Downs AONB Unit MW Project Team West Barn Integrated Strategy and Planning division Penstock Hall Farm Environment, highways and Waste Directorate Canterbury Road Kent County Council East Brabourne Invicta House Ashford, Kent TN25 5LL Maidstone Tel: 01303 815170 Kent. Fax: 01303 815179 ME14 1XX [email protected] www.kentdowns.org.uk

[email protected] Anglesey [email protected] Arnside and th 20 July 2010 Silverdale Dear Rachel By Email only, please contact us if you would like a hard copy. Chilterns Clwydian Range Kent Downs AONB response to KCC: Environment, Highways and Waste Directorate: Statement of Community Involvement: draft for Consultation Gower Thank you for consulting us on the above. The following comments are from the Kent Cranbourne Chase Downs AONB Unit and as such are at an officer level and do not necessarily represent and the comments of the whole AONB partnership. West Wiltshire Downs Background and context: Dorset The Kent Downs Area of Outstanding Natural Beauty partnership (which includes all East Devon the local authorities within the AONB) has agreed to have a limited land use planning role. In summary this is to: • Provide design guidance in partnership with the Local Authorities represented High Weald in the AONB. Isle of Wight • Comment on forward/strategic planning issues-for instance Local Kent Downs Development Frameworks. Llyn • Involvement in development control (planning applications) only in exceptional circumstances. For example in terms of scale and precedence. Nidderdale • Provide informal planning advice/comments on development control (planning Norfolk Coast applications) at the request of a Kent Downs AONB Joint Advisory member North Devon and /or Local Authority Planning Officer. Your request for informal advice has prompted this response. National and Local planning policies are very clear that highest priority should be given to the conservation and enhancement of Areas of Outstanding Natural Beauty. Shropshire Hills Policy Statement 7 (PPS7) (at present being revised and as amended currently by PPS4) confirms that AONBs are equivalent to National Parks in terms of their South Devon landscape quality, scenic beauty and their planning status.

Surrey Hills The status of AONBs has been enhanced through measures introduced in the Tamar Valley Countryside and Rights of Way (CROW) Act 2000, which gave greater support to their planning and management. The statutory duties state that in exercising or performing any functions in relation to, or so as to affect, land' in these areas, relevant authorities “shall have regard” to their purposes (Page 3 of DEFRA guidance).

Enhancing landscapes and life in the Kent Downs The Kent Downs AONB Joint Advisory Committee promotes and co-ordinates the conservation of the Kent Downs AONB. Funding is provided by Natural , Kent County Council and the local authorities of Ashford, Bromley, Canterbury, , Gravesham, Medway, Maidstone, Sevenoaks, Shepway, Swale and Tonbridge and Malling. Other organisations represented on the JAC include the Environment Agency, DEFRA CLA, NFU, Kent Association of Parish Councils and Action with Communities in Rural Kent.

The Act requires a management plan to be produced, and accordingly the first Kent Downs AONB Management Plan was published in April 2004. Subsequently the first revision management plan (2009- 2014) was published in April 2009.

This has been formally adopted all the local authorities of the Kent Downs. The management plan may be viewed on our web site www.kentdowns.org.uk.

Relationship of the Management Plan with production of Local Authority LDPs and Development Management (control) Under the CROW Act the AONB Management Plan must ‘formulate the (Local Authority) policies for the management of the AONB and for carrying out their functions in relation to it’. The policies of the Kent Downs AONB Management Plan are therefore the adopted policies of all the Local Authorities in the Kent Downs. Whilst these policies should not be repeated in the Local Authority LDFs, LPDs and SPDs this relationship should be clear. Any KDAONB responses on consultations on LDF and planning applications under the agreed protocol will reflect the policies of the KD Management Plan and other Kent Downs AONB guidance as set out below.

Other Kent Downs AONB Guidance

• Kent Downs Landscape Design Handbook Design guidance based on the 13 landscape character areas in the Kent Downs. Guidance on fencing, hedges, planting, gateways etc. to help in the conservation and enhancement of all corners of the AONB.

• Kent Downs Renewable Energy Position Statement The purpose of this statement is to provide a clearly articulated position for the Kent Downs AONB partnership with regards to renewable energy technologies. It recognises that each Local Planning Authority must balance the impact of proposals for renewables on the AONB with all the other material planning considerations.

• Kent Rural Advice Service Farm Diversification Toolkit Guidance on taking an integrated whole farm approach to farm developments leading to sound diversification projects that benefit the Kent Downs.

• Kent Downs Land Manager's Pack Detailed guidance on practical land management from how to plant a hedge to creating ponds and enhancing chalk grassland.

• Rural Streets and Lanes A Design Handbook Guidance on the management and design of rural lanes and streets that takes the unique character of the Kent Downs into account. This document discusses the principle of shared space and uses examples from around the UK and Europe. The Rural Streets and Lanes Design Handbook has been adopted as policy by Kent County Council.

• Good Practice Horse Pasture Management (DRAFT) National guidance providing information on equine development covering grassland management, fencing, trees and hedges, waste management and basic planning information.

• Kent Farmstead Guidance and Kent Downs Farmstead Guidance (DRAFT) Guidance on the conservation, enhancement and development change of heritage farmsteads in the Kent Downs based on English Heritage’s Kent and National Character Area Farmstead Statements. Includes an Assessment method and Design Guidance.

Comments: We welcome the clarity of the SCI and would make the following comments:

Para 3.2 Consultation on Minerals and Waste Core Strategy and DPD The KDAONB Unit would like involvement at all stages of the preparation of the Minerals and Waste Core Strategy and DPD. We would have particular interest in the Scoping Consultations and formulation of Strategy and Policy Directions and wish to be involved in the consideration of the overall objectives that should guide the plans and ‘directions’. To this end we would welcome involvement with individual meetings with KCC and in participating in Stakeholder workshops, consultation meetings, Stakeholder liaison groups and through our membership of the Local Strategic Partnership. Issues should include strategic and local environmental constraints and opportunities.

Call for Sites We note that you are currently consulting on a ‘call for sites’ We would be happy to discuss with you both general site selection and individual sites at any stage. It is clear from the scoping report that you are aware that the AONB has the highest protection under national policy and guidance (e.g.PPS7.) You are also aware of the sensitivity of the setting of the Kent Downs AONB and how this affects both visual landscape quality and tranquillity. Consultation on individual sites therefore at this policy stage would be welcome. The KDAONB is aware of the importance of in depth assessment of potential sites at the DPD stage rather than later at the development application stage. KD Management Plan relevant policies SDT1, SDT3, SDT5, LLC1,LLC2, LLC8, GNR4.

(We note Natural England’s comments on the SE Scoping Report and support their view that they would like to see ‘the addition of the words “, their settings” added to the sub-objective after the reference to AONBs.’ We also note that this comment has not been taken on board in the published Scoping report.)

Future SPDs/SGs We would also welcome future consultation on any SPDs /SGs

Para 4.1.3 Publicity and consultation on planning applications. We would refer you to our protocol as set out above. We would consider all waste disposal and mineral applications in the AONB to merit consultation on the basis alone of scale, impact and precedence. However as set out above we are concerned also about the impact of developments outside the boundaries of the AONB in the ‘setting’. We would refer you to our Management plan policies LLC2, LLC8, SDT5. We would therefore request that you consult us on any application, for permission or for approval of reserved matters within this setting. We would welcome discussion about how to determine the boundaries.

We hope that you find our comments helpful, but please feel free to contact me should you wish to discuss them.

Yours sincerely

Nick Johannsen Director, Kent Downs AONB Unit