Constraints Analysis

Home , Epsom Common, Greensand Ridge, Little Bookham, North Downs, Pipp Brook, River Arun

May 2017

Purpose of study ...... 3

Scope of study ...... 3

Section 1: Nature Conservation: European Sites and SSSIs ...... 4

Section 2: Green Belt ...... 21

Section 3: Area of Outstanding Natural Beauty ...... 28

Section 5: Locations at Risk of Flooding ...... 40

Section 6: Common Land and Inalienable Land ...... 47

Section 7: Noise ...... 50

Section 8: Air Quality ...... 55

Section 9: Transport ...... 56

Conclusions ...... 60

Purpose of study 1. The Constraints Analysis is part of a suite of evidence documents which will inform the preparation of a Local Plan for Mole Valley, for the period 2018-2033. The purpose of this study is to identify at an early stage of the plan-making process those significant strategic- level constraints which will have the biggest influence on MVDC’s strategic approach to planning for objectively assessed needs.

2. This analysis will inform the plan-making process, in line with the principles set out in paragraph 14 of the NPPF, which states:

Local planning authorities should positively seek opportunities to meet the development needs of their area;

Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless:  Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or  specific policies in this Framework indicate development should be restricted.” (emphasis added)

3. A footnote to NPPF paragraph 14 lists examples of specific policies which indicate that development should be restricted. Those which are applicable to Mole Valley are listed in paragraph 6, below.

4. As Local Plan preparation progresses, the Constraints Analysis will be further refined as required to inform the selection of a preferred strategic framework for development.

5. The conclusions of the study will also inform discussions with other LPAs under the Duty to Cooperate, which requires MVDC to explore cross-boundary options for meeting the District’s objectively assessed needs in full. Scope of study 6. The starting point of the study is to examine those constraints which are identified in the footnote to NPPF paragraph 14. These are examples of the “specific policies” which para 14 states “indicate development should be restricted”. Of those listed, the following are found within Mole Valley:

 Sites protected under the Birds and Habitats Directives and/or designated as Sites of Special Scientific Interest;  Land designated as Green Belt;  Areas of Outstanding Natural Beauty;  Designated heritage assets;  Locations at risk of flooding.

7. In addition to the above, the study examines the following constraints which it is considered are of sufficiently wide-ranging influence that they could have an impact on strategic options for development:  Areas of Inalienable Land – i.e. Common Land and inalienable land controlled by the National Trust  Noise, focussing on road noise within the M25 corridor and aircraft noise  Air Quality  Transport and Accessibility

8. The study will examine each of the above constraints and define the extent to which they impact on MVDC’s ability to plan for a level of development that meets objectively assessed needs.

Section 1: Nature Conservation: European Sites and SSSIs 9. This section of the Constraints Analysis considers the extent to which land designated for its nature conservation importance acts as a strategic constraint on development. The need to avoid significant effects on European Sites is considered first, focussing on the Mole Gap to Reigate Escarpment Special Area of Conservation, much of which lies within the District, and the Thames Basin Heaths Special Protection Area, which lies to the west and south.

10. The analysis then turns to other designated sites, notably SSSIs, which are specifically mentioned in NPPF paragraph 14. It also identifies certain other local designations which cover a large enough extent of land that they are considered likely to impact on strategic options. European Sites 11. The European Habitats Directive sets out the means to protect habitats and species of European importance through the establishment and conservation of a network of sites known as ‘Natura 2000’. Natura 2000 sites are Special Areas of Conservation (SACs) designated under the Habitats Directive and Special Protection Areas (SPAs) designated under the Birds Directive.

12. As part of the Local Plan preparation process, MVDC will undertake a Habitats Regulations Assessment to identify the implications of the plan on Natura 2000 sites either individually or in combination with other plans or projects. This is in line with the requirements of the Habitats Regulations.

13. This section identifies key issues which are likely to arise in relation to Natura 2000 sites, which may affect the shaping of strategic options. It draws on published Appropriate Assessments and other relevant studies relating to the Natura 2000 sites most likely to be a consideration for Mole Valley’s Local Plan, including:  MVDC Core Strategy Appropriate Assessment 2008  Published Habitats Regulation Assessments for Reigate and Banstead Borough Council’s Core Strategy (2012) and Development management Plan (Draft, 2014)  Thames Basin Heaths SPA Delivery Framework

14. As Local Plan preparation progresses, these issues will be addressed in more detail through the Habitats Regulation Assessment (HRA) process, in collaboration with Natural England, in order to ensure that an appropriate policy framework is incorporated in the Local Plan.

15. The HRA will consider the implications of the Local Plan for all Natura 2000 sites within a 10km radius. However, based on information currently available, it is anticipated that the key considerations will relate to the following two sites:  Mole Gap to Reigate Escarpment Special Area of Conservation (SAC)  Thames Basin Heaths Special Protection Area (SPA)

Mole Gap to Reigate Escarpment SAC

16. The SAC stretches for eight miles between Leatherhead and Reigate, taking in significant areas of Norbury Park, Box Hill and Headley Heath (see map 1, overleaf).

17. The area within the SAC is characterised by a mosaic of chalk downland habitats, ranging from open chalk grassland to scrub and various types of semi-natural woodland on the scarp and dip slopes of the North Downs.

18. One of its most important features is the stand of Box scrub which is unique in the UK. This occurs on steep chalk slopes, where the River Mole has cut into the North Downs escarpment. Natural erosion maintains the open conditions required for the survival of this habitat.

19. There are also large but fragmented areas of nationally significant calcareous grassland, which support an important assemblage of orchid species. Also nationally significant are the stands of Beech and Yew dominated woodland.

20. The site also supports a significant area of dry heathland and acid grassland at Headley Heath. Further species interest includes Great Crested Newt and Bechstein’s Bat

Map 1: Special Area of Conservation

21. Based on MVDC’s current information, the key potential impacts on the SAC are understood to be:  Potential impact on habitat due to increased recreational usage;  Potential impact on habitat due to maintenance (and risk of cessation) of grazing;  Potential impact on habitat due to increased air pollution;  Potential disturbance to roosting populations of Bechstein bats, a European Protected Species.

22. Of the above, the extent to which additional housing to meet forecast population growth will lead to increased recreational use – and what impact that would have on the SAC - is a key consideration in formulating strategic options for Mole Valley’s Local Plan. This will be a key focus for the HRA process.

23. Previous HRAs have indicated that the residual level of growth planned for within the 2009 Core Strategy would not have a significant adverse impact on the SAC, but that there may be a need for mitigation measures. Where these arise, they are likely to focus on visitor management measures. The SAC is under active management by a variety of bodies, including the National Trust, Surrey County Council. Surrey Wildlife Trust, Natural England and the Surrey Hills AONB Management Board. There will be a need to ensure that the HRA process includes close consultation with these agencies, drawing on their expertise about the impact of recreational use and visitor management measures which are effective in safeguarding those habitats which have been identified as of primary importance.

24. A key consideration will be what additional recreational impact is likely to be associated with growth which exceeds the level previously planned for within the Core Strategy. Regard will also have to be had to growth plans within other Districts and Boroughs, taking into account existing evidence that Mole Valley residents form only a small proportion of visitors to the SAC.

Thames Basin Heaths SPA

25. The Thames Basin Heaths lie outside Mole Valley, to the north and west. The SPA includes several sites, covering parts of Surrey, Hampshire and Berkshire. These sites are a rare example of lowland heathland, and are home to three important bird species. Natural England has identified that the cumulative effect of housing growth in Districts and Boroughs surrounding the SPA poses a threat to these habitats. The key risks are associated with cat predation, dog walking and disturbance due to recreational use, all of which present risks to the ground-nesting birds for which the SPA provides a habitat.

26. A policy framework for protection of the SPA is set out in Policy NRM6 of the South East Plan, which remains in force despite the revocation of the remainder of the Plan. This establishes a zone of influence at a 5km linear distance from the SPA boundary, within which mitigation measures are required in connection with new residential development. Mitigation measures include contributions towards access management within the SPA and provision of alternative green spaces (known as Suitable Accessible Natural Greenspace or SANG).

27. The mechanism for delivery of policy NRM6 is the Thames Basin Heaths Delivery Framework. Almost all of the Districts and Boroughs who are within the 5km zone of influence are signatories to the Delivery Framework and have policies in plans to implement policy NRM6.

28. Along with three other authorities, MVDC lies on the outer periphery of the zone of influence and is not a signatory to the Delivery Framework. Only a very small part of the District lies within the 5km zone of influence (see map) and the majority of that area is designated as Green Belt. While that land remains within the Green Belt, the likelihood of any significant residential development within the zone of influence is low and the need for mitigation has been considered on a case by case basis in consultation with Natural England.

29. A larger part of Mole Valley lies within a buffer zone extending from 5km to 7km as the crow flies from the SPA boundary (see map). Based on evidence presented to the South East Plan Examination in Public, the Delivery Framework identifies that developments of 50 units or more within the buffer zone could also have an impact on recreational pressure within the SPA and should be assessed on a case by case basis.

30. The 5-7km buffer zone takes in a larger area in the north of Mole Valley, including land to the north of Leatherhead and Fetcham, which is within the Green Belt (see map 2).

31. Natural England provided advice to MVDC on this issue during work on the abortive Housing and Traveller Sites Plan and further informal discussions have taken place during preparation of this Constraints Analysis. MVDC is not a signatory to the Delivery Framework and Natural England’s advice has been that sites within the 5km and 5-7km zones in Mole Valley should continue to be assessed on a case by case basis, but that there may be a need for mitigation measures to provide new SANGs or make financial contributions towards enhancements and site management of existing semi-natural greenspace that is suitably located.

Map 2: Thames Basin Heaths Special Protection Area: 5km and 7km zones

Implications for Local Plan Strategic Options: European Sites

MVDC is obliged under the Habitats Regulations to assess whether proposals in the Local Plan are likely to have a significant effect on European sites, either individually or in combination with other plans or projects. This will be examined through the Habitats Regulation Assessment process as plan preparation plan progresses. It is intended that the Habitats Regulation Assessment will focus on potential impacts on the Mole Gap to Reigate Escarpment SAC, the Thames Basin Heaths SPA, along with other Natura 2000 sites within a 10km radius of the District.

Based on the information currently available, the key issue of concern is likely to be increased recreational pressure associated with housing growth and its impact on the Mole Gap to Reigate Escarpment SAC and the Thames Basin Heaths SPA.

