Kent Minerals and Waste Sites DPDs

Interim Sustainability Appraisal (SA) Report

May 2012

Prepared for: Kent County Council

UNITED KINGDOM & IRELAND

Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

REVISION SCHEDULE

Rev Date Details Prepared by Reviewed by Approved by

1 May 2012 Interim SA Report Mark Fessey Steve Smith Steve Smith Senior Associate Associate Consultant

Chris Eves Graduate Consultant

URS Infrastructure & Environment UK Limited (“URS”) has prepared this Report for the sole use of Kent County Council (“The Client”) in accordance with the Agreement under which our services were performed. No other warranty, expressed or implied, is made as to the professional advice included in this Report or any other services provided by URS. The conclusions and recommendations contained in this Report are based upon information provided by others and upon the assumption that all relevant information has been provided by those parties from whom it has been requested and that such information is accurate. Information obtained by URS has not been independently verified by URS, unless otherwise stated in the Report. The methodology adopted and the sources of information used by URS in providing its services are outlined in this Report. The work described in this Report was undertaken between January and March 2012 and is based on the conditions encountered and the information available during the said period of time. The scope of this Report and the services are accordingly factually limited by these circumstances. URS disclaim any undertaking or obligation to advise any person of any change in any matter affecting the Report, which may come or be brought to URS’ attention after the date of the Report. Certain statements made in the Report that are not historical facts may constitute estimates, projections or other forward- looking statements and even though they are based on reasonable assumptions as of the date of the Report, such forward-looking statements by their nature involve risks and uncertainties that could cause actual results to differ materially from the results predicted. URS specifically does not guarantee or warrant any estimate or projections contained in this Report. Copyright © This Report is the copyright of URS Infrastructure & Environment UK Limited. Any unauthorised reproduction or usage by any person other than the addressee is strictly prohibited.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

TABLE OF CONTENTS

1 INTRODUCTION...... 1 2 WHAT IS THE PLAN SEEKING TO ACHIEVE? ...... 4 3 WHAT’S THE SUSTAINABILITY ‘CONTEXT’? ...... 5 4 WHAT’S THE SITUATION NOW? ...... 19 5 WHAT WOULD THE SITUATION BE WITHOUT THE PLAN?...... 23 6 WHAT ARE THE KEY ISSUES THAT SHOULD BE A FOCUS OF THE APPRAISAL? ...... 25 7 HOW HAS THE PLAN DEVELOPED UP TO THIS POINT?...... 29 8 HOW HAS THE APPRAISAL AT THIS CURRENT STAGE BEEN UNDERTAKEN?...... 31 9 WHAT ARE THE APPRAISAL FINDINGS / RECOMMENDATIONS AT THS STAGE?...... 35 10 HOW CAN WE BEST MONITOR THE PLAN’S IMPACTS? ...... 48

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

1 INTRODUCTION

1.1 Background

URS is commissioned to undertake the Sustainability Appraisal (SA) in support of Kent County Council’s emerging Minerals and Waste Management Sites Development Plan Documents (DPDs). SA is a mechanism for considering the impacts of a draft plan approach, and alternatives to that approach, in terms of key sustainability issues, with a view to avoiding and mitigating adverse impacts and maximising the positives.

1.2 SA explained

‘SA Report focused’

SA is undertaken in-line with the procedures prescribed by the EU Strategic Environmental Assessment (SEA) Directive1. A key requirement of the Directive is that a report (which we call the ‘SA Report’) is published alongside the draft plan that ‘identifies, describes and evaluates’ the ‘likely significant environmental effects of implementing the plan or programme, and reasonable alternatives’.

Annex 1 of the Directive prescribes the information that must be contained within the SA Report. Providing this information involves answering a logical sequence of nine ‘appraisal questions’. The questions that must be answered within the report are shown in Table 1.1. Table 1.1: Questions that must be answered (sequentially) within the SA Report

APPRAISAL QUESTION CORRESPONDING REQUIREMENT OF THE SEA DIRECTIVE (The report must include…)

1) What is the plan seeking “an outline of the contents, main objectives of the plan or programme and to achieve? relationship with other relevant plans and programmes” (Annex I(a))

2) What’s the sustainability “an outline of the contents, main objectives of the plan or programme and relationship context? with other relevant plans and programmes” (Annex I(a)) “the environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation” (Annex I(e))

3) What’s the situation now? “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” (Annex I(b)) “the environmental characteristics of areas likely to be significantly affected” (Annex I(c))

4) What would the situation “the relevant aspects of the current state of the environment and the likely evolution be without the plan? thereof without implementation of the plan or programme” (Annex I(b))

5) What are the key issues “any existing environmental problems which are relevant to the plan or that should be a particular programme including, in particular, those relating to any areas of a particular focus of the appraisal? environmental importance, such as areas designated pursuant to Directives 79/409/EEC [Special Protection Areas under the Birds Directive] and 92/43/EEC” (Annex I(d)) (Note impacts on European sites will be specifically addressed through Habitats Regulations Assessment)

1 Directive 2001/42/EC

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APPRAISAL QUESTION CORRESPONDING REQUIREMENT OF THE SEA DIRECTIVE (The report must include…)

6) How has the plan “an outline of the reasons for selecting the alternatives dealt with, and a developed up to this point description of how the assessment was undertaken including any difficulties (such as (including the influence of technical deficiencies or lack of know-how) encountered in compiling the required SA)? information” (Annex I(h)) “the environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation” (Annex I(e))

7) How has the appraisal at “an outline of the reasons for selecting the alternatives dealt with, and a description of this current stage been how the assessment was undertaken including any difficulties (such as technical undertaken? deficiencies or lack of know-how) encountered in compiling the required information” (Annex I(h))

8) What are the appraisal “the likely significant effects (1) on the environment, including on issues such as findings / recommendations biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, at this current stage? material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors” (Annex I(f)) “the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme” (Annex I(g))

9) How might we monitor the “a description of the measures envisaged concerning monitoring…” (Annex I(i)) plan’s impacts?

Iterative

Given that the SA Report (published for consultation alongside the final draft version of the plan) must answer the question ‘How has the plan developed up to this point (including the influence of SA)’, it is understood that the plan must be developed alongside SA in an iterative fashion.

An iterative approach to plan-making / SA is being followed as part of preparing the Kent Minerals and Waste Sites DPDs, as described below.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

Figure 7-1: The iterative plan-making / SA process

1. A ‘Call for Sites’ asked operators and landowners to suggest suitable sites for minerals and waste development and providing supporting evidence. Other evidence-gathering work was also undertaken by the Council at this stage. Also at the outset of plan-making, a report was published for consultation (and subsequently finalised) answering the first six SA ‘appraisal questions’ (only). Answering these questions equates to establishing the ‘scope’ of the appraisal, and hence the report was known as the SA Scoping Report. 2. Evidence was used to identify site options, which were then published for consultation In 2011. Interim SA Reports were published as part of the consultations2. 3. The list of site options was refined to reflect: the latest evidence-base (which pointed to there being no need to allocate several types of site) and findings from the Interim SA Reports. KCC subsequently selected preferred options. This report presents an appraisal of the refined list of site options (preferred and non-preferred). 4. Subsequent to the current consultation, KCC will be in a position to prepare draft versions of the two DPDs (known as the ‘Proposed Submission’ versions). The draft DPDs will be subject to SA, and findings presented within an SA Report (which must answer all nine appraisal questions). The SA Report will published for consultation alongside the draft (Proposed Submission) plan document. 5. Following consultation on the draft DPDs, the Council will be in a position to finalise the document for Submission to Government. The SA Report will also be submitted, unless it is the case that significant changes have been made to either DPD, in which case there will be a need to revise this SA Report prior to Submission.

1.3 Structure of this Interim SA Report

Despite the fact that this is an ‘Interim’ SA Report, and does not need to provide the information required of the SA Report (by Annex 1 of the SEA Directive), it is helpful to also structure this report according to the appraisal questions presented in Table 1.1.

2 Two consultations on site options were held.

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2 WHAT IS THE PLAN SEEKING TO ACHIEVE?

“an outline of the contents, main objectives of the plan or programme and relationship with other relevant plans and programmes” (SEA Directive, Annex I(a))

2.1 Introduction

The Minerals and Waste Management Sites DPDs will form part of the Minerals and Waste Development Framework (MWDF). The Minerals and Waste Core Strategy will form the strategy for both the Minerals Sites DPD and the Waste Sites DPD.

KENT MINERALS AND WASTE DEVELOPMENT FRAMEWORK

Minerals and Waste Core Strategy Mineral Sites DPD Waste Management Sites DPD

2.2 The Minerals Sites DPD

The Minerals Sites DPD will include mineral importation sites, secondary and recycled aggregate producing sites and consider a variety of economic mineral resources including: Soft Sand. Sharp Sand and Gravel, Crushed Rock, Brickearth, Silica Sand, Chalk and Clay.

The Minerals Sites DPD, once adopted, will contain allocated sites throughout Kent which will provide mineral resources for the duration of the plan period (up to the end of 2030). The documents will identify where future minerals developments are likely to take place. However, a site allocation does not guarantee development in that location. All planning applications will be assessed upon the development management policies in the adopted Minerals and Waste Core Strategy and the policies in the relevant Local Development Framework (i.e. the district plan where the site is proposed).

2.3 The Waste Management Sites DPD

The Waste Sites DPD will consider a variety of waste management facilities including: Energy from Waste; Hazardous landfill; Non-hazardous landfill; Treatment/Materials Recycling Facilities; Composting; Household Waste Recycling Facilities & Transfer; Inert/Construction, Demolition & Excavation Landfill; and Environmental improvement to closed biodegradable landfill sites.

The Waste Sites Plan, once adopted, will contain allocated sites throughout Kent which will provide waste management facilities for the duration of the plan period (up to the end of 2030). The documents will identify suitable locations for waste facilities. However, a site allocation does not guarantee development in that location. All planning applications will be assessed upon the development management policies in the adopted Minerals and Waste Core Strategy and the policies in the relevant Local Development Framework (i.e. the district plan).

2.4 What are the DPDs not trying to achieve

It is important to emphasise that the Sites DPDs are strategic plans, and as such will not attempt to address every detailed spatial planning issue. Rather, detailed issues will be considered when determining planning applications as and when they are made. The strategic nature of the plan is reflected in the appraisal (see further discussion under the heading ‘How has the appraisal at this current stage been undertaken’).

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3 WHAT’S THE SUSTAINABILITY ‘CONTEXT’?

“an outline of the contents, main objectives of the plan or programme and relationship with other relevant plans and programmes” “the environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation” (SEA Directive, Annex I (a)&(e))

3.1 Introduction

An important step when seeking to establish the appropriate ‘scope’ of a Sustainability Appraisal involves reviewing ‘sustainability context’ messages (e.g. objectives or issues) set out within relevant published plans, policies, strategies and initiatives (PPSIs). A review of the sustainability context is presented within the ‘Kent MWDF SA Scoping Report’.3 Key messages from this review are summarised below.

3.2 Key messages from the 2010 context review and the NPPF

Table 3.1 considers, for a range of sustainability topics a range of key messages that taken together provide an understanding of the ‘sustainability context’. For a more detailed review of the sustainability context, readers should refer back to the 2010 SA Scoping Report.

Readers should note that some of the policy context documents reviewed at the time of preparing the Kent MWDF Scoping Report (2010) have since been superseded. In particular, the series of national Planning Policy Statements (PPSs) has now been superseded by the National Planning Policy Framework. Similarly, the policies set out within the South East Plan are soon to be revoked. However, messages from the PPSs, the South East Plan and other superseded documents can still be useful and relevant to the sustainability context review. The messages repeated below have been informally ‘vetted’ (by URS) for their continued relevance.

In addition to presenting messages from the 2010 Scoping Report, Table 3.1 also ‘updates’ the scope by presenting a review of key messages from the recently published National Planning Policy Framework.

