Kent MWLP Sustainability Appraisal Scoping

Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

Revision Schedule

Scoping Report – Introductory Paper March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 August Draft for Mark Fessey Steve Smith Jeremy Richardson 2009 consultation Assistant Consultant Associate Technical Director

02 March 2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Scott Wilson 6-8 Greencoat Place London SW1P 1PL Tel: +44 (0)20 7798 5000

This document has been prepared in accordance with the scope of Scott Wilson's Fax: +44 (0)20 7798 5001 appointment with its client and is subject to the terms of that appointment. It is addressed www.scottwilson.com to and for the sole and confidential use and reliance of Scott Wilson's client. Scott Wilson accepts no liability for any use of this document other than by its client and only for the purposes for which it was prepared and provided. No person other than the client may copy (in whole or in part) use or rely on the contents of this document, without the prior written permission of the Company Secretary of Scott Wilson Ltd. Any advice, opinions, or recommendations within this document should be read and relied upon only in the context of the document as a whole. The contents of this document do not provide legal or tax advice or opinion.

Table of Contents

1 Introduction ...... 2 1.1 This report...... 2 1.2 Sustainability Appraisal...... 2 2 Consultation Responses ...... 10

List of Tables

Table 1: The SA Framework ...... 6 Table 2: Requirements of the SEA Directive and links to the SA questions...... 8 Table 3: Consultation responses and revisions made to the Scoping Report...... 11

List of Figures

Figure 1: SA and plan-making process...... 3 Figure 2: Local authorities within Kent ...... 5

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1 Introduction

1.1 This report

1.1.1 Set out below is an introduction to the Scoping Report for the Sustainability Appraisal of the Kent Minerals and Waste Development Framework (MWDF). Scoping involves developing the framework for undertaking the appraisal, together with the evidence base to inform it. Scoping can, therefore, be seen to set the boundaries for and focus the appraisal. This Scoping Report has been subject to consultation with stakeholders and subsequently amended.

1.1.2 This Introduction Paper introduces the scoping process, as well as the other stages of SA. The final section of this Paper summarises the consultation responses that were received on this Scoping Report, and the changes that were made.

1.1.3 The remainder of the Scoping Report comprises a series of 14 ‘topic papers’, each of which sets out the framework and evidence base for particular issues.

1.2 Sustainability Appraisal

1.2.1 Strategic Environmental Assessment (SEA) and Sustainability Appraisal (SA) aim to ensure that a strategy is environmentally sound and promotes sustainable development.

1.2.2 The KMWDF is subject to SEA and SA under two different regulations: SEA is required under the Environmental Assessment of Plans and Programmes Regulations 20041; and SA is required under the Town and Country Planning (Local Development) Regulations 20082. Many of the requirements of SA and SEA overlap, so they are typically carried out jointly.

1.2.3 The SA process is based on a five-stage (A –E) approach which is closely integrated with the plan-making process and based on the Guidance issued by the department of Communities and Local Government (CLG)3 – see Figure 1.

1 Available @: http://www.opsi.gov.uk/si/si2004/20041633.htm (accessed 01/09) 2 Available @: http://www.opsi.gov.uk/si/si2008/uksi_20081371_en_1 (accessed 01/09) 3 ODPM (2005) Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents. Available from: http://www.communities.gov.uk/publications/planningandbuilding/sustainabilityappraisal

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Figure 1: SA and plan-making process

Plan making process Sustainability Appraisal

Develop an (evidence Develop an evidence based) framework for base to inform the plan the SA and an evidence base to inform it. Stage A Produce a Scoping Report

Consider options for Appraise the plan the plan and prepare a Iterative options, and preferred Stage B draft plan option.

Prepare the SA Report Finalise the draft plan documenting the SA Stage C process and findings

Consult stakeholders on the draft plan Consult stakeholders on (supported by the SA) the SA Report

Appraise any significant changes to the plan Stage D Finalise plan in light of following consultation consultation submit and produce a revised plan for Government SA Report. inspection

Publish and adopt Plan

Monitor plan implementation Stage E including sustainability effects

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Stage A - scoping

1.2.4 This Scoping Report will set out the findings of Stage A of the SA process – the scoping stage. Scoping involves reviewing evidence of relevance to the SA of the KMWDF, before establishing a framework for undertaking the SA. This Scoping Report has organised the collection and consideration of evidence in 14 topic papers:

1. Air Quality; 2. Biodiversity; 3. Climate Change and Flood-risk 4. Community and Well-being (including equalities and health); 5. Economy and Employment; 6. Heritage; 7. Housing; 8. Land; 9. Landscape; 10. Minerals; 11. Rural Areas; 12. Transport; 13. Waste; and 14. Water.

1.2.5 These topics were identified as the most appropriate around which to organise the collection of evidence following discussions with Kent County Council. In particular, the Council identified that it was important to ensure that a full and transparent consideration be given to issues relating to equalities, health and rural areas.

1.2.6 As well as reviewing evidence according to thematic topics, there is also a consideration of how the evidence varies spatially within Kent. As such, each topic paper will include a considerable spatial emphasis. In particular, evidence and key issues will be considered for each of the three ‘sub-regions’ in Kent, as identified in the South East Plan (2009). There is also a consideration of how the baseline varies across the 12 local authorities within Kent (see Figure 2)

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Figure 2: Local authorities within Kent

1.2.7 Within each topic paper a logical 4 stage approach to scoping evidence is clearly set out:

i. Reviewing key policies, plans, programmes strategies and initiatives (PPPSIs) that set the sustainability context for the KMWDF (e.g. Government White Papers, the South East Regional Spatial Strategy)

ii. Reviewing information that shows the current and likely future state of the sustainability baseline in Kent

iii. Highlighting the key sustainability issues and problems facing the county that are of relevance to minerals and waste planning

iv. Develop the SA framework from the list of key issues and problems, also taking account of any other evidence gathered at the PPPSI and baseline review stages.

1.2.8 The final stage of scoping under each topic involves considering how the evidence collated through the preceding three stages should feed into the SA framework. There is no assumption that one sustainability objective will be developed relating to each topic. Rather, the evidence may highlight that there is a need for more than one sustainability objective relating to a topic, or, conversely, may identify that the topic is best considered as a sub-objective under an objective more closely related to another topic.

1.2.9 Set out below is the complete list of objectives and sub-objectives that form the SA Framework. It is important to recognise from the outset that, although the whole spectrum of sustainability issues has been considered through this scoping, there are many issues that are of limited or no relevance to minerals and waste planning. These issues have been scoped out, and so are not reflected in the SA Framework.