A framework exists for mitigation of impacts on the Thames Basin Heaths SPA, including through the provision of Suitable Alternative Natural Greenspaces (SANGs). MVDC is not a signatory to the Thames Basin Heaths Delivery Framework, because only a very small area of the District is within the 5km zone of influence. During the Local Plan process, MVDC will examine options which may impact on the SPA on a case by case basis in consultation with Natural England. This will particularly affect any strategic options which contemplate additional housing development parts of the District which lie within the 5km zone of influence and 5-7km buffer zone (i.e. land around Bookham and land to the north of Fetcham and Leatherhead).

Additional housing growth may increase the threats associated with recreational use of the Mole Gap to Reigate Escarpment SAC. As Local Plan preparation progresses, the extent to which the impact of recreational pressure is likely to have any significant effect on the protected habitats and/or how any such effects can be mitigated through visitor management measures will be explored in partnership with Natural England and the various bodies involved in managing areas of the SAC.

It is recognised that there is a relationship between potential mitigation measures for both the above European sites. There is an abundance of accessible natural greenspace in the north of Mole Valley, which could potentially provide SANGS for development within the 5-7km zone. However, much of that greenspace is either within, or in close proximity to, the SAC. Therefore discussions with Natural England and other interested parties will focus on working towards an appropriate mitigation strategy which addresses this specific situation within Mole Valley.

SSSIs and other relevant designations 32. Although NPPF para 14 only identifies European Sites and SSSIs as the specific designations which indicate that development should be restricted, the Framework also recognises that LPAs should “set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure” (NPPF para 114). Therefore, while it is recognised that a distinction should be made between the hierarchy of international, national and locally designated sites (para 113), it is also considered appropriate to recognise the interrelationships between areas of land designated at different levels and for different reasons. In several locations within Mole Valley, there is a network of interrelated sites which together give a wider picture of the constraints that could have a bearing on strategic options. Therefore, the maps which follow illustrate the extent of European sites and SSSIs alone (Map 3) and in combination with all local nature conservation designations (Map 4).

Map 3: Sites of Special Scientific Interest

Map 4: Other Nature Designations (see Maps 1, 2 and 3 for European Sites and SSSIs)

Ashtead, Leatherhead, Fetcham and Bookham

33. North of Ashtead is a large area of open land dominated by Ashtead Common and adjacent woodland or meadows. These open spaces are designated as SSSI and/or Common Land. In the south western corner (on land bordering the northern edge of the Rye Brook) is a section of land largely used for horsiculture, which is not currently covered by any nature conservation designation. However, part of this Rye Brook corridor has been identified by the Surrey Local Sites Partnership as meeting the requirements for designation as a Site of Nature Conservation Importance and is being actively managed by a local trust for its nature conservation value.

34. Within the built up area of Ashtead are areas of open space at the Wood Field and Ashtead Park which are designated as SNCIs and, in the case of the Wood Field, also as Common Land.

35. The open land to the south of Ashtead is largely undesignated but contains a block of Ancient Woodland/SNCI close to the M25. There are also a number of substantial tree belts and hedgerows that were highlighted during work on the Ashtead NDP as being of considerable ecological value, although they are at present undesignated. These also provide a network of green corridors along rights of way through this area.

36. Land on the west side of Ashtead and the east side of Leatherhead forms a narrow open corridor between the built up areas and either side of the M25. This land is not designated for nature conservation reasons, apart from some slivers of ancient woodland. Nevertheless, it does act as a natural corridor linking the countryside to the north and south of Ashtead/Leatherhead.

37. The land around the immediate southern fringes of Leatherhead, Fetcham and Bookham contains fewer designated areas. However, the River Mole is an important green corridor through the built up area, which includes areas of local importance (SNCI and Local Nature Reserve), in the area between the town centre and the A246/A24 junction.

38. Moving west, the open land north of Leatherhead and Fetcham is sporadically developed with low density housing, horsiculture and golf courses. This area does not include any SSSIs, but there are several small blocks of ancient woodland, a relatively large SNCI at Teazle Wood (owned by a local trust) and a smaller SNCI and Local Nature Reserve at River Lane Fields. Much of this area is also within the 5-7km buffer around the Thames Basin Heaths SPA.

39. Further west, the open land north and north west of Bookham is much more significantly protected. Very little of this land is undesignated. It includes the large block of Bookham Common which, as well as being a SSSI, is also Common Land and within the custodianship of the National Trust. This whole area to the north and north west of Bookham is also within the 5km buffer around the Thames Basin Heaths SPA.

40. Land between Bookham and Effingham, between Lower Road and the A246 does not include any nature conservation designations.

North Downs 41. Within the North Downs, very extensive tracts of land are designated SSSI and/or SAC and there are also several very large blocks of Ancient Woodland. The areas designated for their nature conservation importance take in a significant proportion of the countryside north of Dorking and south of Ashtead, Leatherhead, Fetcham and Bookham. The largest designated areas are towards the south and take in the steep scarp slope of the North Downs, most of which is designated SSSI and/or Special Area of Conservation. All the areas within the Mole Gap to Reigate Escarpment SAC are within this tract of countryside.

42. South of the scarp slope, the lower-lying land is generally free of designations, although there are some substantial blocks of ancient woodland, particularly in the west, near Westcott and Wotton.

Dorking 43. There are several small pockets of ancient woodland around the southern and eastern fringes of Dorking. Larger designated areas comprise a Local Nature Reserve and SNCI at Inholms Lane and the Glory Woods, which is a block of Ancient Woodland extending into the built up area and designated as a Site of Nature Conservation importance.

Greensand Hills 44. The Greensand ridge formed by very resistant rocks of the Lower Greensand, in particular the Hythe Beds, have produced prominent escarpments that form an arc around the northern edge of the Low Weald, running parallel to and just south of the chalk escarpment of the North Downs. This stretch of the Greensand has become the most closely identified with the term "Greensand Ridge", and it includes the second highest point in south-east England, Leith Hill in Surrey. There are very extensive areas of ancient woodland and some large SSSIs on the plateau of the Greensand Hills in and around Leith Hill. When the expanses of Ancient Woodland are taken into account, a significant proportion of this area of countryside is designated for its nature conservation importance and it includes significant areas managed by the National Trust for their nature conservation value.

Wooded Weald 45. These are lower lying areas where alternating clays and sandstones occur where as these rocks are not as hard as the greensand where as result of fluvial erosion has flattened these areas into a series of hills and vales. This more fragmented landscape as a result of its topography is characterised by pockets of very rural land with densely wooded pockets. In the lower-lying areas south of the Greensand Hills, the land covered by nature conservation designations reflects this topography and is more fragmented, with a scattering of ancient woodland and SNCIs and fewer SSSIs. This largely rural area is known as the Wooded Weald and there is an extensive network of locally designated sites set within shallow valleys surrounded by low ridges, with several long, thin sites forming linkages between blocks of ancient woodland and other designations.

46. There are SSSIs at Smokejack Clay Pit, Vann Lake and Ockley Woods and Clockhouse Brickworks.

Low Weald 47. The Weald is a large clay valley which was once was covered with thick inhospitable forest, and its name, Old English in origin, signifies woodland The underlying geology shapes the landscape as the softer sandstones and clays form a gentler rolling landscape. I The Weald was used for centuries, possibly since the Iron Age, for transhumance of animals along droveways in the summer months. Over the centuries, deforestation for the shipbuilding, charcoal, forest glass, and brickmaking industries has left the Low Weald with only remnants of that woodland cover, but with evidence of this historic industrial activity. The woodland cover that remains represents a significant and historic ecological resource alongside the historic changes. In the portion of the Low Weald in the south east of the District ), the countryside is generally more open, but is spotted with irregular blocks of woodland and a network of tributaries and gills of the River Mole. The network of designated sites is less extensive than elsewhere, but due to the historical context in ecological terms the area is noted for these remaining areas of ancient woodland and gill woods, many of which are scattered and small in size.

48. The routeways in this area (now roads and Rights of Way) in the form of ridge-top roads reflect the historic dense system of radiating droveways. The droveways are often narrow, deeply sunken, and edged with trees, hedges, wildflower-rich verges and boundary banks. These routes remain as distinctive and attractive rural roads however they are impractically narrow for the modern vehicle and have little prospect for widening or use as sustainable transport routes. Additionally increases in traffic represents a threat to their survival as a snapshot of the ancient droving routes.

49. There are some larger blocks of ancient woodland around the north of Newdigate and a substantial SSSI at Glovers Wood, west of Charlwood.

Implications for Local Plan Strategic Options: Nature Conservation Designations

In the following areas, there are significant expanses of land which is designated for its nature conservation importance:

 Land north of Ashtead, including Ashtead Common and its environs;

 Land north and north west of Bookham, including Bookham Common;

 The North Downs, which takes in the Mole Gap to Reigate Escarpment Special Area of Conservation, together with several SSSIs and very extensive areas of ancient woodland;

 The Greensand Hills, south west of Dorking.

In the above areas, the amount of land of national or international significance for its nature conservation value would preclude strategic-scale allocations for new development.

There are further areas where there is a very extensive network of smaller nature conservation sites, including some nationally important sites. Throughout the District, nature conservation is likely to be a consideration in the allocation of sites.

Biodiversity Opportunity Areas 50. As part of its remit to protect biodiversity in Surrey in alignment with DEFRA’s Biodiversity 2020 Strategy, the Surrey Local Nature Partnership has identified several Biodiversity Opportunity Areas (BOAs). These are extensive areas where there is a spatial concentration of already recognised and protected sites as well as other areas of priority habitat, which is not yet officially designated. They represent areas where improved habitat management and efforts to restore and re-create Priority habitats will be most effective in enhancing connectivity to benefit recovery of Priority species in a fragmented landscape.

51. Map 5 (below) illustrates the extent of BOAs across Surrey. Those which include land within Mole Valley are as follows:

 TBL02 Clandon to Bookham Parkland

 TBL04 Ashtead & Epsom Woodland, Princes Coverts & Horton Country Park

 ND02 North Downs Scarp and Dip; Guildford to the Mole Gap

 ND03 North Downs Scarp; Mole Gap to Reigate

 WG08 Leith Hill, Wotton, Abinger & Holmwood Greensand Ridge

 LW03 Wallis Wood

 LW06 Newdigate Woodland

 LW04 Vann Lake

 LW05 Glovers Wood & Edolph’s Copse

 RO5 River Mole & tributaries

 RO6 River Wey & tributaries

Map 5: Biodiversity Opportunity Areas

52. As can be seen from the map, BOAs cover a substantial geographical area. Designation of an area as a BOA does not in principle preclude development. However, they indicate areas where there may be an opportunity for strategic development options to incorporate opportunities to enhance biodiversity, as the Local Plan progresses.