3 Available @ http://www.kent.gov.uk/environment_and_planning/planning_in_kent/minerals_and_waste/evidence_base/sustainability_appraisal/scoping_reports.aspx (accessed 02/12)

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Table 3-1: Key ‘sustainability context’ messages SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC Air Quality The EU Air Quality Framework Directive (96/62/EC) has set out a consistent, The NPPF identifies that a Core Planning Principle is that: strategic framework for tackling air quality by setting European-wide limit values ‘Planning should… take account of and support local strategies to improve for 12 air pollutants. The National Emission Ceiling Directive (NECD) also sets health, social and cultural wellbeing for all.’ There is also a need to: ceilings for each EU Member State for emissions of ammonia, nitrogen oxides, prevent both new and existing development from ‘contributing to or being sulphur dioxide and volatile organic compounds (VOCs). put at unacceptable risk from, or being adversely affected by unacceptable At the national level, the Governments air strategy sets out plans to improve and levels of land, air, water or noise pollution or land instability’. protect air quality in the UK. Health-based ambient air quality objectives are Finally, the NPPF identifies that ‘Planning policies should sustain listed for nine main pollutants. Government guidance4 on mineral planning has compliance with and contribute towards EU limit values or national identified impacts relating to air quality as a ‘principle environmental impact’ of objectives for pollutants, taking into account the presence of Air Quality minerals working5. Management Areas and the cumulative impacts on air quality from The Environment Act 1995 places statutory duties on local authorities for local individual sites in local areas. Planning decisions should ensure that any air quality management. Under this legislation authorities are required to new development in Air Quality Management Areas is consistent with the conduct regular reviews and assessments against eight of the national local air quality action plan.’ objectives (excluding Ozone). If it is found that these objectives are unlikely to be met, authorities must designate Air Quality Management Areas (AQMAs) and produce Air Quality Action Plans.

4 CLG (2006). Minerals Planning Statement 1: Planning and Minerals [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/mineralspolicystatement5 (accessed 02/09) 5 Note that dust, noise and vibration/blasting/flyrock are also identified as ‘principle environmental impacts’ of minerals working in MPS1, however, these issues have been scoped out of requiring explicit consideration through this sustainability appraisal as a result of being more site specific, rather than strategic.

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SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC

Biodiversity Commitment to the Convention on Biological Diversity (CBD) led to the 1994 UK Planning should help to deliver a healthy natural environment for the Biodiversity Action Plan (UK BAP), which identifies those habitats and species benefit of everyone and safe places which promote wellbeing, and that as under the greatest threat and includes action plans with targets for their part of this there is a need to ‘[recognise] the wider benefits of ecosystem recovery. The Government has given consideration to how best to conserve UK services’ and ‘minimis[e] impacts on biodiversity and provid[e] net gains in BAP species and maintain ecosystem services under the banner of the biodiversity, where possible’. ‘Ecosystems Approach’. More specifically, the NPPF highlights the importance of: Government guidance on minerals planning identifies impacts relating to • ‘internationally or nationally designated, protected or sensitive species and plant identifying and mapping components of the local ecological networks, and wildlife habitats’ as a potential environmental impact of minerals working6. including: international, national and local sites of importance for However, the guidance also notes that mineral workings often provide the biodiversity, and areas identified by local partnerships for habitat opportunity in their restoration and after-use to create new wildlife habitats. restoration or creation; Furthermore, Government guidance on biodiversity and planning states, in • promoting the preservation, restoration and re-creation of priority relation to minerals and waste planning, that: habitats, ecological networks and the recovery of priority species ‘Active phases can be very beneficial for biodiversity and geological populations, linked to national and local targets; conservation… Documents should therefore include policies which ensure that • capitalising on opportunities to incorporate biodiversity in and around biodiversity and geology is conserved and enhanced during any active phases in developments; and addition to those relating to restoration schemes.’ • avoiding the loss or deterioration of irreplaceable habitats, including The South East Green Infrastructure Framework (2009) identifies the ancient woodland and the loss of aged or veteran trees found outside conservation and enhancement of biodiversity, including the need to mitigate the ancient woodland, unless the need for, and benefits of, the development potential impacts of new development, amongst the key functions of green in that location clearly outweigh the loss. infrastructure in the South East.

6 CLG (2006). Minerals Planning Statement 1: Planning and Minerals [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/mineralspolicystatement5 (accessed 02/09)

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SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC

Climate Change and The UK is committed to exceeding targets of the 1997 Kyoto Protocol. The The NPPF, within the ‘Climate Change, Flooding and Coastal Change’ Flood-risk Climate Change Act 2008 commits to an 80% reduction in GHGs by 2050 Chapter, states that the planning system should ‘secure radical reductions (against a 1990 baseline). Government guidance emphasises that tackling in greenhouse gas emissions, minimising vulnerability and providing climate change is a key priority for the planning system. As part of this, resilience to the impacts of climate change, and supporting the delivery of authorities should ensure that the “spatial distribution, location and design [of renewable and low carbon energy and associated infrastructure’.’ new development is] planned to limit carbon dioxide emissions”7. Allied to its emphasis on ‘plan[ning] for new development in locations and This message is re-iterated in Minerals Policy Statement 1, which advocates ways which reduce greenhouse gas emissions’’, the NPPF also highlights locally sources minerals in order to reduce carbon emissions of transportation that local authorities should set transport policy with the objective of over long distances by road. The bulk transportation of minerals should be by ‘support[ing] reductions in greenhouse gas emissions…’ rail, sea and inland waterways wherever practicable. In terms of renewable and low carbon energy infrastructure, the NPPF The Government’s flood strategy advocates integrating planning with highlights the need for local authorities to: ‘identify opportunities where groundwater, surface run-off and urban flooding considerations8. Important development can draw its energy supply from decentralised, renewable or strategy is set out within Catchment Flood Management Plans and Shoreline low carbon energy supply systems and for co-locating potential heat Management Plans. customers and suppliers.’ Government guidance on minerals planning emphasises the importance of The NPPF gives consideration to flood risk alongside ‘climate change’ and ensuring that mineral extraction proposals do not have a significant adverse ‘coastal change’. The following objectives are set: impact on flood flows or flood storage capacity, do not increase the risk of • Avoid inappropriate development in areas at risk of flooding by directing flooding at other properties or locations and, where practicable, increase flood 9 development away from areas at highest risk, or where development is storage capacity . necessary, making it safe without increasing flood risk elsewhere; and • Reduce risk from coastal change by avoiding inappropriate development in vulnerable areas or adding to the impacts of physical changes to the coast. Amongst the more specific points made is the following: ‘When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure.’

7 CLG (2007). Supplement to Planning Policy Statement 1: Planning and Climate Change [online] available at http://www.communities.gov.uk/publications/planningandbuilding/ppsclimatechange (accessed 02/09).

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SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC

Community and Government guidance promotes the development of cohesive and socially The NPPF highlights that: Well-being (including inclusive communities through ensuring accessibility to jobs and services and ‘The Government attaches great importance to the design of the built equalities and mixes of housing tenures10. Government guidance on minerals planning states environment. Good design is a key aspect of sustainable development, is health) the importance of accounting for the value of the wider countryside and indivisible from good planning, and should contribute positively to making landscape, including opportunities for recreation, including quiet recreation, and places better for people.’ as far as practicable maintaining access to land. Similarly, the NPPF identifies the following as a ‘Core Planning Principle’: The Health Act 1999 places a duty of partnership between the health agencies and local authorities to “secure and advance the health and welfare of the ‘Planning should… always seek to secure a good standard of amenity for people”. Government aims to simultaneously improve the health of everyone, existing and future occupants of land and buildings.’ whilst also focusing efforts on improving the health of the worst off in particular. Developments should be located and designed where practical to: create The Waste Framework Directive (91/156/EEC) (WFD) requires Member States safe and secure layouts which minimise conflicts between traffic and of the EU to establish a network of disposal facilities, with Article 4 of the cyclists or pedestrians Directive seeking to ensure that waste is recovered or disposed of without The NPPF also includes a chapter on promoting healthy communities, endangering human health and without using processes or methods which could which identifies that there is a need to achieve the following objectives: harm the environment, and in particular: • • create a built environment that facilitates social interaction and healthy, without risk to water, air, soil and plants and animals; inclusive communities • without causing a nuisance through noise or odours; and • deliver the right social, recreational and cultural facilities and services to • without adversely affecting the countryside or places of special interest. meet local needs; and • ensure access to high quality open spaces and opportunities for sport and recreation that promote the health and well-being of the community. Related to this, it is important to note that the following is identified as a Core Planning Principle: ‘Planning should… take account of and support local strategies to improve health and wellbeing for all.’

8 DEFRA, DfT, ODPM and HM Treasury (2005). Making Space for Water: Taking forward a new Government strategy for flood & coastal erosion risk management [online] available at: http://www.defra.gov.uk/Environ/Fcd/policy/strategy.htm (accessed 02/09) 9 CLG (2006). Minerals Planning Statement 1: Planning and Minerals [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/mineralspolicystatement5 (accessed 02/09) 10 ODPM (2003). Sustainable Communities: Building for the future [online] available at: http://www.communities.gov.uk/publications/communities/sustainablecommunitiesbuilding (accessed 02/09).

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SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC

Economy and Government guidance on sustainable development stresses the importance of a The NPPF states that the ‘economic role’ of planning should involve: Employment strong, stable and productive economy and requires planning authorities to ‘Build[ing] a strong, responsive and competitive economy, by ensuring that ensure that the necessary infrastructure is provided to support new and existing sufficient land of the right type, and in the right places, is available to allow economic development. Accessibility to jobs and services is highlighted as a growth and innovation; and by identifying and coordinating development means of achieving social cohesion and inclusion. requirements, including the provision of infrastructure’ Policy KTG2 of the South East Plan aimed to guide economic growth and The importance of driving a targeted approach to growth is also reflected in regeneration in the Kent Thames Gateway.11 It identified that the local economy the following ‘Core Planning Principle’: should be dynamic and widely based, providing employment for the community as a whole. ‘Planning should… proactively drive and support sustainable economic development to deliver the homes, business and industrial units, Other relevant Government guidance promotes the importance of an economy infrastructure and thriving local places that the country needs. Every effort built on innovation12, including the need to increase skills levels to create a more should be made objectively to identify and then meet the housing, business flexible and productive workforce13. A government White Paper also seeks to and other development needs of an area, and respond positively to wider broaden innovation policy and highlights the role of creating market demand14. opportunities for growth.. Innovation, skills and market demand all represent key considerations for waste management. The appropriate role for planning as a market actor is also helpfully reflected in this Core Planning Principle: Government guidance on minerals planning states the importance of enabling the minerals industry, so far as is practicable, to secure productivity growth and ‘Plans should take account of market signals, such as land prices and high and stable levels of employment15. There is a particular focus on housing affordability, and set out a clear strategy for allocating sufficient maximising the potential for minerals waste to be used for recycling or in-site land which is suitable for development in their area, taking account of the restoration, but if not required for these purposes and where practicable, to needs of the residential and business communities.’ identify a market for its potential use. Within the ‘Planning for Prosperity’ Chapter of the NPPF, the objective of ‘sustainable economic growth’ is identified, by which it is meant growth that builds on inherent strengths. It is identified that sustainable economic growth will often involve restructuring the economy, and will also mean growth that enables a low carbon future. The Chapter goes on to identify that, to achieve sustainable economic growth, there is a need to: • plan proactively to meet the development needs of business…; • promote the vitality and viability of town centres…; and • create jobs and prosperity in rural areas by promoting a strong, growing, rural economy

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SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC

Heritage Government guidance on the historic environment states that ‘The physical Within the ‘Historic Environment’ Chapter, the NPPF calls upon planning survivals of our past are to be valued and protected for their own sake, as a authorities to recognise ‘heritage assets as irreplaceable resources’ and central part of our cultural heritage and our sense of national identity.’ It also presents the following objectives: highlights the importance of protecting listed buildings and their settings; • Conserve heritage assets in a manner appropriate to their significance; considering the quality of conservation areas as a whole; considering Registered and Parks and Gardens; and taking account of the wider costs of transport choices on the historic environment16. • Contribute to our knowledge and understanding of our past by capturing Separate guidance focuses on the need to reconcile development pressures evidence from the historic environment and making this publicly with the interests of archaeology, emphasising the principle of early assessment, available, particularly where a heritage asset is to be lost. that development proposals take into account archaeological interest, and that The Chapter emphasises the importance of taking a strategic approach to important remains are preserved in situ17. the conservation and enjoyment of the historic environment, taking into Government minerals planning guidance identifies impacts relating to account: the desirability of sustaining and enhancing the significance of ‘archaeological and heritage features’ as a potential ‘principle environmental heritage assets; the wider social, cultural, economic and environmental impact’ of minerals working. However, guidance also highlights that small benefits that conservation of the historic environment can bring; and the quarries can play an important role in providing historically authentic building desirability of new development making a positive contribution to local materials. There is also a growing realisation that minerals extraction can character and distinctiveness. produce unique archaeological information. The need to give an integrated consideration to landscape and heritage issues is reflected in the NPPF, which (within the ‘Natural Environment’ Chapter) highlights that ‘The conservation of wildlife and cultural heritage are important considerations in [areas of landscape importance]’. Similarly, the Chapter highlights the importance of ‘maintain[ing] the character of the undeveloped coast, protecting and enhancing its distinctive landscapes, particularly in areas defined as Heritage Coast, and improve[ing] public access to and enjoyment of the coast.’