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Table 1: The SA Framework Objective Sub-objective Reduce the risk of flooding and the resulting Ensure that development does not lead to increased detriment to public wellbeing, the economy and the flood risk on or off site environment Seek to mitigate or reduce flood risk through developments that are able to slow water flow and promote groundwater recharge Ensure that development will not impact on Add to the biodiversity baseline by creating important elements of the biodiversity resource and opportunities for targeted habitat creation (which, where possible contributes to the achievement of ideally, contributes to local or landscape scale the Kent Biodiversity Action Plan and other habitat networks). strategies Avoid hindering plans for biodiversity conservation or enhancement Support increased access to biodiversity Protect and enhance Kent’s countryside and historic Protect the integrity of the AONBs and other environment particularly valued or sensitive landscapes Take account of the constraints, opportunities and priorities demonstrated through landscape characterisation assessments and other studies at the landscape scale. Protect important heritage assets and their settings, as well as take account of the value of the character of the wider historic environment Maintain and improve the water quality of the Kent’s Ensure that minerals and waste development seeks rivers, ground waters and coasts, and achieve to promote the conservation of water resources sustainable water resources management wherever possible Avoid pollution of ground or surface waters, particularly in areas identified as being at risk or sensitive Address the causes of climate change through Recover energy from waste where possible reducing emissions of greenhouse gases through energy efficiency and energy generated from Promote sustainable design and construction of renewable sources facilities and support wider efforts to reduce the carbon footprint of minerals and waste operations. Minimise minerals and waste transport movements, journey lengths and encourage transport by rail and water. Reduce and minimise unsustainable transport Ensure that minerals and waste transport does not patterns and facilitate the transport of minerals and impact on sensitive locations, including locations waste by the most sustainable modes possible already experiencing congestion and locations where planned growth or regeneration is reliant on good transport networks. Ensure that minerals and waste development does not contribute to poor air quality Plan for the correct waste management facilities, in Put in place the facilities and infrastructure that will the right place at the right time support integrated waste management and move waste management up the waste hierarchy Minimise potential negative effects associated with waste management facilities Support self sufficiency where possible

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Make efficient use of land and avoid sensitive Make best use of previously developed land locations Avoid locations with sensitive geomorphology

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

Stimulate economic revival and targeted employment generation in deprived areas

Stage B – Appraisal

1.2.10 Stage B in the SA process involves the appraisal of the Kent MWDF itself. The appraisal is set to be undertaken in three stages as the MWDF develops:

1. SA of the KMWDF objectives or goals. 2. SA of the options under consideration for delivering the objectives of the KMWDF. 3. SA of the draft KMWDF, which will consist of the Council’s draft preferred options for delivering the objectives, which themselves will have been identified taking account of the previous ‘options’ SA findings.

Stage C – SA Report

1.2.11 The SA Report, in addition to the Scoping Report, will include all of the information that must be included in the ‘Environmental Report’ required under the SEA Directive. Both the Scoping Report Topic Papers, and the SA Reports, will be structured in such a way that it is clear how the requirements of the SA Directive are being met. Table 2 sets out the sub-headings that have been used to structure the Scoping Report, and will be used to structure the SA Report.4

4 Note that the Scoping findings will be included in the SA Report under the headings set out in Table 2, but in summarised form.

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Table 2: Requirements of the SEA Directive and links to the SA questions. Questions that will be used to Key requirement of the SEA Directive (the ‘environmental report’ structure the SA must include…) Scoping Report What’s the sustainability “an outline of the contents, main objectives of the plan or programme context? and relationship with other relevant plans and programmes” (Annex I(a)) “the environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation” (Annex I(e)) What’s the current and “the relevant aspects of the current state of the environment and (likely) future baseline? the likely evolution thereof without implementation of the plan or programme” (Annex 1(b)) “the environmental characteristics of areas likely to be significantly affected” (Annex I(c)) “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” (Annex I(b)) What are the key “any existing environmental problems which are relevant to the sustainability issues? plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC” [NB problems relating to European sites are addressed through the HRA / AA] (Annex I(d)) What decision-making “the environmental protection objectives, established at criteria should make up the international, Community or Member State level, which are SA framework? relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation” (Annex I(e)) What further data is “an outline of the reasons for selecting the alternatives dealt with, and required? a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information” (Annex I(h)) SA Report (the above plus…) What will be the situation “the likely significant effects (1) on the environment, including with the plan? on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors [our emphasis] (1) These effects should include secondary, cumulative, synergistic, short, medium and long-term permanent and temporary, positive and negative effects” (Annex I(f))

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Questions that will be used to Key requirement of the SEA Directive (the ‘environmental report’ structure the SA must include…) Scoping Report How can we mitigate / “the measures envisaged to prevent, reduce and as fully as enhance effects? possible offset any significant adverse effects on the environment of implementing the plan or programme” (Annex I(g)) How should we monitor “a description of the measures envisaged concerning sustainability impacts? monitoring…” (Annex I(i))

Stage D – Consultation

1.2.12 The SEA Directive sets out a requirement to consult on SA findings. Therefore, Stage D of the SA process is a requirement to consult on the final SA Report alongside the draft KMWDF.

Stage E – Monitoring KMWDF implementation

1.2.13 Following the publication of the KMWDF Kent County Council will monitor implementation on the ground through its Annual Monitoring Report (AMR). In order to effectively monitor the KMWDF, a series of indicators will be developed. In line with the requirements of the SEA Directive, these indicators must include measures for monitoring the significant environmental effects of the KMWDF, as identified through the SA process.

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2 Consultation Responses

2.1.1 This Scoping Report was consulted on for the statutory five week period5 in late 2009. The following five questions were put forward to focus the consultation:

1. Are there any further policies, plans, programmes, strategies or initiatives with implications for the appraisal of the MWDF and should be included in this Scoping Report? 2. Is there any further baseline data that is relevant to the appraisal of the MWDF and should be included in this Scoping Report? 3. Are the key issues represented and are they suitably focused on the MWDF? 4. Are there any further data gaps that should be highlighted? 5. Given the remit of the MWDF and the appraisal, are there any further areas of the Scoping Report that you would recommend alteration to?

2.1.2 Table 3 summarises the consultation responses that were received, and the subsequent changes that were made to this Scoping Report.

