastbourne the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F73 Objective Assessment comments

14. To protect, conserve and 0 There is a BAP priority habitat adjacent to the site but there are where appropriate enhance unlikely to be significant impacts. East Sussex and Brighton & Hove’s biodiversity and geodiversity

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Nearby industrial estates, large retail units, a school and generated from renewable residential areas may present an opportunity to connect to heat sources users.

Economic

Table F.40 IND/T Hollingbury Industrial Estate, Brighton

Objective Assessment comments

Social

2. To protect the amenity of 0 There are residential areas 100m from the site. The impact of residents and neighbouring using the site for waste uses is unlikely to be significantly worse land uses than existing uses. Mitigation: Development should provide additional screening of residential areas through appropriate screening and tree planting.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F74 Objective Assessment comments

Environmental

6. To maintain and improve ? Site is within groundwater source protection zones 2 and 3. water quality Adverse impacts on groundwater are possible. Mitigation: Any planning application should be accompanied by an assessment which demonstrates no risk to groundwater in accordance with Environment Agency standing advice..

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

13. To protect, conserve and 0/? The National Park borders the site, which is highly visible from enhance East Sussex and the Park. Impacts are unlikely to be significantly different from Brighton & Hove’s existing site uses for most types of waste facility. However, countryside and historic certain types of waste development are likely to have an and built environment additional impact, particularly if buildings are high or there is a stack. There are unlikely to be adverse impacts on historic assets. Mitigation: Development to be designed to minimise adverse impacts on the National Park.

14. To protect, conserve and - The site is adjacent to several areas of BAP priority habitat, two where appropriate enhance Local Nature Reserves and an SNCI and is within 1 km of East Sussex and Brighton & several areas of ancient woodland. Adverse impacts are Hove’s biodiversity and possible from reduced air quality due to facility emissions and geodiversity vehicle emissions. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F75 Objective Assessment comments

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy The site is within 2 km of a heat cluster with relatively generated from renewable undeveloped land in between which presents an opportunity to sources use heat from the facility which will increase energy efficiency.

Economic

17. To provide employment + Development of the site will create job opportunities fairly close opportunities and develop to some deprived areas of Brighton and Hove, although on its and maintain a skilled own it is not likely to significantly improve overall employment workforce prospects for deprived areas.

Table F.41 IND/U Home Farm Industrial Estate, Brighton

Objective Assessment comments

Social

2. To protect the amenity of 0 There are views of the industrial estate from residential areas on residents and neighbouring the other side of the railway, but new development is not likely land uses to significantly increase adverse effects. Development could potentially improve the townscape but effects are not likely to be significant.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve ? The site is located within groundwater source protection zone 2 water quality and there is the potential for adverse impacts with new development. Use of existing units is unlikely to have an adverse effect. Mitigation: A planning application should be accompanied by measures to ensure no risk to groundwater in accordance with Environment Agency standing advice.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F76 Objective Assessment comments

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality - Lewes Road to the south of the site is an AQMA. Effects are not and reduce air pollution likely to be significantly greater than existing uses of the industrial estate and any effects could be mitigated with a routing strategy. Mitigation: Any planning application should be accompanied by a Transport Assessment and an assessment of impacts on air quality. A vehicle routing strategy should be put in place.

13. To protect, conserve and 0/? The site is adjacent to the National Park. Use of existing units is enhance East Sussex and not likely to alter effects on the SDNP. Any new development Brighton & Hove’s could alter the effect for better or worse. countryside and historic Mitigation: Any development should have a high quality of and built environment design and ancient woodland should be retained.

14. To protect, conserve and - There are several sites of local nature conservation importance where appropriate enhance near to the site, including Wild Park LNR which is immediately East Sussex and Brighton & adjacent. There is the potential for adverse impacts on Hove’s biodiversity and biodiversity from waste-related development, from predation, geodiversity disturbance and air quality impacts. The nature of impacts will depend on the type of waste management facility delivered on the site. Mitigation: Any planning application should be accompanied by an ecological assessment and appropriate mitigation put in place. Development which attracts vermin should not be permitted.

15. To increase energy ?/0 Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy It is within 1 km of the University of Brighton Moulsecoomb generated from renewable and Preston Barracks heat user cluster, although separated by sources railway. Falmer heat user cluster approximately within 2km to north, although the cost of implementing a heat network through the built-up area is likely to be high therefore impacts on energy efficiency are unlikely.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F77 Objective Assessment comments

Economic

Table F.42 IND/V Hove Technology Park, St Joseph's Close, Brighton

Objective Assessment comments

Social

2. To protect the amenity of 0 There are residential areas adjoining the site. The impact of residents and neighbouring using the site for waste uses is unlikely to be significantly worse land uses than existing uses. Mitigation: Development should provide additional screening of residential areas through an appropriate buffer and tree planting.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Site is within groundwater source protection zone 3. Adverse water quality impacts on groundwater are unlikely.

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F78 Objective Assessment comments

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality - The site is located close to an AQMA and adverse impacts on air and reduce air pollution quality are possible from a waste management facility and associated transport if this is greater than that associated with existing site uses. Mitigation: Any planning application should be accompanied by a Transport Assessment and an assessment of impacts on air quality. A routing strategy should be provided to minimise the number of vehicles travelling within the AQMA.

11. To reduce adverse +/0 The site is located in the urban area, which will help to reduce impacts of transporting waste transport, and there is a Household Waste Recycling waste and minerals on the Centre adjacent to the site which presents an opportunity to co- environment locate waste management facilities. There is a railway line adjoining the site but no sidings, therefore there are only limited opportunities to use sustainable modes of transport.

13. To protect, conserve and 0/? No impacts on landscape and countryside have been identified. enhance East Sussex and The northern part of the site has been identified as having Brighton & Hove’s potential for remains to exist below ground. countryside and historic Mitigation: Development should undertake an assessment of and built environment historic assets.

14. To protect, conserve and 0 No biodiversity or geodiversity impacts identified. where appropriate enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity

15. To increase energy ?/0 Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy The site is within 1 km of a heat cluster, but the costs of generated from renewable constructing a heat network through the built up area is likely to sources be high.

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F79 Table F.43 IND/W Hyde Business Park, Bevendean, Brighton

Objective Assessment comments

Social

2. To protect the amenity of 0/- There are residential areas adjoining the site but the site is well- residents and neighbouring screened. Development could provide additional screening and land uses so positive impacts are possible. However, access is poor through residential roads and adverse impacts are likely if there are additional vehicle movements above current levels. Mitigation: Any planning application should be accompanied by a transport assessment which demonstrates that vehicle movements will be at acceptable levels. Site is an existing industrial estate and use of a unit may be acceptable if there are no additional vehicle movements compared to existing non- waste uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located in the urban area, which will help to reduce impacts of transporting waste transport, and there is a recycling business on the estate waste and minerals on the which presents an opportunity to co-locate waste management environment facilities. However, no opportunities have been identified to use sustainable modes of transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F80 Objective Assessment comments

13. To protect, conserve and 0/- The site is bordered by the SDNP but is well screened. Impacts enhance East Sussex and /? are unlikely to be significantly different from existing site uses Brighton & Hove’s for most types of waste facility. However, certain types of waste countryside and historic development are likely to have an additional impact, and built environment particularly if buildings are high or there is a stack. There has been prehistoric and medieval activity in the area and there is the potential for remains to have survived. Mitigation: Development should be designed to minimise adverse impacts on the National Park. Development should undertake an assessment of historic assets.

14. To protect, conserve and - The site is surrounded by a Local Nature Reserve and BAP where appropriate enhance priority habitats and is 200m from a second LNR. There are East Sussex and Brighton & several SNCIs within 1 km. Adverse impacts are possible from Hove’s biodiversity and reduced air quality due to facility emissions and vehicle geodiversity emissions. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity.

Economic

Table F.44 IND/X Ivyhouse Lane Industrial Estates, Hastings

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F81 Objective Assessment comments

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Hastings the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

12. To conserve and enhance +/- The site is mostly previously developed although there are some important soil functions /? areas of greenfield land. Development may help to encourage and types the composting of biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F82 Objective Assessment comments

13. To protect, conserve and 0/+ The site is adjacent to the High Weald AONB. However, enhance East Sussex and /? development is unlikely to have a significantly different impact Brighton & Hove’s on the AONB from the existing site uses, and presents an countryside and historic opportunity to improve the view from the AONB. There are and built environment several undesignated heritage assets within 1 km and there is the potential for archaeological remains to exist on site. Mitigation: Development should be of high-quality design and landscaping and screening should be used to improve the impact on the AONB. Any planning application should be accompanied by an assessment of the site archaeology.

14. To protect, conserve and - There are several patches of ancient woodland and local nature where appropriate enhance conservation sites within 1km. The site contains an area of BAP East Sussex and Brighton & priority habitat and there are several local nature conservation Hove’s biodiversity and sites within 1 km. Adverse impacts are possible from reduced geodiversity air quality due to facility emissions and vehicle emissions and ecological networks would be reduced with the loss of BAP habitats and woodland. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity. Areas of BAP priority habitat and woodland within the site should be avoided.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Other occupants of the industrial estate present opportunities to generated from renewable connect to heat users. sources

Economic

Table F.45 IND/Y Mile Oak Depot (Polegate Depot), Polegate

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F83 Objective Assessment comments

2. To protect the amenity of ? There are residential areas adjoining the site and any residents and neighbouring development of the site may have adverse visual impacts land uses depending on the height of any buildings or the existence of a stack. Mitigation: Development should provide screening from residential areas through appropriate screening and tree planting. Existing vegetation should be retained.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is in flood zone 1 and 80m from flood zones 2 and 3, of flooding although adverse impacts on flood risk are unlikely.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The location near to Eastbourne could make a contribution to reducing waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

12. To conserve and enhance +/- The site is part previously developed land and part greenfield important soil functions /? land. Development may help to encourage the composting of and types biodegradable waste, but this depends on the type of facility that is developed, which is unknown at this stage.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F84 Objective Assessment comments

14. To protect, conserve and - There are BAP priority habitats adjacent to the site and records where appropriate enhance of protected species in the vicinity. Adverse impacts are East Sussex and Brighton & possible from reduced air quality due to facility emissions and Hove’s biodiversity and vehicle emissions, from disturbance and land-take. geodiversity Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity. An ecological assessment should be undertaken to determine the presence of protected species and appropriate mitigation put in place.

Economic

Table F.46 IND/Z Millbrook Business Park, Crowborough

Objective Assessment comments

Social

2. To protect the amenity of ? There are residential areas adjoining the site and any residents and neighbouring development of the site may have adverse visual impacts land uses depending on the height of any buildings or the existence of a stack. Some existing uses of the estate may not be compatible with some types of waste-related development. Mitigation: Development should provide screening from residential areas through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no adverse impact on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F85 Objective Assessment comments

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - The site contains areas in flood zones 2 and 3. of flooding Mitigation: Areas of flood risk 3 should be avoided. Any planning application should be accompanied by a flood risk assessment and take opportunities to reduce flood risk in the area.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 There is an existing waste facility on the estate providing an impacts of transporting opportunity to co-locate waste operations. However, no waste and minerals on the opportunity has been identified for the use of sustainable modes environment of transport.

13. To protect, conserve and ?/? The site is adjacent to the AONB, and adverse visual impacts are enhance East Sussex and possible depending on the height of buildings and the existence Brighton & Hove’s of a stack. There is the potential for historic remains to have countryside and historic survived below ground. and built environment Mitigation: Any planning application should be accompanied by an assessment of visual impact on the AONB and appropriate mitigation put in place if necessary. Any planning application should be accompanied by an assessment of historic assets.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F86 Objective Assessment comments

14. To protect, conserve and - The site is adjacent to several patches of ancient woodland, is where appropriate enhance 500m from a Local Nature Reserve and BAP priority habitats, East Sussex and Brighton & 20m from an SNCI and there are records of protected species in Hove’s biodiversity and the vicinity. Adverse impacts are possible from reduced air geodiversity quality due to facility emissions and vehicle emissions, from disturbance and possibly from predation. The site is 3.3km from Ashdown Forest SAC/SPA and adverse impacts are possible from reduced air quality. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation with particular focus on the impacts on biodiversity. An Appropriate Assessment may be required.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Other industrial units within the estate and neighbouring generated from renewable residential areas may provide opportunities to connect to heat sources users.

Economic

Table F.47 IND/AA More House Farm, Wivelsfield

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F87 Objective Assessment comments

2. To protect the amenity of - There is a dwelling adjacent to the site and residential areas residents and neighbouring 230m from the site. The site is set in a sensitive landscape land uses context although it has businesses uses on site already. However, the visual impact from waste development may be greater than the existing uses. There are capacity constraints accessing the site and there may be adverse impacts on residential environments from HGV traffic on local roads. Mitigation: Development should provide screening from residential buildings through appropriate screening and tree planting. Large scale development is unlikely to be acceptable in this location. Any planning application should be required to demonstrate that there will be no impact from noise and odours on neighbouring land uses. Any planning application should be accompanied by a transport assessment which demonstrates that vehicle movements will be at acceptable levels.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating between Haywards Heath and Burgess Hill the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located between Haywards Heath and Burgess Hill, impacts of transporting which will help to reduce waste transport. However, no waste and minerals on the opportunities have been identified for co-location of waste environment facilities or use of sustainable modes of transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F88 Objective Assessment comments

13. To protect, conserve and 0/? No impacts on landscape and countryside. There is the enhance East Sussex and potential for adverse impacts on the setting of adjacent listed Brighton & Hove’s buildings, and for there to be archaeological remains on the site. countryside and historic Mitigation: Development should provide screening from and built environment residential buildings through appropriate screening and tree planting. Large scale development is unlikely to be acceptable in this location. Any planning application should be accompanied by an assessment of the site archaeology.