Implications for Local Plan Strategic Options: Biodiversity Opportunity Areas

The inclusion of land within a Biodiversity Opportunity Area (BOA) does not preclude development in principle (although parts of the BOA may also be covered by other designations which do preclude development e.g. SSSIs).

As Local Plan preparation progresses, strategic options for development should take account of opportunities to enhance biodiversity, taking into account guidance in the Policy Statement for each BOA.

Section 2: Green Belt 53. NPPF Paragraph 14 includes designation of land as Green Belt among the constraints which may indicate that development should be restricted. Map 6 (below) illustrates the extent of the Green Belt in Mole Valley. About 76% of the land within the District boundaries is Green Belt (see Map 6, below). This represents about 83% of the land outside the existing built up areas and larger villages. Therefore this is a significant consideration for Mole Valley’s emerging Local Plan.

54. The NPPF emphasises that the essential characteristics of Green Belts are their openness and their permanence (NPPF para 79). Green Belt boundaries should only be altered in exceptional circumstances, through preparation or review of a Local Plan (NPPF para 83). It therefore falls to MVDC to consider as part of the Local Plan review process whether “exceptional circumstances” exist to suggest that any changes are required to the existing Green Belt boundary. The remainder of this section considers that question.

Map 6: Green Belt

Housing White Paper

55. In February 2017, the Government published “Fixing Our Broken Housing Market” – a White Paper addressing the shortage of new housing to meet existing and future demand. The White Paper reiterates that Green Belt boundaries should be amended only in exceptional circumstances when plans are being prepared or revised. However, it elaborates on NPPF guidance to indicate an approach which local authorities should take to consider whether exceptional circumstances exist. Paragraph 1.39 of the White Paper proposes an addition to national policy to make clear that authorities should amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements, including:

 Making effective use of suitable brownfield sites and the opportunities offered by estate regeneration;

 The potential offered by land which is currently underused, including surplus public sector land where appropriate;

 Optimising the proposed density of development; and

 Exploring whether other authorities can help to meet some of the identified development requirement.

56. The White Paper is not yet part of national planning policy and its contents may change as it progresses through Parliament. Nevertheless, the above paragraph gives a useful framework for considering whether exceptional circumstances exist to suggest that land might need to be removed from the Green Belt in Mole Valley.

Brownfield and underused land:

57. The first two points above are addressed in the Brownfield Land Availability Assessment which considers the availability of brownfield land to meet development needs. As part of the process of preparing that assessment, site submissions were invited from owners of brownfield land – including a range of public bodies. MVDC also drew on a detailed analysis of all previously developed land which is not already in residential use.

58. The Brownfield Land Availability Assessment identifies a number of previously developed sites which could be allocated to help meet the District’s development needs, particularly for housing. However, the capacity of identifiable sites is assessed as being approximately 2800 homes, which represents about 35% of total objectively assessed needs. On the whole, brownfield sites in Mole Valley tend to be small in scale and the vast majority are in active use and not known to be available for development. There are no substantial tracts of underused or surplus public sector land. Privately-owned land tends to be redeveloped quickly when it becomes available and the opportunities to identify sites for future development are limited.

Optimising density:

59. In making an assessment of brownfield capacity, MVDC has sought to be ambitious in optimising the proposed density of development. This is particularly the case in town centre sites – notably in Leatherhead, where a number of sites are proposed for redevelopment as part of the Transform Leatherhead project. As Local Plan preparation progresses, appropriate and achievable ways to maximise density will continue to be explored. However, the indications are that, even with the most ambitious density

assumptions, there would remain a significant shortfall between the amount of suitable and available brownfield land and the scale of MVDC’s objectively assessed needs.

Exploring options with other authorities:

60. MVDC will explore options to work with other authorities under the duty to cooperate, to establish whether some of the identified development requirement can be met through cross-boundary cooperation. This process commenced with consultation on MVDC’s Duty to Cooperate Scoping Statement in February 2017, alongside preparation of evidence base documents. The Scoping Statement identifies housing delivery as a key cross-boundary strategic issue, which will be a focus for ongoing engagement under the duty to cooperate. It also identifies that “One of the challenges for MVDC is to identify potential options for a proportion of Mole Valley's objectively assessed housing needs to be met through cross-boundary co-operation, particularly where the land within adjacent districts/boroughs lies outside the Green Belt and /or is less constrained than land within Mole Valley.”

61. It must be recognised at the outset, however, that the Green Belt is a significant constraint throughout MVDC’s identified Strategic Housing Market. In terms of meeting objectively assessed needs, similar challenges are faced by all four partner authorities (MVDC, Epsom and Ewell Borough Council, Royal Borough of Kingston upon Thames). A significant proportion of undeveloped land in all three partner authorities is also designated as Green Belt and/or Metropolitan Open Land (in the case of Kingston upon Thames).

62. Other neighbouring authorities in Surrey (Guildford, Waverley and Reigate and Banstead) are also significantly constrained by Green Belt and/or AONB designations. There are areas within Waverley Borough which adjoin Mole Valley and are not within the Green Belt and this may be an area where options for cross-boundary cooperation can be explored, although the Borough Council is well advanced in the preparation of its own local plan, and has experienced severe difficulty in identifying sufficient housing land to meet its own requirements.

63. Looking south, the Borough of Crawley is highly constrained by a very tight boundary around the existing built up area. It has recently adopted a new Local Plan for the period to 2030 which already seeks to maximise densities and relies on housing provision in adjoining authorities to meet a proportion of objectively assessed need. It is considered highly unlikely that there is scope to meet a proportion of MVDC’s needs within Crawley, although discussions will be held to explore any potential options.

64. Finally, the neighbouring District of Horsham lies outside the Green Belt and, again, this may be an area where options for cross-boundary cooperation can more realistically be explored. It is recognised that Horsham District Council adopted a District Planning Framework in November 2015 which already includes proposals for 800 new homes per annum and already includes housing proposals to help meet the objectively assessed needs of adjacent authorities (notably Crawley). It is further recognised that Horsham District also includes areas which are significantly constrained, notably the South Downs National Park which takes in the southern part of the District.

65. With the above in mind, the initial indications are that it will be unlikely that unmet housing needs could be met through reliance on cross-boundary cooperation. While all options will be explored, it appears highly likely that MVDC will have to consider options to release Green Belt land to help meet objectively assessed housing needs.

Other Issues

66. Looking beyond the approach set out in the Housing White Paper, there are a number of other issues which tend to indicate that options including release of Green Belt land should be considered.

Housing mix

67. The SHMA identifies a significant need for smaller dwellings (3 bedrooms or fewer). There can be practical difficulties with delivering smaller dwellings on a significant scale within the existing built up areas, particularly where those areas are currently characterised by much more spacious, low density development.

68. There are also a variety of specialist housing needs which the Local Plan will have to address, including housing for older people (including those in need of care), plots for self and custom build, a variety of affordable housing products and sites to cater for gypsies, travellers and travelling showpeople. In order to meet a wide range of housing needs, it is likely that larger-scale greenfield sites will have to be released, at a scale which can absorb those uses which generate lower land values without compromising the overall viability of development. Since a very high proportion of the rural areas in Mole Valley are within the Green Belt, rejecting Green Belt options as a matter of principle would seriously limit the options available to meet such needs.

Countryside beyond the Green Belt

69. The countryside beyond the Green Belt in Mole Valley is mostly very rural, with only a handful of very small, dispersed settlements. There is little scope to focus new development within an area where there are existing services such as public transport, local shops, schooling and health services. Of the four villages which are located entirely beyond the Green Belt, three have no shop, school or health services. The fourth (Ockley) has a slightly wider range of services including a village shop, but lacks a doctor’s surgery and the village infant school is currently under threat of closure.

70. The transport network is similarly poor within much of the area that is beyond the Green Belt. Most existing villages are served by rural lanes and have very limited access to public transport. The exception is the A24 corridor south of Capel where there are more frequent bus services. There are no railway stations in this area; the nearest station at Ockley lying within the Green Belt.

71. Many (but not all) of the parts of the District which are within the Green Belt benefit from better access to local services and sustainable transport options. Therefore, in terms of promoting sustainable development, release of Green Belt land could have advantages over more isolated locations, in the area beyond the Green Belt.

Rural Villages

72. Little development has taken place in the rural villages in Mole Valley for many decades. While this has achieved environmental protection objectives, it has had the unintended consequence of leading to an aging and often shrinking rural population within the villages. The demographic change is one of a number of social changes that has reduced demand for local facilities, which cumulatively can result in the closure of village schools, shops or pubs, and reduction in community activities, such as local sporting teams, which erodes their sustainability, social cohesion and sense of community. While development pressures on village locations need to be handled very carefully, continuing absolute 25

Green Belt restrictions would prevent other options being considered to reinvigorate village communities in the District.

Conclusion

73. In conclusion, there are a number of factors which, in combination, indicate that there are exceptional circumstances to justify changes to the Green Belt boundary in order to meet identified development requirements. These are listed above and summarised in the box which follows.

74. At the same time, Paragraph 14 of the NPPF lists the Green Belt as one of a number of constraints which indicate that development should be restricted. This paragraph indicates that these constraints may amount to a reason why Local Plans do not plan for objectively assessed needs in full. In considering the extent to which strategic options should include release Green Belt land, MVDC will keep this principle in mind and seek to strike an appropriate balance between meeting objectively assessed needs in full and continuing to safeguard the openness and permanence of the Green Belt for the benefit of current and future generations.

75. This will be informed by further analysis of Green Belt areas, focussed on the extent to which all parts of the Green Belt continue to serve one or more of the following five purposes, as set out in paragraph 80 of the NPPF:

 to check the unrestricted sprawl of large built-up areas  to prevent neighbouring towns merging into one another  to assist in safeguarding the countryside from encroachment  to preserve the setting and special character of historic towns  to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

76. The scope and extent of more detailed Green Belt review work, based on the principles above, will be refined following public consultation on alternative strategic options for development.

Implications for Local Plan Strategic Options: Green Belt

The NPPF confirms that Green Belt boundaries should only be altered in exceptional circumstances, through preparation or review of a Local Plan. Therefore the starting point for developing strategic options should be to consider whether such exceptional circumstances exist.