5 Environmental Assessment of Plans and Programmes Regulations (2004) Regulation 12 (6). Available from: http://www.opsi.gov.uk/si/si2004/20041633.htm

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Table 3: Consultation responses and revisions made to the Scoping Report Organisation Response Yes / No How / Why Southfleet The Parish Council is concerned that proposed schemes could be more about None The SA will test the MWDF Parish quick wins and solving immediate problems than being long-term sustainable against a range of Council solutions. sustainability objectives. It is the role of this scoping process to identify the most appropriate objectives. Lafarge There is a missed opportunity to identify and recognise the sustainable benefits None The importance of adhering to Aggregates that can be delivered through local land-won aggregates and strategically located the ‘proximity principle’ is Ltd wharves. It is felt that this theme should run through the minerals, transport and recognised in the ‘Key climate change topic papers given the clear benefits that can be derived from Sustainability Issues’ table local supply and sustainable and well located wharves. within the Transport Paper. It is considered that the Minerals Topic Paper undermines a number of policies None The importance of adhering to for minerals planning as set out in Minerals Policy Statement 1. Section 15 the ‘proximity principle’ is reiterates the importance and benefits which local supplies of minerals can recognised in the ‘Key deliver. It is also felt that the Minerals Topic Paper should recognise the ability of Sustainability Issues’ table local land-won aggregates to deliver sustainable benefits to the local community, within the Transport Paper. particularly in achieving sustainable supplies that minimise transportation and deliver clear economic benefit as well as benefits at the restoration stage e.g. value amenity and recreation resource, diverse wildlife in primary extraction sites, important geological exposures and archaeological features uncovered from mineral extraction. It is considered that the benefits to society and the local economy accrued from None Potential local economic land-won aggregates should be emphasised in the Topic Paper e.g. creation of benefits are already new jobs, safeguarding existing jobs, contributing to the economy in terms of recognised in the ‘Key wages, the purchase of goods and services, business rates, investment in plant Sustainability Issues’ table equipment, contract employment used in major preparatory stages such as earth within the Economic Paper. movement and restoration. There is a need to make reference to the fact that secondary and recycled None The Minerals Paper does not materials will not be able to fully replace natural land won aggregates as it will imply that recycled materials not always be economically or technically feasible to use these arisings. will ever be able to replace land won aggregates. In the introduction, it is not clear that the policy basis and each step identified is None Response noted followed through in the topic papers with specific reference and understanding of the issues relevant to existing minerals policy, supply and future patterns. Framework should recognise the importance of maintaining a steady and Yes Text added to Table 2 in

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adequate supply of minerals which are essential in meeting the wider needs of Minerals Topic paper to the economy and society. address response The Minerals Topic Paper does not set a complete baseline understanding of the None Scott Wilson’s understanding main characteristics and issues facing the MDF. Hope to see clear data sets and of the key issues is set out sources that enable a view to be taken on primary local sales as well as imports across all 14 Topic papers and recycled or secondary sources, as well as a spatial understanding of existing supply against which future patterns can be considered. Would also like to see an understanding of the economic geology of the County. The commitment to maintaining a steady and adequate supply is supported. None The importance of adhering to However, this does not translate into a commitment to local supply wherever the ‘proximity principle’ is practicable. recognised in the ‘Key Sustainability Issues’ table within the Transport Paper. There is concern that there is a question over likely future mineral requirements, Yes Further detail has been added which appears potentially to question the apportionment process and national in the Minerals Paper re. the policy guidance for aggregates and the specific policy guidance for other apportionment process minerals. The land use topic paper does not appear to relate to a baseline that reflects the None These issues identified in the minerals focus of the SA and the LDF. The focus (particularly in parts 1.5 and Land and Geology Topic paper 1.6) reads more appropriate to an LDF considering built environment, than are considered to be within the minerals. It is felt that the references to green belt, use of previously developed scope of this SA land, loss of agricultural land and coastal geodiversity are not particularly relevant to the major parts of the minerals sector. In the transport topic paper, there is concern that much of the baseline is not None Scott Wilson have drawn on directly related to minerals and deals with general transport patterns rather than the evidence base readily minerals transport modes and characteristics. available to identify issues relevant to MWDF as accurately as possible. The climate change paper does not appear to reflect carbon reduction and the None The importance of adhering to benefits of sustainable transport, importing minerals through appropriate wharves the ‘proximity principle’ is and from locally sourced primary supply. recognised in the ‘Key Sustainability Issues’ table within the Transport Paper. There is concern about comments in the economy topic paper relating to quarry Yes Text amended in Economy employment being low skilled. The fact that some of the work is of a manual Topic paper nature should not be taken to be low or unskilled. Concluding point – concerns that the focus is not adequately minerals or waste None Response noted

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specific and focuses on broader policy objectives that may be less relevant to minerals. Brenchley It is hoped that the plans will not lead to loss of distinctiveness in the landscapes None The SA will test the MWDF Parish of Kent or decrease ‘tranquillity’ or a sense of remoteness. Need to better against a range of Council understand the metrics that are used to assess the impact of the planning sustainability objectives, that policies and consider how best to continue to manage the often conflicting have been developed so that demands of spatial development strategies. they can most accurately take account of the likely significant effects of the MWDF Care must be taken when locating waste management facilities, to ensure that None It is thought that these issues they do not contribute to the further degradation of landscapes, tranquillity of are adequately addressed rural settlements and the well-being of communities. within the topic papers/ Natural In terms of biodiversity, Natural England would recommend that the regional Yes BOAs are now addressed England Biodiversity Opportunity mapping produced by the South East England Biodiversity Forum is included in the Scoping Report as this resource can be used to inform and identify opportunities for habitat creation and enhancement through individual development/ aftercare schemes. Ancient Woodland inventories should be included - the revised Ancient Yes Reference made to making use Woodland inventories have recently been produced by Ashford and Tunbridge of Ancient Woodland Wells councils Inventories when this information is available and will help to identify likely significant effects. In terms of landscape, the High Weald AONB Management Plan should be Yes Reference made to the High included (only that of the Kent Downs AONB is presently referred to in the Weald AONB in the Landscape Scoping Report). and Geology Topic paper. Local and County Landscape Character Assessments should be included, as Yes Reference made to the South should the recently issued South East Green Infrastructure Framework6 (this East Green Infrastructure document is also relevant to other areas such as Biodiversity, Community and Framework and the need to Housing). draw on local LCA where this information is available and will help to identify likely significant effects. Natural England suggests that the following additional baseline data should be Yes Mapping updated. SSSIs included: included. LWS not readily

6 Available to download from http://www.gos.gov.uk/497648/docs/171301/SEGIFramework.finaljul09.pdf

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• Mapping of all SSSIs, Local Wildlife Sites and Local Nature Reserves available. Reference made to • Areas of land covered by agri-environment schemes taking account of LWSs and • Reference to biodiversity assets within Kent - the Kent Habitat Survey LNRs where this information is data includes details of various habitats covering the County and the Kent available and will help to and Medway Biological Records Centre7 should be able to provide identify likely significant effects. records for protected species, species of principal importance and BAP priority species The importance of environmental stewardship in Kent is highlighted.