14. To protect, conserve and - The site is within 1km of a number of patches of ancient where appropriate enhance woodland. Adverse impacts are possible from reduced air East Sussex and Brighton & quality due to facility emissions and vehicle emissions. Hove’s biodiversity and Mitigation: Any planning application should be accompanied by geodiversity an assessment of impacts on air quality, with particular focus on the impacts on biodiversity.

Economic

17. To provide employment + Development of the site will create job opportunities although opportunities and develop these will not be near to deprived communities and on its own it and maintain a skilled is not likely to significantly improve overall employment workforce prospects for deprived areas.

Table F.48 IND/AB Moulsecoomb Fairways Industrial Estate, Brighton

Objective Assessment comments

Social

2. To protect the amenity of - There are residential areas adjoining the site and there is the residents and neighbouring potential for adverse impacts on amenity from waste-related land uses development. Mitigation: New development should be designed to prevent adverse impacts, including through provision of a buffer and incorporation of trees.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F89 Objective Assessment comments

Environmental

6. To maintain and improve ? Part of the site is within a groundwater source protection zone 1. water quality Mitigation: Any planning application should be accompanied by a risk assessment that demonstrates no risk to groundwater.

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality - There is an AQMA to the south of the site which could be and reduce air pollution affected by vehicles accessing new development, although there are unlikely to be significantly different movements compared to existing uses. Mitigation: Any planning application should be accompanied by a Transport Assessment and an assessment of impacts on air quality. A routing strategy should be provided to minimise the number of vehicles travelling within the AQMA.

11. To reduce adverse +/0 The site is located in the urban area, which will help to reduce impacts of transporting waste transport, and there is an existing waste management waste and minerals on the facility close by which presents opportunities to co-locate waste environment facilities to reduce transport. There is a possible opportunity for use of the main line to transport waste by rail but this is likely to be problematic.

13. To protect, conserve and 0/? Significant impacts are unlikely on landscape. The site is within enhance East Sussex and 300m of several undesignated heritage assets, including one Brighton & Hove’s within 90m. There is also the potential for prehistoric, Roman countryside and historic and medieval remains. There is therefore potential for adverse and built environment impacts on heritage assets from waste-related development. Mitigation: Any planning application should be accompanied by an assessment of the archaeological value of the site. Development should be sensitively designed to minimise adverse impacts on undesignated heritage assets.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F90 Objective Assessment comments

14. To protect, conserve and - The site is within 150 m of an area of BAP Priority Habitat and where appropriate enhance within 1km of several sites of local nature conservation East Sussex and Brighton & importance and areas of ancient woodland. Adverse impacts Hove’s biodiversity and are possible from reduced air quality from transport and geodiversity emissions from a facility, and from predation by vermin. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity. Development which attracts vermin should not be permitted unless appropriate mitigation is put in place.

15. To increase energy ?/0 Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy The site is within 2km of two heat user clusters, but the cost of generated from renewable implementing a heat network are likely to be high. sources

Economic

Table F.49 IND/AC Newhaven Industrial Estate Plots 4 to 9, Beach Road/Beach Close/Railway Road, Newhaven

Objective Assessment comments

Social

2. To protect the amenity of - There are residential properties adjacent to the site and adverse residents and neighbouring impacts are possible from waste development, from visual land uses impact and from vehicles accessing the site, although the site is an existing industrial estate and therefore adverse impacts may not be significantly greater than from current site uses. Mitigation: Development should be well-designed and have appropriate landscaping to minimise visual impact.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F91 Objective Assessment comments

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - The entire site is within flood zones 2 and 3, mostly zone 3. of flooding Mitigation: Any planning application should be accompanied by a flood risk assessment and should demonstrate no adverse impact on flood risk and improvement of flood risk where possible. Development in the functional flood plain should be avoided.

11. To reduce adverse +/- Being situated between Brighton and Eastbourne, the site will impacts of transporting make a contribution to reducing the adverse impacts of waste waste and minerals on the transport. No opportunities have been identified to co-locate environment waste facilities or use sustainable modes of transport. There are capacity constraints on the local road network. Mitigation: Any planning application should be accompanied by a transport assessment which should demonstrate adequate capacity on the local road network.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F92 Objective Assessment comments

13. To protect, conserve and 0/? The site is 200m from the National Park. However, the site is in enhance East Sussex and existing industrial use and therefore any waste development is Brighton & Hove’s unlikely to have a significant additional adverse effect on the countryside and historic Park. There is the potential for historic remains to have and built environment survived below ground. Mitigation: Any planning application should be accompanied by an assessment of visual impacts on the SDNP. Any planning application should be accompanied by an assessment of historic assets.

14. To protect, conserve and - There are several local nature conservation sites within 1km, where appropriate enhance including one adjacent to the site. There is a BAP priority East Sussex and Brighton & habitat adjacent to the site and records of protected species in Hove’s biodiversity and the vicinity. Adverse impacts are possible from reduced air geodiversity quality due to facility emissions and vehicle emissions, from disturbance and predation and from litter. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation with particular focus on the impacts on biodiversity. An ecological assessment should examine the existence of protected species on site and in the vicinity and appropriate mitigation put in place.

15. To increase energy ? Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy There may be an opportunity to connect to heat users if land to generated from renewable the east is developed for residential and retail. sources

Economic

Table F.50 IND/AD Newtown Road Industrial Estate, Brighton

Objective Assessment comments

Social

2. To protect the amenity of 0 There are residential areas adjacent to the site, but use of residents and neighbouring existing units will not add to the impacts. New development is land uses not likely to significantly increase adverse effects and could potentially improve the townscape but effects are not likely to be significant.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F93 Objective Assessment comments

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality - The site is very close to parts of the Brighton, Portslade and and reduce air pollution Rottingdean AQMA. Effects are not likely to be significantly greater than existing uses of the industrial estate and any effects could be mitigated with a routing strategy. Mitigation: Any planning application should be accompanied by a Transport Assessment and an assessment of impacts on air quality.

11. To reduce adverse +/0 The site is located in the urban area, which will help to reduce impacts of transporting waste transport. The site is also adjacent to a railway line and waste and minerals on the there may be potential to reinstate sidings. However, no environment opportunities have been identified for co-location of waste facilities. Mitigation: Any planning application should be accompanied by a preliminary assessment of the viability of reinstating sidings and use of rail transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F94 Objective Assessment comments

13. To protect, conserve and 0 Significant impacts are unlikely on landscape and the historic enhance East Sussex and built environment Brighton & Hove’s countryside and historic and built environment

14. To protect, conserve and 0 Significant impacts on biodiversity and geodiversity are where appropriate enhance unlikely. East Sussex and Brighton & Hove’s biodiversity and geodiversity

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy The site is close to large retail units and there are possible generated from renewable opportunities to connect to major heat users through wider sources redevelopment of Hove Station area and the Sackville Trading Estate.

Economic

17. To provide employment + Development of the site will create job opportunities fairly close opportunities and develop to some deprived areas of Brighton, although on its own it is not and maintain a skilled likely to significantly improve overall employment prospects for workforce deprived areas.

Table F.51 IND/AE Peacock Industrial Estate, Lyon Close, Hove

Objective Assessment comments

Social

2. To protect the amenity of 0 There are residential properties adjacent to the site, but waste residents and neighbouring development is unlikely to have significantly greater adverse land uses effects than existing site uses, and could improve visual amenity. Mitigation: Any development should be of high-quality design and provide tree screening for residential properties.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F95 Objective Assessment comments

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues near to the site and adverse and reduce air pollution impacts are unlikely.

13. To protect, conserve and ? No impacts on landscape and countryside. The site is adjacent enhance East Sussex and to a conservation area but development is unlikely to harm the Brighton & Hove’s conservation area and may improve the visual impact of the site. countryside and historic There are archaeological remains above ground and there are and built environment likely to be remains below ground. Mitigation: An assessment of the visual impact on the conservation area should accompany any planning application and appropriate mitigation provided. It should also be accompanied by an assessment of the site archaeology.

14. To protect, conserve and ? The site is 250m from woodland BAP priority habitat and 750m where appropriate enhance from an SNCI. No impacts on biodiversity or geodiversity East Sussex and Brighton & identified. Impacts are possible if development has an adverse Hove’s biodiversity and impact on air quality, but unlikely. geodiversity Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F96 Objective Assessment comments

Economic

Table F.52 IND/AF Ponswood Industrial Estate, St Leonards-on-Sea

Objective Assessment comments

Social

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F97 Objective Assessment comments

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Hastings the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located in the urban area of Hastings, which will help impacts of transporting to reduce waste transport. There is an existing waste facility on waste and minerals on the the site which presents an opportunity to co-locate waste environment facilities. No opportunities have been identified for the use of sustainable modes of transport.

14. To protect, conserve and - There are several patches of ancient woodland and local nature where appropriate enhance conservation sites within 1km, and areas of ancient woodland East Sussex and Brighton & and local nature conservation sites adjacent to the site. There Hove’s biodiversity and are BAP priority habitats and a local nature conservation site geodiversity adjacent to the site. Adverse impacts are possible from reduced air quality due to facility emissions and vehicle emissions, leachate and litter. Mitigation: Any planning application should be accompanied by an assessment of impacts on air and water quality and littering with particular focus on the impacts on biodiversity. A 15m buffer should be provided to the ancient woodland.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Other occupants of the industrial estate and a nearby generated from renewable supermarket present opportunities to connect to heat users. sources

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F98 Objective Assessment comments

Economic

Table F.53 IND/AG Potts Marsh Industrial Estate, Eastbourne Road, Westham

Objective Assessment comments

Social

2. To protect the amenity of - There are residential properties about 60m from the site and a residents and neighbouring children’s centre adjacent to the site and therefore there may be land uses adverse impacts on amenity and visual impacts, depending on the scale of development and the existence of a stack. Mitigation: Development should provide screening from residential buildings through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no adverse impact from noise and odours on residential areas and neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F99 Objective Assessment comments

8. To reduce risk and impact - The site is entirely within flood zone 3. of flooding Mitigation: Any planning application should be accompanied by a flood risk assessment which should demonstrate no adverse impact on flood risk and an improvement in flood risk where possible. Development should be avoided in the functional flood plain.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Eastbourne the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located near to Eastbourne, which will help to reduce impacts of transporting /? waste transport. No opportunities have been identified for the waste and minerals on the use of sustainable modes of transport. There is the potential for environment more than one waste use to be located together in the future.

13. To protect, conserve and 0/? No impacts on landscape and countryside. There is a high enhance East Sussex and potential for there to be archaeological remains on the site. Brighton & Hove’s Mitigation: Any planning application should be accompanied by countryside and historic an assessment of the site archaeology. and built environment

14. To protect, conserve and - There is a SSSI and two SNCIs within 1km. There are BAP where appropriate enhance priority habitats adjacent to the site and records of protected East Sussex and Brighton & species in the vicinity. Adverse impacts are possible from air Hove’s biodiversity and emissions from facilities and transport, from disturbance and geodiversity from predation. The site is 820m from Pevensey Levels SCI and Ramsar site and adverse impacts on water quality are possible from surface water run-off. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with a particular focus on effects on biodiversity. Development which attracts vermin should not be permitted unless appropriate mitigation is put in place. An ecological assessment should be undertaken to assess the existence of protected species and appropriate mitigation put in place. An Appropriate Assessment may be required.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F100 Objective Assessment comments

Economic

Table F.54 IND/AH Ridgewood Industrial Park, Uckfield

Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

Social

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F101 Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

9. To limit the causes of and +/0 The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating on the edge of Uckfield, the site will not make a significant contribution to reducing emissions from waste transport.

10. To protect air quality 0 There are no air quality issues near the site and impacts are and reduce air pollution unlikely.

11. To reduce adverse 0/+ By locating on the edge of Uckfield, the site is away from centres impacts of transporting of population and will not help significantly to reduce waste waste and minerals on the transport. No opportunities have been identified for the co- environment location of waste facilities or the use of sustainable modes of transport.

13. To protect, conserve and 0/? No impacts on landscape and countryside. There is potential for enhance East Sussex and historic remains to exist below ground. Brighton & Hove’s Mitigation: Any planning application should be accompanied by countryside and historic an assessment of historic assets. and built environment

14. To protect, conserve and - There are two SNCIs close to the site, including one adjacent to where appropriate enhance it. There is an area of BAP priority habitat adjacent to the site East Sussex and Brighton & and records of protected species in the vicinity. A local nature Hove’s biodiversity and conservation site is adjacent to the site. Adverse impacts are geodiversity possible from reduced air quality due to facility emissions and vehicle emissions and from disturbance. The site is 6.4km from Ashdown Forest SAC/SPA and adverse impacts on air quality are possible from facilities and vehicles. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity. An ecological assessment should be undertaken to determine the presence of protected species and appropriate mitigation put in place. An Appropriate Assessment may be required.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F102 Objective Decision-making criteria and interpretation. Will the strategy/option/policy…?