There are a number of factors in Mole Valley which together could be regarded as exceptional circumstances which justify some degree of Green Belt release to meet development needs during the Local Plan period:

 A significant shortfall in capacity to meet objectively assessed development needs on previously developed land and/or through significantly higher density development;

 A lack of large scale underused sites, including a lack of surplus public sector land on any significant scale;

 Limited apparent opportunities for cross-boundary cooperation to meet housing needs, bearing in mind the similar level of constraint faced by the majority of neighbouring authorities (although such opportunities which may exist will be fully explored in fulfilment of the duty to cooperate);

 A range of housing needs including a number of specific and specialist forms of housing, which is likely to necessitate larger-scale development to create viable development options that provide a mix of housing types and address lower-value and specialist housing needs alongside market housing;

 Sustainability issues within the part of the District which is beyond the Green Belt, where access to local services and sustainable transport options is much more limited than elsewhere in the District.

 Options for allowing modest growth in rural villages to maintain sustainability and community cohesion

Given the above circumstances, it would not be appropriate for MVDC to rule out all Green Belt land from strategic development options as a matter of principle. However, Local Plan preparation will follow the guidance in paragraph 14 of the NPPF which indicates that certain constraints – including the Green Belt – may mean that a Local Plan is unable to meet objectively assessed needs in full.

Strategic options will aim strike an appropriate balance between meeting objectively assessed needs while safeguarding the openness of the Green Belt and upholding the principle that the Green Belt should have a strong degree of permanence. This will be informed by further analysis of Green Belt areas focussed on the extent to which all parts of the Green Belt continue to serve one or more of the five purposes of including land within it. The scope and extent of more detailed Green Belt review work will be refined following public consultation on alternative strategic options for development.

Section 3: Area of Outstanding Natural Beauty 77. The Surrey Hills was one of the first landscapes to be designated as an Area of Outstanding Natural Beauty in 1958. Designation seeks to protect and enhance natural beauty whilst recognising the needs of the local community and economy. The Surry Hills AONB designation links together a chain of varied upland landscapes including the North Downs, traditionally the day trip destination for southeast London. Rising near Guildford as the narrow Hog’s Back, the ridge of the downs stretches away to the Kent border, an unmistakable chalk landscape of swelling hills and beech-wooded combes with a steep scarp crest looking south to the Weald. The whole AONB takes in 25% of land in Surrey. As it stretches east/west across the county and links with the protected landscapes of the Kent Downs AONB to the east and the South Downs National Park to the south and west, it could be considered as being of regional significance.

78. The NPPF confirms that “Great weight should be given to conserving landscape and scenic beauty in … Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty.” (NPPF para 115)

79. NPPF para 14 recognises that the AONB designation means that development should be restricted.

80. Planning policy within the Surrey Hills AONB is also informed by the Surrey Hills AONB Management Plan, the latest version of which is for the period 2015-2019. The Management Plan is a statutory management plan for the District and Borough Councils within the AONB and has been adopted by MVDC. It highlights the special qualities and enduring significance of the AONB, presents a vision for its future and sets out agreed policies and actions to support that vision. Because the AONB is located in the busy South East of England, it is hugely popular with visitors including those travelling out from Greater London. Therefore the Management Plan faces the challenge of preservation alongside the role of the designation as it seeks to protect and enhance natural beauty whilst recognising the needs of the local community and economy.

81. The AONB Management Plan further states that “the existence of an AONB designation should be considered at the very outset in Local Plan preparation and should influence the Local Plan in terms of the strategic location of development …”.

Map 7: Area of Outstanding Natural Beauty

82. With Mole Valley, the Surrey Hills Area of Outstanding Natural Beauty covers about 94km2 of land, amounting to 36% of the total land area within the District (see Map 7, above). This is a key constraint within the central and western part of the District. The AONB takes in the North Downs corridor, between the southern boundaries of Bookham, Fetcham and Leatherhead and the North Downs ridge, just north of Dorking. The villages of Westhumble, Mickleham and Box Hill lie entirely within the AONB.

83. Moving south, the AONB wraps around the west and south west of Dorking and extends approx. 6km further south, to the edge of the villages of Forest Green and Ockley. The settlements of Westcott, Abinger Hammer, Abinger Common, Coldharbour, Holmbury St Mary, Mid Holmwood and South Holmwood all lie entirely within the AONB. The villages of Forest Green, Ockley and Beare Green all lie just outside its boundary but benefit from this protected landscape setting.

Implications for Local Plan Strategic Options: AONB

MVDC considers that it would be inappropriate in principle to plan for strategic-level development in the form of strategic urban extensions, new settlements or substantial expansion of existing villages within the AONB. It is highly unlikely that such proposals would be compatible with the principle that great weight should be given to conserving landscape and scenic beauty.

Where there are existing settlements adjoining or within the AONB, the scope for smaller-scale development will be carefully considered. In this context “smaller-scale” development refers to individual sites that would provide fewer than 100 dwellings, or an equivalent scale of development for other uses. There may be some sites of this scale where limited further development could occur on the edge of existing settlements, without detrimental effect on the environment, landscape and recreational opportunities within the AONB. However, such development would require a careful design approach to ensure that the quality of the landscape is preserved and the likelihood is that this would limit the development potential.

The scope for such limited development to contribute towards meeting the District’s objectively assessed needs will be kept under review. Evidence to support allocation of sites under 100 dwellings within the AONB would have to include robust assessment of the landscape impact, including proposals for mitigation of potential landscape impacts where this appears appropriate.

Area of Great Landscape Value and Surrey Hills AONB Boundary Review

84. Parts of the countryside adjacent to the AONB are covered by a County-level designation known as the AGLV (Area of Great Landscape Value). The extent of the AGLV is shown on Map 8, below. It covers a total area of 116km2, which is 45% of the District.

Map 8: Area of Great Landscape Value

85. The AGLV has its origins in the first Surrey County Plan (1958). When the AONB was designated in the same year, all of the AGLV was incorporated the new designation. 86. County Plan Reviews in 1971 and another in the early 1980s resulted in further areas being designated, effectively as extensions to the AONB boundary. The AGLV takes in a number of areas which have their own inherent landscape quality and are significant in conserving the landscape setting of certain settlements. 87. It is recognised that local designations such as the AGLV do not carry the same weight in national policy as the AONB itself. However, there are particular local circumstances which lead MVDC to believe that the landscape importance of the AGLV should continue to be recognised as a strategic-level constraint on development for plan-making purposes. 88. In October 2013, the Surrey Hills AONB Board formally requested that Natural England consider modifying the AONB boundary. This followed two separate studies undertaken in 2007 and 2013, which indicated that there is a case for reviewing the AONB boundary and that such a review would potentially incorporate parts of the AGLV into the AONB. There has not been a review of the Surrey Hills AONB boundary since it was first designated in 1958. A key purpose of the review will be to establish whether land currently designated as AGLV should be “upgraded” and included in the AONB designation. 89. Natural England has indicated that it will undertake a review of the Surrey Hills AONB boundary in 2018. Their review will consider the whole AONB boundary, following Natural England’s agreed methodology for such reviews. 90. The current strategic landscape policy (CS13) in the Mole Valley Core Strategy 2009 safeguards the AGLV until such time as an AONB boundary review has been completed. A similar position was included in Reigate and Banstead Borough Council’s Core Strategy, which was adopted in 2014 (i.e. in the context of up to date landscape policies in the NPPF). The Core Strategy Inspector accepted this strategic approach, while recommending modifications to address the future treatment of any areas of AGLV which are not incorporated in the AONB as part of the review. 91. Against this background, MVDC remains of the view that it is appropriate to continue safeguarding the AGLV for its landscape value, at least until such time as the AONB boundary review is completed. The AGLV takes in some very rural parts of Mole Valley where there has been little development or landscape change since the designation was first established. They remain areas of great landscape value and it would not be appropriate to consider these areas for strategic-scale development until such time as their potential inclusion in a review AONB boundary has been properly considered.

Implications for Local Plan Strategic Options: AONB Review and the AGLV

MVDC considers that the Area of Great Landscape Value designation should be retained at least until such time as Natural England’s review of the Surrey Hills AONB boundary has been concluded. It will ensure that areas which are of AONB quality are not “lost” to large scale development in advance of that review.

Therefore, it would be inappropriate in principle to plan for strategic-scale development in the form of strategic urban extensions, new settlements or substantial expansion of existing villages within the AGLV.

Smaller-scale development (under 100 dwellings or equivalent) may be acceptable in principle, but would be subject to the same level of scrutiny as proposed for smaller sites on the edge of settlements in the AONB.

Section 4: Designated Heritage Assets 92. Mole Valley District has a rich heritage with an extensive network of heritage assets. There are 28 Conservation Areas wholly or partly within the district and just over 1000 Listed Buildings; a higher than average number across Surrey Districts and Boroughs. In addition, there are 27 Scheduled Ancient Monuments in Mole Valley and five gardens on the register of Parks and Gardens. The National Trust is almost certainly the largest landowner in the District.

93. The NPPF requires that Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment1, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account:  the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation  the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring  the desirability of new development making a positive contribution to local character and distinctiveness; and  opportunities to draw on the contribution made by the historic environment to the character of a place

94. Following these requirements means that heritage assets pose a constraint to development whilst meeting the need to plan positively to conserve and enhance the historic environment. Other practical constraints occur such as the scale and cost of development that can be delivered within or near to heritage assets.

95. The NPPF identifies heritage assets as buildings, monuments, sites, places, areas or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest. This analysis considers the implications of the following designations on strategic options for developments:  Listed Buildings  Conservation Areas  Registered Parks or Gardens  Scheduled Ancient Monuments  County Sites of Archaeological Importance  Areas of High Archaeological Potential

96. The extent and significance of individual heritage assets is highly variable. Many are small, individual properties while some are much more extensive. Generally they are low density and low rise. Some larger heritage assets are often set in extensive grounds often designated as historic parks and gardens. The surroundings of historic buildings are part of the asset and an important to their setting. Therefore, in terms of plan-making, the need to safeguard the wider setting of heritage assets must also be taken into account.

97. This analysis focuses on those heritage assets which are most likely to have an influence on shaping strategic options – either because of their influence on the character of an area , their intrinsic significance or of the large extent of the designated land and/or its setting.