References to protected species, species of principal importance and BAP priority species do not form an important part of the evidence base (given the strategic nature of likely significant effects). Natural England welcomes a strategic approach involving the consideration of None Scott Wilson consider that the ecosystem services in evaluating natural environment opportunities and importance of protection of constraints. However, whilst the potential exists for mineral and waste nationally and internationally development to provide opportunities for, in particular, biodiversity enhancement, designated sites is adequately NE would caution against anything that might give any impression that minerals considered. or waste development opportunities exist in nationally and internationally designated nature conservation sites or areas that would detrimentally affect such sites. The importance of the need for protection of such sites should be given more prominence. NE welcomes the specific sub-objective of protecting the integrity of AONBs and Yes Reference to “their settings” other particularly valued or sensitive landscapes but thinks this should include made in text. landscapes forming the setting of AONBs. Natural England would like to see the addition of the words “their settings” added to the sub-objective after the reference to AONBs. In the landscape topic paper, Natural England would suggest that a further None It is not considered that a category of “Contributing to and protecting Connectivity” could be added to Table specific category for 3: Key sustainability issues at 1.5.1 of the paper. This issue could cover matters contributing to and protecting such as Green Infrastructure, sustainable transport and quality of life. connectivity is required

7 www.kmbrc.org.uk

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Natural England believes further data gaps include the following: None Reference is already made to • Kent Phase 1 survey data SSSI PSA targets within the • SSSI PSA target data Biodiversity Paper. • Bird disturbance studies in and between SPA and Ramsar sites (Natural England is currently co-ordinating studies in the North Kent area and can Reference has been made to provide information to the Council when it becomes available; NE believe the fact that it may be gathering such an evidence base will be important in assisting necessary to draw on phase 1 environmentally sustainable spatial planning in light of increasing data (assuming it is readily development and recreational pressure on designated sites) available) as part of the appraisal. Port of The transport topic paper on page 13 provides details on a number of ports Yes Agree. The Port of London London within the area. 'Thames Europort' now known as CdMR Dartford is one of the Authority covers 150km of Authority terminals within the Port of London and therefore should not be listed as a port in coastline of the Greater its own right. The wording relating to 'Thames Europort' is very out of date. For Thames Estuary; it has 80 example, the site has been part of the Cobelfret group since early 2006 and the terminals, with 18 of them in site has not been operational since earlier this year. The PLA would welcome Kent and is thought to provide discussions with Kent County Council and Dartford Borough Council regarding 35,300 jobs and handles over the future use of this site. 53 million tonnes of freight annually. The PLA incorporates the CdMR Dartford terminal, formerly Thames Europort, which until mid-2009 provided roll-on/roll- off freight services from the port to Rotterdam and Ostend. Due to falling freight volumes these operations, as of 2009, have been relocated to Purfleet. It is understood the Port of London Authority would welcome discussions with Kent County Coucil and Dartford Borough Council regarding the future use of the Dartford terminal. Environment Overall, the scoping report appears to be a very generic document. It doesn’t None The Scoping Report has drawn Agency seem to have a particular focus on the minerals and waste issues that are the on the evidence base available framework’s subject. The EA would hope to see further detail relating to waste to identify a framework that will

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and mineral specific issues explored in the Final Sustainability Appraisal Report. ensure that the SA will focus on the likely significant effects of the MWDF. However, scoping is a ‘live process’ and it is possible to take account of new evidence at any point in the SA process. WATER TOPIC PAPER: It would have been useful to carry out a basic collation None It is not clear that this evidence of minerals/waste management/processing related abstraction licenses and/or is readily available. discharge consents. Without this level of information, it is not clear how the Furthermore, it is not clear that development of high level plans will be able to assess options in relation to water it would ever be possible to quality/water resources or the impacts on other sensitive features and hence quantify the effects of the ensure that the objective set out in section 1.6.1 can be achieved. strategic actions promoted through the MWDF in terms of these elements of the baseline. The EA think it would be worthwhile finding out if Figure 3 (1.4.5) recognises the Yes Agree .Text added to reflect aspiration to achieve Water Neutrality within the Thames Gateway. This may response - These data do not have some influence over suggested actions or policy decisions taken in the account for the aspiration of Thames Gateway area. See “Environment Agency – Towards Water neutrality in the Environment Agency and the Thames Gateway. Summary of the study undertaken to inform policy and government to keep total develop the concept of water neutrality.” http://publications.environment- demand for water in the agency.gov.uk/pdf/SCHO1107BNMC-e-e.pdf?lang=_e Thames Gateway the same between 2005 and 2016. Section 1.4.9 – explain the switch over to the Water Framework Directive (WFD) Yes Text amended clarifying that classifications, from the earlier GQA system to give context to the rating of the the classifications are based water bodies. on the Water Framework Directive classifications. Section 1.4.24 should recognise the water requirements of new habitat that will None It is not clear whether the be created. The Greater Thames CHAMP has identified that there will be MWFD will impact on the Hoo significant losses of intertidal habitat in the Greater Thames Catchment over the Peninsular or directly result in next 100 years. There are proposals set out in TE2100 Draft Plan and Thames habitat creation (Hoo Region Habitat Creation Programme to compensate for this loss with intertidal Peninsula is located in the habitat creation – some of these proposals are located on the Hoo Peninsula. Medway Local Authority area) In Section 1.4.21 it should be noted that Medway is not a Sensitive Area. Yes Text amended to reflect response In Section 1.5 the ‘location of wastewater treatment works’ is talked about. None This SA will appraise the

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However, it should be understood that it is the location and size of urban areas effects of the MWDF only. that will determine sizes of existing discharges, and by extension, their pollution This representation might potential. The chief variable in the plan is where additional growth will be placed. relate better to District LDF Growth should be placed so water quality deterioration risks are managed, and Core Strategy development. improvement to meet WFD objectives is not compromised. We are working with local authorities across Southern Region to ensure that population growth is distributed to meet these principles. Section 1.3.3 - Replace ‘Environment Agency (2001). Water Resources Strategy: Yes Text amended to reflect Water Resources for the Future’ with ‘Environment Agency (2009) Water for response people and the environment Water Resources Strategy for England and Wales’. Also, replace “CAMS enable the consideration of how much water can be abstracted from watercourses without damaging the environment” with “The CAMS process calculates how much water is available for abstraction, from both groundwater and surface waters, against the environmental need for water”. Section 1.3.7 - Replace Groundwater Directive (80/68/EC) with Groundwater Yes Text amended to reflect Directive (2006/118/EC) commonly referred to as the Groundwater Daughter response Directive. Section 1.4.31 - Replace “candidate Source Protection Zone” with “candidate Yes Text amended to reflect Water Protection Zone”. response BIODIVERSITY TOPIC PAPER: The EA think the following should be Yes Text amended to reflect acknowledged in the Thames Gateway box of Table 3: ‘The Greater Thames response Champ has identified that there will be significant losses of intertidal habitat in the Greater Thames Catchment over the next 100 years. There are proposals set out in TE2100 Draft Plan and Thames Region Habitat Creation Program to compensate for some of this loss with intertidal habitat creation on the Hoo Peninsula.’ This text will go some way towards addressing bullet 4 of 1.7.1. EA recommend that important Flood and Coastal Risk strategies such as Yes Text amended to reflect Thames Estuary 2100 (TE2100) and the Shoreline Management Plans are importance of coastal risk included in the second box of the Key Sustainability Issues. strategies and SMPs The new potential Special Protection Area (pSPA) at Outer Thames Estuary and None Access to the pSPA and cSAC draft Special Area of Conservation (dSAC) at Margate and Long Sand, are datasets is not readily omitted from the Natura 2000 habitat figure shown on page 8 – these should be available. included. CLIMATE CHANGE AND FLOOD RISK TOPIC PAPER - This section appears to None Scott Wilson believes the topic split broadly in two – adaptation and mitigation. Although the EA understand why paper focuses on the key it may have been structured in this way, the overriding feeling is that we have to issues that will arise as a result be prepared for increased flooding due to climate change (adaptation). There is of the decisions made through