Economic

Table F.55 IND/AI Ringmer Business Centre, Chamberlaines Lane, Ringmer

Objective Assessment comments

Social

2. To protect the amenity of - The nearest residential property is about 250m away so there is residents and neighbouring potential for limited impacts on residential amenity. However, land uses the site is in an area of sensitive landscape character and there is the likelihood of visual impacts. Mitigation: Development should be small-scale and well screened from the surrounding countryside with tree planting. Existing vegetation should be retained.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is located in flood zone 1. of flooding

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F103 Objective Assessment comments

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse 0 No opportunities have been identified for co-location of waste impacts of transporting facilities or the use of sustainable modes of transport. waste and minerals on the environment

13. To protect, conserve and -/? The SDNP is approximately 500m away and there are long enhance East Sussex and views into the site. There may be adverse impacts on the SDNP Brighton & Hove’s depending on the scale of development and existence of a stack. countryside and historic There is the potential for there to be archaeological remains on and built environment the site. Mitigation: Any planning application should be accompanied by an assessment of the visual impact on the SDNP. Large scale development should be prohibited. Any planning application should be accompanied by an assessment of the site archaeology.

14. To protect, conserve and - The site is 2.7km from Lewes Downs SAC and the A26 runs where appropriate enhance within 200m of Ashdown Forest SAC/SPA. Adverse impacts on East Sussex and Brighton & air quality are possible from facilities and vehicles. Hove’s biodiversity and Mitigation: An Appropriate Assessment may be required. geodiversity

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy There is an educational establishment to the west of the site generated from renewable which may present an opportunity to connect to a heat user. sources

Economic

Table F.56 IND/AJ Shoreham Port, South Portslade, Hove

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F104 Objective Assessment comments

2. To protect the amenity of ? There are residential areas adjoining the site, including a school. residents and neighbouring The effect on residential amenity will vary depending on the land uses location of any waste management facilities within the area of search. Adverse effects are possible from waste management activities including waste transport. A well-designed and well- screened facility with an appropriate routing strategy could avoid adverse effects and may improve visual impacts. Part of the site contains retail frontage which will not be appropriate for waste development. Mitigation: Any waste development should be of high quality design and be well-screened by vegetation. A routing strategy should be developed which avoids residential areas and the school. Any planning application should be required to demonstrate no adverse impact on the seafront and beach. 160m from the site but these are screened by trees and other buildings, therefore impacts on amenity are unlikely. The retail frontage should be excluded from the area of search.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - Most of the site is in flood zones 2 and 3, although there are of flooding flood defences in place. Mitigation: A flood risk assessment should be undertaken to demonstrate no increase in flood risk and a reduction where possible.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Brighton, the site will help to reduce emissions from waste transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F105 Objective Assessment comments

10. To protect air quality - A259 Kingsway and main roads heading north are part of an and reduce air pollution AQMA and development could add to poor air quality, either through the facility itself or the associated waste transport or both. However, the effect may be no worse than that from existing site uses that are replaced. Mitigation: Any planning application should be accompanied by an assessment of the impacts on air quality and should demonstrate no additional adverse effect on air quality.

11. To reduce adverse + By locating near to Brighton, the site will contribute to a impacts of transporting reduction in waste transport. There is an existing waste facility waste and minerals on the within the port which presents an opportunity to co-locate environment waste facilities. As an operational port, the site provides opportunities for the use of sustainable modes of transport.

13. To protect, conserve and 0/? There will be no impacts on landscape and countryside. There enhance East Sussex and is a listed seafront shelter within the site, and there is some Brighton & Hove’s potential for Roman or Saxon remains to exist below ground. countryside and historic Mitigation: Any planning application should be accompanied by and built environment an assessment of historic assets.

14. To protect, conserve and - Basin Road South is an SNCI, and there are two others within where appropriate enhance 1km. The site is adjacent to a BAP priority habitat. Adverse East Sussex and Brighton & impacts are possible from reduced air quality due to facility Hove’s biodiversity and emissions and vehicle emissions, direct land take, disturbance, geodiversity predation and reduced water quality. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality, disturbance, predation and water quality, with particular focus on the impacts on biodiversity. Development should be prohibited on the SNCI.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Shoreham harbour is a heat cluster and therefore presents generated from renewable opportunities to connect to major heat users. sources

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F106 Table F.57 IND/AK Southebourne Business Park, Courtlands Road/Waterworks Road/May Ave, Eastbourne

Objective Assessment comments

Social

2. To protect the amenity of - There is a large number of residential properties adjacent to the residents and neighbouring site and therefore there may be adverse impacts on amenity, land uses depending on the scale of facility and the existence of a stack. Visual impacts are not likely to be significantly different than existing uses. Mitigation: Development should provide screening from residential buildings through appropriate screening and tree planting. Any planning application should be required to demonstrate that there will be no adverse impact from noise and odours on residential areas.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve ? Part of the site is within groundwater source protection zones 1, water quality 2 and 3. Mitigation: Any planning application should be accompanied by a risk assessment that demonstrates no risk to groundwater.

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact - The site is contains a large area of flood zones 3 and some flood of flooding zone 2. Mitigation: Any planning application should be accompanied by a flood risk assessment which should demonstrate no adverse impact on flood risk and an improvement in flood risk where possible. Development should be avoided in the functional flood plain.

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Eastbourne the site will help to reduce emissions from waste transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F107 Objective Assessment comments

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located near to Eastbourne, which will help to reduce impacts of transporting /? waste transport. No opportunities have been identified for co- waste and minerals on the location of waste facilities. The site is adjacent to a railway and environment it may be financially viable to construct sidings for a large facility. The local road network is predominantly residential roads and adverse effects are possible from waste transport. Mitigation: A planning application for a large-scale facility should be accompanied by an assessment of the potential for use of rail to transport waste. A transport assessment should be undertaken which demonstrates no unacceptable adverse effects on the local road network.

14. To protect, conserve and - There is an SNCI and BAP priority habitats adjacent to the site. where appropriate enhance There is the possibility of protected species on site. Adverse East Sussex and Brighton & impacts are possible from air emissions from facilities and Hove’s biodiversity and transport, from leachate, from disturbance and from predation. geodiversity Mitigation: Any planning application should be accompanied by an assessment of impacts on air and water quality with a particular focus on effects on biodiversity. Development which attracts vermin should not be permitted unless appropriate mitigation is put in place. An ecological assessment should be undertaken to assess the existence of protected species and appropriate mitigation put in place.

15. To increase energy ? Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Heat users are available nearby although installation of a generated from renewable network may not be financially viable. sources

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F108 Table F.58 IND/AL Sussex House Industrial Area, Brighton

Objective Assessment comments

Social

2. To protect the amenity of + A high quality design and appropriate screening could residents and neighbouring improve the visual amenity for neighbouring residential areas. land uses Mitigation: Any planning application should contain proposals to mitigate visual impacts.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F109 Objective Assessment comments

10. To protect air quality - The site is close to an AQMA, but effective routing of vehicles and reduce air pollution could avoid adverse impacts. Mitigation: Planning application should be accompanied by a Transport Assessment and routing strategy.

13. To protect, conserve and 0 No impacts identified. enhance East Sussex and Brighton & Hove’s countryside and historic and built environment

14. To protect, conserve and 0 Significant impacts on biodiversity or geodiversity are unlikely. where appropriate enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity

Economic

Table F.59 IND/AM The Birch and Maple Road Industrial Estates, Lottbridge Drove, Eastbourne

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F110 Objective Assessment comments

2. To protect the amenity of - There are residential properties and a school adjacent to the site residents and neighbouring and therefore there may be adverse impacts on residential land uses amenity and visual impacts, depending on the scale of facility and the existence of a stack. There are also capacity problems on the local road network which could be added to by a waste facility, particularly a large-scale one. Mitigation: Development should provide screening from residential buildings through appropriate screening and tree planting. Large scale development is unlikely to be acceptable in this location. Any planning application should be required to demonstrate that there will be no adverse impact from noise and odours on neighbouring land uses. Any planning application should be accompanied by a transport assessment which demonstrates that vehicle movements will be at acceptable levels.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating near to Eastbourne the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F111 Objective Assessment comments

14. To protect, conserve and - There are several local nature conservation sites within 1km, where appropriate enhance including 1 within the site boundary. The site is adjacent to BAP East Sussex and Brighton & priority habitat and there are records of a protected species in Hove’s biodiversity and the vicinity. Adverse impacts are possible from reduced air geodiversity quality due to facility emissions and vehicle emissions, from disturbance, direct land-take and predation. Mitigation: Development should avoid the SNCI. Any planning application should be accompanied by an assessment of impacts on air quality, disturbance and predation, with particular focus on the impacts on biodiversity. An ecological assessment should be undertaken to determine the presence of protected species and appropriate mitigation put in place.

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy Nearby industrial estates and residential areas may present an generated from renewable opportunity to connect to heat users. sources

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F112 Table F.60 IND/AN The Broyle, Ringmer

Objective Assessment comments

Social

2. To protect the amenity of - There are several residential properties adjacent to the site and residents and neighbouring adverse effects on residential amenity are possible, depending land uses on the scale of any facility and the existence of a stack. Mitigation: Any development should be well screened from residential areas. Existing vegetation should be retained. Any planning application should be accompanied by an assessment of impacts on residential amenity and appropriate mitigation put in place. Large scale development is unlikely to be acceptable in this location.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

10. To protect air quality 0 There are no air quality issues in the vicinity and adverse and reduce air pollution impacts are unlikely.

11. To reduce adverse +/0 Part of the site is an existing waste site and therefore the site impacts of transporting presents an opportunity to co-locate waste facilities. No waste and minerals on the opportunities have been identified to use sustainable modes of environment transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F113 Objective Assessment comments

13. To protect, conserve and ?/? A large scale facility could adversely affect the countryside enhance East Sussex and setting of the village. There are two listed buildings close to the Brighton & Hove’s site to the south and west, although waste development is not countryside and historic likely in these parts of the site due to existing business uses. and built environment There is the potential for historic remains to have survived below ground. Mitigation: Any planning application should be accompanied by an assessment of historic assets. Development should be of an appropriate scale to minimise adverse effects on the village setting.

14. To protect, conserve and - The site is 3km from Lewes Downs SAC and adverse impacts on where appropriate enhance air quality are possible from facilities and vehicles. East Sussex and Brighton & Mitigation: An Appropriate Assessment may be required. Hove’s biodiversity and geodiversity

15. To increase energy ?/+ Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy The enterprise park to the east of the site could present an generated from renewable opportunity to connect to heat users. sources

Economic

17. To provide employment + Development of the site will create job opportunities, although opportunities and develop not particularly near to deprived communities and on its own it and maintain a skilled is not likely to significantly improve overall employment workforce prospects.

Table F.61 IND/AO The Old Cement Works, South Heighton

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F114 Objective Assessment comments

2. To protect the amenity of - There are residential properties and a caravan park adjacent to residents and neighbouring the site, but the site is well-screened from residential properties. land uses Waste development may have adverse impacts on residential amenity, but the visual impact is unlikely to be significantly greater than existing uses, depending on the height of any buildings or the existence of a stack. Mitigation: Existing trees should be retained and screening enhanced through additional planting. Development should be of a high quality design and any planning application should be accompanied by an assessment of impacts on residential amenity and demonstrate no adverse effects on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact ? Most of the site is within flood zone 3, although there are also of flooding some small areas of flood zones 1 and 2. Mitigation: A planning application should be accompanied by a flood risk assessment which demonstrates no adverse effect on flood risk and improves flood risk where possible. Development should avoid the functional flood plain.

9. To limit the causes of and +/0 The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating between Brighton and Eastbourne, the site will make a contribution to reducing emissions from waste transport.

10. To protect air quality 0 There are no air quality issues near the site and impacts are and reduce air pollution unlikely.

11. To reduce adverse +/0 By locating between Brighton and Eastbourne, the site is near to impacts of transporting centres of population and will help to reduce waste transport. waste and minerals on the There is an existing recycling facility on site which presents an environment opportunity to co-locate waste facilities. No opportunities have been identified for the use of sustainable modes of transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F115 Objective Assessment comments

13. To protect, conserve and ?/0 The site is 30m from the SDNP and there are views into the site enhance East Sussex and from the SDNP. However, visual impacts may not be Brighton & Hove’s significantly different from existing industrial uses on the site, countryside and historic depending on the scale of any development and the existence of and built environment a stack. No effects on the historic environment. Mitigation: Any planning application should be accompanied by an assessment of visual impacts on the SDNP and mitigation put in place. Existing trees should be maintained and screening enhanced to minimise views of development from the National Park.

14. To protect, conserve and - There are three SNCIs within 1km. There are areas of BAP where appropriate enhance priority habitat adjacent to the site and records of protected East Sussex and Brighton & species in the vicinity. Adverse impacts are possible from Hove’s biodiversity and reduced air quality due to facility emissions and vehicle geodiversity emissions. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity. An ecological assessment should be undertaken to determine the presence of protected species and appropriate mitigation put in place.