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SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC

Housing The Government’s key housing policy goal is to ensure that everyone has the An early chapter of the NPPF highlights that planning should have a ‘social opportunity of living in a decent home, which they can afford, in a community role’ that: where they want to live. Government guidance seeks to deliver on the ‘Support[s] strong, vibrant and healthy communities, by providing the commitment to improving the affordability and supply of housing in all supply of housing required to meet the needs of present and future communities by providing a step-change in housing delivery, achieved through a generations; and by creating a high quality built environment, with more responsive approach to land supply at local level. The guidance also accessible local services that reflect the community’s needs and support its states that 60% of new housing should be on previously developed land and health, social and cultural well-being’. seeks to ensure that the planning system delivers18: • In the ‘Core planning principles’ the NPPF notes that ‘Every effort should High quality housing that is well-designed and built to a high standard; be made objectively to identify and then meet the housing, business and • A mix of housing, both market and affordable, particularly in terms of tenure other development needs of an area.’ and price, to support a wide variety of households in all areas, both urban Within the Chapter ‘Planning for People’, the NPPF then emphasises the and rural; importance of: • A sufficient quantity of housing taking into account need and demand and • increasing the supply of housing; seeking to improve choice; • widening opportunities for home ownership; • Housing developments in suitable locations, which offer a good range of community facilities and with good access to jobs, key services and • delivering a wide choice of high quality homes that people want and infrastructure; and need; and • A flexible, responsive and efficient supply of land. • creating sustainable, inclusive and mixed communities, including through the regeneration and renewal of areas of poor housing.

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SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC

Land Government guidance on minerals planning19 identifies impacts relating to Local authorities should: ‘nationally protected geological and geomorphological features’ as a ‘principal ‘Take into account the economic and other benefits of the best and most environmental impact’ of minerals working20. Guidance promotes efficient use of versatile agricultural land. Where significant development of agricultural land and also emphasises the after uses opportunities of mineral workings, land is demonstrated to be necessary, local planning authorities should including the achievement of UK Geodiversity Action Plan targets. Guidance seek to use areas of poorer quality land in preference to that of a higher also refers to protecting the coastal environment from increased erosion or quality’. vulnerability to flooding21. Local authorities should ensure that substantial weight is given to any harm Government guidance on planning for waste management recognises the need to the Green Belt. The following would be acceptable: to protect Green Belt, but also recognises that the particular locational needs of some types of waste management facilities may be suited to such locations22. • buildings for agriculture and forestry; Government waste planning guidance also promotes the re-use of previously- • the extension or alteration of a building provided that it does not result in developed land, and redundant buildings where possible and also identifies ‘land disproportionate additions over and above the size of the original stability’ as a key locational criterion. building; Government guidance sets out the objective of taking a strategic approach to the • conservation, enhancement and restoration of geology through the form and the replacement of a building; 23 location of development . Additionally, Government guidance on sustainable • limited infilling or the partial or complete redevelopment of previously development in rural areas indicates that high quality agricultural land should developed sites (brownfield land), whether redundant or in continuing 24 where possible be protected from irreversible damage . use (excluding temporary buildings), which would not have a greater The 2006 EC Thematic Strategy for Soil seeks the protection, sustainable use impact on the openness of the Green Belt and the purpose of including and restoration of soil; and the maintenance of full soil functions. A draft Soil land within it than the existing development. Strategy for England was prepared and issued for consultation in March 2008. Certain other forms of development are also appropriate in Green Belt This will succeed the First Soil Action Plan for England, which sought to maintain provided they preserve the openness of the Green Belt and do not conflict the quantity, diversity and quality of the nation’s soils with the purposes of including land in Green Belt. These include: • mineral extraction; • engineering operations; • local transport infrastructure which can demonstrate a requirement for a Green Belt location.

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SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC

Landscape In 2006, the UK ratified the European Landscape Convention (ELC)25. Natural Under the heading ‘Conserving and enhancing the natural environment’, England is leading its implementation in England and states that: the NPPF emphasises the importance of ‘protecting and enhancing valued landscapes’; planning positively for the creation, protection, enhancement ‘The ELC argues that the protection, management and planning of all and management of networks of biodiversity and green infrastructure; and landscapes in Europe is a task, not just for governments, but for all sectors of 26 maintaining the character of the undeveloped coast and improving public civil society, entailing rights and responsibilities for everyone’ . access to and enjoyment of the coast Government guidance on minerals planning identifies impacts relating to The NPPF also states that authorities should set criteria based policies landscape character and visual intrusion into the local setting and the wider against which proposals for any development on or affecting protected landscape as two potential ‘principle environmental impacts’ of minerals 27 wildlife sites or geodiversity sites or landscape areas will be judged. working . The Kent Downs and High Weald Areas of Outstanding Natural Distinctions should be made between the hierarchy of international, Beauty Management Plans set out policies to prevent inappropriate development national and locally designated sites. and to promote good design that is integrated into the landscape. Minerals Minerals Policy Statement 1 states the importance and benefits of local minerals The NPPF includes a chapter dedicated to presenting policy for ‘Minerals’. supply28. Local land-won aggregates can support the local economy and help The overarching objectives are to: reduce carbon emissions by minimising transportation distances. Although self- • secure an adequate and steady supply of indigenous minerals needed sufficiency of supply is desirable, in practice it may be unachievable at either to support sustainable growth, whilst encouraging the recycling of regional or local level due to the influence of local geology. suitable materials to minimise the requirement for new primary It is recognised that there are other minerals worked in the region which extraction; and contribute to the local economy and character. These are worked on a smaller • scale and have fewer impacts than those extracted on a larger scale. These can ensure that there are no unacceptable adverse impacts on the natural play an important role in providing historically authentic building materials for and historic environment, human health or aviation safety; and 29 cultural and historic buildings and structures . • facilitate sustainable use of energy minerals. Import and processing facilities, especially in waterfront locations, are often under pressure for development for other higher value uses such as housing. It is important that these resources are not sterilised or lost as they make an important contribution towards meeting Kent's mineral needs30. It is important to emphasise the importance of mineral importation in Kent, and in particular marine importation.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC

Rural Areas Government guidance on rural areas has a focus on the particular needs of rural Under its ‘Core planning principles’ the NPPF calls upon planning to economies. It sets the objective of developing competitive, diverse and thriving ‘recognis[e] the intrinsic character and beauty of the countryside and rural enterprise that provides a range of jobs and underpins strong economies31. suppor[t] thriving rural communities within it’. At the same time, it sets the objective of ensuring good quality, sustainable The Government’s objective in relation to ‘Supporting a prosperous rural development that respects and, where possible, enhances local distinctiveness economy’ is to ‘support economic growth in rural areas in order to create and the intrinsic qualities of the countryside. Rural authorities are tasked with jobs and prosperity by taking a positive approach to sustainable new taking due care when determining the location of employment sites in rural development.’ areas. Planning strategies should maintain a prosperous rural economy including through: • supporting the sustainable growth of rural businesses; • promoting the development and diversification of agricultural businesses; • supporting sustainable rural tourism and leisure developments; and • promoting the retention and development of local services and community facilities.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC

Transport Government guidance relating specifically to transport promotes the integration The NPPF points out that transport policies have an important role to play of planning and transport at the national, regional, and local levels to promote in facilitating sustainable development, and wider sustainability and health more sustainable transport choices32. Of particular relevance to minerals and objectives. It calls for plans to ‘protect and exploit opportunities for the use waste, it states that land use planning should facilitate a shift in transport of of sustainable transport modes’. freight to rail and water; attention should be paid to the value of disused In the case of developments which generate ‘significant movements’, plans transport sites; and traffic management should be designed to reduce and decisions should ensure that they are located where ‘the need to travel environmental/social impacts. will be minimised and the use of sustainable transport modes can be The Highways Agency (HA) cautions that the MWDF should not rely upon the maximised’, whilst taking into account policies elsewhere in the framework, provision of additional capacity on the Strategic Road Network (SRN). Whilst particularly within rural area. individually, small minerals and waste sites are unlikely to produce a significant The NPPF also highlights that transport policies should provide impact on the SRN, in combination they may become materially significant. In encouragement ‘to solutions which support reductions in greenhouse gas particular, waste transportation has the potential to generate a significant emissions’. number of HGV trips. Therefore, the HA seeks to support measures which ensure close proximity between waste disposal sites and sources of waste. Government guidance on minerals planning identifies impacts relating to ‘traffic’ as a potential ‘principal environmental impact’ of minerals working, and promotes33 recognition of the need to improve transportation within and from sites so as to minimise impacts to nearby receptors (taking account of the benefit of supplying minerals locally); and transport by rail and water where feasible, including through identifying and safeguarding potential loading and unloading depots and wharves.

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SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC

Waste Government guidance describes the pivotal role of ‘positive planning’ in The NPPF highlights the need to deliver waste infrastructure alongside providing sufficient opportunities for new waste management facilities of the right infrastructure needed for transport, minerals, energy, telecoms, water type, in the right place and at the right time34. The UK Waste Strategy (2007) supply and water quality. sets out the Government’s vision of a waste collection and treatment infrastructure35. This includes recovering electricity and heat from waste where appropriate, better joining up between municipal and private sectors to enable the provision of local as well as regional facilities and properly managed landfill. The Kent Joint Municipal Waste Management Strategy does not include information on specific sites; however, it does include some policies that are of some relevance. Transfer station network are to be improved across Kent to promote the efficient transport of wastes for treatment, recovery and disposal. Kent will also procure landfill capacity to meet the need for the disposal of residual waste for which recovery capacity is not contracted, and will work to secure composting capacity. Waste management facilities should not be precluded from the Green Belt and small-scale waste management facilities for local needs should not be precluded from Areas of Outstanding Natural Beauty where the development would not compromise the objectives of the designation

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SUSTAINABILITY KEY MESSAGES FROM THE 2010 SCOPING REPORT KEY MESSAGES FROM THE NPPF (2012) TOPIC

Water A key driver, in terms of water quality, is the EU Water Framework Directive The NPPF identifies the importance of providing infrastructure for water (WFD), which requires that all inland and coastal waters reach ‘good ecological supply and water quality alongside infrastructure for transport, minerals, status’ by 201536. River Basin Management Plans and Catchment Abstraction waste, energy and telecoms. Management Strategies (CAMS) will contribute to achievement of WFD It also gives consideration to water quality under the objective: Preven[t] objectives. A key objective of CAMS is to achieve a sustainable balance both new and existing development from contributing to or being put at between the water needs of abstractors and of the environment. unacceptable risk from, or being adversely affected by unacceptable levels Also of relevance is the Groundwater Directive (2006/118/EC) which prohibits of land, air, water or noise pollution or land instability. the direct or indirect pollution of groundwater. The Environment Agency has No reference is made within the NPPF to the issue of achieving water defined Source Protection Zones for 2000 groundwater sources such as wells, efficiency through building design measures, although the it does call upon boreholes, and springs used for public drinking water supply37. local planning authorities to ‘adopt proactive strategies to mitigate and Government guidance on planning and pollution control states that the planning adapt to climate change, taking full account of flood risk, coastal change system plays a key role in determining the location of development which may and water supply’. give rise to pollution, either directly or indirectly but that planning must also be sure to integrate closely with wider pollution control regimes38. Government guidance on minerals planning identifies both impacts relating to ‘groundwater’ and ‘surface water’ as ‘principal environmental impacts’ of minerals working39. The guidance promotes consideration of the potential for mineral developments, individually or cumulatively, to affect the flow, quality and quantity of surface and groundwater supplies and the water table. It promotes the use of best available options to prevent pollution from leachate.