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mention of the need to recover energy from waste and to reduce Greenhouse the MWDF. Regarding Gas (GHG) emissions, but the language used is not particularly aspirational – i.e. mitigation, the language is where possible or there is potential… It would be good to strengthen the considered appropriate. mitigation aspect of this section by setting out challenging methods for addressing reducing GHG and producing green energy and energy recovery, but to also require stronger resource efficiency and reduction of waste and use of raw material in the first place. In section 1.6.3 (Bullet 1) ‘Recover energy from waste where possible’, it would None It is not considered necessary be useful if the plan at later stages looked at the potential for district heat to refer specifically to district networks under this bullet. Further info can be found here: heating networks. http://www.lbbd.gov.uk/6-living/envir-protect/envir-sustainability/energy- action-heating.html It would be also be beneficial if this chapter acknowledged the Kent Thameside None It is not clear that this evidence Eco-Assessment Work. The contact at Kent Thameside is Matt Fosker - would be of use in terms of Temporary Sustainable Energy Officer [email protected] identifying issues. MINERALS TOPIC PAPER - Section 1.5.1 -Table 2 should include the need to None The level of provision of make provision for the production of 1.4mtpa of secondary aggregate by secondary aggregate by 2016 2016. Are you are going to use data to show what is happening in this market at is presented in the the moment? Sustainability context section. WASTE TOPIC PAPER - In Section 1.3, given the desire to facilitate innovation None Section 1.3 provides a in waste management technologies, the EA think an acknowledgement of a balanced representation of the degree of flexibility in strategic site allocation would be prudent. PPSI context. Could this also be added to the Sustainability issues? It is not thought that referring to ‘flexibility’ would add anything to the text already included in Table 1.3. Further to this, in Section 1.3.8 mentions open windrow composting. Is there None The Key Issues Table refers to scope for this document to outline a hierarchy of treatment options for the waste hierarchy Kent? Open windrow composting would sit below other treatment options which capture of harness the by-products more effectively. In Section 1.4.11 bulky waste from Household Waste Recycling Centre is None Yes, there may well be scope planned will be taken to landfill. Is there scope to reduce the size/volume and/or to do this. Representations recycle this waste rather than landfill it? should be made to KCC. Further guidance recommended: Yes The identified documents have • GW&CL have a framework for the regulation and management of been taken into account in the groundwater in a set of documents, collectively known as Groundwater evidence base.

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Protection: Policy and Practice (GP3). The GP3 documents should be reviewed and considered during the development of the Kent Minerals Biodiversity Opportunity Area and Waste Development Framework (MWDF). http://www.environment- maps have been included agency.gov.uk/research/library/publications/40741.aspx within the Biodiversity topic • South East Biodiversity Strategy and the resulting Biodiversity Opportunity paper Area maps produced as outputs from the SE Biodiversity Forum might be useful. These should be considered in Table 1 of the full report “Objectives for Biodiversity”. http://www.sebiodiversity.org.uk/pages/regional-biodiversity- strategy.html) Kent Wildlife Biodiversity 1.4.12 - The Trust welcomes the inclusion of the Living Landscapes Yes BOAs now included. Trust map, however this map has been superseded by the Biodiversity Opportunities map. Copies of the BOAs map and the accompanying statements can be obtained from William Moreno at KCC or Richard Moyse at Kent Wildlife Trust. These BOAs have been adopted by the South East Biodiversity Strategy and the Kent Biodiversity Partnership and are being used by many of the Local Authorities as the basis of their Green Infrastructure. It is therefore requested that the Biodiversity Opportunity Areas be taken into consideration within the SA process and mineral and waste sites be assessed in relation to their impacts on the BOAs. Site allocation should ensure that no important links, corridors, or site connectivity is disrupted by minerals or waste sites. For further information on the BOAs and more detailed mapping see the South East Biodiversity Strategy at http://www.kentbap.org.uk/resources/boas/ Biodiversity - 1.4.2 - no mention of Local Wildlife Sites. There are 456 LWS in Yes The text on LWSs in the Kent and Medway which contain large tracts of priority habitat and shelter many Biodiversity Paper has now of the priority species that are of at least county, if not national importance. Many been updated. are extensions of national and international sites and harbour species for which international sites are of importance. The Trust would recommend that these sites are also identified and analysed within the baseline information. Table 3 - There is no mention of the SPAs, SACs and Ramsar sites that are None Please see Figure 1: Natura protected under European law although certain sites are mentioned within the 2000 habitat in Kent in the document. In the case of the SACs rare habitat such as chalk grassland, Biodiversity Topic paper vegetated shingle and ancient woodland is protected. SPAs safeguard migratory bird species which use the foreshore and marshes to feed and roost and Ramsar sites are designated for their importance as international wetland sites. All European designations should be identified within the baseline information and consideration given to assessing the impact of this plan for these sites under the

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Habitat Regulations. 1.7 Further evidence - Some of the further evidence required could be obtained None The Biodiversity Paper has by reviewing the LWS designations held by the Kent Biodiversity Partnership. been revised to take account of Although some of this evidence is now historical, if permission can be gained, some further sources of these sites are re-surveyed every ten years and will contain up to date evidence. It is now thought information on habitat condition and species presence. Many of the Local that sufficient evidence is Authorities have produced background documents, ancient woodland presented to highlight the inventories, Landscape Character Assessments or Local Biodiversity Action strategic issues that exist Plans detailing the condition and extent of priority habitats as well as the species within Kent, that are of of importance within the area. This information should be reviewed to provide a relevance to the SA of the fuller picture regarding biodiversity for the Minerals and Waste Development MWDF. There will be potential Framework. New evidence is also likely to be obtained within the proposed to draw on further evidence in habitat survey review. the future, should this be needed in order to inform the assessment. Air Quality - In the case of chalk grassland SAC's within Dover Thanet, Shepway None It is Kent CC’s responsibility to and Tonbridge and Malling/Medway, the impact of pollutants resulting directly or screen for HRA indirectly from the minerals and waste industry should be assessed, both alone and in combination with other development within the area to ensure no damage to these important sites. This is likely to need to be appraised under the Habitats Regulations by production of an Appropriate Assessment. Transport – Increase in transport by rail and air could cause disturbance to None It is not thought that this wading bird species, limiting their feeding and roosting opportunities. The evidence helps to identify the ecology of the coastline is sensitive and is likely to be affected by increased boat likely significant effects of the movements, particularly along the Medway and Thames. MWDF. Minerals - Increased importation of minerals or creation of new wharves should None It is Kent CC’s responsibility to be assessed in the light of their impact on the European sites. If there are plans screen for HRA to increase importation, consideration will need to be given to the production of an Appropriate Assessment to assess the risks of disturbance to birds caused by increases in mineral importation on the coastal SPA's and Ramsar sites and increased transport emissions on the SACs. The proposed increase in marine won aggregates may also have an effect on the ecology of the sea bed. These impacts should also be assessed. The forthcoming Marine Bill is likely to identify protected areas including SPAs and SACs in the marine environment. Damage to these may need to be assessed via an Appropriate Assessment before permission to extract is granted.