Economic

Table F.62 IND/AP Tidy’s Industrial Estate/Mid Sussex Business Park, Ditchling Common

Objective Assessment comments

Social

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F116 Objective Assessment comments

2. To protect the amenity of - There are residential properties adjacent to the site and there is residents and neighbouring the potential for adverse impacts on residential amenity from land uses waste development. Development would present an opportunity to improve the visual impact of existing site uses and so could have positive visual benefits for residential properties and public footpaths, depending on the scale of development and the existence of a stack. Mitigation: Existing trees should be retained and screening enhanced through additional planting. Development should be of a high quality design and any planning application should be accompanied by an assessment of impacts on residential amenity and demonstrate no adverse effects on neighbouring land uses.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. The site could potentially serve Burgess Hill and Haywards Heath and in doing so could help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues near the site and impacts are and reduce air pollution unlikely.

11. To reduce adverse +/0 By locating near to Burgess Hill and Haywards Heath, the site is impacts of transporting near to centres of population and will help to reduce waste waste and minerals on the transport. No opportunities have been identified for the co- environment location of waste facilities or for the use of sustainable modes of transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F117 Objective Assessment comments

13. To protect, conserve and -/? The site is 160m from the SDNP and there is the potential for enhance East Sussex and adverse impacts from development and associated traffic. Brighton & Hove’s However, visual impacts may not be significantly different from countryside and historic existing industrial uses on the site, depending on the scale of and built environment any development and the existence of a stack. There is a listed building adjacent to the site although any development is unlikely to have significantly worse effects on its setting than existing site uses. Mitigation: Any planning application should be accompanied by an assessment of visual impacts on the SDNP and the listed building from development and traffic and appropriate mitigation put in place. Existing trees should be maintained and screening enhanced to minimise views of development from the National Park.

14. To protect, conserve and - There are several patches of ancient woodland and nature where appropriate enhance conservation sites within 1km, including 1 SNCI adjacent to the East Sussex and Brighton & site. There is a SSSI 10m from the site. There are areas of BAP Hove’s biodiversity and priority habitat adjacent to the site and records of protected geodiversity species in the vicinity. Adverse impacts are possible from reduced air quality due to facility emissions and vehicle emissions, and from disturbance, predation and litter. Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity, and from disturbance. An ecological assessment should be undertaken to determine the presence of protected species and appropriate mitigation put in place. Development which attracts vermin should not be permitted unless appropriate mitigation is put in place.

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F118 Table F.63 IND/AQ Victoria Road Industrial Area, Brighton

Objective Assessment comments

Social

2. To protect the amenity of 0/- There are residential areas adjacent to the site, but use of residents and neighbouring existing units will not add to the impacts. New development is land uses not likely to significantly increase adverse effects and could potentially improve the townscape but effects are not likely to be significant. Development of the vacant plot could potentially increase the visual impact on residential areas. Mitigation: Any planning application to develop the vacant plot should be sensitively designed to minimise the impact on residential amenity.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Effects on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality - Vehicles accessing the site would need to pass through an and reduce air pollution AQMA and could add to poor air quality. Mitigation: Any planning application should be accompanied by a Transport Assessment and an assessment of impacts on air quality.

11. To reduce adverse +/0 The site is located in the urban area, which will help to reduce impacts of transporting waste transport. However, no opportunities have been waste and minerals on the identified for the co-location of waste facilities or use of environment sustainable modes of transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F119 Objective Assessment comments

13. To protect, conserve and 0/? Significant impacts are unlikely on landscape. There is potential enhance East Sussex and for adverse impacts on archaeology from new development, Brighton & Hove’s although the previous development of the site is likely to have countryside and historic affected the value of any assets. and built environment Mitigation: Any planning application should be accompanied by an assessment of the archaeological value of the site.

14. To protect, conserve and - The site is within 150 m of an area of BAP Priority Habitat and where appropriate enhance within 1km of several Sites of Nature Conservation Importance. East Sussex and Brighton & Adverse impacts are possible from reduced air quality from Hove’s biodiversity and transport and emissions from a facility. geodiversity Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity.

Economic

Table F.64 IND/AR Woodingdean Industrial Estate, Brighton

Objective Assessment comments

Social

2. To protect the amenity of - There are residential areas adjoining the site and there are high residents and neighbouring quality offices on the site. There is therefore the potential for land uses adverse impacts on amenity from waste-related development. Mitigation: New development should be designed to prevent adverse impacts, including through provision of a buffer and incorporation of trees to screen residential areas, offices and the National Park..

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F120 Objective Assessment comments

3. To improve equality and 0 No impacts identified. access to sustainable waste management

Environmental

6. To maintain and improve 0 Part of the site is within a groundwater source protection zone 3. water quality However, adverse impacts on groundwater are unlikely.

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 Site is located in flood zone 1. of flooding

9. To limit the causes of and + The site provides an opportunity to develop a facility to reduce adapt to climate change the amount of waste landfilled and recover resources, thereby reducing emissions of greenhouse gases from waste. By locating close to Brighton the site will help to reduce emissions from waste transport.

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse +/0 The site is located in the urban area, which will help to reduce impacts of transporting waste transport. However, no opportunities have been waste and minerals on the identified to co-locate waste management facilities or use environment sustainable modes of transport.

13. To protect, conserve and 0/- The site is bordered by the SDNP. Impacts are unlikely to be enhance East Sussex and /0 significantly different from existing site uses for most types of Brighton & Hove’s waste facility. However, certain types of waste development are countryside and historic likely to have an additional impact, particularly if buildings are and built environment high or there is a stack. No impacts on heritage assets have been identified. Mitigation: Development should be designed to minimise adverse impacts on the SDNP. Any development which incorporates a stack would need careful design or mitigation of adverse impacts. A routing strategy should be developed which minimises vehicle movements through the National Park.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F121 Objective Assessment comments

14. To protect, conserve and - The site is within 1 km of a SSSI, several local nature where appropriate enhance conservation sites and BAP priority habitats. Adverse impacts East Sussex and Brighton & are possible from reduced air quality from transport and Hove’s biodiversity and emissions from a facility. geodiversity Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity.

15. To increase energy ?/0 Development of the site could create an opportunity to recover efficiency and the energy from waste, depending on the type of facility developed. proportion of energy The site is within 2km of a heat user cluster, which presents generated from renewable opportunities to produce CHP. However, this is likely to be sources inappropriate due to the potential for adverse landscape impacts on the National Park.

Economic

Table F.65 IND/AS Woodland Centre, Whitesmith/Chiddingley

Objective Assessment comments

Social

2. To protect the amenity of ? There are three residential properties within 120m of the site. residents and neighbouring Any development of the site may have adverse visual impacts land uses depending on the height of any buildings or the existence of a stack. Mitigation: Development should provide screening from residential areas through appropriate screening and tree planting. Existing vegetation should be retained.

3. To improve equality and 0 No impacts identified. access to sustainable waste management

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F122 Objective Assessment comments

Environmental

6. To maintain and improve 0 Adverse impacts on water quality are unlikely. water quality

7. To seek the protection of Not relevant to selection of sites. and sustainable use of water resources

8. To reduce risk and impact 0 The site is within flood zone 1. of flooding

10. To protect air quality 0 There are no air quality issues in the vicinity of the site and and reduce air pollution adverse impacts are unlikely.

11. To reduce adverse 0/? No opportunities have been identified for the co-location of impacts of transporting waste facilities or the use of sustainable modes of transport. waste and minerals on the Adverse impacts may be caused on the local road network by environment the site access. Mitigation: Any planning application should be accompanied by a transport assessment which should demonstrate adequate site ingress and exit.

12. To conserve and enhance +/? The site is mostly previously developed land. Development important soil functions may help to encourage the composting of biodegradable waste, and types but this depends on the type of facility that is developed, which is unknown at this stage.

13. To protect, conserve and 0/? No adverse impacts on landscape and countryside. There is the enhance East Sussex and potential for historic remains to have survived below ground. Brighton & Hove’s countryside and historic Mitigation: Any planning application should be accompanied by and built environment an assessment of historic assets.

14. To protect, conserve and - The site is adjacent to patches of ancient woodland and areas of where appropriate enhance BAP priority habitat. Adverse impacts are possible from East Sussex and Brighton & reduced air quality due to facility emissions and vehicle Hove’s biodiversity and emissions. geodiversity Mitigation: Any planning application should be accompanied by an assessment of impacts on air quality with particular focus on the impacts on biodiversity.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F123 Objective Assessment comments

Economic

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL F124 Annex G

Effects Arising from Other Plans and Strategies

1 INTRODUCTION

This annex sets out the findings of a review of other plans and strategies relevance to the Waste and Minerals Sites Plan (WMSP). It summarises the contents of each of those plans and strategies that have either been adopted or are reasonably likely to be adopted, and which could potentially give rise to effects in combination with the WMSP. The purpose of the review was to inform an assessment of the likely cumulative impacts of arising from the WMSP and other plans acting in combination.

1.1 EASTBOURNE CORE STRATEGY LOCAL PLAN, FEBRUARY 2013

The spatial development strategy will deliver at least 5,022 dwellings and 55,430m2 of employment land by 2027 within the built up area boundary.

The priority locations for balanced housing growth alongside delivering significant improvements to the provision of community facilities and services and improving linkages will be in the two sustainable centres:

• The Town Centre (approximately 1,242 new dwellings); and • Sovereign Harbour (up to a maximum of 150 new dwellings).

The delivery of new employment land and community facilities alongside new residential development in the two centres will be required to cater for increased growth and improve their sustainability as neighbourhoods.

Table 1.1 Housing Delivery in Each Neighbourhood up to 2027

Neighbourhood Identified Net Units Town Centre 1,190 Upperton 399 Seaside 448 Old Town 101 Ocklynge & Rodmill 258 Roselands & Bridgemere 116 Hampden Park 84 Langney 178 Shinewater & North Langney 69 Summerdown & Saffrons 40 Meads 358 Ratton & Willingdon Village 12 St Anthony's & Langney Point 25 Sovereign Harbour 150 Eastbourne total 3,428

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G1 The vision for Seaside will, in part, be promoted by:

• Delivering greater economic activity through the regeneration of commercial areas; • Providing new housing through redevelopments, change of use and conversion of floorspace above shops; • Developing tourism and leisure offers at Fishermans Green and the Redoubt; • Improving linkages across Seaside through the reduction of traffic and congestion, resulting in reduced road accidents and pollution; • Encouraging sustainable travel through the provision of safe walking and cycling routes; • Enhancing the quality of public transport provision through a Quality Bus Corridor on the approach to the Seaside roundabout; and • Encouraging opportunities for renewable energy generation including potential for district heating networks.

The vision for Roselands & Bridgemere will, in part, be promoted by:

• Encouraging opportunities for refurbishment or redevelopment for employment use in the neighbourhood’s industrial estates; • Providing new safe walking and cycling routes to link the neighbourhood with other parts of town; • Delivering additional housing through making more efficient use of land; and • Encouraging opportunities for renewable energy generation.

The vision for Hampden Park neighbourhood will, in part, be promoted by:

• Delivering housing through infill development on underused land; • Encouraging intensification of industrial estates; and • Protecting and enhancing retail provision in shopping centres; Supporting sustainable modes of transport through the provision of safe walking and cycling routes linking residential areas with neighbourhood centres, and by supporting the creation of interchange facilities at Hampden Park railway station.

The vision for St Anthony’s & Langney Point neighbourhood will be promoted by:

• Encouraging the redevelopment and intensification of Industrial Estates; • Upgrading public realm in the Industrial Estates to make it more attractive for potential and existing businesses; • Providing affordable housing where opportunities arise; • Developing land adjacent to the Sovereign Centre for a leisure facility; and • Promoting the provision of safe walking and cycle routes and links to the existing National Cycle Network route.

The vision for Sovereign Harbour neighbourhood will be promoted by:

• Providing extensive employment opportunities through the development of a Business Park (B1a Office); • Allowing up to a maximum of 150 new homes, (including affordable homes) the substantial majority of which should be houses rather than flats, but only if the community facilities are guaranteed to be delivered; • Increasing the importance of the Waterfront as a leisure and tourist centre;

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G2 • Encouraging opportunities to improve the provision of public transport through improvements to bus routes; • Enhancing the importance of the Marina for tourism through appropriate measures including the provision of additional berths and associated boat storage facilities; • Enhancing the provision of cycle and walking routes to improve connections within the neighbourhood and to other parts of the town; and • Encouraging opportunities for renewable energy generation particularly combined heat and power (CHP) on development sites.

New development should be designed to maximise the opportunities to accommodate a district heating solution.

Job growth and economic prosperity in Eastbourne will be supported. This will enable the achievement of a sustainable economy and a town where people want to live and work. This will be achieved by:

• Encouraging development which supports improvements in the local jobs market through creation of additional jobs and employment diversification; • Supporting development which provides for, or achieves, units for new start-up businesses; • Identify sites and land for employment use to meet the need for 55,430m2 floorspace in the period to 2027; • Maximising the use of existing employment sites, through redevelopment for employment use and increased density on existing industrial estates, and the upgrading of the existing stock; • Allocating land within the town centre through the Town Centre Local Plan for new B1(a) office use; • Supporting the development of B1(a) office use at Sovereign Harbour; • Supporting the Education and Training sector of the Eastbourne economy through a flexible approach to expansion proposals; and • Protecting good quality employment space, and resisting change of use.