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4 WHAT’S THE SITUATION NOW?

“the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” “the environmental characteristics of areas likely to be significantly affected” (SEA Directive Annex I (b) & (c))

4.1 Introduction

An important step when seeking to establish the appropriate ‘scope’ of a Sustainability Appraisal involves reviewing ‘baseline conditions’ for a range of sustainability issues. Doing so helps to enable identification of those key sustainability issues that should be a particular focus of the appraisal, and also helps to provide ‘benchmarks’ for the appraisal of significant effects.

A review of the sustainability ‘baseline’, in relation to strategic minerals and waste planning in Kent, was undertaken in late 2009 / early 2010 with findings set out within the ‘Kent MWDF SA Scoping Report’. The purpose of this chapter is to present some selected information in order to give a ‘flavour’ of the baseline situation.

4.2 Selected messages from the baseline review

Environmental baseline

Although it is not easy to pick out detail from Figure 4.1, it does serve to highlight some key spatial trends in terms of the environmental baseline. For example, within Kent: • Natura 2000 habitat is concentrated around the coast, particularly around the Thames Gateway (much within Medway UA), The Isle of Thanet and the Stour Estuary and Dungeness. • The Kent Downs AONB covers nearly a quarter of the County, whilst the High Weald AONB is shared with East Sussex. • There are relatively extensive areas of high quality (grade one) agricultural land. • Sites of Special Scientific Interest (SSSI) cover 8.5% of the county and the county has about 10% of the national resource of ancient woodland. • Approximately 10% of Kent’s population lives within an area of identified flood risk.

One spatial variable not shown on the map is the extent of groundwater South Protection Zones (SPZs). In Kent, these are primarily associated with the chalk geology of the North Downs, but that there are also some smaller SPZs in the vicinity of Tonbridge and Tunbridge Wells.

Another is listed buildings. What is known is that the South East has more listed buildings than any other region other than the South West, and Kent has significantly more that any other South East county (17,205). A relatively low amount of these are found in Medway, Dartford, Gravesham Shepway and Thanet.

Green Belt is another important spatial constraint as it represents land that should be kept open in order to achieve the purposes set out within National Policy. In Kent, Green Belt comprises the majority of Sevenoaks, Tonbridge and Malling and Gravesham Districts, as well as a proportion of Tunbridge Wells and Dartford Districts.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

Figure 4.1: Key spatial constraints within Kent

Socio-economic baseline

Over the ten year period 1997-2007 the population of Kent rose by 7%. Kent also has an older age profile than the national average. Kent has the largest rural population of any county in the South East (29%) and identified problems of ‘rural deprivation’, e.g. associated with access to services, facilities and affordability of housing. Sevenoaks and Dover having the strongest rural elements, whilst the vast majority of rural areas in Kent are best described as ‘less sparse’ .

In terms of the Index of Multiple Deprivation, Kent ranks 102nd out of 152 county and unitary authorities, placing it within England’s least deprived third of authorities. In 2007 the KCC area ranked 106th. A move of four positions up the national ranking in IMD2010 means that relative to other areas, Kent is more deprived in IMD2010 than it was in IMD2007.

Districts in east and north Kent are more deprived than those districts located in the west and south of the county. Thanet is Kent’s most deprived district and is ranked 49th out of 326 authorities in England placing it within England’s 20% most deprived authorities (the only Kent district within this quintile). Sevenoaks is Kent’s least deprived district and is ranked 276th out of 326 authorities in England placing it within England’s 20% least deprived authorities along with Tonbridge & Malling (ranked 268th). Shepway has seen the greatest increase moving from national rank 114th (out of 326) to rank 97th in IMD2010. Deprivation levels have decreased in four Kent districts, relative to other areas in England. Tonbridge & Malling has seen the greatest decrease moving from national rank 256th to rank 268th in IMD2010.

As shown by Figure 4.2, 11% of Kent’s LSOAs (94 areas) are amongst England’s most deprived 20% in IMD 2010. This is 16 more areas than there were in IMD 2007 (78 areas). The most deprived LSOA within Kent based on the overall IMD for 2010 is Thanet 003A within Margate Central ward. Within the same ward, the most deprived LSOA in ID2007 was Thanet 001E.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

Figure 4.2: National rank of Lower Super Output Areas (LSOAs) in Kent based on the Index of Multiple Deprivation 2010

N.B. More detailed information about deprivation within Kent can be found @ http://www.kent.gov.uk/your_council/kent_facts_and_figures/deprivation/id2010.aspx.

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Waste and minerals sites ‘baseline’

Finally, as part of the baseline review, it is important to consider the location of existing waste and minerals sites. Whilst it is not possible to infer that existing sites will be associated with effects that have resulted in the local environmental or socio-economic baseline becoming more sensitive to further development, it is known that sites can have significant ‘cumulative’ effects on a local area (i.e. although a single site on its own may not result in a significant effect, a significant effect can result from more than one site). This can be particularly the case for road transport effects (and associated knock on effects, for instance relating to air quality).

The County Council has an accurate and up-to-date record of existing (and recently closed) waste and minerals sites. Maps can be found within the Minerals and Waste Development Framework Annual Monitoring Report (AMR) @

http://www.kent.gov.uk/environment_and_planning/planning_in_kent/minerals_and_waste/ann ual_monitoring_report.aspx.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

5 WHAT WOULD THE SITUATION BE WITHOUT THE PLAN?

“the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” (Annex I(b))

5.1 Introduction

Just as its important for the scope of SA to be informed by an understanding of current baseline conditions, its also important to ensure that thought is given to how baseline conditions might ‘evolve’ in the future under the ‘no plan’ / ‘business as usual’ scenario. A review of the likely situation without the plan is presented within the Kent MWDF SA Scoping Report (2010).

Readers should refer to the Scoping Report for a detailed review of the likely future without the plan. The aim of this chapter is to update/enhance our understanding slightly by presenting a brief review of measures planned and prioritised by local authorities for their areas. In particular, set out below is a review of the number of houses planned for each of the local authority areas.

5.2 A brief review of local authority housing targets

Local Housing targets Notes Authority Dartford The adopted Core Strategy (2011) sets 17,140 are allocated to the Thames Gateway a target of 867 dwellings per annum. area, whilst the remaining 200 are allocated to the rural area south of the A2. Sevenoaks The adopted Core Strategy (2011) sets Focused entirely within existing built up areas a target of 165 dwellings per annum. (predominantly Sevenoaks), enabling the Green Belt to be maintained. Tonbridge and Provision is made for the development Concentrated within the confines of the urban Malling of at least 425 dwellings per annum. areas of: Tonbridge; the Medway Gap; and the part of the Medway Towns urban area that lies within the Borough. Gravesham Consultation on growth scenarios finished on 22 December 2011. The Council reports that 90% of respondents favoured the ‘long term migration trend’ scenario, which would involve delivering significantly less housing than was envisaged for the borough by the South East Plan. Tunbridge The adopted Core Strategy (2010) sets Concentrated at Royal Tunbridge Wells and Wells a target of 300 dwellings per annum. Southborough to support the ‘Regional Hub’ role within Tonbridge. Medway The Submission Draft of the Core Focused in the Thames Gateway. Only around Strategy (2012) suggests a target of 624 units in total are expected to be built in the 814 dwellings per annum. ‘rest of’ area (much of which will be a the former Cemex cement plant at Halling) Maidstone A consultation draft of the Core Strategy Focused within and next to Maidstone‟s urban (2011) suggested a target of 540 area dwellings per annum. Swale A consultation draft of the Core Strategy Focused at Sittingbourne (53%), (2012) suggests a target of 520 Sheerness/Minster (21%), Faversham (12%) dwellings per annum. and the eastern rural area (13%).

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

Ashford The adopted Core Strategy (2011) sets 93% focused on the Ashford Growth Area, a target of 1093 dwellings per annum. A review is underway. Canterbury Does not have an adopted Core Strategy. A Local Plan is now in development, with adoption expected in 2014. Shepway The Submission Draft of the Core Focused at Folkestone and Hythe and the Strategy (2012) suggests a target of ‘strategic corridor’ to the west of the towns. 400 dwellings per annum. Dover The adopted Core Strategy (2011) sets 70% focused at Dover, 10% at Deal, 7% at a target of 700 dwellings per annum. A Aylesham and 5% at Sandwich. review is underway. Thanet Thanet does not have an adopted Core Strategy. A 2010 consultation sought views on a housing figure of 375 dwellings per annum (as per the South East Plan target).

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6 WHAT ARE THE KEY ISSUES THAT SHOULD BE A PARTICULAR FOCUS OF THE APPRAISAL?

“any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC [Special Protection Areas under the Birds Directive] and 92/43/EEC” (Annex I(d)) (Note impacts on European sites will be specifically addressed through Habitats Regulations Assessment)

6.1 Introduction

Drawing on the review of the sustainability context and baseline, the 2010 SA Scoping Report was able to identify a range of sustainability issues and objectives. The objectives have been drawn-on and used as a methodological ‘framework’ for the appraisal presented within the subsequent chapter ‘What are the appraisal findings and recommendations at this current stage’.

Table 6.1 considers, for each topic, selected sustainability issues highlighted by the 2010 Scoping Report (recognising that some of the issues identified are of limited relevance to this appraisal given the scope of the Sites DPDs). Table 6.2 then presents the 2010 sustainability ‘objectives’ in full.

6.2 Key issues and objectives (2011) Table 6.1: Sustainability issues Selected key issues from the 2010 SA Scoping Report

Air quality • Traffic on the motorway and A-road network is the cause of the majority of designated Air Quality Management Areas (AQMAs) • Future development at existing population centres is likely to put further pressure on the road network, and lead to new and worsened occurrences of poor air quality. • There remain instances where point source air pollution is a strategic issue

Biodiversity • Ambitious BAP targets have been set, including for habitat recreation and for reducing fragmentation / improving connectivity. Landscape scale projects are underway with biodiversity conservation and access to biodiversity as central components. • It is possible to increase the connectivity between important habitat patches by incorporating habitat creation as part of new development. There is a particular need to maximise the biodiversity benefits associated with restoration of minerals sites.

Climate change • There is the potential to promote energy from waste as well as other technologies that increase the energy efficiency of minerals and waste operations. • There is extensive flood risk in Kent, and this situation is set to become worse with climate change.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

Community and • Clear spatial variation across Kent exists in terms of income, employment and health well-being deprivation. • Rural deprivation is also a recognised problem, for example for the Isle of Sheppey and the Romney Marsh area. • Aspects of deprivation is focused amongst particular socio-economic groups, for example Gypsies and travellers. • At the Examination in Public into the Partial Review of the South East Plan (Policy MP3 - Aggregates) a number of local authorities presented evidence of local community impacts associated with the proximity of quarries and also lorry movements.

Economy • There area ambitious plans for economic regeneration, for example in East Kent and the Kent Thames Gateway. • There are local disparities in economic activity (including problems of ‘rurality’)

Heritage • The need to take account of designated heritage assets and their settings as well as undesignated assets and wider historic character

Land and • There is a need to make best use of previously developed land and avoid the loss of geology the county’s best and most versatile agricultural land. There is also a need to avoid conflict with coastal geomorphology

Landscape • There is a need to protect the integrity of the most valued and sensitive landscapes as well as to avoid damage to the landscape character more widely (signs of change inconsistent with countryside character have been identified in several areas). • Along with a loss of the distinctiveness of the landscape character there has been a noticeable decrease in the tranquillity of landscapes and landscapes that are genuinely ‘wild and remote’. • Specific landscape impacts can be associated with minerals and waste development. Appropriate restoration should be sought to mitigate effects.