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Waste - If there is to be an increase in waste transport by water and sensitive None It is Kent CC’s responsibility to bird areas are to be disturbed then the impacts should be evaluated as part of an screen for HRA Appropriate Assessment to ensure that appropriate mitigation is put in place. Water – The SA and AA should account for the implications (e.g. pollution and None It is not clear that there is a water) on estuarine habitats, which are of international value for bird species. need for a particular emphasis on estuarine habitats. Biodiversity - The location of new quarries should not further fragment the None The importance of green important habitats within Kent or block important migratory routes established infrastructure and connectivity within the Green Infrastructure. is addressed. The Trust would disagree that aims to secure appropriate management for None All the MWDF could impact Biodiversity Action Plan Habitats is not of relevance to the Minerals and Waste upon BAP Habitats, it would Development Framework as stated in paragraph 1.4.6. We believe that such not impact on their aims should be included as factors that will need to be appraised within the SA. management Table 2 – include info on the appropriate management of quarries. If quarries Yes The biodiversity value of are to be restored to include areas of BAP habitat, then long term management restored and unrestored of these habitats is needed. There are also occasions when un-restored quarries quarries is identified provide habitat for rare birds and invertebrates. See Nature After Minerals report at http://www.afterminerals.com/projectinfo.aspx for further info. Nature after Minerals is referenced

Table 2 identifies the Habitat Action Plan objectives for Priority Habitats in Kent. Climate Change – It is important that proposed sites do not block migratory Yes There is an increased corridors and that there is appropriate mitigation to ensure no impact on emphasis on species specific connectivity. connectivity, taking account of the likely significant effects of M&W development. Government Could you say more about the implications of each sub-objective for the minerals Noted The objectives have been Office for the and waste core strategy? Taking paragraph 1.6.3 of the Economy topic paper as reviewed to ensure that they South East an example, what does "Stimulate economic revival and targeted employment will focus the SA on the likely generation in deprived areas" mean for this plan? Does it mean that the plan significant effects of the plan. might target certain waste facilities to deprived areas to generate employment It should be noted that effects opportunities? If so, why not say so and make that an objective? Likewise, what of the plan will be assessed in exactly does "Support the development of a dynamic, diverse and knowledge- terms of the objectives, taking based economy that excels in innovation with a higher value, lower impact account of the other evidence activities" mean for this particular plan? We will leave you to work through the set out within the scoping

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sub-objectives from the rest of the topic papers in considering this general point. report. Following on from the previous bullet point, it would be helpful if strategic plan None Plan objectives will be set out objectives could be teased out from the material so that GOSE can get a clearer within the MWDF. The idea about what the minerals and waste development plan is going to deliver, introductory paper of this SA leaving sustainability objectives separately to inform choices between realistic Scoping Report introduces the delivery options and alternative locations for development to meet those strategic remit of the MWDF. objectives. Linked to that, it may be helpful to draw out the key drivers for change to inform strategic objectives. Could the objectives and sub-objectives from each of the topic papers be drawn None The MWDF objectives will be together briefly to make the distinction between strategic and sustainability appraised at Stage B of the objectives and to identify potential synergies and conflicts between them? SA. Could more be said in paragraph 1.6.3 of the Biodiversity topic paper to reassure Yes It is the responsibility of KCC to consultees that you have covered the requirements of the European Habitats screen for HRA/AA. Reference Directive and national regulations? is made to this however within the Biodiversity Paper Topic papers helpful in flagging up areas where knowledge is limited and note None Response noted from the Waste topic paper the need for more robust data on current and future waste arisings from the Construction & Demolition (C&D) and Commercial & Industrial (C&I) sectors. In the absence of such data, as work on the core strategy progresses, will SW be giving any thought to contingency planning to cover the possible range of future requirements, linked to monitoring arrangements that can trigger necessary contingencies in time to meet requirements? GOSE suggests SW develop a methodology for undertaking a SA that is None Response noted proportionate to the issues raised and keeps in mind the key issues of viability, deliverability, habitats regulations, other sustainability issues and results of public consultation. East Sussex County Council have been giving some thought to this. Highways HA cautions that the MWDF should not rely upon the provision of any additional Yes This response is now reflected Agency capacity on the Strategic Road Network (SRN) in the future. Furthermore, direct in the Transport Paper access shall not be taken from the SRN. The MWDF proposals must be developed in accordance with the requirements of PPS12 ‘Tests of Soundness’ and built upon a robust and credible Transport Evidence Base which is ‘effective’ and ‘justified’. Attention should be paid to the advice set out in Chapter 5 of the DfT/CLG None Response noted Guidance on Transport document. Paragraph 21(i) point 4 of PPS10 suggests that Waste Planning Authorities Yes Transport scoping report text

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should consider the capacity of existing infrastructure and should also seek to amended to reflect this shift transportation of waste to non road-based modes. information. Whilst individually, small Minerals and Waste sites are unlikely to produce a Yes This response is now reflected significant impact on the SRN, when examined in combination either with other in the Transport Paper potential sites, their individual impacts will be compounded and they may then become materially significant. The transportation of waste in particular has the potential to generate a significant number of HGV trips, a large proportion of which are likely to use the SRN. Therefore, the HA is supportive of measures which seek to ensure close proximity between waste disposal sites and sources of waste. In addition, the MWDF should seek to promote transportation of waste by rail or waterborne modes wherever this may be possible.