98. Map 9, overleaf illustrates the distribution of heritage assets around the District.

Map 9: Heritage Assets

Ashtead, Leatherhead, Fetcham and Bookham 99. Within the built up area of Ashtead is a significant block of open land which incorporates a cluster of designated heritage assets, notably the Grade II* listed Ashtead Park House (now part of City of London Freemen’s School), Grade II Registered Ashtead Park (which also includes a Site of High Archaeological Potential) and the Ashtead House Conservation Area. There is a further Grade II* listed building (Ashtead Park Farm House), off Farm Lane, just outside the Registered Park and north of the Conservation Area.

100. Within Ashtead Common, to the north of Ashtead, are the remains of a Roman camp, which is a Scheduled Ancient Monument. There are also a number of areas designated for their archaeological potential.

101. The built up areas of Ashtead, Leatherhead, Fetcham and Bookham all include areas designated as Conservation Areas and/or areas of High Archaeological Potential, focussed on their historic centres. East of Leatherhead town centre is also the extensive campus of St John’s School, which includes a range of Grade II listed buildings.

102. West of Bookham, the Little Bookham Conservation Area is an example of a Conservation Area which extends outside the built up area, into the more sporadically developed and open land between Effingham and Bookham. The Conservation Area focusses around two distinct clusters of listed buildings whose rural surroundings make a significant contribution to their setting.

103. There are no very extensive designated heritage assets within the land north of Leatherhead, Fetcham and Bookham, but notable smaller assets within this area include a Scheduled Ancient Monument at Pachesham Farm, north west of Leatherhead Business Park and a particularly important group of listed buildings at Slyfield (Grade I listed) close to the District boundary north of Bookham.

North Downs 104. Much of this area is chalk downland and only sparsely developed. However, it includes a number of heritage assets which are extensive in terms of the amount of land included in the designation and the extent of their landscape setting.

105. The RAF complex at Headley Court is focussed on a Grade II listed building and there are also several sites of archaeological potential in the vicinity.

106. Cherkley Court, just south of Leatherhead, is a Grade II listed country house (currently being converted to a hotel and golf course), the grounds of which include a substantial Site of High Archaeological Potential.

107. Norbury Park is a Grade II Registered Park, south of Fetcham, south of which is the Grade II* listed Norbury Park House. The Registered Park abuts Mickleham Conservation Area, the centre of which also includes a Site of Archaeological Potential and the Grade II* listed Parish Church.

108. West of Norbury Park and south of Bookham is the National Trust’s flagship property and regional centre at Polesden Lacey, a Grade II* listed country house standing in its Grade II* listed Registered Garden. There is a distance of only just over 1km as the crow flies between the Registered Parks at Norbury Park and Polesden Lacey, giving a clear indication of the historic significance of this part of the North Downs.

109. All of the above heritage assets are within the North Downs landscape, within a distance of 2.5km from the edge of the built up areas to the north. Taken together, they form a belt of 36

former country house estates which is part of the historic landscape of this part of the North Downs. Constraints to development would not only apply to land close to these heritage assets the views into and from this string of heritage assets would be a constraint at a greater distance.

110. At a smaller scale, but also covering a wide geographical area, the scarp slope of the Downs is noted for a series of defensive installations in the form of pill boxes.

Dorking 111. In the centre of the District, the town of Dorking has a large historic core, with an extensive Conservation Area including an Area of High Archaeological Potential. In the heart of the Conservation Area is the Grade II* listed St Martin’s Church, the spire of which is a prominent landmark. Views of the spire are available throughout the town and from the surrounding landscape and are highlighted in the Dorking Conservation Area Appraisal and Management Plan as a feature which merits safeguarding.

112. South of the town centre, Dorking’s Conservation Area takes in the substantial open space at Cotmandene, which in turn abuts the Grade II* Deepdene Estate Registered Park, creating a linked set of heritage assets within the undeveloped areas on this edge of the town. MVDC is engaged in a project to restore and open up the Deepdene estate, raising the profile of this historic landscape and opening it up to public access and this is a very significant heritage asset on the edge of the town.

113. West of Dorking, the village of Westcott includes two Conservation Areas. As well as the existing developed part of the village, these take in more open areas on its edge, at Milton Heath and around the Parish Church. Therefore the setting of these Conservation Areas extends into the surrounding, largely wooded landscape.

114. Also between Westcott and Dorking is the Grade II* listed Milton Heath House, which benefits from an extensive landscape setting along the valley formed by the course of the Pipp Brook.

115. To the east of Dorking is a succession of villages (Brockham, Betchworth and Buckland), each with its own Conservation Area. In each case, the Conservation Area takes in open land and areas of woodland beyond the built up part of the village, which have been identified as forming an important part of its setting.

Greensand Hills and Wooded Weald 116. Within this largely rural area, there is a significant number of listed buildings. Although many of these are small, domestic-scale properties, they are scattered throughout the area and make a rich contribution to the character of villages and hamlets in this part of the District.

117. The larger and more notable properties include Wotton House, which is a Grade II* listed country house (now a hotel), standing in grounds which are also a Grade II* Registered Park. There are also significant Grade II* listed buildings at Goddards, in Abinger Common and at Leith Hill Place with local cultural and landscape links of national importance, as well as several of the parish churches. The Grade 1 St John’s Church at Wotton is of particular note and owes much of its charm to its prominent, open position in the landscape.

118. Almost all the villages in this area have Conservation Areas at their heart, all of which take in areas of open land around each village which contribute to their historic setting. In the case of Coldharbour and Ockley, these also include areas with high archaeological

potential, notably the Anstiebury Camp at Coldharbour, which is also a Scheduled Ancient Monument.

119. The route of the Stane Street Roman Road is also designated as a long, narrow Site of High Archaeological Potential which extends from the southern District boundary, through Ockley and north to the southern edge of Dorking.

Low Weald 120. This area also has a substantial number of listed buildings, both within the villages and scattered throughout the rural area. A high proportion of these are buildings that serve or once served agricultural purposes.

121. Almost all villages include conservation areas, most of which also include Areas of High Archaeological Potential. The village of Charlwood has a particularly high concentration of listed buildings, including the Grade I listed parish church and several mediaeval farm houses around the periphery of the village, whose settings include areas of adjacent open countryside. All the village conservation areas include areas of open land around the village centre, which often incorporates important views into and out of the village. The inclusion of open land within a conservation area boundary reflects the strong relationship between these historic villages centre and the surrounding Wealden landscape, which is very much part of the character of southern Mole Valley.

Implications for Local Plan Strategic Options: Designated Heritage Assets

There are five Registered Parks in Mole Valley. Since the heritage interest of this designation is intrinsically associated with their landscape value, the land included in this designation will be safeguarded from strategic development as a matter of principle. Such safeguarding extends to the setting of each Park or Garden.

All other heritage assets will continue to be protected. The need to safeguard heritage assets and their setting will be a key consideration and may limit achievable development. The following conclusions are drawn from the analysis of heritage assets and will be taken into account when working towards a preferred strategic option for development.

In the north of the District, designated heritage assets are mainly focussed within the built up areas, particularly around their historic centres. But three key exceptions are:

 The south eastern part of Ashtead, in the area of Ashtead Park and the Ashtead House Conservation Area. Within this area, multiple heritage designations cover a substantial area which lies outside the existing built up area.

 Little Bookham, whose Conservation Area takes in land outside the existing built up area, in the more sporadically developed area between Bookham and Effingham.

 The cluster of buildings together with their setting adjacent to the River Mole at Slyfield that includes two Grade 1 listed buildings.

There are extensive heritage assets within the rural landscape of the North Downs, including a series of historic country houses lying south of Ashtead, Leatherhead, Fetcham and Bookham. When their grounds (some of which are Registered Parks) are taken into account, these have an influence over a substantial part of the AONB landscape.

In the centre of the District, the setting of Dorking’s Conservation Area takes in several long views of St Martin’s Church spire from several parts of the surrounding rural landscape, including the Nower, White Downs, Ramore Common, Denbies hillside and Box Hill.

The Deepdene Estate on the south eastern edge of Dorking is also a key heritage asset which has an influence over an extensive area of undeveloped land, particularly when viewed in combination with the open space at Cotmandene, on the edge of the Conservation Area.

West of Dorking, the two Grade II* country houses at Milton Court and Wotton House stand in extensive landscape settings, which should be safeguarded.

Elsewhere in the rural areas, the key constraint is the need to safeguard the setting of conservation areas, with almost all villages including a conservation area that takes in open land, reflecting the strong connection between these Wealden villages and their rural surroundings.

Section 5: Locations at Risk of Flooding 122. Paragraph 100 of the NPPF states that ‘inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere’.

123. A sequential, risk-based approach should be applied to location of development. The aim of this is to steer development to areas with the lowest probability of flooding.

124. This analysis focuses on the areas that are most at risk from fluvial and surface water flooding and are therefore most likely to have an impact on directing strategic options. It identifies areas of highest risk and has been informed by information from Surrey County Council and the Environment Agency that post dates Mole Valley’s existing strategic Flood Risk Assessment (SFRA).

125. MVDC has commissioned a joint Level 1 SFRA, in partnership with Reigate & Banstead Borough Council and Tandridge District Council. Surrey County Council is also reviewing their Flood Risk Management Strategy and developing a Bookham Flood Alleviation Scheme. The Environment Agency is in the process of compiling new Flood Alleviation Schemes for Dorking, and Fetcham and Leatherhead. Additional evidence emerging from these ongoing projects will feed into the Local Plan process as and when it is available.

126. Catchment flood management plans (CFMPs) consider all types of inland flooding and are a further source of information to help the Environment Agency and their partners to plan and agree the most effective way to manage flood risk in the future.

127. Mole Valley falls within the River Thames and River Arun CFMP. The Middle Mole and Upper Mole policy units are within the River Thames CFMP and cover the majority of the District. The Rural Wey area covers some of the west of the District and a slither of the Hogsmill policy unit covers the north east. The River Arun catchment covers the south west corner of the District.

128. The built up areas of Leatherhead, Dorking and Fetcham are on the River Mole. There are also tributaries to the Mole which contribute to fluvial flooding in and around the built up areas, chiefly the Pip Brook which runs through Dorking and the Rye Brook which runs along the north edge of Ashtead.

129. Mitigation of flood risk will be an important factor when bringing forward the Transform Leatherhead project as this will include a substantial riverside re-development and offer opportunities to improve both fluvial and surface water flooding in the area.

130. The Mole and a number of smaller tributaries flow through Brockham and Betchworth, and parts of these areas were subject to severe flooding in 2103/14.