Contribution to Cumulative Effects

Effects may arise in combination with sites IND/A, IND/AM, IND/Q, IND/P, IND/S, IND/E AND IND/AK, particularly with the envisaged growth in housing and economic activity in Seaside, Roselands & Bridgemere, Hampden Park, St Anthonys & Langney Point and Sovereign Harbour. Housing growth and an increase in tourism is likely to increase the demand for road space which could lead to increased congestion and a deterioration in air quality with potential negative effects on human health and biodiversity. However, measures are included within neighbourhood policies to reduce traffic and congestion and promote sustainable modes of transport which will help to reduce the likelihood of congestion and may help to improve air quality and reduce the risk of adverse impacts on health and ecosystems. Opportunities for combined heat and power and district heating systems will be promoted, helping to increase energy efficiency and reduce greenhouse gas emissions. The redevelopment and use of industrial estates for economic activity will benefit the local population through increased access to employment and may help to reduce deprivation in Eastbourne.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G3 1.2 EASTBOURNE PROPOSED DRAFT EMPLOYMENT LAND LOCAL PLAN, DECEMBER 2013

The draft Employment Land Local Plan needs to provide an appropriate and realistic requirement for additional employment land over the Core Strategy Plan Period up to 2027, differentiated by B-class. The Plan identifies a need to allocate approximately 43,000 m2 of additional class-B use space over the plan period to 2027.

The draft Plan identifies a need to create sufficient jobs for the changing population, based on robust and realistic growth assumptions and allowing for expected shifts in age profiles, economic activity rates and the impact of changes to the ‘statutory’ retirement age. Although Eastbourne is represented across a range of employment sectors and activities, the town’s economy is still heavily reliant on tourism, and employment diversification will increase choice for local jobseekers and reduce reliance on the service industry sector. Expanding skills and education provision could help attract younger, skilled workers to the area. Also, by encouraging existing key businesses and their supply chains, there is an opportunity to grow existing specialisms and ‘clusters’.

There are a number of significant economic development projects that are being undertaken in Eastbourne. Recently, the South East Local Enterprise Partnership (SELEP) via the Growing Places Fund allocated £6m towards the development of a state of the art business park (Innovation Mall) at Sovereign Harbour with the potential to provide up to 300 new jobs. Other important planned projects include:

• £70m extension and transformation of the Arndale Centre; • £35m Devonshire Park Project to create a cultural destination, including new conferencing facilities, major renovation of 3 listed leisure buildings and extensive upgrade of international tennis facilities; and • £1.5m purchase of 3.5ha of strategic land for the Council to take direct action in delivering new employment space

The Employment Land Local Plan Objectives are:

• ELLP1 - Stimulate Economic Growth - To stimulate sustainable economic growth to meet the needs of the community within environmental constraints and encourage economic competitiveness through attracting increased investment and new and innovative businesses • ELLP2 - Encourage Small and Start-up Businesses - To diversify the local economy and deliver a variety of new employment opportunities by providing a range of flexible employment spaces that can be used by existing businesses and new start-up businesses • ELLP3 - Diversify the Local Economy - To diversify the local economy and support job growth, and broadening the economic base to enable innovation and entrepreneurship to flourish • ELLP4 - Support Existing Businesses - To support existing businesses to relocate to premises in the town that better meet their needs. • ELLP5 - Promote Sustainable Employment Locations - To promote the delivery of employment space in sustainable locations to accommodate an appropriate amount of additional employment floorspace by 2027.

The preferred option for meeting the employment land requirements in Eastbourne is intensification of industrial estates, development of the town centre and development of Sovereign Harbour.

The ‘Sustainable Centres' are neighbourhoods in which housing growth will be

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G4 balanced by significant improvements in the provision of employment opportunities and community services and facilities. The designated Sustainable Centres are the Town Centre and Sovereign Harbour.

There are seven industrial estates in Eastbourne, located within three broad areas (Hampden Park, Lottbridge Drove and Courtlands Road) and covering approximately 72 hectares. The industrial estates contain a number of uses that would be incompatible with residential use, and their location on the periphery of the built up area makes them an ideal location for such uses. There is an opportunity to deliver new floorspace through redevelopment at higher density, intensifying and diversifying the offer of employment space provision within the existing industrial estates.

Contribution to Cumulative Effects

Effects may arise in combination with sites IND/A, IND/AM, IND/Q, IND/P, IND/S, IND/E AND IND/AK, particularly with the intensification of uses on industrial estates and the envisaged growth in housing and economic activity at Sovereign Harbour. Economic growth, residential development and additional retail and leisure facilities are likely to increase the demand for road space which could lead to increased congestion and a deterioration in air quality with potential negative effects on human health and biodiversity. However, measures are included within the neighbourhood policies within the Core Strategy to reduce traffic and congestion and promote sustainable modes of transport which will help to reduce the likelihood of congestion and may help to improve air quality and reduce the risk of adverse impacts on health and ecosystems. The redevelopment and use of industrial estates for economic activity will benefit the local population through increased access to employment and may help to reduce deprivation in Eastbourne.

1.3 BRIGHTON AND HOVE SUBMISSION CITY PLAN PART ONE, FEBRUARY 2013

Spatially the majority of new housing, employment and retail development will be directed to eight specific development areas:

• DA1 - Brighton Centre and Churchill Square Area; • DA2 - Brighton Marina, Gas Works and Black Rock Area; • DA3 - Lewes Road Area; • DA4 - New England Quarter and London Road Area; • DA5 - Eastern Road and Edward Street Area; • DA6 - Hove Station Area; • DA7 – Toad’s Hole Valley; and • DA8 - Shoreham Harbour.

Table 1.2 Distribution of new development 2010-2030

New Homes New Employment New Retail floorspace Floorspace (m2) (m2) DA1 Brighton Centre 20 20,000 and Churchill Square DA2 Brighton Marina 1940 2,000 5,000 DA3 Lewes Road 810 15,600 DA4 New England 1185 20,000

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G5 New Homes New Employment New Retail floorspace Floorspace (m2) (m2) Quarter and London Road DA5 Eastern Road 470 18,200 - 22,200 and Edward Street DA6 Hove Station 630 1,000 DA7 Toad's Hole 700 25,000 Valley DA8 Shoreham 400 7,500 Harbour Rest of the City 3945 11,257 Small site 1250 development Total 11,350 100,500 to 105,500 25,000

DA1 Brighton Centre and Churchill Square Area

The strategy for the development area is to secure a new state of the art conference centre in a landmark new building to benefit the city and the region and to sustain the tourism and service economy for the next 30 years, positioning Brighton & Hove as one of Europe’s leading conference and meeting destinations. The redevelopment of the Brighton Centre will form part of a comprehensive scheme including the extension of the Churchill Square Shopping Centre and new leisure facilities.

Appropriate transport infrastructure improvements will be required that provide and promote public and sustainable transport to support the redevelopment including the need for integrated links to rapid/express bus- based services on the A259.

Improvements to local air quality at the West Street/A259 junction are required, through the implementation of the council’s Air Quality Action Plan, to ensure developments do not increase the number of people exposed to poor air quality.

DA2 Brighton Marina, Gas Works and Black Rock Area

Provision will be made for the following amounts of additional development to be provided by 2030:

• 1,940 residential units (including the 853 residential units already granted planning permission for the outer harbour); • 5,000m2 retail (A1-A5) floorspace; • 2,000m2 employment (B1a, B1c) floorspace; • 10,500m2 of leisure and recreation floor space • A community building within the Marina; • A health facility within or in the vicinity of the Marina to be agreed with the relevant NHS organisation; and • A primary school or increase in the number of school places within or in the vicinity of the Marina.

Proposals will be supported which:

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G6 • Enhance the transport infrastructure at the Marina, promote more sustainable forms of transport and maximise opportunities to reduce car ownership; and • Contribute towards the production of or provide opportunities for the sustainable production of heat and power for the district.

DA3 Lewes Road

The strategy for the development area is to further develop and enhance the role of Lewes Road as the city’s academic corridor by supporting proposals which:

• improve further and higher education provision in the Lewes Road area; • facilitate improved sustainable transport infrastructure that provides choice, including travel by bus, walking and cycling; • secure improvements to the townscape and public realm; • deliver inter-connected green infrastructure and biodiversity improvements; and • improve air quality in the Lewes Road area.

Provision will be made for the following amounts of additional development to be provided by 2030.

• 810 residential units; • 15,600m2 employment floorspace including an Innovation Centre; • Business School and additional academic floorspace (16,000m2); • Student Accommodation (1300 rooms); and • Community building at Bevendean.

DA4 New England Quarter and London Road Area

The strategy for this development area is to revitalise the London Road shopping area, create a major new business quarter for Brighton & Hove consisting of high quality business accommodation connecting London Road with the New England Quarter, and to maintain and enhance a green gateway to the city to the west of Preston Road.

The Plan seeks to ensure improvements to local air quality through the implementation of the council’s Air Quality Action Plan, through improvements to bus, pedestrian and cycle routes to achieve a modal shift and help reduce the impact of traffic and ensure developments do not increase the number of people exposed to poor air quality or traffic noise.

Provision will be made by 2030 for the following minimum amounts of development:

• 1185 residential units; • 20,000m2 B1a B1b floorspace; and • 300 bed space student housing.

Development within the short list of priority areas will be expected to incorporate infrastructure to support low and zero carbon decentralised energy and in particular heat networks subject to viability.

DA6 Hove Station Area

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G7 The strategy for the development area is to secure the long term regeneration opportunities around the Hove Station area and enable its development as an attractive and sustainable mixed-use area focused on employment. The aim is to secure the creation of a high quality employment environment that will attract investment and new employment opportunities for the city and promote the efficient use of land through, predominantly employment and residential, mixed use developments.

The Plan seeks to enhance the sustainable transport interchange at Hove Station by improving the walking and cycling network in the wider area, improving permeability within the area, encouraging accessibility improvements over the railway at the station, strengthening north-south connections across the railway and beyond the area and east-west connections along Old Shoreham Road.

Development within this area will be encouraged to consider low and zero carbon decentralised energy and in particular heat networks and to either connect where a suitable system is in place (or would be at the time of construction) or design systems so that they are compatible with future connection to a network.

Provision will be made by 2030 for the following minimum amounts of development within this Development Area:

• 630 residential units; • Within Conway Street Industrial Area - retention/replacement of 12,000m2 employment floorspace; and • Outside the Conway Street Industrial Area - retention/replacement of existing with an additional 1,000m2 employment floorspace

DA8 – Shoreham Harbour

Shoreham Harbour is identified as a broad location for future development. A development capacity assessment has indicated the potential to accommodate the following levels of development which will be further tested and explored through the JAAP process:

• 400 new residential units within Brighton & Hove (which are included as part of the City's long term overall housing target); and • 7500m2 net additional employment floorspace

Development within the long-list of priority areas will be encouraged to consider low and zero carbon decentralised energy and in particular heat networks.

SA1 - The Seafront

Priorities for the whole seafront include:

• Secure improvements to sustainable transport infrastructure along the A259, including a rapid/ express bus-based services and improve air and noise quality, pedestrian and cycle routes and crossing opportunities in order to achieve a modal shift and thereby reduce the impact of traffic; and • Development will be encouraged to consider low and zero carbon decentralised energy and in particular heat networks

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G8 The council will work with partners, stakeholders and communities to provide an integrated, safe and sustainable transport system that will accommodate new development, support the city’s role as a sub- regional service and employment hub and improve accessibility. It will promote and provide measures that will help to manage and improve mobility and lead to a transfer of people and freight onto sustainable forms of transport to reduce the impact of traffic and congestion, increase physical activity and therefore improve people’s health, safety and quality of life.

Contribution to Cumulative Effects

Effects may arise in combination with sites: WMSP-A/C (DA2); IND/I, IND/U, WMSP-A/E, IND/AB (DA3); IND/AE (DA4); IND/AL, IND/N, IND/V, WMSP- A/B (DA6); IND/AJ (DA8); and WMSP-A/C and IND/AJ (SA1).

Housing growth and increases in economic activity are likely to increase the demand for road space which could lead to increased congestion and a deterioration in air quality with potential negative effects on human health and biodiversity. However, measures are included within development area policies to reduce traffic and congestion and promote sustainable modes of transport which will help to reduce the likelihood of congestion and may help to improve air quality and reduce the risk of adverse impacts on health and ecosystems. Opportunities for combined heat and power and district heating systems will be promoted, helping to increase energy efficiency and reduce greenhouse gas emissions. The promotion of economic activity will benefit the local population through increased access to employment and may help to reduce deprivation in Eastbourne.

1.4 WEALDEN CORE STRATEGY LOCAL PLAN, FEBRUARY 2013

Land will be identified in subsequent Development Plan Documents for the provision of some 4525 net additional dwellings in Wealden District to provide for 9440 dwellings over the period 2006-2027.

Provision will be made for some net additional 40,000m2 net employment floorspace (B1/B2/B8) to provide for 128,695m2 net employment floorspace and 17,000m2 net additional retail floorspace over the period 2006-2027.

The strategy seeks to concentrate growth at the urban areas, but especially at Hailsham and Uckfield.