Transport • Much of the primary road network operates at, or above, capacity and there is a shortage of freight paths on the rail network. • There is a need to adhere to the proximity principle wherever possible. • There is a need to increase the amount of waste and, in particular, minerals transported by rail or inland waterway. • The RSS set out to improve the transport infrastructure within and to the Thames Gateway to maximise regeneration potential, East Kent to support economic regeneration and Ashford to support development. The Kent MWDF should recognise and support the aims of regional hubs.

Waste • There is a need to divert waste from landfill and seek to maximise the value of waste as a resource

Water • Water scarcity is set to become a greater problem in coming as a result of population growth, climate change and the need to comply with the requirements of the Water Framework Directive. • Groundwater pollution from a range of sources is evident across much of Kent. • Minerals and waste operations will have varying potential to lead to significant pollution of surface, coastal and estuarine waters.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

Table 6.1: Sustainability objectives

OBJECTIVE SUB-OBJECTIVE

Reduce the risk of flooding and the Ensure that development does not lead to increased flood risk on or off site resulting detriment to public wellbeing, the economy and the Seek to mitigate or reduce flood risk through developments that are able to slow environment water flow and promote groundwater recharge

Ensure that development will not Add to the biodiversity baseline by creating opportunities for targeted habitat impact on important elements of the creation (which, ideally, contributes to local or landscape scale habitat networks). biodiversity resource and where possible contributes to the Avoid hindering plans for biodiversity conservation or enhancement achievement of the Kent Support increased access to biodiversity Biodiversity Action Plan and other strategies Protect and enhance Kent’s Protect the integrity of the AONBs and other particularly valued or sensitive countryside and historic landscapes environment Take account of the constraints, opportunities and priorities demonstrated through landscape characterisation assessments and other studies at the landscape scale. Protect important heritage assets and their settings, as well as take account of the value of the character of the wider historic environment Maintain and improve the water Ensure that minerals and waste development seeks to promote the conservation quality of the Kent’s rivers, ground of water resources wherever possible waters and coasts, and achieve sustainable water resources Avoid pollution of ground or surface waters, particularly in areas identified as management being at risk or sensitive Address the causes of climate Recover energy from waste where possible change through reducing emissions of greenhouse gases through energy efficiency and energy Promote sustainable design and construction of facilities and support wider efforts generated from renewable sources to reduce the carbon footprint of minerals and waste operations. Reduce and minimise unsustainable Minimise minerals and waste transport movements, journey lengths and transport patterns and facilitate the encourage transport by rail and water. transport of minerals and waste by the most sustainable modes Ensure that minerals and waste transport does not impact on sensitive locations, possible including locations already experiencing congestion and locations where planned growth or regeneration is reliant on good transport networks. Ensure that minerals and waste development does not contribute to poor air quality Plan for the correct waste Put in place the facilities and infrastructure that will support integrated waste management facilities, in the right management and move waste management up the waste hierarchy place at the right time Minimise potential negative effects associated with waste management facilities Support self sufficiency where possible Make efficient use of land and avoid Make best use of previously developed land sensitive locations Avoid locations with sensitive geomorphology

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Support efforts to create and Help to redress spatial inequalities highlighted by the Index of Multiple deprivation sustain sustainable communities, and other indicators. particularly the improvement of health and well-being Help to tackle more hidden forms of deprivation and exclusion, such as that which is experienced by residents of rural areas and particular socio-economic groups within communities. Take account of locally specific issues associated with rurality. Support the delivery of housing Ensure that minerals and waste development does not act as a constraint to targets housing Ensure that the necessary aggregates are available for building, and that the necessary waste infrastructure is in place Support economic growth and Support the development of a dynamic, diverse and knowledge-based economy diversification that excels in innovation with higher value, lower impact activities Stimulate economic revival and targeted employment generation in deprived areas

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7 HOW HAS THE PLAN DEVELOPED UP TO THIS POINT?

“an outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information” “the environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation” (SEA Directive, Annex I (h) & (e))

7.1 Introduction

Chapter 1 has already explained that this report is an ‘Interim’ SA Report, published for consultation alongside the ‘Preferred Options’ versions of the Minerals and Waste Sites DPDs in order to A) provide information to those who might wish to make representations during the consultation period; and B) provide information to the Council, who will be able to take this on- board when drafting the next version of the plan document. The purpose of this chapter is to explain the reasoning behind the plan-making steps taken up to this point (i.e. up to the point of selecting preferred options), including the influence of SA.

7.2 Selecting preferred options

The Call for Sites was formally open between 24 May and 29 October 2010 and received nearly 100 site submissions. A small number of late submissions were also received in 2011. All sites received were published as part of the ‘options’ consultation. An appraisal of all sites was also undertaken at this stage, with findings published within Interim SA Reports.

Subsequent to the options consultation, the Council has selected preferred options taking into account the following: • Call for Sites submission form information • Relevant national and regional planning policy • The emerging Minerals and Waste Core Strategy and supporting evidence base. • Consultation comments from Kent County Council's internal consultees including Biodiversity, Highways and Archaeology. Consultation comments from key external consultees, such as the Environment Agency, Natural England, Highways Agency and District Councils. • Consultation comments from Parish Councils, residents and community/special interest groups. – Over 3,000 responses were received from members of the public and the County Council's external and internal consultees. The comments were summarised into consultation commentary reports • Site visits to record issues such as the views of the site from a distance, adjoining land uses and current access conditions. • GIS mapping data that ascertains proximity to environmental designations or sensitive receptors such as schools. • Sustainability Appraisal (SA) and Habitats Regulation Assessment (HRA).

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Influence of the options SA

In-line with SA findings, the approach taken to the identification of preferred options has involved: • Rejecting sites which are likely to give rise to significant adverse impacts upon national and international designated sites, including AONB, SSSIs, SACs, SPAs, Ramsar sites, Ancient Monuments and registered Historic Parks and Gardens. – One exception to this approach is Minerals Site 24: Land North of Addington Lane, situated within the AONB, which is preferred option for its nationally important silica sand mineral, which makes up two thirds of the sand resources within the site. • Rejecting sites which would be likely to give rise to a significant adverse impact upon Local Wildlife Sites (LWS), Local Nature Reserves (LNR), Ancient Woodland and groundwater resources. • Rejecting sites which are not well located in relation to Kent's major road network, and also those which would give rise to significant numbers of lorry movements through villages or on unacceptable stretches of road.

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8 HOW HAS THE APPRAISAL AT THIS CURRENT STAGE BEEN UNDERTAKEN?

“an outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information” (Annex I(h))

8.1 Introduction

This Chapter explains the approach that has been taken to undertaking the appraisal, the findings of which are presented subsequently (within Chapter 9).

8.2 A methodological approach based on clear assumptions

Although all site options have already been the subject of appraisal (with findings presented within the Interim SA Reports published at the time of the options consultations) it was thought necessary to re-appraise all sites, following a different (improved) methodological approach.

When developing the methodology, a starting point was the need to appraise each site option (taking into account the type of development proposed) in terms of the sustainability issues / objectives established through scoping (see Chapters 3 - 6). However, data gaps mean that, for a number of issues/objectives, appraising the performance of sites is a challenge - see Box 8.1.40 Box 8.1: Methodological challenges associated with strategic site appraisal Although, for most issues/objectives, we have a good understanding of how the baseline situation varies (and the degree to which problems/opportunities vary) at a broad spatial scale (and we might also have an understanding of particular problems/opportunities associated with discrete areas); for many issues/objectives it has not been possible to collect evidence to understand the how the baseline situation varies (and the degree to which problems/opportunities vary) ‘continuously’ across the County at a spatial resolution that enables the performance of site options to be differentiated.

Given the data that is available it has been possible to categorise (see Table 8.1) the performance sites in terms of the SA objectives drawing on a set of assumptions (Table 8.2).

It is important to emphasise that the ‘assumptions based approach’ to appraisal that has been followed is limited in terms of what has been taken into account. Essentially, what has been appraised is a proposed use at a given site only. Little or no account has been taken of the detailed approaches proposed for given sites.

Given SEA Directive requirements, it is also important to note that the scoring rules were developed, as far as possible, to ensure that account is taken of the potential for effects to be: • direct/in-direct; • of varying magnitudes; • felt over varying spatial extents; • cumulative; • short/medium/long-term; and • permanent / temporary.

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Table 8.1: Effects categories Symbol Significant positive effect ++ Some positive effect + No effect 0 Some adverse effect - Significant adverse effect -- Uncertain effect ?

Table 8.2: Assumptions underpinning the appraisal of sites

OBJECTIVE ASSUMPTIONS USED TO APPRAISE EFFECTS COMMENTS

Reduce the risk of • Mineral extraction in flood zones 2 & 3a = (+) • In flood zones 2 & 3a mineral extraction sites are water compatible flooding and the resulting • Sand & grave extraction in flood zone 3b = (+) and can help to reduce the flood risk faced by nearby communities by detriment to public providing additional storage for flood waters. • Non-sand & gravel minerals extraction in flood zone 3b = (--) wellbeing, the economy • Sand & gravel workings are compatible with flood zone 3b. and the environment • Waste facility in flood zone 2 = (-) • In practice, there is much potential to mitigate flood risk through the • Waste facility, excluding landfill or hazardous waste, in flood zone 3a = incorporation of sustainable drainage systems. (-) • Landfill or hazardous waste facility in flood zone 3a = (--) • All waste facilities in flood zone 3b = (--)

Ensure that development • Site within 200m of a designated site of international, national or local • In practice, there is much potential to avoid and mitigate effects where will not impact on importance, or an area of ancient woodland = (-) a waste or minerals site is located in close proximity to an important important elements of the • Site adjacent to or situated on a designated site of international, biodiversity site. Indeed biodiversity enhancements on minerals sites biodiversity resource and national or local importance, or an area of ancient woodland = (--) can be beneficiaries to wider biodiversity. where possible contributes to the achievement of the Kent Biodiversity Action Plan and other strategies

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Protect and enhance • Site located within an AONB = (--) • Waste sites are generally unsuitable for the Green Belt; although if Kent’s countryside and • Site within 200m of an AONB = (-) situated on brownfield land a judgement on whether they are have a historic environment greater effect than the existing use must be made. • SAMs or listed buildings on site, or if the site is within a historic park • and garden = (--) Sites which have archaeological potential could have positive or negative effects, dependent on the management of excavations. • Site is located within 100m of a SAM, listed building, or historic park • and garden = (-) The effect of individual developments on the countryside and historic environment can be influenced by a number of factors, including lines • Site with archaeological potential = (?) of sight. As such, in practice there is much potential to avoid and • Mineral site located on greenfield land within Green Belt = (-) mitigate effects where minerals and waste sites and sensitive features • Waste site located on brownfield land within Green Belt = (-) are in close proximity. • Waste site located on greenfield land within Green Belt = (--)

Maintain and improve the • Waste facility, excluding landfill or hazardous waste, in SPZ 2 or 3 = • The EA has advised that there is no objection to non-landfill waste water quality of the (0) management uses in Source Protection Zone (SPZ) 2 or 3, and to Kent’s rivers, ground • Waste facility, excluding landfill or hazardous waste, in SPZ 1 = (-) existing sites which are in SPZ 1. waters and coasts, and • • Landfill or hazardous waste site in SPZ 2 or 3 = (-) New non landfill waste management sites in SPZ 1 may have a achieve sustainable water negative effect on water quality due to accidental pollution incidents. resources management • Landfill or hazardous waste site in SPZ 1 = (--) • Minerals extraction and landfill or hazardous waste sites in SPZ 2 or 3 • Minerals extraction in SPZ 2 or 3 = (-) could potentially lead to some negative effects on water quality due to • Minerals extraction in SPZ 1= (--) accidental pollution impacts, whilst in Source Protection Zone 1 the effects of such incidents may be significantly negative. • In practice, there is much potential to avoid and mitigate effects through onsite design and management measures.