131. In the south east corner of the District the River Mole and Gatwick Stream converge. There are also a number of smaller tributaries, not all of which lie within the District, that contribute to fluvial flooding in the villages of Charlwood and Hookwood. The discharge of water from Gatwick Airport can also have an impact on the river levels and fluvial flooding in this area.

132. A number of areas in the District are also susceptible to localised surface water flooding which occurs through run-off from adjacent land normally following heavy rain fall. Areas affected include the built up areas of Bookham and Fetcham and parts of the village of Brockham and Strood Green.

133. The role the countryside plays in minimising the risk of flooding should also be considered in how the rural area of the District plays a key role in strategic flood management. Natural Flood Management schemes can be combined with hard defences together with lagoons, swales and porous surfaces to absorb water in towns. But this could constrain development upstream from urban areas in the countryside.

134. The following sections highlight more specific areas affected by fluvial (river) and surface water flooding, in different parts of the District.

Map 10: Risk of Fluvial Flooding

Fluvial Flooding

135. Areas at risk of fluvial flooding are shown on Map 10 (above).

Ashtead, Leatherhead, Fetcham and Bookham

136. The Rye Brook runs along the north edge of Ashtead, creating an area at risk of fluvial flooding along the northern edge of the built up area.

137. In Leatherhead, parts of the town centre are at risk of fluvial flooding, in the immediate vicinity of the River Mole. Much of the River Mole corridor between Leatherhead and Fetcham is in Flood Zone 3. North of the town, the River Mole floodplain widens out within the generally flatter terrain and a substantial area either side of the watercourse is in Flood Zone 3.

138. In Fetcham, properties in the around Cannon Way and Cannon Grove are susceptible to flooding and there was significant property flooding in the 2013/14 flood event. Although much of this area is within Flood Zone 2, there are indications that this may be reviewed (i.e. that the level of flood risk has increased) as a result of ongoing remodelling work. In this part of Fetcham there are issues with both fluvial and surface water flooding and a Flood Alleviation Scheme is under development which aims to address the combined impact.

139. Around Bookham, the key issue is surface water flooding, associated with the underlying geology and a particular issue in the Lower Road area. Fluvial flooding is less of an issue, although there is a small area in the north of Bookham, near the railway station and extending into Bookham Common, which is identified as being at risk.

North Downs

140. Flood risk within this area is focussed on the River Mole, where it flows through the Mole Gap. Areas on the edges of Mickleham and Westhumble lie within the area at risk of flooding.

Dorking

141. Around Dorking, there are areas at risk of fluvial flooding in Pixham, in the north east of the town and along the course of the Pipp Brook; a tributary of the River Mole flowing from west to east just north of the town centre. The Pipp Brook valley also includes areas at risk of flooding west of the town and around the north and west of Westcott. But in general, these are relatively narrow compared to the flood plains of the River Mole.

Greensand Hills and Wooded Weald

142. This area is mostly within the River Wey catchment with the south western most corner covered by the River Arun CFMP. Within the Greensand Hills, areas at risk of flooding are generally small and dispersed. There are some very small areas at risk of fluvial flooding, along the Tillingbourne which flows west through Abinger Hammer.

143. Further south, there are areas at risk of flooding along tributaries of the River Arun, flowing south through the rural areas.

144. In general, in this part of the District, areas at risk of fluvial flooding are fairly contained and do not spread over a wide area.

Low Weald

145. The section of the River Mole south east of Dorking has a largely rural flood plain. The river and tributaries are small in size but cover an extensive area. To the south, the river often forms the District boundary. But when it turns towards the west, the areas at risk of flooding skirt around the edge of Betchworth and take in a significant corridor through the village of Brockham.

146. The Gad Brook also flows into the Mole at Brockham and there are further areas to the south of the village which are at risk of surface water flooding, meaning that Brockham is affected by flooding from several different sources.

147. In the south of Mole Valley, Charlwood and Hookwood are further villages with significant areas at risk of flooding. The River Mole and Gatwick Stream converge downstream of Crawley and the Withy Brook, Hookwood Common Brook and Spencer’s Gill are short tributaries which drain the land to the north-west of Gatwick Airport. Conditions on the River Mole can impact on these tributaries, affecting the flow of water away from communities like Hookwood. Much of the countryside around Hookwood is within Flood Zones 2 or 3 and there are also significant areas at risk of flooding to the south and east of Charlwood.

148. A significant flood alleviation scheme has been undertaken around the Upper River Mole catchment to provide flood relief to the Crawley and Gatwick area. A further flood detention reservoir at Ifield was previously proposed, however the planning application for this site has recently been postponed to allow time for the business case to be revisited. The location of the proposed works is close to the southern boundary of the District.

Map 11: Risk of Surface Water Flooding

Surface Water Flooding

149. Areas at risk of surface water flooding are shown on the Map 11 (above).

Ashtead, Leatherhead, Fetcham and Bookham

150. Parts of Bookham are at risk of surface water flooding, particularly in the Lower Road area. The Great Bookham Flood Risk Study Initial Assessment (Surrey County Council 2012) puts forward a series of recommendations for potential alleviation schemes. The 'Wet Spots' database shows that a number of locations are experiencing difficulties, including as a result of blocked gullies, drains and culverts, some of which are on private property. Some incidents may also be as a result of highways and land drainage issues as water drains northwards into Bookham Common.

151. Surface water flooding has also been identified as an issue in Fetcham, where the dispersal of surface water is in places impeded by the raised railway line.

North Downs

152. In places the River Mole floodplain and roads are bounded by steep sided hills which may be a source of flooding as a result of overland flow. There are a number of records of surface water flooding in this area particularly affecting the main roads. However, it should be noted that a series of drainage and re-surfacing improvements were carried out along the A24 in 2015 and 2016.

Dorking

153. Very few incidents of surface water flooding have been reported in Dorking although there is anecdotal evidence that some surface water drains, particularly in relation to roads, have been unable to cope with water flows at times of heavy rain fall; and some can take a long time to clear.

154. In general, there are very few reported incidents of surface water flooding of a significant scale in the more rural areas. The exception is in the village of Brockham, where surface water flooding is a significant issue in the area south of Brockham and around Strood Green. In 2013, planning permission was refused for development of the reserve housing site on the west side of Strood Green on grounds of unacceptable flood risk. This decision was upheld at appeal.

Implications for Local Plan Strategic Options: Flooding

Parts of the District where there is a significant area known to be at risk of flooding include:

 The area between Fetcham and Leatherhead, along the River Mole corridor, including the Cannon Grove area of Fetcham (fluvial and surface water);

 Land north of Leatherhead, along the River Mole (fluvial);

 Parts of Bookham (surface water);

 The Pixham area of Dorking (fluvial);

 The village of Brockham and Strood Green (fluvial and surface water);

 Areas around Charlwood and Hookwood (fluvial).

The NPPF states that development should be directed away from areas of highest risk and this will inform the consideration of strategic options for development.

Land within the functional flood plan (Flood Zone 3b) is excluded from development to meet strategic housing or employment needs as a matter of principle. This land will be identified in the Strategic Flood Risk Assessment.

Beyond that, if insufficient land is available in the areas at lowest risk, strategic options will be subject to a sequential and exception tests, in order to take into account the potential impact of any development on increased flood risk in the wider area and the effects of climate change.

In some cases, development in areas at risk of flooding may have potential to incorporate measures to reduce risk from both fluvial and surface water flooding.

A Strategic Flood Risk Assessment is under preparation. Consultation with the Environment Agency and Surrey County Council as Lead Local Flood Authority will also help MVDC to develop strategic options which take appropriate account of flood risk issues.

Section 6: Common Land and Inalienable Land 155. In parts of Mole Valley, there are substantial swathes of land which are designated as Common Land. The National Trust also has significant landholdings, which in some cases adjoin Common Land and extend the area of constraint. Substantial areas of the National Trust estate are designated as inalienable land.

156 Map 12 (below) illustrates the extent of land which is Common Land and/or National Trust inalienable land.

Map 12: Common and Inalienable Land

157. Under the terms of the National Trust Acts, inalienable land held for the Trust’s charitable purposes is effectively unavailable for development, other than for small scale proposals to facilitate the operational work of the National Trust, which are compatible with the National Trust Acts and do not have a negative impact on the physical quality and features of the land as a special place of natural beauty or historic interest which led to it being declared inalienable.

158. Furthermore, inalienable land cannot be sold or given away and cannot be compulsorily purchased except through Special Parliamentary Procedure. Therefore this land is safeguarded in perpetuity and it can safely be assumed that there is no reasonable prospect of strategic-scale development taking place on inalienable National Trust land.

159. Within Common Land, development is strictly controlled under the Commons Act 2006. In circumstances where development is proposed that would not be consistent with the traditional use of the common, it would generally be necessary to obtain consent for deregistration of the Common Land in question. Furthermore, applications which would require more than 200sqm of land to be deregistered are required to include a proposal for a replacement area of Common Land to be provided (s16 Commons Act 2006).

160. In practice, there is little realistic prospect that large-scale development would take place on Common Land and MVDC considers that it is reasonable to rule out all such areas from inclusion in strategic options for development.

161. The most significant areas of Common and Inalienable land in the District are as follows:

 Ashtead Common includes just over 2km2 of designated Common Land, which continues beyond the District boundary into Epsom Common, immediately to the east and includes the Wood Field, on the edge of the built up area, south of the railway station.

 Bookham Common extends to approximately 1.75km2 of Common Land, which is also inalienable National Trust land.

 Within the North Downs there are very large expanses of inalienable National Trust land at Norbury Park, Ranmore Common, Box Hill, Mickleham Downs and Headley Heath. Within this area are two large expanses of Common Land, at Ranmore Common (approx. 2.5km2) and Headley Heath (approx. 2km2)

 The Leith Hill area includes substantial areas of both Common Land and inalienable National Trust land, extending to over 6km2 and taking in much of the land around Coldharbour and between Abinger Common and Forest Green.

 In the west of the District, Abinger Roughs is an area of about 1km2 which is inalienable National Trust Land, lying north of the A25 and south of the railway line.

 Holmwood Common; to the south of Dorking and North Holmwood, this is an area of approximately 2.5km2 all of which is both Common Land and inalienable National Trust land.

162. At a much smaller scale, there are several open spaces within and adjacent to the built up areas which are designated as Common Land. Larger examples include Common Meadow (immediately north of the River Mole, between Leatherhead and Fetcham), the Kingston Road recreation ground in Leatherhead, Cotmandene on the southern edge of Dorking, parts of Milton Heath on the west side of Dorking, the Big Field at Brockham and several of the village greens in the south of the District.