In light of the recent wharves to be located close to the marketplace and/or to be None Response noted rail served to minimise the number of road based trips. By way of guidance, the HA would like to see a distribution of waste None It will be the role of KCC to management and minerals facilities which contribute to the overall reduction in present options in a way that the distance which materials are transported, especially by road. The HA best supports meaningful recommend that the distribution of waste management and mineral facilities analysis and consultation. should be supported by a transport evidence base and be fully considerate of the wider transport impacts of the proposals. Spatial distribution options which are likely to have a significant impact on the SRN would not be deemed appropriate, unless accompanied by suitable mitigation measures. Individual sites should be supported by a transport assessment and travel plan. South East SE England Partnership Board commends: None Response noted England • the topic based approach taken Partnership • spatial focus on each of the sub regions in Kent Board • the application of the Regional Sustainability Framework (RSF) to develop more tailored objectives The average annual housing figure quoted in the housing paper should be Yes Number updated 32,700 and not 33,125. (Paragraph 1.3.3) In the climate change paper the Policy from the South East Plan should be CC2 Yes Text amended and not SP5. (Paragraph 1.3.11). With regards to climate change predictions and impacts, any Local Climate None No LCLIPs were identified, Impact Profiles (LCLIP) that have been undertaken should be drawn upon to however caution must be taken enhance the evidence base. regarding using LCLIPs as evidence base. Their focus is on identification of events over

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the recent past rather than future climate change. Brett Further policies, plans, programmes, strategies or initiatives with implications for Yes It is not necessary to reference Aggregates the appraisal of the MWDF and should be included in this Scoping Report: the letter from CLG, as the (1) CLG released their new National and Regional Guidelines for Aggregate Paper has been amended to Provision in England: 2005-2020. Both this document and the covering letter reflect the outcomes of the from the Chief Planner at CLG (29 June 2009), are material matters which later South East Plan Partial should be considered in the SA. Review. (2) MPS1 is national government minerals policy and its requirements should be acknwoledged and met in the SA. MPS1 has already been (3) National Planning Policy in relation to MDFs and LDFs, ie PPS12. referenced in Minerals Paper (4) The outcomes from the EiP of SE Plan Minerals Policy M3 is material to the emerging Kent MDF DPDs. Inert landfill referenced. (5) Waste Strategy 2007 acknowledgement that inert landfilling 'has a place' for the restoration of quarries. In terms of baseline, SEERAWP reports and the role of the RAWPS have not None Noted been considered. It is felt that the key issues are not fully represented. According to Brett None It is primarily the role of the Aggregates, the key issues (other than those mentioned) should relate to MPS1 Plan-makers to take account of requirements- ie the requirements of MPS1, and Exploration; Survey; Safeguarding (land won minerals, wharves and railheads the role of the SA to consider and associated infrastructure); Supply (the Managed Aggregate Supply System whether doing so will result in including landbanks in particular); any wider sustainability implications. Bulk Transportation; Efficient Use; Restoration; Alternatives to Primary Aggregates and Borrow Pits. MPS1 (Para 4.2) acknowledges that minerals operations are often long term in order to take into consideration various factors including the fact that individual sites, when permitted, need sufficient reserves to be economically viable, so consideration of the landbank needs to be flexible enough to allow for this. The requirements of PPS12 should also be considered in terms of making provision sufficient mineral sites and facilities to provide for the MPS1 landbank requirements for at least a 15 year plan period. It should also consider how it will ensure 'deliverability' of proposed sites in the emerging DPDs. It should also clarify how/what will be 'strategic sites'. There is very little data in this Minerals Topic Paper and so there are large gaps. None Noted The Baseline section should give a summary of the current situation regarding None It will be the role of KCC to

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Kent landbanks for soft sand/concreting sand and gravel/hard rock (obtainable consider the landbanks that from RAWP reports), together with a discussion on the 'Areas of Search' exist. identified in the 1993 Kent MLP and why many of these sites have failed to materialise into mineral extraction sites. Brett Aggregates would welcome the opportunity to view (and comment) on the None Noted related minerals topic papers and to meet to discuss the Kent MDF at regular intervals. Some of this document appears confusing such as in section 1. The statement in Yes Further detail has been added Para 1.3.7 'although self sufficiency...... gypsum' does not reflect the re. regional apportionment. requirements of National Minerals Policy in MPS1 or those of the minerals policies in the RSS. There should be an acknowledgement that KCC is required by national minerals Yes Further detail has been added policy to identify sites for future mineral working in its DPDs to meet the MASS re. regional apportionment. requirements in MPS1 and the Sub-regional apportionment allocations through the SE Plan Minerals Policy; The sub -county areas identified in Para 1.4.10 are not that relevant to minerals None These sub-county areas are planning, as it is the County as a whole which has to meet its sub-regional considered an appropriate apportionment requirements over the plan period. scale at which to collect evidence and identify sustainability issues, and therefore an appropriate scale at which to consider the effects of the MWDF. However, the new planning system requires consideration of spatial issues and None The Scoping Report has so therefore locational issues relating to existing and proposed sites would be collected in a focused way, to more useful in relation to the major conurbations and growth areas than these highlight the issues that will be lists in the sub-county baseline. pertinent to a consideration of the likely significant effects of the MWDF. However, it is important to note that scoping is an ongoing / live process, and so there will be opportunity to take account of further evidence, should this be required in order to undertake the assessment. Table 1 East Kent and Ashford has ommitted the aggregate importation wharf at Yes Amended

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Dover. It is not made clear how the SA will be carried out, or how it will comply with the None See Introductory Paper relevant legislation and guidance/good practice on carrying out SAs. The statement at end of Para 1.6.1 that a 'number of sustainability objectives None All Topic Papers were oulined in the other topic papers have been assigned sub-objectives relating consulted upon simultaneously specifically to minerals' needs clarification and explanation as (i) the other topic papers have not yet been released and so we are unable to comment on them (ii) unless there is clarity and open-ness, this statement (and therefore the proposed methods to be used in the SA) flies in the face of PPS12 which requires transparency and accessibility as well as timely, effective and conclusive discussion with key stakeholders on the deliverability of options for Core Strategies. As worded, this Minerals Topic Paper does not give any comfort that these requirements have been (or will be?) carried out? Waste The MWDF should identify clay extraction sites which could readily provide a None This representation should be Recycling suitable material source such as for flood defences and bulk fill for major made to the plan-makers - Group infrastructure or civil engineering projects, particularly where the resultant void KCC. can readily accommodate an established fill material. In terms of baseline, sufficient void must be identified to accommodate ash None This representation should be disposal arising from the County's EfW waste strategy. made to the plan-makers - KCC. The Sustainability Appraisal could include provision for strategically located None It will be the role of the plan- waste transfer facilities. makers to consider how to ensure such provision. Stephen This is a clay pit that provides engineering clay for a variety of uses including None It will be the role of KCC to Bowley landfill engineering and sea defences. The quarry also provides the landfill ensure that full consideration is Planning facility for the Allington waste incineration plant which requires long term capacity given to clay, including a Consultancy for the hazardous waste residues. detailed assessment of existing (on behalf of 1. The Minerals report focuses on aggregates. It is important that full sites and the uses of clay etc the owner of consideration is given to clay, including a detailed assessment of existing sites Norwood and the uses of clay etc. The Waste Report has not Quarry on the been amended, as no Isle of 2. The Waste Report needs to acknowledge the requirement for a long term evidence is provided to support Sheppey) landfill for hazardous waste to cater for the requirements of the Allington Plant. this statement. The Coal The Coal Authority supports the identification of the former coal mining Yes It is not clear that this Authority operations within east Kent in the text below Table 1 of the Minerals Topic Paper. information is of relevance to However, the Authority considers that this text could also make reference to the the SA of the MWDF. potential land stability and other public safety risks which may arise as a result of However, the Paper has been