Address the causes of • Data limitations prevent an appraisal of sites in terms of this objective. climate change through reducing emissions of greenhouse gases through energy efficiency and energy generated from renewable sources

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Reduce and minimise • Data limitations prevent an appraisal of sites in terms of this objective. If data becomes available (to enable a consistent appraisal of sites that unsustainable transport highlights the relative merits of alternative sites) then this will be drawn on to appraise sites against this objective at the Proposed Submission / SA patterns and facilitate the Report stage. transport of minerals and waste by the most sustainable modes possible Plan for the correct waste • There are no criteria by which it is possible to determine the degree to which a potential waste site is located ‘in the right place’. management facilities, in the right place at the right time Make efficient use of land • Waste site (excluding landfill) that would result in loss of grade 1 or 2 • Waste sites that would result in the loss of grade 1 or 2 agricultural and avoid sensitive agricultural land = (--) land may have a significant negative effect, as the loss of this high locations • Minerals or landfill site that would result in loss of grade 1 or 2 quality land does not represent efficient usage. Minerals and landfill agricultural land = (-) sites score a lesser negative effect, due to the potential for their restoration • Site located on previously developed, brownfield land = (++)

Support efforts to create • Site within 100m of a dwelling = (-) • Sites which are within, adjacent, or close to an Air Quality and sustain sustainable • Site within within 50m = (--) Management Area (AQMA) may have a negative effect if they result in communities, particularly air pollution directly or indirectly as a result of increased traffic. • Site within or adjacent to an AQMA = (--) the improvement of health • In practice, there is much potential to mitigate effects on health and • and well-being Site within 200m of an AQMA = (-) well-being, although it may be possible to avoid effects all together as • Site adjacent to, or crossed by a footpath (public right of way) = (--) the public perception of waste and minerals development is almost • Site within 50m of a footpath = (-) always poor. Where sites are in close proximity to sensitive receptors, onsite design and management measures can reduce pollution (e.g. noise, odour and dust), whilst careful management of traffic will be another important consideration.

Support the delivery of • Data limitations prevent an appraisal of sites in terms of this objective. housing targets Support economic • Data limitations prevent an appraisal of sites in terms of this objective. growth and diversification

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9 WHAT ARE THE APPRAISAL FINDINGS / RECOMMENDATIONS AT THS CURRENT STAGE?

“the likely significant effects (1) on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors” “the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme” (SEA Directive, Annex I(f)&(g))

9.1 Introduction

Set out within the tables are the findings of the sites appraisal. Appraisal of sites proposed for the same use are presented alongside one another, so as to allow the reader to better interpret their relative merits.

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Table 9.1: Sites proposed for energy from waste Site (with preferred sites shaded Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary blue) historic env. change and well- being 13 A New 4th Line at Allington EfW 0 - ? - ++ - The impact of this site and its traffic on air quality is a key Facility concern due to its location within the Town Centre AQMA, especially due to the large capacity of the proposal. The Allington Quarry SSSI is in close proximity. The site is located in SPZ1&2 and so could present a risk to water quality. Cumulative environmental effects possible due to adjoining industrial estate. However, this is a brownfield site with existing infrastructure and good access which would contribute to a positive sustainable outcome. 54 Richborough Power Station A -- -- - 0 ++ -- Potential adverse impacts relate to proximity to the Sandwich Bay and Hacklinge Marshes SSSI. It is also located 38 metres from a Scheduled Ancient Monument (the Saxon Shore Fort, Roman Port and associated remains at Richborough). The site is within Flood Zones 2, 3 & 3b. A national footpath crosses or is adjacent to the site. Positive impacts relate to the location of the site being on previously developed and derelict land. 61 Former SCA Packaging, New - - ? - ++ -- Potential adverse impacts relate to the proximity to the Hythe Holborough to Burham Marshes (SSSI) and the fact the site is within Flood Zone 3. It should be noted that the boundary of the site may overlap with Flood Zone 3b, in which case significant negative effects could occur. Water quality risk due to location within SPZ1. A national footpath is on or adjacent to the site. Positive impacts relate to the efficient use of land (conversion of industrial land). 107 Lower Lane, Swanscombe - 0 -- 0 ++ - There are no identified access issues to the site, however, the proposed operation needs to consider the nearby AQMA at Northfleet Industrial Estate. The site is also in Flood Zone 2 and 3. A listed building, Church of All Saints II, is adjacent to the site. Use of the existing derelict industrial land will help to minimise the impact on the local environment. 46 Sheppy Ltd -Ashford Road, 0 -- - 0 -- - A greenfield site in close proximity to Leeds Castle Historic Hollingbourne Park and Garden and adjacent to the Leeds Castle Estate Local Wildlife Site. The site is known to hold a rich archaeological resource. 47 Sheppy Ltd -Rushenden Road, 0 -- - 0 ++ -- Adjacent to the Medway Estuary & Marshes SSSI, which is Queenborough also designated as being of international importance. It is also less than 100m from the Queensborough Castle Scheduled Ancient Monument and less than 50m from a listed building. It is within 26m of the nearest dwelling. Having said this, the site is in existing industrial use. It is also important to consider the potential for benefits to the local economy of Queensborough. 48 Sheppy Ltd -Argent Road, - 0 ? 0 0 -- A greenfield site that falls within Flood Zone 3. It is also within Queenborough 100m of existing residential dwellings and is crossed by a national footpath. 55 Ightham Sandpit Gasification 0 0 -- 0 0 0 The location of this site within the AONB and Green Belt means that landscape impacts have been assumed. Otherwise, this site does not appear to be significantly constrained. 103 Former Pfizer Site, Sandwich -- -- 0 0 0 0 Adjacent to the Sandwich Bay to Hacklinge Marshes SSSI, which is also designated as being of international importance. The site is within Flood Zones 2, 3 & 3b. 104 Land between Orpington Bypass 0 -- -- 0 0 0 Located within the Kent Downs AONB and also includes and M25 ancient woodland within the site.

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Table 9.2: Sites proposed for hazardous landfill Site (with preferred sites shaded Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary blue) historic env. change and well- being 60 Norwood Landfill Extension 0 0 ? 0 - -- Potential adverse impacts relate to the use of Grade 2 agricultural land, although this may be mitigated by later restoration. A footpath crosses the site. Overall the site is relatively distant from environmental constraints and settlements/dwellings. 63 Pinden Quarry Extension 0 0 ? 0 0 -- This site is within the Green Belt, but is the method of restoration for quarry activities and so can be regarded as appropriate. A footpath crosses the site. It is relatively unconstrained, although it is noted that archaeological potential has been identified.

Table 9.3: Sites proposed for non-hazardous landfill Site (with preferred sites shaded Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary blue) historic env. change and well- being 22 Rushenden Marshes -- -- ? 0 0 -- This site has the potential to result in impacts to biodiversity as it is located adjacent to an internationally important site. Part of the site has previously undergone satisfactory appropriate assessment under the Habitat Regulations and so this may not be a constraint. It is 18m from a dwelling and adjacent to a footpath. The majority of the site is in Flood Zone 2, but areas are within Flood Zones 3 & 3b. 15 BurntwickIsland 0 -- ? 0 0 0 Located within the Medway Estuary & Marshes SSSI which is also designated as being of international importance for biodiversity. 95 Stone Gate 0 0 ? - 0 -- Adjacent existing residential areas and the A226 London Road Air Quality Management Area. The site is also located within groundwater Source Protection Zone 2 and 3.

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Table 9.4: Sites proposed for treatment/materials recycling facilities Site (with preferred sites shaded blue) Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary historic env. change and well- being 11 Lees Yard and Adjacent Land, 0 - - -- ++ 0 This site could result in impact to a locally important Rochester Way, Dartford biodiversity site located nearby. The site is within SPZ 1, and so its extension could result in negative effects. It is located in the Green Belt, although the new development may have no greater impact than the existing facility. The site scores positively for its use of previously developed land. 14 Longfield Farm, Paddock Wood 0 0 - 0 0 -- Adjacent residential uses and potential of increased traffic could cause impacts on transport and community well being. A listed building is also adjacent to the site and impacts should be considered given the open processing. 27 Otterpool Quarry, Sellindge 0 - - 0 ++ 0 Potential issues surround the proximity of the site to the listed Otterpool Manor. The site would make good use of previously developed land. The adjacent SSSI is designated for its geological value and impacts are not thought likely. 51 Ridham - -- ? 0 0 - Potentially adverse impact due to the proximity of the site to the Swale (designated as a Ramsar, SPA and SSSI site). in the site is also within Flood Zone 3a. Positive impacts surround the potential use of the site to generate renewable energy and to use waste heat on site, although this is not really a site allocations consideration. 63 Pinden Quarry 0 0 -- 0 0 0 This site is located within the Green Belt and the potential for archaeological value has been identified. The operators are simply seeking permanent use of temporary existing waste recycling facilities and so in practice this can not have little adverse effect. 64 Richborough Hall - - ? 0 ++ 0 Potential adverse impacts relate to the proximity of the site to Thanet Coast & Sandwich Bay (a Ramsar, SPA and SSSI designated site). The site is located within Flood Zone 3a. 65 Land North of Stevens & Carlotti - -- ? 0 ++ 0 The site adjoins a locally designated wildlife site (Ash Level and South Richborough Pasture) and is about 200m from an internationally designated site. This site is mostly outside of flood zones and the small area that is in Flood Zone 2 is not thought to pose a problem in practice given expected uses. There are two very tiny areas of Flood Zone 3b in the SW corner that should not be developed. Positive impacts relate to the development of previously developed land and the potential for the site location to reduce transport distances and therefore emissions. 72 Unit 14 Canterbury Industrial 0 - ? 0 ++ 0 The site is previously developed land, but does border a site Park of international importance for biodiversity and so careful thought will have to be given to the effect of change of use. 88 Sevington Rail Depot Ashford 0 0 - 0 ++ -- The site is not in close proximity to any designated nature conservation areas and the proposed fully enclosed nature of the waste management facility should have minimal on or near site impacts. However, listed buildings (part of a wider settlement) are in close proximity as is a footpath. In practice, impacts to residents are unlikely given the presence of a railway and woodland separating dwellings from the site. Also, it is known that dwellings will not be on the lorry route. 8 Chelsfield Ammunition Depot 0 -- -- - ++ - Located within the Kent Downs AONB, the site also contains ancient woodland. Residential dwellings are also nearby. 12 Newington 0 0 ? 0 ++ -- The site includes previously developed land, although there may also be a risk of some loss of grade one agricultural land. This is uncertain. The site is adjacent to residential dwellings and a footpath. 20 Tovil Recycling 0 - - 0 ++ -- Adjacent to the Town Centre AQMA and 175m from a listed

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building. Also 63m from Loose Valley Local Wildlife Site. 52 Weatherlees 0 -- ? 0 0 0 Adjacent to Sandwich Bay to Hacklinge Marshes SSSI. 59 Shelford Waste Management 0 -- -- 0 -- -- Would impact on the West Blean & Thornden Woods ancient Facility woodland and is also located within the Kent Downs AONB. Also adjacent to existing dwellings. 79 Tilmanstone Works 0 0 ? 0 ++ -- Located within 50m of existing residential dwellings. Would partially make use of previously developed land.