Implications for Local Plan Strategic Options: Common Land and Inalienable Land

For purposes of considering Local Plan strategic options, it can be assumed that there is no prospect of development to meet the District’s strategic housing or employment needs on land which is registered as Common Land and/or which has been designated by the National Trust as inalienable land.

Section 7: Noise 163. Paragraph 14 of the NPPF does not include noise within the list of constraints which might indicate that development should be restricted. However, paragraph 123 states:

Planning policies and decisions should aim to:

 avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development;  mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions;  recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established; and  identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason.” (NPPF Paragraph 123, emphasis added in italics)

164. Further guidance on noise issues is included in National Planning Policy Guidance. This reflects the contents of the Noise Policy Statement for England and confirms that plan- making should consider noise issues, including whether the overall effect of the noise exposure would be above or below the significant observed adverse effect level. It is further noted that noise exposure is a complex technical issue and it may be appropriate to seek experienced specialist assistance.

165. National Planning Policy Guidance also emphasises that noise issues should not be considered in isolation but alongside other social, economic and environmental factors.

166. This section focusses on significant noise sources which have a constraining influence over a significant area of land in Mole Valley and which could have an impact on strategic options for development. The first is road noise in the M25 area around Leatherhead and Ashtead. The second is aircraft noise associated with Gatwick Airport.

M25 road noise 167. In the north of the District, the M25 motorway enters Mole Valley close to the District boundary and turns south through the gap between Leatherhead and Ashtead. In this area, the motorway and its associated slip roads are a significant noise source, very close to the existing built up area. The A24 Leatherhead Bypass passes through the same corridor.

168. In order to inform the plan-making process, MVDC commissioned Southdowns Environmental Consultants to undertake a Strategic Noise Assessment of this M25 corridor. The assessment uses computer modelling to examine the influence of road noise on currently undeveloped land within 250m of the motorway, in the Leatherhead and Ashtead area.

169. The aim of the Southdowns assessment was to identify the extent to which road noise originating from the M25 and adjacent major roads acts as a strategic constraint on residential development within this corridor. It focusses on residential uses, because housing is likely to be the largest component of strategic development options and because residential uses are likely to be more sensitive to noise than other uses considered during the plan-making process.

170. The aim was to gain a better understanding of the current noise environment and understand what design and mitigation measures might be required to achieve a satisfactory residential environment.

171. In order to provide a complete understanding of the noise environment, the study considers three “Zones”, each of which has a different topographical relationship with the M25. It must be emphasised that all the land within the study area is within the Green Belt and therefore currently safeguarded from development as a matter of principle. Inclusion of land within the noise study area does not change this position and does not pre-empt the process of developing strategic options and considering the most appropriate means of meeting the District’s objectively assessed needs. Where residential development is shown in the study report, it is purely for purposes of modelling, in order that a better understanding of the noise environment can be developed. Nothing in the Southdowns report should be taken as implying support for allocation of any specific site in the Local Plan.

172. World Health Organisation guideline values for outdoor living areas indicate that few people may be moderately or seriously annoyed below criteria levels of 50 dB LAeq,T and 55 dB LAeq,T respectively. The Southdowns assessment reveals that traffic noise exceeds these levels throughout the study area. In many of the existing residential areas, it can be seen that the buildings appear to be effective in screening noise and reducing outdoor noise levels to within the 50-55 dB LAeq,T range or below. However, this is not the case in all areas closest to the motorway.

173. The assessment examines the theoretical impact of residential development within the study area. It reveals that in most locations windows would have to remain closed in order to achieve acceptable guideline levels. Therefore noise mitigation measures are likely to include alternative ventilation provision.

174. The assessment further indicates that properties closest to the M25 should not have habitable rooms facing towards the motorway. Furthermore, such properties should be positioned such that they create a near continuous façade, in order to serve as a noise screen for land further from the M25.

175. The implication is that, if strategic options contemplate the release of greenfield sites in close proximity to the M25, significant noise mitigation measures will be required. In practice, this is likely to involve high residential densities in the areas closest to the M25, in order to create a building mass which would maximise noise screening for land in its “shadow”. Housing in almost all areas would also require a high standard of sound proofing and alternative ventilation systems to enable windows to be kept closed.

176. In areas north of Leatherhead, there appears to be scope to create an acceptable outdoor environment through careful positioning of buildings to create garden areas which are sheltered from noise. However, this is more difficult to achieve in the rest of the study area, where baseline noise levels are higher. Therefore, should greenfield sites in this area be considered, they would have to accommodate forms of development catering for households who do not have a requirement for a private garden (e.g. flats). Mitigation measures are likely to include careful design of enclosed and relatively quiet external amenity spaces – for example spaces enclosed within courtyard developments – in order to provide residents with access to outdoor spaces protected from noise.

177. The mitigation measures recommended in the Southdowns assessment are broadly in line with National Planning Policy Guidance, which suggests that noise impacts on residential development may be partially off-set if residents have access to a relatively quiet façade and/or are provided with access to nearby quiet external amenity spaces (NPPG paragraph 009 Reference ID:30-009-20140306).

Aircraft Noise 178. In the south of the District, aircraft movements to and from Gatwick Airport generate substantial noise levels which have an influence over much of the south east of Mole Valley. In order to monitor the areas so affected, the Civil Aviation Authority’s Environmental Research and Consultancy Department estimates noise exposures around London’s airports (Heathrow, Gatwick and Stansted) for the Department for Transport on an annual basis. The magnitude and extent of the aircraft noise around the airports are depicted on maps by contours of constant aircraft noise index (Leq) values.

179. Map 13 (below) illustrates the extent of the noise contours for Gatwick Airport.

Map 13: Gatwick Noise Contours 53

180. Charlwood is the most directly affected existing settlement, with much of the southern and eastern part of the village significant affected by aircraft noise. But the area affected by aircraft noise also takes in a substantial area of open countryside in the south of the District, south of Newdigate and Capel and extending west slightly beyond the A24.

181. The level of aircraft noise which constitutes a significant adverse impact is not clearly defined, either in the NPPF or the Noise Policy Statement for England. UK policy has historically identified 57dB LAeq as the threshold at which daytime noise marks the onset of significant community annoyance. The Government’s Aviation Policy Framework 2013 sets out that overall policy on aviation noise is to limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise. It further confirms the Government’s intention to continue to treat the 57dB LAeq 16 hour contour as the average level of daytime aircraft noise marking the approximate onset of significant community annoyance.

182. Arguably, the 57dB LAeq 16 hour contour may not fully reflect the day-to-day experience of people living within the affected area. The noise contours are based on modelling of an equivalent continuous sound level, taking into account daily movements over a 16 hour period. Within that period, residents may also experience short bursts of more intense sound, so that peak noise levels may be in excess of the apparent 57dB threshold.

183. World Health Organisation guidelines indicate a significant risk that open space and amenity areas will be adversely affected by noise levels in excess of 55dB (LAEQ16hr), which implies that a wider area would be significant affected by aircraft noise. A Civil Aviation Authority Survey of Noise Attitudes (2014) also discovered that a higher proportion of residents experienced high levels of annoyance at levels below 57dB, compared with a 1982 study.

184. Nevertheless, for purposes of the Local Plan, the 57 dB LAeq 16 hours contour is a readily available source of evidence, which is consistent with current Government aviation policy on noise levels. Therefore, it can be used to indicate the minimum area where it can reasonably be assumed that aircraft noise should be regarded as a strategic constraint on development and where it would not be appropriate to plan for a significant level of population growth. Any subsequent guidance which suggests a different threshold can be used to inform development of the Local Plan, as and when required.

Implications for Local Plan Strategic Options: Noise

Strategic modelling indicates that baseline road noise levels in the M25 corridor in the Leatherhead and Ashtead area exceeds World Health Organisation and BS8233 guidelines for an acceptable indoor and outdoor living environment.

Should residential development be contemplated in the affected area, significant noise mitigation measures would be required. A detailed approach would require further, site-specific analysis, but generic mitigation measures are likely to involve:

 Arranging buildings to provide a near-continuous façade along site boundaries closest to the M25, in order to shelter land at a greater distance.

 Avoiding habitable rooms in façades directly facing the M25.

 Providing a high standard of sound insulation in the structure of the building.

 Providing alternative forms of ventilation, in order that a comfortable internal environment can be maintained with windows closed.

 Arranging buildings to shield outdoor areas from noise and create acceptable outdoor amenity levels.

In parts of the area, family housing with private gardens may not be achievable, because of the difficulty in achieving satisfactory noise levels in outdoor areas. The likelihood is that higher density (e.g. flatted) development would be more effective in achieving satisfactory noise mitigation. The design approach would need to ensure that residents had easy access to shared outdoor amenity areas with an acceptable noise environment.

In line with National Planning Policy Guidance, the implications of the above measures on the design of development will be considered alongside other social, environmental and economic factors, when deciding whether locations in close proximity to the M25 should be included in strategic options for development.

In the south east of the District, the 57LAeq 16 hour noise contour indicates an area where aircraft noise is likely to cause significant community annoyance and where any material increase in population should be avoided as a matter of principle. This is consistent with the approach in the Government’s Aviation Policy Framework 2013. Any subsequent guidance which suggests a different threshold should be adopted will be used to inform development of the Local Plan as required.

Section 8: Air Quality 185. National Planning Policy Guidance advises that air quality issues should be taken into account in plan-making, in order to take account of air quality management areas and other areas where there could be specific requirements or limitations on new development because of air quality. Local Plans may need to consider the cumulative impact of smaller development as well as the effect of more substantial development. The appropriate use of mitigation measures can also be a consideration. 55

186. MVDC undertakes air quality monitoring in order to identify any relevant areas where it is considered that the government’s air quality objectives will be exceeded. To date, monitoring reports have concluded that there are no requirements to proceed to detailed assessments for any pollutants of concern in the Mole Valley District (2016 Air Quality Annual Status Report (ASR)). The Council will continue to maintain and review existing monitoring sites throughout the district with a view, where possible, to increasing spatial coverage and understanding. 187. Potential air quality issues in Mole Valley are most likely to arise from increased road use within and around the district. Mole Valley monitors in these areas for NO2 through the deployment of diffusion tubes. Monitoring locations have been selected to be representative of the types of location where pollution from road traffic is most likely to give rise to air quality issues, including in the vicinity of the M25 and in West Street, Dorking, where there is a pattern of stationery traffic on a narrow highway enclosed between relatively tall buildings.