Table 1.3 Distribution of housing, employment land and retail

Settlement Total dwellings (2006- New New retail 2027) employment allocations (m2) allocations (m2) Uckfield 1742 12650 10707 Hailsham and Hellingly 2945 8650 6230 Polegate and Willingdon 1265 16890 0 Stone Cross and Westham 692 Crowborough 932 0 0 Heathfield and Waldron 292 0 0 Adjacent to Tunbridge 173 Wells boundary (within Frant Parish)

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G9 Settlement Total dwellings (2006- New New retail 2027) employment allocations (m2) allocations (m2) Rural villages 1373 0 0 Total 9414 38190 16937

The following strategic development areas are the locations that are considered to be critical to the delivery of the overall strategy and provide for the new housing employment and community facilities as follows:

• SD1: Land at West Uckfield - provision of around 1,000 dwellings, 12,650m2 net employment floorspace and education provision; • SD2: Land at East Hailsham- provision of around 600 dwellings; • SD3: Land at North Hailsham - provision of around 700 dwellings, 8,650m2 net employment floorspace, 300m2 retail floor space and education provision; • SD4: Land at South Polegate and East Willingdon- provision of around 700 dwellings, 8,600m2 net employment floorspace, leisure, recreation and community facilities; • SD5: Land at Dittons Road, Polegate - provision of around 8,290m2 net employment floorspace; • SD6: Land at East and South East of Stone Cross - provision of around 220 dwellings with flexibility between SD6 and SD7; • SD7: Land at North Stone Cross - provision of around 430 dwellings with flexibility between SD6 and SD7; • SD8: Land at Pine Grove, Crowborough and SD9: Land at Jarvis Brook, Crowborough - provision of around 140 dwellings; • SD10:Land at South East Crowborough - provision of around 160 dwellings; and • SD11: Land adjacent to Tunbridge Wells, in the Parish of Frant - provision of around 120 dwellings.

Development in the Hailsham, Hellingly, Stone Cross, Polegate and Willingdon area will be subject to the delivery of transport mitigation measures required to resolve capacity and safety constraints at the appropriate time. The strategy for development at Uckfield will provide through Site Allocation DPDs a detailed scheme to reduce traffic congestion.

The strategy for development at Crowborough includes:

• improving linkages between the primary shopping core and other areas of the town, including public transport; • supporting measures which help reduce the impact of vehicular traffic on the town centre and improve the pedestrian and cyclist environments; and • encouraging tourist opportunities for visitors, by supporting additional visitor accommodation, interpretation facilities and other attractions and helping establish the farmers’ market as a central feature of the town’s offer.

The strategy for development at Heathfield supports improved public transport connections with neighbouring settlements. 1.5 WEALDEN SUBMISSION STRATEGIC SITES LOCAL PLAN, MARCH 2014

Development proposals will only be permitted if:

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G10 • development does not have an unacceptable impact upon air quality in conformity with the objectives set out in the latest Air Quality Strategy for England; • Sustainable modes of transport are promoted including through the provision of a green travel plan; • The siting, layout, orientation and design should achieve the highest practicable degree of energy efficiency, taking into account the characteristics of the site and the need to mitigate the effects of climate change; • All development must show a net gain in biodiversity, taking into account the need to retain, as far as possible, the existing ecological features on the site that cannot be replicated or would take significant time, or uncertainty in their ability, to be re-established; and • The preference is that existing wildlife corridors and stepping stones should be protected.

Contribution to Cumulative Effects

Effects may arise in combination with sites: IND/D, WMSP-S/D, IND/AH (SD1); WMSP-A/G, IND/L, WMSP-O/E, WMSP-O/F (SD2/SD3); IND/Y, IND/J, IND/M (SD4/SD5/SD6/SD7); IND/O, IND/Z (SD9/SD10).

Housing growth and increases in economic activity are likely to increase the demand for road space which could lead to increased congestion and a deterioration in air quality with potential negative effects on human health and biodiversity. However, policies are included to promote sustainable transport and avoid adverse impacts on air quality which should help to reduce traffic and congestion and protect air quality and reduce the risk of adverse impacts on health and ecosystems. The promotion of economic activity will benefit the local population through increased access to employment.

1.6 THE HASTINGS PLANNING STRATEGY 2011-2028, FEBRUARY 2014

The target for housing development will be at least 3,400 net new homes for the period 2011 – 2028.

Local economic growth and diversification will be met through the development of up to 70,000m2 of employment floorspace between 2008 and 2028. This will be achieved in part by:

• the development of Enviro21 Innovation parks in the Queensway Employment Corridor, circa 15,300m2; and • the development of floorspace opportunites on existing employment areas across the Borough by 2028 primarily at the following locations: Churchfields, Castleham, Ponswood, West Ridge and also Ivyhouse Lane.

The retail need for new comparison goods floorspace is estimated to be 20,500m2 for the period 2014 -2028. This need is to be met primarily within Hastings Town Centre. 2,800m2 of retail warehousing needs for the period 2014 to 2028 will be met on edge-of-centre sites or out-of-centre sites, which are well served by a choice of means of transport.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G11 Table 1.4 Distribution of new housing, employment land and retail floorspace

Housing to 2028 Additional employment Additional retail land (m2) floorspace (m2) Western area 1100-1290 36,700 0 Central area 1220-1500 21,700 Up to 20,500 Eastern area 740-920 Subject to further study 0

Western Area

The Plan supports the delivery of the proposed Bexhill - Hastings Link Road and A21 Baldslow Link improvements and the implementation of the strategic network of cycle routes to link communities and facilities.

Renewable energy opportunities will be explored on the fringes of the urban area, and opportunities for combined heat and power (CHP) connected to district heating systems or combined cooling, heat and power (CCHP) for development proposals within the vicinity of the Conquest Hospital.

Central Area

Opportunities for Combined Heat and Power connected to District Heating systems in the vicinity of the Summerfields Sports Centre will be explored.

The Plan supports the implementation of the strategic network of cycle routes from the town centre out to strategic open spaces, the seafront, nature conservation areas and community facilities.

Eastern Area

The Plan supports the use and management of land between Ivyhouse Lane and Rock Lane, to secure environmental and access improvements in association with development in the locality. It also supports the implementation of the strategic network of cycle routes that will link communities to the strategic open spaces, the seafront, nature conservation areas and community facilities.

The Plan requires development to:

• provide accessible forms of development that reduce the need to travel by car and are integrated with public transport and other sustainable modes of travel, allow for ease of movement and provide safe environments; • protect against light, air, water, land and noise pollution; and • support the move to a low carbon economy.

Hastings Borough Council will explore opportunities for CHP systems connected to district heating networks in the vicinity of the Conquest Hospital, Summerfields Sports Centre, and Hastings town centre.

The Council will work to promote and secure sustainable tourism development in the town. A more diverse and high quality tourism offer will be encouraged that seeks to lengthen the tourism season, increase the number of visitors, provide job opportunities and sustain the tourism economy.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G12

The Council will seek the earliest possible implementation of the following road and rail schemes that will reduce peripheriality, and support the regeneration of Hastings:

• Bexhill - Hastings Link Road; • Wider improvements to the A21 and A259 corridor; • Ashford to Hastings line – capacity and journey time improvements; and • Hastings to Tonbridge line capacity and power supply improvements.

The Council will work with East Sussex County Council using the Local Transport Plan 3 policy framework and other partners to achieve a more sustainable transport future for Hastings. Particular priority will be given to:

• improving bus routes, through support for the provision and improvement of bus priority lanes and junction approaches, services and passenger facilities; • supporting the provision of new and enhanced cycle routes in the town, and in particular, supporting the implementation of the strategic cycle network as identified on the key diagram and the Policies Map; • improving walking routes for pedestrians; • ensuring that new development is located close to existing public transport provision where possible; • requiring developers to consider the needs of pedestrians and cyclists in developments and deliver appropriate measures; • improving the safety of the highway network; • improving air quality and the environment generally; • examining the potential for adopting other “smarter choices” measures, including workplace and school travel plans; and • travel awareness campaigns, car clubs/car sharing schemes, teleworking and home shopping.

Contribution to Cumulative Effects

Effects may arise in combination with sites: IND/G, IND/K, IND/H, WMSP-O/D, WMSP-S/E (Western Area); IND/AF (Central Area); WMSP-S/B, WMSP-S/A, IND/X (Eastern Area).

Housing growth and increases in economic activity including from tourism are likely to increase the demand for road space which could lead to increased congestion and a deterioration in air quality with potential negative effects on human health and biodiversity. However, policies are included to promote sustainable transport which should help to reduce traffic and congestion, protect air quality and reduce the risk of adverse impacts on health and ecosystems. Opportunities for combined heat and power and district heating systems will be promoted, helping to increase energy efficiency and reduce greenhouse gas emissions. The promotion of economic activity will benefit the local population through increased access to employment and should help to reduce deprivation in Hastings.

1.7 ROTHER DISTRICT COUNCIL PROPOSED SUBMISSION CORE STRATEGY, AUGUST 2011 AND SCHEDULE OF MAIN MODIFICATIONS, AUGUST 2013

The Strategy for the Overall Spatial Development is to:

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G13

• Plan for at least 5,700 dwellings (net) in the district over the period 2011-2028; and • Plan for at least 100,000m2 of gross additional business floorspace.

The Council will identify suitable sites for development, focusing new development at Bexhill, giving particular attention to promoting economic regeneration and growth of the Hastings and Bexhill area, including through mixed use developments, while providing for some development in Battle and Rye and limited development for villages.

Table 1.5 Approximate development levels 2011-2028

Housing Employment Bexhill 3100 dwellings At least 60,000m2 Hastings fringes 100-250 dwellings At least 3,000m2 Battle 475-500 dwellings At least 10,000m2 Rye 355-400 dwellings At least 10,000-20,000m2 Villages 1670 dwellings At least 10,000m2 Total 5700 dwellings At least 93,000 – 103,000m2

Support will be given to the improvement of strategic infrastructure that will strengthen the role of Rother, and especially Bexhill, as an area of economic activity and investment opportunity. Priority will be to improve connectivity along key transport corridors, enable regeneration and reduce entrenched economic and social disparities. This will include:

• Support for early implementation of the Bexhill to Hastings Link Road and associated bus and cycle improvements; • Working with agencies and stakeholders to deliver effective management of strategic transport corridors; • Investment into providing transport choice; and • Working with agencies to upgrade the capacity and capability of the East Coastway and Hastings to London rail corridors.

Improvements in the provision and use of sustainable transport will be achieved through:

• maximising the best and most effective use of the existing transport network and facilitating enhancements with priority given to improving bus, community transport and rail network; • the promotion of public transport patronage and associated infrastructure; • supporting the provision of a high quality cycle network to encourage a modal shift away from the car; • improvements to the pedestrian environment and wider public realm to encourage integration between different modes of transport, employment areas and settlement centres; • promotion of road safety through education and design; and • safeguarding sites and routes with the potential to contribute towards the provision of an efficient and sustainable public transport network.

New development should minimise the need to travel and support good access to

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G14 employment, services and communities facilities, as well as ensure adequate, safe access arrangements.

The strategy to mitigate and adapt to the impacts of climate change includes policy to:

• Require proposed developments of more than 100 dwellings or 1,000m2 of non- residential floorspace to provide a comprehensive energy strategy, including an assessment of the potential for solar, biomass and wind generated energy, and of combined heat and power, and consider extending this requirement to smaller schemes; • Achieve high levels of energy performance on the strategic mixed use developments to the north east of Bexhill, including by Combined Heat and Power (CHP) and/or wind energy generation; and • Promote more sustainable travel patterns and widespread fast broadband coverage.

Biodiversity and green space will be protected and enhanced by multi-agency working where appropriate to:

• maintain and develop a district-wide network of green infrastructure where possible linking areas of natural green space; • support opportunities for management, restoration and creation of habitats in line with the opportunities identified for the Biodiversity Opportunity Areas and targets set out in the Sussex Biodiversity Action Plan; • ensure that development retains, protects and enhances habitats of ecological interest, including ancient woodland, water features and hedgerows, and provides for appropriate management of these features; and • require developers to integrate biodiversity into development schemes by avoiding adverse impacts from development on biodiversity or habitat, or where wholly unavoidable, provide appropriate mitigation against or compensation for any losses. Developers will also be expected to consider and promote opportunities for the creation and/or restoration of habitats appropriate to local context.

The overall strategy for Bexhill includes:

• Promoting the economic growth of the town, and wider area, including through encouraging growth in new and established local firms, especially in high value- added sectors, prioritising development for employment purposes, increasing the supply of land and premises and promoting efficient infrastructure; and

• Improving road, rail, bus and cycling access within Bexhill and between the town and Hastings, via an integrated sustainable local transport strategy for the Bexhill and Hastings area, key elements of which will be the Bexhill to Hastings Link Road, associated ‘greenway’ and new ‘quality bus corridors’, and a cycle network that focuses on ‘utility’ routes to the town centre, schools, colleges and workplaces, and recreational routes into the Countryside Park and along the seafront.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G15 Contribution to Cumulative Effects

Effects may arise in combination with sites: WMSP-S/C, IND/G, IND/F, IND/C (Bexhill area).

Housing growth and increases in economic activity are likely to increase the demand for road space which could lead to increased congestion and a deterioration in air quality with potential negative effects on human health and biodiversity. However, policies are included to promote sustainable transport, which should help to reduce traffic and congestion, protect air quality and reduce the risk of adverse impacts on health and ecosystems. Opportunities for combined heat and power and district heating systems will be promoted, helping to increase energy efficiency and reduce greenhouse gas emissions. The promotion of economic activity will benefit the local population through increased access to employment and should help to reduce deprivation in Bexhill.