Table 9.5: Sites proposed for composting Site (with preferred sites shaded blue) Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary historic env. change and well- being 23 Blaise Farm 0 -- - 0 0 0 The site is adjacent to an ancient woodland, and so there is the potential for impacts to biodiversity. The Chapel of St Blaise is close to the site and impacts should be considered given the open processing. The site is also located within the Green Belt, although landscape impacts are uncertain. 27 Otterpool Quarry, Sellindge 0 - - 0 ++ 0 Potential issues surround the proximity of the site to the listed Otterpool Manor. The site would make good use of previously developed land. The adjacent SSSI is designated for its geological value and impacts are not thought likely. 51 Ridham - -- ? 0 0 - Potentially adverse impact due to the proximity of the site to the Swale (designated as a Ramsar, SPA and SSSI site). in the site is also within Flood Zone 3a. Positive impacts surround the potential use of the site to generate renewable energy and to use waste heat on site, although this is not really a site allocations consideration. 65 Land North of Stevens & Carlotti - -- ? 0 ++ 0 The site adjoins a locally designated wildlife site (Ash Level and South Richborough Pasture) and about 200m from an internationally designated site. This site is mostly outside of flood zones and the small area that is in Flood Zone 2 is not thought to pose a problem in practice given expected uses. There are two very tiny areas of Flood Zone 3b in the SW corner that should not be developed. Positive impacts relate to the development of previously developed land and the potential for the site location to reduce transport distances and therefore emissions. 52 Weatherlees 0 -- ? 0 0 0 Adjacent to Sandwich Bay to Hacklinge Marshes SSSI. 79 Tilmanstone Works 0 0 ? 0 ++ -- Located within 50m of existing residential dwellings. It would partially make use of previously developed land. 82 Milton Manor Farm 2 0 - - - 0 -- About 150m from Larkey Valley Wood SSSI / Local Nature Reserve and 30m from a listed building and the presence of a footpath is another contraint. The site is within groundwater Source Protection Zone 1. 83 Westbere 0 -- ? 0 0 -- This site is adjacent to existing dwellings and shares a long boundary with an ancient woodland. 84 Highstead, Herne Bay 0 0 ? 0 -- -- This site is about 50m from residential dwellings and would result in the loss of grade 2 agricultural land. 85 Charing Quarry (Waste) 0 - ? 0 0 -- The site is in close proximity to existing dwellings and ancient woodland / Hurst Wood Local Wildlife Site.

Table 9.6: Sites proposed for household waste recycling centres Site (with preferred sites shaded blue) Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary historic env. change and well- being 13 Allington Waste Management 0 - ? - ++ - The impact of this site and its traffic on air quality are a key Facility concern due to its location within the Town Centre AQMA, especially due to the large capacity of the proposal. Environmental impacts possible, with the Allington Quarry

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SSSI in close proximity. The site is located in SPZ1&2 and so could present a risk to water quality. Cumulative environmental effects possible due to adjoining industrial estate. However, this is a brownfield site with existing infrastructure and good access which would contribute to a positive sustainable outcome. 37 Cobbs Wood Industrial Estate 0 0 ? 0 ++ - This is a relatively unconstrained site, although the fact that it is located near to a settlement means that careful consideration will need to be given to traffic and pollution related impact pathways. 12 Newington Industrial Estate 0 0 ? 0 ++ -- The site includes previously developed land, although there may also be a risk of some loss of grade one agricultural land. This is uncertain. The site is adjacent to residential dwellings and a footpath. 28 Waterbrook Park 0 0 - 0 -- -- About 100m from residential dwellings and a listed building and would result in the lost of Grade 2 agricultural land. A footpath represents another constraint. 57 Pike Road Eythorne Extension 0 0 ? 0 ++ -- This site is located on previously developed land adjacent to an existing waste site. It is located 120m from a listed building. A footpath is adjacent.

Table 9.7: Sites proposed for soft sand Site (with preferred sites shaded blue) Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary historic env. change and well- being 6 Land adjacent to Platt Industrial 0 - ? - 0 -- The site makes use of existing infrastructure and good access Estate routes. The nearby M26 is subject to an AQMA so site traffic impacts on local air quality will need to be considered. The settlement of Borough Green & Platt is nearby, whilst a footpath also crosses the site, leading to potential adverse effects on heath and well-being. Environmental impact concerns due nearby ancient woodland, LWS and EPS. Cumulative environmental effects possible due to adjacent mineral workings, industrial estate and railway line. Although well screened and not within the Kent Downs AONB, its proximity (583m) means that consideration must be given to landscape impacts. Nearby Roman remains suggest possible heritage impact. Nearest European site is North Down Woodland SAC approximately 7km to the north-east. 24 Land north of Addington Lane 0 - -- - 0 -- Potential adverse impacts on: the nearby settlement of Addington from site traffic and noise, landscape character, given location within Kent Downs AONB, local archaeological sites and nearby listed building. LWS containing ancient woodland and a SSSI located nearby which may be adversely impacted from quarrying. Restoration to include heathland and acid grassland, or if restoration is to agriculture, to include ponds and species rich hedges, with positive biodiversity effects. Nearest European site is North Down Woodland SAC approximately 3.2km to north-east. 75 Boltons Fields, Lenham Quarry - 0 ? - 0 -- Two LWS are within close distance to the extension Extension boundary. The site is located within close proximity to a number of residential dwellings and could impact these. Nearest European site is North Down Woodland SAC approximately 14.6km to west. 76 Chapel Farm 0 ------The site is adjacent to ancient woodland and close to the Kent Downs AONB and would also result in loss of Grade 2 agricultural land. The site is unlikely to have major access restrictions and has good access to the A20. The site may be visible from the North Downs. A residential dwelling is nearby. Nearest European site is North Down Woodland SAC

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approximately 14.6km to west. 77 Burleigh Farm and Tile Lodge 0 - - - 0 -- An ancient woodland is 140m away, but otherwise the site is not located within close proximity to designated nature sites. A listed building is adjacent as is another residential property. A footpath represents another constraint. The tributaries of the Great River Stour flow around and through the site and measures to minimise risk of pollution need to be fully addressed, in particular considering the site is located within Flood Zone 2. The site has good access to the A20. Measures are proposed to minimise transport impacts by using a conveyor to move minerals from the site to the processing plant. Nearest European site is Wye & Crundale Downs SAC approximately 14.2km to east. 97 Shrine Farm 0 ------Estimated operational lifespan of 60 years may have long term significant effects on local amenity, depending on exploitation/remediation programme. Adjacent to an ancient woodland and would result in loss of grade 2 agricultural land. Nearby dwellings and a footpath also represent contraints. Nearby excavations have identified the potential for rich historical remains on or near the site. The scale of the development means that it will be visible in the wider landscape (AONB). 105 Borough Green Sandpit 0 - -- - 0 0 Located within the AONB, although proposed restoration Extension (after 10 years) from the current grade 3a agricultural land to combination of amenity, grassland, woodland and biodiversity enhancements post exploitation should deliver improvements to social and environmental amenity. Air quality impacts need to be considered in light of the M20 AQMA. The nearest European site is North Down Woodland SAC approximately 6.9km to the north. An ancient woodland is 140m distant. 10 Pluckley Road, Charing 0 - ? - 0 - This site is 128m from a listed building, 78m from a residential dwelling, 168m from Hurst Wood Local Wildlife Site and is within groundwater Source Protection Zone 2. 50 Ightham Sand Pit Western 0 0 -- - 0 -- Located within the AONB and also adjacent to Igtham Court Extension Historic Park and Garden (which includes a listed building 82m from the site). Residential dwellings are also in close proximity. 62 Newlands Farm, Charing 0 - - -- 0 -- 195m from an ancient woodland and 6m from Hurst Wood Local Wildlife Site. The site is also within groundwater Source Protection Zone 1 and adjacent to residential dwellings. 69 Burleigh Farm, Charing 0 0 ------Adjacent to a listed building and residential dwellings. The site is also within groundwater Source Protection Zone 2. 74 Charing Quarry Extension 0 0 - - 0 -- The site is 153m from a listed building and 59m from residential dwellings. The site is also within groundwater Source Protection Zone 2. 100 Double Quick Farm, Lenham 0 0 0 - 0 -- This site is located 15m from the nearest residential dwelling Heath and a footpath is another constraint.

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Table 9.8: Sites proposed for sand and gravel Site (with preferred sites shaded blue) Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary historic env. change and well- being 2 Beltring Green Farm + - - 0 ? -- Impacts on land are uncertain as details of current agricultural grade of the site are not provided. Proposed restoration to wildlife conservation area, ponds and reed beds should provide long term environmental and social benefits. Environmental concerns relate to adjacent LWS. Restoration may deliver biodiversity and flood alleviation benefits. A listed building is 40m distant, whilst residential dwellings are adjacent. Nearest European site is North Down Woodland SAC approximately 12.3km to the north. 17 Moat Farm + 0 - 0 0 -- Phased wetland restoration should contribute to biodiversity. Impact on landscape and communities possible due to nearby settlement (450m), location to the north of the High Weald AONB, and anticipated highly visible nature of the site. The Listed Moat Farmhouse is also located nearby (which also accounts for the negative score in relation to health and well- being). Nearest European sites are North Down Woodland SAC approximately 15.3km to the north and Ashdown Forest SAC/SPA approximately the same distance to the south. 49 Land Adjacent to Hammer Dyke + ------This site is likely to have a range of adverse sustainability impacts including its proximity to the High Weald AONB, the presence of a listed building nearby and the use of grade 2 agricultural/pasture land. A locally important wildlife site is 190m distant. 51% of the site lies within Flood Zone 2 and is in Groundwater Source Protection Zone 1. Nearest European sites are North Down Woodland SAC approximately 17.2km to the north and Ashdown Forest SAC/SPA approximately the same distance to the south. 71 Stonecastle Farm Quarry + - - -- 0 - The site has a history of extraction with proposed additional Extension life of 8-11 years. Existing process plant and access can be utilised. Potential risk of cumulative impact with other nearby sites needs to be managed considering the large estimated workable minerals reserves. The agricultural land is of low grade but 95% within Flood Zone 2 and 100% within Flood Zones 3 and 3b. A footpath is nearby. There is an identified potential for impacts on prehistoric sites which have been recorded locally. Nearest European sites are North Downs Woodlands SAC approximately 16km to the north and Ashdown Forest SAC/SPA/Ramsar site approximately 18km to the south-west. 73a Lydd Quarry Extensions + -- - 0 ++ 0 The extension will fall within the Dungeness, Romney Marsh (Southern, Pigwell and Derings) and Rye Bay SSSI. It is also in close proximity to the Dungeness SAC but future restoration of the site could contribute positively to these areas in the longer term with the intention to restore the whole site to open water bodies. The extension would result in agricultural/derelict land take and is adjacent to a variety of uses. The site is fully within floodzone 2 and set within an open landscape and likely to be visible from various vantage points. Given the interest features of the Dungeness complex of sites, and their potential vulnerabilities, a range of potential impacts need further investigation before it can be concluded that a significant effect is unlikely. 3 Arnolds Lodge Farm West + - - 0 - -- This site is adjacent to a residential dwellings and a listed building. The site is also 110 from Hale Street ponds and pasture Local Wildlife Site. 4 Woodfalls Farm + -- - 0 0 - Adjacent to the River Beult SSSI and 127m from the Twyford Bridge in Yalding parish Scheduled Monument. A listed

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building is also 131m distant. 5 Filstone Lane, Shoreham + 0 ------This site is located within the AONB. Residential dwellings are adjacent. 26 Hollowshore + -- -- 0 - -- Adjacent to the Swale SSSI, which is also designated as being of international importance for biodiversity. The site is also likely to impact on a Scheduled Ancient Monument. A residential dwelling is also adjacent. 73 Lydd Quarry Extension Areas + -- ? 0 0 -- Adjacent to Dungeness, Romney Marsh and Rye Bay SSSI. Residential dwellings are in close proximity.

Table 9.9: Sites proposed for silica sand Site (with preferred sites shaded blue) Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary historic env. change and well- being 24 Land North of Addington Lane 0 - -- - 0 -- Potential adverse impacts on: the nearby settlement of Addington from site traffic and noise, landscape character, given location within Kent Downs AONB, local archaeological sites and nearby listed building. LWS containing ancient woodland and a SSSI located nearby which may be adversely impacted from quarrying. Restoration to include heathland and acid grassland, or if restoration is to agriculture, to include ponds and species rich hedges, with positive biodiversity effects. Nearest European site is North Down Woodland SAC approximately 3.2km to north-east.