188. Air Quality Management Areas (AQMAs) are declared when there is an exceedance of likely exceedance of an air quality objective. MVDC currently does not have any AQMAs and the 2016 ASR confirmed that there have been no significant changes to NO2 concentrations or emissions elsewhere in the district since the previous round of review and assessment.

189. Based on the information available from current air quality monitoring measures, there is no indication that air quality issues will be a material issue in determining the most appropriate strategic options for development. National Planning Policy Guidance provides the framework for the issue to be kept under review and if it becomes apparent that site- specific mitigation measures are required in any specific location, this can be addressed as the Local Plan progresses.

Implications for Local Plan Strategic Options: Air Quality

There are no Air Quality Management Areas within Mole Valley. Based on the most recent monitoring reports, there is no evidence that air quality issues will be a material issue in determining the most appropriate strategic options for development.

Should it become apparent that site-specific mitigation measures are required in any specific location, this can be addressed through allocations policies, as the Local Plan progresses.

Section 9: Transport 190. Transport infrastructure is not one of the constraints identified in Paragraph 14 of the NPPF. However, the NPPF requires local planning authorities to work with providers and other authorities to assess the quality and capacity of transport infrastructure (NPPF para 162) during the plan-making process. National Planning Policy Guidance also highlights the importance of establishing a robust transport evidence base in order to support the preparation of a Local Plan. The evidence base should identify opportunities for encouraging a shift to more sustainable transport usage, where reasonable to do so and highlight infrastructure requirements which will need to be progressed during implementation of the Local Plan.

191. Local Planning Authorities must also have regard to Circular 02/2013 which sets out principles for local authorities working with Highways England during the plan-making process, to safeguard the strategic road network.

192. As a first step in establishing the evidence base for transport considerations, MVDC commissioned Surrey County Council to analyse current transport patterns and issues in the District. Their report provides an insight into existing transport trends and constraints, covering all modes of transport. It covers the following topics:

 Commuting patterns, including modes of transport, distances travelled to and from work and the most prevalent workplace destinations both within and outside Mole Valley.

 Recent trends in traffic growth.

 Existing patterns of congestion and the parts of the highway network most affected.

 Locations with known road safety issues.

 Usage of public transport services (bus and rail), including an analysis of level of public transport availability in different areas of the District and the areas which are most accessible by bus or rail, both within and outside the District.

 Cycle usage including the availability of cycle routes and factors affecting people’s propensity to cycle as a regular means of transport.

 Future transport schemes, covering planned improvements to highways, public transport and cycling facilities.

193. The following issues are identified which will have a bearing on the development of strategic development options for the Local Plan:

 Analysis of travel to work patterns and the modes of transport used indicate a high reliance on the private car. Car availability is higher in Mole Valley than in Surrey and the South East as a whole.

 The proportion of Mole Valley residents walking to work or working from home is higher than the Surrey average. But use of public transport and cycling is below County and Regional levels.

 There is potential for greater use of more sustainable modes of transport, including cycling, particularly for journeys of 2-5km.

 The majority of Mole Valley residents who commute by car are also travelling to a workplace within the District, with the town centre of Leatherhead and Dorking being key destinations.

 Traffic flows have remained relatively constant in Mole Valley between 2010 and 2014, with traffic levels falling slightly between 2010 and 2013 and then rising marginally the following year.

 There are existing congestion issues on the approaches into both Leatherhead and Dorking centres, notably in the areas around the Knoll Roundabout/A24/Leatherhead bypass and Waterway Road, Leatherhead and the A24 in the area of the North Holmwood roundabout/Chart Lane/Deepdene Avenue in Dorking. To a lesser extent, congestion is also identified as an issue on the A25 approaches to the east and west of

Dorking, the Randalls Road approach into Leatherhead, parts of the A243 Kingston Road and roads linking to the A24 south of Leatherhead.

 Congestion on the M25 clockwise between junctions 8 and 10, including the off slip at junction 9a Leatherhead, is highlighted as an issue.

 Generally speaking, highway safety in Mole Valley is good, with the District having the lowest proportion of casualties of all the Surrey Districts and Boroughs. However, some specific safety issues are highlighted in Dorking town centre (High Street and South Street), the A24 at Mickleham and Junction 9a of the M25.

 There is relatively good coverage of bus routes and services serving the main centres of Leatherhead and Dorking. Accessibility to bus services in the rural areas is not so good, although demand responsive bus services aim to address this issue. Throughout the District, bus reliability is well below target levels, which is likely to be associated with congestion and parking issues in the built up areas and is also likely to be a factor in residents’ reluctance to use buses for regular journeys.

 Use of rail for commuting is most prevalent for journeys of 30-40km, with Central London being a key destination for Mole Valley residents. Rail-based commuting into Mole Valley tends to be from shorter distances (e.g. from Epsom and Ewell and Reigate & Banstead).

 Within Surrey, Mole Valley is the District with the highest proportion of residents that have cycled in the last 12 months. 27% of residents cycle up to 2-3 times per week, according to a SCC Survey in 2015. But leisure and off-road cycling is more popular than cycling on the roads as a main means of transport. Safety concerns are a key reason why people choose not to cycle and improved cycle infrastructure is one of the means to address this.

 Highways improvement schemes currently in the pipeline include a Transport Study of Dorking, Highways England investigations of measures to address issues at M25 Junction 9a and improved road safety measures on the A24 at Mickleham.

 A Sustainable Transport Package for Leatherhead is being developed jointly between MVDC and SCC as part of the Transform Leatherhead project and a Dorking Sustainable Transport Package is also underway focussed on public transport improvements, including linkages between Dorking Deepdene and Dorking Main railway stations. The Mole Valley Cycle Plan covers a range of measures to improve cycle infrastructure and encourage greater participation in cycling.

194. As Local Plan preparation progresses, MVDC will work with SCC and Highways England to ensure that strategic development options take account of known transport issues and incorporate appropriate mitigation of the additional impact on the transport network. This will include a strategic transport assessment to model the impact of growth on traffic levels both within Mole Valley and across administrative boundaries.

Implications for Local Plan Strategic Options: Transport

In line with national planning guidance, Local Plan preparation should include measures to encourage a shift to more sustainable transport usage, where reasonable to do so and highlight infrastructure requirements which will need to be progressed during implementation of the Local Plan.

The development of strategic options should take account of existing known congestion issues, particularly affecting the approaches into Leatherhead and Dorking town centres. Strategic transport modelling will be undertaken as part of the process of developing a preferred strategic option.

Account should also be taken of different levels of accessibility to public transport options, with the urban areas generally being significantly better served than the rural ares.

Close working with Highways England will be required to understand the implications of congestion and safety concerns on the M25, particularly at Junction 9a.

Provision of cycle infrastructure as part of strategic options may be a factor in realising the potential for a shift away from use the private car for shorter journeys of 2-5km.

Conclusions 195. The boxes at the end of each of the above sections highlight the key constraints which will influence the strategic direction of the Local Plan. In some cases, they identify fundamental constraints which preclude development of a strategic scale on land within certain categories. In this context, development of a strategic scale refers to developments providing more than 100 dwellings, or an equivalent amount of development for alternative uses.

196. The areas within which strategic-scale development is ruled out as a matter of principle are as follows:  Land within the Surrey Hills Area of Outstanding Natural Beauty (AONB)  Land within the Area of Great Landscape Value (until such time as a review of the AONB boundary has been completed by Natural England)  Land which is designated as a Site of Special Scientific Interest  Land which is designated as a Special Area of Conservation  Land which is designated as a Registered Park or Garden  Land within the Functional Flood Plain (Flood Zone 3b)  Common Land  Inalienable Land within the ownership of the National Trust

These areas are shaded grey on Map 14 (below).

Map 14: Areas excluded from strategic-scale development on principle 61

197. In addition to these fundamental constraints, there are a number of key areas where it can be anticipated that strategic options would have to incorporate mitigation measures to take account of important constraints. These are illustrated on Map 15 (below) and the issues can be summarised as follows:

Constraint Implications for strategic options

Nature Conservation: Further engagement is required with Natural England and European Sites other stakeholders to inform the Habitats Regulations Assessment of the Local Plan and develop strategic approach which does not have an adverse impact on the integrity of European Sites and incorporates an appropriate mitigation strategy where required.

Discussions will particularly focus on the implications of any strategic options involving land within the 5km or 5-7km zones around the Thames Basin Heaths SPA and options which are land in locations which are likely to increase recreational pressure on the Mole Gap to Reigate Escarpment SAC.

Nature Conservation: There is an extensive network of nature conservation sites SSSIs and other throughout the District. Only SSSIs and European Sites are designated areas excluded from strategic options as a matter of principle (see map above), however the need to safeguard other designated sites is likely to be an issue throughout the District.

Nature Conservation: Strategic options should identify opportunities to enhance Biodiversity Opportunity biodiversity within BOAs. Areas

Green Belt Land will only be released from the Green Belt if it is concluded that there are exceptional circumstances to justify such release.

Any such releases will be informed by a Green Belt Review which identifies areas which make a less significant contribution to the purposes of including land within the Green Belt.

Map … below identifies parts of the Green Belt and the Countryside beyond the Green Belt which lie outside those areas excluded from strategic options as a matter of principle.

Heritage There is an extensive number of heritage assets throughout the District and the need to safeguard heritage assets and their setting will influence the development of a strategic approach.

Constraint Implications for strategic options

Registered Parks and Gardens are excluded from strategic options as a matter of principle (see above). Map … below also highlights Conservation Areas, which are likely to have the largest influence in terms of geographical extent. However, there are also a great number individual listed buildings and other heritage assets which will influence the Local Plan’s strategic approach. Key areas affected are highlighted in Section 4.

Flooding The Strategic Flood Risk Assessment will inform the development of a strategic approach to flood risk. Strategic options will take account of national planning policy guidance, including the adoption of a sequential approach to minimise development in areas at risk of flooding. Map … below highlighted land within Flood Zones 2 and 3. Areas at risk of surface water flooding will also be taken into account.

Noise Significant noise mitigation measures are expected to be required if the strategic approach includes release of greenfield land in the vicinity of the M25.

Transport Strategic transport modelling will be undertaken to inform the strategic approach to development. Based on existing information, Leatherhead and Dorking town centres and Junction 9a are key areas where congestion is a significant concern and mitigation measures are likely to be required to address increased traffic linked to strategic development.

Map 15: Combined Constraints