1.8 LEWES JOINT CORE STRATEGY – PROPOSED SUBMISSION DOCUMENT, JANUARY 2013

In the period between 2010 and 2030, 4,500 net additional dwellings will be provided in the plan area (approximately 225 net additional dwellings per annum).

In the period between 2012 and 2031, in the region of 74,000m2 of employment floorspace (B1, B2 and B8) will be provided in the plan area. 60,000m2 of this floorspace will be as industrial space (B1c, B2 and B8), and 14,000m2 will be as office space (B1a). No net additional floorspace is envisaged on top of existing provision.

2,408 net additional dwellings will be distributed as follows:

• Land at North Street, Lewes – 350 net additional units; • Land to the north of Bishops Lane, Ringmer – 120 net additional units; • Land at Greenhill Way, Haywards Heath (within Wivelsfield Parish) – 140 net additional units; • Land at Harbour Heights, Newhaven – a contribution towards the 780 planned net additional units at Newhaven; and • Planned housing growth at the following settlements: o Lewes – 360 net additional units; o Newhaven – 780 net additional units; o Peacehaven & Telscombe – 220 net additional units; o Seaford – 90 net additional units; o Barcombe Cross – 10 net additional units; o North Chailey – 30 net additional units; o South Chailey – 10 net additional units; o Cooksbridge – 30 net additional units; o Ditchling – 15 net additional units; o Newick – 100 net additional units; o Plumpton Green – 50 net additional units; o Ringmer & Broyle Side – 220 net additional units (although if the contingency allocation for the land to the north of Bishops Lane is implemented through this policy, the figure will be 100 net additional units); o Wivelsfield Green – 30 net additional units.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G16 In order to stimulate and maintain a buoyant and balanced local economy through regeneration of the coastal towns, support for local and key strategic businesses and the rural economy and ensuring that the district’s economy does not become reliant on one or two sectors, the local planning authority will take a flexible and supportive approach to economic development. The Council will:

• support the appropriate intensification, upgrading and redevelopment of existing employment sites for employment uses; • Promote the development of sustainable tourism, including recreation, leisure, cultural and creative sectors; • Support the continued use of Newhaven port for freight and passengers including plans for expansion and modernisation of the port; • Promote modern and high speed e-communications and IT infrastructure; and • Encourage sustainable working practices (eg. homeworking and live/work).

The local planning authority will seek to improve air quality throughout the district, having particular regard to any Air Quality Management Area (AQMA) designations. Applications for development that by virtue of their location, nature or scale could impact on an AQMA will be required to:

• Have regard to any relevant Air Quality Action Plans (AQAP) and to seek improvements in air quality through implementation of measures in the AQAP; and • Provide mitigation measures where the development and/or associated traffic would adversely affect any declared AQMA.

All applications for development will be required to:

• Provide mitigation measures where the development and/or its associated traffic could lead to a declaration of a new or extended AQMA; • Ensure that the development will not have a negative impact on the surrounding area in terms of its effect on health, the natural environment or general amenity, taking into account cumulative impacts; • Promote opportunities for walking, cycling and public transport and congestion management to reduce traffic levels in areas of reduced air quality, particularly in town centre locations, and promote the opportunity for cycling through the provision of cycleways; and • Secure best practice methods to reduce levels of dust and other pollutants arising from the construction of development and/or from the use of the completed development.

The local planning authority will promote and support development that encourages travel by walking, cycling and public transport, and reduces the proportion of journeys made by car, in order to help achieve a rebalancing of transport in favour of sustainable modes by:

• Ensuring that new development is located in sustainable locations with good access to schools, shops, jobs and other key services by walking, cycling and public transport in order to reduce the need to travel by car (unless there is an overriding need for the development in a less accessible location); • Ensuring that the design and layout of new development prioritises the needs of pedestrians, cyclists and users of public transport over ease of access by the

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G17 motorist; • Ensuring that new residential developments are designed to achieve speeds of 20 mph or less; • Ensuring that new development minimises the need to travel and incorporates appropriate measures to mitigate for any transport impacts which may arise from that development; • Expecting new development to contribute to delivering the priorities of the East Sussex Local Transport Plan.; • Requiring new development to provide for an appropriate level of cycle and car parking; and • Requiring development which generates a significant demand for travel, and/or is likely to have other transport implications to: o Be supported by a Transport Assessment/Transport Statement and sustainable Travel Plan, where appropriate; o Contribute to improved sustainable transport infrastructure, including the provision of safe and reliable sustainable transport modes; and o Provide facilities and measures to support sustainable travel modes.

The local planning authority will work with East Sussex County Council and other relevant agencies to encourage and support measures that promote improved accessibility, create safer roads, reduce the environmental impact of traffic movements, enhance the pedestrian environment, or facilitate highway improvements. In particular, the local planning authority will:

• Support the expansion and improvement of public transport services, particularly those providing links between the rural and urban areas; • Encourage improvements to existing rail services, new or enhanced connections or interchanges between bus and rail services, and improvements to the quality and quantity of car and cycle parking at railway stations; and • Support the development of a network of high quality walking and cycling routes throughout the district.

The local planning authority will encourage renewable and low carbon energy in all development, with proposals responding to the potential identified in the Energy Opportunities Map. Development location and design that takes advantage of opportunities for decentralised, renewable and low carbon energy will be encouraged.

Contribution to Cumulative Effects

Effects may arise in combination with sites: IND/AN, IND/AJ (Ringmer); IND/B, IND/AO, WMSP-O/A, WMSP-O/C, IND/AC, WMSP-A/A (Newhaven); WMSP- O/A (Peacehaven).

Housing growth and increases in economic activity are likely to increase the demand for road space which could lead to increased congestion and a deterioration in air quality with potential negative effects on human health and biodiversity. However, policies are included to promote sustainable transport, which should help to reduce traffic and congestion, protect air quality and reduce the risk of adverse impacts on health and ecosystems. Opportunities for decentralised, low carbon energy systems will be promoted, helping to increase energy efficiency and reduce greenhouse gas emissions. The promotion of economic activity will benefit the local population

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G18 through increased access to employment and should help to reduce deprivation in Newhaven.

1.9 SHOREHAM HARBOUR JOINT AREA ACTION PLAN: DRAFT FOR CONSULTATION, FEBRUARY 2014

The nine overarching strategic objectives of the JAAP are as follows:

• SO1. Sustainable Development: To promote sustainable development; • SO2. Shoreham Port: To support a growing, thriving port; • SO3. Economy and Employment: To stimulate the local economy and provide new jobs; • SO4. Housing and Community: To provide new homes to address local needs; • SO5. Sustainable Transport: To improve connections and promote sustainable transport choices; • SO6. Managing Flood Risk: To reduce the risk of flooding and adapt to climate change; • SO7. Nature Conservation: To conserve and enhance the harbour’s environmental assets; • SO8. Recreation and Leisure: To enhance and activate the harbour’s leisure and tourism offer; • SO9. Place Making and Design Quality: To promote high design quality and improve townscape.

The JAAP contains seven individual character areas with specific priorities for development:

• 1: South Quayside – port operations, improving operational efficiencies, developing new trade and exploring opportunities for sustainable energy generation; • 2: Aldrington Basin – a strategic employment and mixed use area; • 3: North Quayside and South Portslade - a strategic employment and mixed-use area, including some appropriately located residential development, and an operational port area; • 4: Portslade and Southwick Beaches - improvements to the quality, access, appearance and maintenance of the Public Right of Way corridor, beach promenade, public areas and beach environment; • 5: Fishergate and Southwick Waterfront - comprehensive reconfiguration, improving operational efficiencies, developing new trade and exploring opportunities for sustainable energy generation; • 6. Harbour mouth – restoration and redevelopment of fort and rowing club, and environmental and public realm improvements; • 7. Western Harbour Arm - sustainable, mixed-use residential area, access improvements and biodiversity enhancements.

Of these, character area 4 is key in its potential to give rise to cumulative effects in combination with the WMSP.

Priorities for North Quayside and South Portslade

• To designate South Portslade Industrial Area as a Strategic Employment/Mixed- use Area, including some appropriately located residential development;

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G19 • To develop North Quayside as a new and improved Port operational area accommodating new and relocated port uses with limited land reclamation and a new access road (within the Port boundary) in line with the Port Masterplan; • To secure improvements to legibility, permeability and connectivity through high quality building design, townscape and public realm, ensuring to respect and complement the character of surrounding areas; • To improve connections and townscape around key linkages including Boundary Road/Station Road (B2194) district retailing centre, Church Road (B2193) and along the A259; • To ensure that all development takes in to account the findings and recommendations of the current Strategic Flood Risk Assessment; • To ensure that new development proposals take account of noise and air quality impacts and that improvements are sought wherever possible.

It is recommended that the core of the industrial estate remains protected for employment uses with a limited number of carefully selected plots around the periphery promoted for redevelopment, including for residential uses.

Opportunities exist to enhance the permeability of South Portslade Industrial Estate, seeking to repair and reconnect sites to adjacent neighbourhoods and key routes. During the plan period, opportunities may exist to create new north-south connections. Beyond the plan period, further opportunities may exist to unlock and extend routes (pedestrian or vehicular).

New areas of green space and landscaped areas are proposed as part of new development proposals. Linkages to existing recreation and open space assets such as Hove Lagoon, West Hove and Portslade/Southwick Beaches will also be encouraged.

The Partnership will work with developers and stakeholders to deliver approximately 400 new homes and 7,500m2 of new employment floorspace (in combination with SS1: Aldrington Basin).

In accordance with the Shoreham Harbour Transport Strategy, opportunities will be sought to support the delivery of a reconfigured access road at Basin Road North to increase efficiency of port traffic movements and encourage HGVs to use the advisory routes.

Harbour-wide policies

Within the Strategic Site areas, opportunities should be sought to provide linked district heating networks.

Development within or adjacent to an AQMA, or that is likely to have an impact on an AQMA, will be required to provide a contribution towards implementing AQAP objectives, such as sustainable transport improvements. Proposals will be required to demonstrate that appropriate mitigation measures are introduced to ensure that new and existing residents are not exposed to poor air quality associated with existing industrial uses and traffic pollutants in both the short and long-term.

New development in the JAAP area should help to deliver sustainable transport improvements as identified in the Shoreham Harbour Transport Strategy. Developments will be required to contribute towards the delivery of transport

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G20 infrastructure that reduces congestion and increases the use of sustainable transport modes. Improvements should focus on identified priority corridors, including the A259 and A283, and should seek to minimise the impact of traffic, including HGV’s, on surrounding communities.

Proposals that incorporate facilities and/or initiatives to promote the use of the river as a means of transport, such as provision of pontoons and additional moorings will be encouraged.

Contribution to Cumulative Effects

Effects may arise in combination with site IND/AJ.

Residential development and increases in economic activity are likely to increase the demand for road space which has the potential to lead to increased congestion and a deterioration in air quality with potential negative effects on human health and biodiversity. However, measures are included within the JAAP to reduce traffic and promote sustainable modes of transport, which will help to reduce the likelihood of congestion. This, in combination with measures that seek improvements in poor air quality and transport infrastructure, should help to improve air quality and reduce the risk of adverse impacts on health and ecosystems. Opportunities for combined district heating systems will be promoted, helping to increase energy efficiency and reduce greenhouse gas emissions. The promotion of economic activity and provision of new housing will benefit the local population through improved availability and quality of housing and increased access to employment. This should help to reduce deprivation in Shoreham.

1.10 EAST SUSSEX LOCAL TRANSPORT PLAN 2011-2026, JUNE 2011

The Local Transport Plan aims to provide transport infrastructure which delivers sustainable economic growth in areas which have been identified as needing greater investment for regeneration and development: Hastings/Bexhill, Eastbourne/South Wealden, and Newhaven .

In delivering sustainable economic growth, the focus will be on planning and providing the following transport infrastructure:

• localised road improvements to tackle congestion at bottlenecks on the network; • targeted strategic transport improvements within and outside East Sussex to improve the connectivity within the county and with the south east, London and beyond; • road safety through enforcement, education and engineering measures including integration of highway maintenance with safety improvement schemes; • promotion and infrastructure for public transport e .g. accessible bus stops, shelters; • implementation of infrastructure to support integrated sustainable travel – walking, cycling, public transport, car sharing; • improvements to pedestrian routes to key trip attractors, better rail/bus/cycle interchanges, less street clutter and enhanced public spaces; • better use of technology to make the best use of the existing transport network e.g. Urban Traffic Control (linking of traffic signals), Real Time Bus Information, charging points for electric vehicles and smart ticketing initiatives; and

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G21 • parking control and enforcement.

The Plan also seeks to provide infrastructure which facilitates development and delivery of sustainable economic growth in Uckfield.

To maintain economic activity and quality of life across the county as a whole, the Plan gives priority to:

• Effective Highway Maintenance and Management of Transport Assets; • Improving Road Safety; and • Supporting the delivery of Public and Community Transport.

The Plan also seeks to secure strategic infrastructure improvements for road and rail, and encourage non-transport measures which reduce the need to travel.

The Council will continue to pursue the following strategic road improvements to deliver sustainable economic growth in East Sussex:

• A259 Bexhill to Hastings Link Road; • A21 Baldslow Link; • A23 Handcross to Warninglid; • A21 Tonbridge to Pembury dualling; • A21 Kippings Cross to Lamberhurst; and • A21 Flimwell to Robertsbridge.