Table 9.10: Sites proposed for chalk for agriculture and engineering use Site (with preferred sites shaded blue) Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary historic env. change and well- being 63 Pinden Quarry Extensions 0 0 ? 0 0 0 This is a relatively unconstrained site, although it is located within the Green Belt and the potential for archaeological value has been identified. 16 Beacon Hill Quarry 0 -- -- - 0 0 Adjacent to important ancient woodland and located within the Kent Downs AONB. . 56 Hegdale Quarry 0 - -- 0 0 - Located within the Kent Downs AONB, this site is also 14m from Cradle Bottom ancient woodland and 172m from a listed building.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

Table 9.11: Sites proposed for brickearth Site (with preferred sites shaded blue) Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary historic env. change and well- being 19 Paradise Farm 0 -- 0 - - -- The site may utilise the M2 to transport minerals given its very close proximity. Limited long term impacts given the short extraction period of six weeks per year. Potential impacts on biodiversity due to close proximity of the Queendown Warren SSSI & SAC which is sensitive to atmospheric nitrogen deposition associated with vehicle exhaust emissions and is already in exceedence of the critical load for this habitat. However, given that this site will only be worked for six weeks per year it is considered that (in practice) it will result in a negligible change in traffic flows on the M2 and therefore would not result in a detectable and attributable change in nitrogen deposition within the SAC. 98 Jefferies Site 0 0 - - - -- The short term operational life of the project should have only limited impacts considering no additional lorry movements above existing consented levels are predicted. There is concern that restoration of the site will be to lower agricultural value than at present (Grade 1). Use of this brickearth at local Sittingbourne brickworks will help contribute directly to the local economy. There are a number of residences and the settlement of Teynham is within close proximity of the site. The site is unlikely to have any significant impacts on local environmental quality. 101 Barbary Farm 0 0 - 0 - 0 Concern about the loss of Grade 1 agricultural land if restoration activities restore this to a lower productivity level. Need to consider impacts on local scheduled ancient monuments and listed buildings. Potential for impact on nearby ancient woodland and hedgerow connectivity. The site is also somewhat within close proximity to The Swale SPA/Ramsar site. However, given that there are no hydraulic pathways linking this site to the SPA, and that brickearth extraction is not a noisy form of mineral working, it is likely that the only issue requiring further investigation, in relation to its effect on the European Site, is whether the fields subject to minerals extraction regularly support significant populations of SPA/Ramsar birds 102 Barrow Green Farm 0 0 - 0 - -- There is concern the development would result in loss of Grade 1 agricultural land but that restoration activities would only restore this to a lower productivity level. There is a need to consider impacts of the development on nearby local scheduled ancient monuments and listed buildings. Nearest European site is The Swale SPA/Ramsar site approximately 1.5km to the north. 92 Land at Bax Farm + 0 0 0 - 0 This site is 133m from a listed building. It is also noted that evidence is available to suggest that access routes from the site are likely to be inappropriate for lorries.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

Table 9.12: Sites proposed for clay Site (with preferred sites shaded blue) Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary historic env. change and well- being 60 Norwood Quarry Extension, Isle 0 0 ? 0 - -- Potential adverse impacts relate to the use of grade 2 of Sheppey agricultural land and the proximity of the site to an SSSI (Sheppey Cliffs & Foreshore). Overall the site is relatively distant from European protected sites and ancient monuments and not located in Flood Zones 2 and 3. Nearest European site is The Swale SPA/Ramsar site approximately 2km to the south. A footpath is adjacent.

Table 9.13: Sites proposed for minerals importation Site (with preferred sites shaded blue) Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary historic env. change and well- being 1 East Peckham Quarry 0 - - 0 ++ 0 Good access to enable supply to west Kent of processed materials through use of existing infrastructure. Proximity to the Green Belt, ancient woodland and to a designated nature site are biodiversity concerns. Cumulative environmental effects due to surrounding land uses to be considered. Nearest European site is North Down Woodland SAC approximately 14km to the north-east.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

Table 9.14: Sites proposed for secondary and recycled aggregates Site (with preferred sites shaded blue) Flooding Biodiversity Countryside/ Water Climate Transport Waste Land Health Housing Economy Commentary historic env. change and well- being 21 Conway Rochester Way, 0 -- -- 0 0 0 Potential biodiversity impacts due to proximity to Wansunt Pit Dartford. SSSI, ancient woodland and adjoined heathland. No proposal to enhance biodiversity on site beyond marginal landscaping. Possible landscape and community impact as Braeburn Housing can see parts of site. Impacts on heritage assets possible due to nearby listed building. Nearest European site is Thames Estuary & Marshes SPA/Ramsar site approximately 16km to the east. 65 Land North of Stevens and - -- ? 0 ++ 0 The site adjoins a locally designated wildlife site (Ash Level Carlotti. and South Richborough Pasture) and is about 200m from an internationally designated site. This site is mostly outside of flood zones and the small area that is in Flood Zone 2 is not thought to pose a problem in practice given expected uses. There are two small areas of Flood Zone 3b that should not be developed. Positive impacts relate to the use of previously developed land and the potential for the site location to reduce transport distances and therefore emissions. 72 Unit 14, Canterbury Industrial 0 -- ? 0 ++ 0 The site is previously developed land, but does border a site Estate. of international importance for biodiversity and so careful thought will have to be given to the effect of change of use. 91 Animal Products Site. -- - - 0 ++ - The site’s close proximity to the Swale Ramsar/SPA/SSSI needs to be fully assessed as noise impacts from the change of use to an aggregate recycling facility could affect these. Reuse of existing land will not result in any additional land take. It is noted that this site is a currently operational glass recycling facility and that the proposal is primarily to continue to utilise this site for glass recycling. Given that the proposal would be a continuation of the existing activity it is considered that likely significant effects would not occur in practice. 99 Broomway Ltd, Swanscombe. - -- -- 0 ++ -- Located on a brownfield site, it will ensure efficient use of land and will minimise impacts on local biodiversity. The site lies within flood zones 2 and 3. The northern area benefits from flood defences. It is recommended consideration be given to site design and layout to minimise contamination of surface water from operations on site. Nearest European site is Thames Estuary & Marshes SPA/Ramsar site (7km distant). 12 Newington Industrial Estate. 0 0 ? - ++ -- The site includes previously developed land, although there may also be a risk of some loss of grade one agricultural land. This is uncertain. The site is adjacent to residential dwellings and a footpath. 79 Tilmanstone 0 0 ? - ++ -- Located within 50m of existing residential dwellings. Would partially make use of previously developed land. 8 Chelsfield Ammunition Depot. 0 -- -- - ++ - Located within the Kent Downs AONB, the site also contains ancient woodland. Residential dwellings are also nearby. 45 Dunbrik Depot. 0 0 -- 0 0 -- This site is within the AONB and 47m from the nearest residential dwelling. 52 Weatherlees. 0 -- ? 0 0 0 Adjacent to Sandwich Bay to Hacklinge Marshes SSSI. 56 Hegdale Quarry 0 - -- 0 0 - Located within the Kent Downs AONB, this site is also 14m from Cradle Bottom ancient woodland and 172m from a listed building. 80 Faversham Quarry. 0 0 - 0 0 -- This site is 63m from a listed building and 28m from the nearest residential dwelling. 81 Milton Manor Farm. 0 -- - 0 0 - This site is 42m from a listed building and adjacent to a Local Wildlife Site (the Great Stour River). 86 Charing Quarry. 0 - ? 0 0 - This site is within close proximity (12m) to Hurst Wood Local Wildlife Site.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

9.2 Summary, cumulative effects and mitigation

Flooding

The appraisal (based on strict assumptions as it was) predicts that three of the preferred sites will result in significant negative effects, whilst ten further sites will have lesser negative effects. It is unlikely that cumulative effects will occur.

Were the appraisal able to take into account a wider set of factors, it would no doubt have found that measures are already planned for many sites to ensure that any flood risk that exists is mitigated. It will be important for the Site Allocation DPDs to ensure that sufficient mitigation is possible. In practice, there is much potential to mitigate flood risk through the incorporation of sustainable drainage systems.

Biodiversity

The appraisal (based on strict assumptions as it was) predicts that 13 of the preferred sites will result in significant negative effects, whilst 20 further sites will have lesser negative effects. In some instances there could be the potential for cumulative effects to particular sites of biodiversity importance.

Were the appraisal able to take into account a wider set of factors, it would no doubt have found that measures are already planned for many sites to ensure that effects are mitigated. It will be important for the Site Allocation DPDs to ensure that sufficient mitigation is possible. In practice, there is much potential to avoid and mitigate effects where a waste or minerals site is located in close proximity to an important biodiversity site. Indeed biodiversity enhancements on minerals sites can be beneficiaries to wider biodiversity.

Countryside / historic environment

The appraisal (based on strict assumptions as it was) predicts that nine of the preferred sites will result in significant negative effects, whilst 16 further sites will have lesser negative effects. It is unlikely that cumulative effects will occur (i.e. that multiple sites will impact on a particular asset).

Were the appraisal able to take into account a wider set of factors, it would no doubt have found that measures are already planned for many sites to ensure that effects are mitigated. It will be important for the Site Allocation DPDs to ensure that sufficient mitigation is possible. In practice there is much potential to avoid and mitigate effects through breaking lines of sight.

Water

The appraisal (based on strict assumptions as it was) predicts that three of the preferred sites will result in significant negative effects, whilst 12 further sites will have lesser negative effects. It is unlikely that cumulative effects will occur (i.e. that multiple sites will impact on a particular asset). It is not thought that cumulative effects will be significant.

Were the appraisal able to take into account a wider set of factors, it would no doubt have found that measures are already planned for many sites to ensure that effects are mitigated. It will be important for the Site Allocation DPDs to ensure that sufficient mitigation is possible. In practice, there is much potential to avoid and mitigate effects through onsite design and management measures.

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Sustainability Appraisal of the Kent Minerals and Waste Sites DPDs

Land

The appraisal (based on strict assumptions as it was) predicts that 20 of the preferred sites will result in significant positive effects (through making good use of previously developed land). None of the preferred sites are predicted to result in significant positive effects; however, 10 are predicted to result in lesser negative effects. It is not thought that cumulative effects will be significant.

Were the appraisal able to take into account a wider set of factors, it would no doubt have found that measures are already planned for many sites to ensure that effects are mitigated. It will be important for the Site Allocation DPDs to ensure that sufficient mitigation is possible. For minerals sites, there is much potential to avoid impacts in the long term through ensuring that appropriate restoration occurs.

Health and well-being

The appraisal tables indicate that 21 of the preferred sites would result in significant negative effects, whilst six further sites are predicted to result in lesser negative effects. The analysis has not highlighted any potential for cumulative effects (i.e. multiple sites impacting on a single community, household etc.)

Were the appraisal able to take into account a wider set of factors, it would no doubt have found that measures are already planned for many sites to ensure that effects are mitigated. It will be important for the Site Allocation DPDs to ensure that sufficient mitigation is possible. In practice, there is much potential to mitigate effects on health and well-being, although it may be possible to avoid effects all together as the public perception of waste and minerals development is almost always poor. Where sites are in close proximity to sensitive receptors, onsite design and management measures can reduce pollution (e.g. noise, odour and dust), whilst careful management of traffic will be another important consideration.

10 HOW CAN WE BEST MONITOR THE PLAN’S IMPACTS?

“a description of the measures envisaged concerning monitoring…” (SEA Directive, Annex I(i))

The time for finalising monitoring measures is at the time of plan adoption. This is recognised by the SEA Directive, which requires that at adoption a ‘Statement’ is published that sets out (amongst other things) ‘the measures decided concerning monitoring’.

Within the SA Report (to be published alongside the Proposed Submission Plan) the Directive requires that ‘a description of the measures envisaged concerning monitoring’ is presented. This reflects the fact that the draft plan should be near finalised, and so there should be a reasonable understanding of the likely residual sustainability effects.

At this current stage, the appraisal has highlighted the potential for a range of significant negative effects (including cumulative effects) and also highlighted a number of uncertain effects. The next step will be for the County Council to take these findings on-board when preparing the Proposed Submission Version of the DPDs.

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