The Council will continue to lobby for the following targeted rail infrastructure improvements which improve East Sussex’s connectivity to London, Ashford and Brighton:

• electrification and dual tracking on the Hastings – Ashford line, • electrification and dual tracking of the Uckfield – Hurst Green section of the Uckfield line; • increased capacity on the wider rail network serving the county and the London termini; • new stations at Glyne Gap, Wilting, Stone Cross/North Langney and Polegate; • reinstatement of the Willingdon Chord without prejudicing existing rail passenger services to Eastbourne; and • reinstatement of the Lewes – Uckfield line as part of wider rail capacity.

The approach for freight is to:

• promote the use by goods vehicles of our advisory freight route network of A and B class roads; • develop Freight Quality Partnerships with industry and communities to address local freight issues; • support the transfer of freight by rail; • work with Ordnance Survey and the freight industry to help address inappropriate use of routes identified by satellite navigation systems; • encourage more sustainably accessible locations for new business premises; • encourage safer, more efficient deliveries and raise awareness of freight and distribution; and • ensure the freight traffic generated by potential new goods distribution facilities

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G22 does not have a significant impact on the Ashdown Forest SAC/SPA.

The Council will ensure that appropriate measures, subject to funding, are implemented and contribute to addressing the transport related issues within the AQMAs .

Contribution to Cumulative Effects

Policies to promote sustainable transport will help to reduce traffic and congestion, protect air quality and reduce the risk of adverse impacts on health and ecosystems.

1.11 SOUTH EAST LOCAL ENTERPRISE PARTNERSHIP GROWTH DEAL AND STRATEGIC ECONOMIC PLAN, MARCH 2014

The LEP’s ambition is to:

• enable the creation of 200,000 sustainable private sector jobs over the decade to 2021, an increase of 11.4% since 2011; • complete 100,000 new homes by 2021, which will entail, over the seven years, increasing the annual rate of completions by over 50% by comparison with recent years; and, • lever investment totalling £10 billion, to accelerate growth, jobs and homebuilding.

A potential second runway at Gatwick Airport, the busiest single runway airport in the world, will bring significant benefits for East Sussex with the creation of around 20,000 jobs on and off the airport.

East Quay at Newhaven is a key opportunity site for E.ON operations and maintenance base for the Rampion OWF and potential turbine construction. It also has future potential for other manufacturing and service activities in the OWF sector and the subsequent attraction of supply-chain activity linked to OWF.

A21/A259: Hastings - Bexhill

There are many investment opportunities on, or close to, the A21, for commercial, leisure and housing uses. In Hastings, these include commercial developments at North Queensway, and the Priority Quarter Business District Phase 4 and significant development sites at Churchfields and Ivyhouse Lane. There is opportunity for strategic housing and commercial development in North East Bexhill. To enable new growth, the LEP is seeking investment in the Queensway Gateway Road, and a number of improvements to junctions and capacity improvements in Hastings and Bexhill, including the North Bexhill Access Road.

In this corridor there is the opportunity to directly create 5,278 jobs and 765 new homes by 2021 and facilitate 9,700 jobs and 11,300 homes through proposed transport schemes.

2,500m2 of managed business space at Bexhill Enterprise Park, will be delivered with a £6.5m loan from SEFUND, which will be repaid from the eventual refinancing of the business space centre when fully let. The centre will provide essential office facilities for growing small and medium size local businesses, and will create 300

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G23 additional jobs. Bexhill Enterprise Park comprises a number of strategic development sites that will be accessed by the Bexhill to Hastings Link Road when completed in early 2015. Local Growth Funds of £12m will act as a catalyst to unlock sites for wider development with the potential to yield up to 2,000 jobs.

A22/A27 Eastbourne - South Wealden

The LEP is seeking investment in upgrading the A27 between Eastbourne and Lewes to address constraints, improving connectivity to A23/M23, Gatwick Airport and London and supporting business and housing growth plans in the Eastbourne - South Wealden growth corridor.

The corridor includes land in Uckfield for business growth and housing and employment sites in Hailsham and Polegate. Sovereign Harbour in Eastbourne contains two key linked sites and the new Innovation Centre will provide a catalyst for further development.

The LEP is seeking improvements to a series of junctions on the A22/A27 corridor around Polegate, and other town centre improvements in Eastbourne, Uckfield and Hailsham, with a sustainable transport corridor from Eastbourne to Hailsham via Polegate. They are already supporting growth in this corridor through Uckfield and Hailsham town centre improvements, the committed developments in Sovereign Harbour, including the retail park, and sites in Eastbourne including the Arndale Centre. The LEP is planning to make investments in Polegate Enterprise Park, Sovereign Harbour site 6 and town centre developments.

This corridor has the capacity for 5,000 jobs, and 3,000 homes by 2021. Polegate Innovation Park will deliver 175 homes 2019/20 – 20/21 and 525 homes by 2021/27.

Newhaven Clean Tech and Maritime Growth Corridor

The area offers potential to become a CleanTech and Maritime Growth Corridor. This will capitalise on proposed investments from E.ON in its operations & maintenance base for Rampion Offshore Wind Farm (OWF), Veolia in its Energy Recovery Facility, proposals for a Marine Enterprise & Training Centre, and the decision by Government to approve a new University Technical College (UTC) specialising in marine and environmental engineering. Newhaven Port & Properties has prepared a masterplan to increase the volume of trade through the port, establish this renewable energy cluster, and support the development of the fishing and marine leisure sectors.

The Newhaven Port Access Road is an important requirement for re-establishing Newhaven as an important gateway to mainland Europe. The first phase is funded and currently being constructed.

Newhaven has substantial physical capacity for growth, including on large brownfield sites on six sites in and around the town centre and waterfront which will be more readily developed after the flood defences are in place. Between them they could provide 4500 jobs and 190 homes. The wider Transport schemes will facilitate 725 jobs and 1700 homes by 2020/21. In order to enable this growth, the LEP is promoting the port access road, the Newhaven ring road and local capacity improvement works. There is also work planned by the Environment Agency on flood defence work which will help release employment sites. Further works will

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G24 also be required to the North and East Quay sites.

Developments already committed in Newhaven include a housing and employment development at Eastside, and a Coastal Communities funded extension of Denton Island Enterprise Centre and children’s centre.

East Sussex

The LEP is currently investing £56.8m in the Bexhill Hastings Link Road which will unlock sites for over 1,500 homes and create nearly 3,000 jobs in North Bexhill and Hastings, and through £20m from the SE LEP Growing Places Fund, it is currently delivering projects in Hastings, Bexhill and Eastbourne. This needs to be supported with investment by the Highways Agency and Network Rail in upgrading the quality of the strategic road and rail networks serving East Sussex, in particular the A27 and A21 corridors and the Hastings – Ashford rail line,

The under-exploited port at Newhaven offers an opportunity to develop both passenger and freight services, environmental and clean technologies and maritime activities. A number of high-value and distribution businesses have successfully made East Sussex their HQ and there are major opportunities to attract further inward investment of this type. Newhaven also has significant potential to deliver growth as part of the Greater Brighton City Region City Deal under the Coast to Capital LEP.

Contribution to Cumulative Effects

Effects may arise in combination with sites: IND/B, IND/AO, WMSP-O/A, WMSP- O/C, IND/AC, WMSP-A/A (Newhaven); WMSP-S/C, IND/F, IND/C, IND/G, IND/AF, IND/H, IND/K, WMSP-O/D, WMSP-S/E, WMSP-S/B, WMSP-S/A, IND/X (Bexhill and Hastings); IND/A, IND/AM, IND/Q, IND/P, IND/S, IND/E, IND/AK, IND/AG, IND/M, IND/J, IND/Y, WMSP-E/A, WMSP-O/F, WMSP-O/E, IND/L, WMSP-A/F, WMSP-A/G, WMSP-E/B (Eastbourne, Polegate and Hailsham).

Housing growth and increases in economic activity are likely to increase the demand for road space which could lead to increased congestion and a deterioration in air quality with potential negative effects on human health and biodiversity. Road improvements will help to increase capacity, but this may encourage increased traffic volumes, which may not lead to improved air quality, although the likelihood and significance of effects are uncertain. However, policies are included to promote sustainable transport, which should help to reduce traffic and congestion, protect air quality and reduce the risk of adverse impacts on health and ecosystems. Upgrading of port services will help to encourage the transport of waste by water. The promotion of economic activity will benefit the local population through increased access to employment and should help to reduce deprivation in Newhaven, Eastbourne, Bexhill and Hastings.

1.12 COAST TO CAPITAL STRATEGIC ECONOMIC PLAN, MARCH 2014

The Plan reflects and includes all the challenges, priorities and investments which have been set out in the Greater Brighton City Deal, including:

• The creation of a new cluster location for digital businesses in Brighton;

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G25 • Access to ultrafast broadband via a digital exchange; • Commitments to flood defences at Newhaven and Shoreham; • Support for business innovation; and • Creation of Business Growth Centres in Newhaven, Shoreham, Burgess Hill, Preston Barracks and Worthing.

The LEP plans to:

• Bring forward a major investment programme in transport infrastructure which will unlock growth in jobs, homes and employment space; • Develop plans for each of the strategically important business locations which will safeguard their competitiveness, and create a positive planning and regulatory environment; • Bring in public and private sector funding, investing in transport, premises and digital connectivity to create dynamic and catalytic transformations; • Deliver interventions in brownfield and greenfield sites which will provide the capacity for employment and housing growth, including Enterprise Zone designation at Newhaven; • Reduce car journeys through sustainable transport improvements thereby contributing to national requirements to reduce carbon emissions; • Improve resilience to weather events and transport disruptions; and • Deliver all the commitments set out in Greater Brighton City Deal.

Spatial priorities include:

• Burgess Hill o Two 30 ha sites to create 5000 jobs; o 3385 new homes north of the town; o Town centre residential developments delivering 1280 homes; o Transport improvements to the link to the A23/M23.

• Brighton and Hove o The comprehensive regeneration of the Marina to help to create a new residential neighbourhood o A259 Corridor Transport Scheme and Seafront Infrastructure Transport Scheme – will secure improvements to sustainable transport infrastructure along the A259, and improve air and noise quality, pedestrian and cycle routes and crossing opportunities in order to achieve a modal shift and thereby reduce the impact of traffic o The overall development of the Preston Barracks site will comprise 650,000 sq ft of commercial space, 350 new homes, 1250 student beds, 35,000 sq ft of retail space, a health centre, a new business school and the 50,000 sq ft Central Research Laboratory.

• Shoreham Harbour and Airport o Flood defences for Adur Tidal Wall Western Harbour Arm; o Improvements to road access including the junction at the A27; o Environmental Technologies Growth Centre at Shoreham – building on Ricardo UK’s new £10m Vehicle Emissions Research Centre, at the Airport as well as renewable energy business at the Harbour; o These sites will provide space for 1,740 new jobs at Shoreham Harbour and Shoreham Airport, as well as 1,500 new waterside homes.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G26

• Newhaven Enterprise Zone o Construction of flood defences – a City Deal commitment; o Creation of new enterprise and move on space on Denton Island; o Opening of the UTC o Port Access Road – phases 1 and 2; o Development of the port area for wind farm operations; o Marine Enterprise and Training Centre; o Clearance and development of three major sites on East Quay; o Improvements to rail stations and sustainable transport enhancements; o Town centre improvements; o New transport interchange hub; o Re-zoning of employment land, including some possible re-locations; o Development of the leisure marine offer, including new visiting and berthing facilities; o Further site clearance and development.

The measures which are core to nearly all transformational packages are:

• Improvements to walking and cycling links and the urban realm; • Tackling the severance caused by busy roads, rivers, railway lines, level crossings and other physical barriers; • Improvements to junctions and traffic management systems to ease traffic flow and reduce congestion; • Improvements to rail stations, including better cycling and pedestrian access; • Improvements to public transport, such as bus and taxi priority measures and better interchanges; • Behavioural change measures, including improved information to the travelling public; • Improving accessibility to rural areas; and • Improving road safety.

Contribution to Cumulative Effects

Effects may arise in combination with sites: IND/AA, IND/AP (Burgess Hill); WMSP-A/C, IND/I, WMSP-A/E, IND/U, IND/AB (Brighton and Hove); IND/AJ (Shoreham); IND/B, IND/AO, WMSP-O/A, WMSP-O/C, IND/AC, WMSP-A/A (Newhaven).

Housing growth and increases in economic activity are likely to increase the demand for road space which could lead to increased congestion and a deterioration in air quality with potential negative effects on human health and biodiversity. However, the emphasis on promoting sustainable modes of travel and digital connectivity will help to ease congestion and may offset to some extent the adverse effects on air quality, although the extent to which this will apply is uncertain. A shift to more sustainable transport choices will also help to limit greenhouse gas emissions. The promotion of economic activity will benefit the local population through increased access to employment and should help to reduce deprivation in Brighton & Hove and Newhaven. Improvements to flood defences at Newhaven and Shoreham is likely to contribute to reduced flood risk for a number of sites.

ENVIRONMENTAL RESOURCES MANAGEMENT EAST SUSSEX COUNTY COUNCIL, SOUTH DOWNS NATIONAL PARK AUTHORITY AND BRIGHTON & HOVE CITY COUNCIL G27