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the legacy of coal mining in this area. amended to reference these issues Making specific reference to coal mining legacy within the Sustainability None This information would be Appraisal is an essential part of helping to raise awareness of such issues. It will more relevant to a District LDF also help to ensure that the Minerals and Waste Core Strategy contains Core Strategy. appropriate policies to ensure that any new development proposals within this area take account of these issues and incorporate appropriate mitigation measures where necessary in line with the guidance in PPG14. The following additional text is suggested: "The coal mining operations within east Kent will have left an environmental legacy which has the potential to cause land stability and other public safety risks. There are for example, around 50 recorded mine entries within this area. As such, it will be important that new development proposals within this area take account of any risks associated with former coal mining activities and, where necessary, incorporate suitable mitigation measures to address them." Reason - to ensure that land stability and other public safety issues associated with the former coal mining activities in east Kent are given due consideration within the Minerals and Waste Development Framework in line with the guidance in PPG14 (Development on Unstable Land). CPRE Air Quality - A pre-works audit is essential where Strategic Rail Freight None This will be taken into account Maidstone Interchanges are proposed or being built to monitor the amount of Carbon when considering measures to District Dioxide and particle emissions that will be produced by the associated lorry mitigate any negative effects of Committee traffic. the MWDF that are highlighted through the SA. However, it is thought unlikely that such action would be an appropriate way to mitigate the effects of the strategic choices made through the MWDF. A thorough audit of methane emissions produced from livestock and waste that None This evidence is not available, is produced. and it is not clear how it could add value to this SA. Biodiversity Topic Paper - to improve the fulfilment of the sustainability of 1.6.2 None The Biodiversity Paper need to assess: includes that evidence that is • Areas designated to receive protected species displaced by mineral readily available and which will workings to ensure that they will provide a really suitable habitat for assist in the identification of significant effects associated

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displaced species. with the MWDF. • The extent of traditional orchards and their rate of decline to determine the effect on the biodiversity of the areas in which such orchards are located and which might be affected by mineral workings. • The extent of fenland so as to preserve that fenland by avoiding any destruction due to mineral workings or waste disposal landfill. Climate Change and Flood Risk Topic Paper: None The Climate Change and Flood • Further data needed to determine a more specific relationship between Risk Paper includes that the details of weather, especially the basic temperature, precipitation, evidence that is readily wind speed and direction, and the averages that make up the climate. available and which will assist There is a need to factor the position of the "Jet Stream" and the effects of in the identification of the "El Nino" Current. significant effects associated • Sustainable waste to energy should be encouraged, providing the plants with the MWDF. are located at sites that do not have an adverse effect on the countryside or the quality of the life of nearby residents. Community and Well-Being Topic Paper: None The Community and Well- • The development of both mineral workings and waste disposal sites are Being Paper includes that often resisted by local residents particularly because of the increase in evidence that is readily heavy lorry traffic both for the construction and for the operational phases. available and which will assist There is also the fear that health will be adversely affected by the in the identification of emissions from the lorries and the dust from working the sites and from significant effects associated "poisons" from waste disposal plants. The views of local people should be with the MWDF. respected. Mineral workings and landfill sites are usually in the open rural countryside which is destroyed by such workings. • Additional data is required on the cost to the community in terms of noise, emissions and traffic of such workings and on the rate of restoration of the different type of sites for different types of restoration and the habitats to be created. Such data should reduce the time for which any mineral workings and landfill activities area blight of the landscape of the countryside and a cause of fear that the quality of life of local residents will be reduced. • Assessment of former mineral workings or even former landfill sites should involve the local community on the suitability of these sites as permanent residential sites for gypsies and travellers. Economy and Employment Topic Paper: None Response noted • Although mineral workings and waste disposal facilities can provide

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employment that must not be at the expense of ruining the environment and the quality of life for people living in an area. Heritage Topic Paper None Response noted • As mineral workings and landfill waste disposal is likely to destroy Heritage evidence there must be detailed surveys before any work is begun. The Kent Historical Environment Record will be useful, as heritage includes landscape, topography as well as vegetation, Public Rights of Way, buried archaeological and surface remains. Housing Topic Paper None Response noted • Expect and factor in changes to the present allocation for new dwellings in Kent coupled with the need to try and assess the amount of "minerals required to meet house building targets", that could be obtained from recycling materials. • To assess the most appropriate disposition throughout Kent for waste disposal sites both "incineration" and "landfill" to cope better with existing waste and to cope well with additional waste from the new housing developments, which is a cost on the sustainable of such developments. The objective must be on reducing the distance for lorries to travel with the waste and the disturbance to local communities. Location is very important. Landscape Topic Paper None Response noted • Emphasis should be put on the monitoring framework for, in order to protect, "Landscapes of Local Importance", including those with a special designation in relation to their position relative to nationally designated landscapes such as AONBs and Heritage sites. • The decline of Traditional Orchards and Hop Gardens in Kent, in the landscape should be carefully monitored in order to safeguard them as part of Kent's Heritage. Minerals Topic Paper None Response noted • With consideration of the likelihood of the amount of recycled material to be available. • Further data is required of any unutilised gas/oil deposits which might exist across the county of Kent. Rural Areas Topic Paper None Some of these representations • Additional data is required on the effects both positive and negative, of the might be more usefully made role and practices determined by the policies of multiple retailers on the as part of the process of

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rural economy of Kent. District LDF Core Strategy • Need for an investigation of the role of rural kent could play in the development. production of Green Energy. • Data needs to be collected on how new mineral workings and landfill sites, which will almost certainly be situated in the countryside, will affect rural communities. Transport Topic Paper None It is not clear that this data • Additional data is required on the viability in terms of cost to the would add value to the SA of community as well as financially of Strategic Rail Freight Interchanges the MWDF. close to areas of congestion already with high pollution and population. • Mineral workings and waste disposal development should be examined in Agree with the second point, relation to any proposals for Strategic Rail Freight Interchanges. which is identified as a key issue in the Transport Paper. Waste Topic Paper None The sustainability objective • Support statement 1.6.3. the cost of recycling waste in relation to demand developed for waste needs to be realistic. management is considered • Additional data is required on the most appropriate location of all types of appropriate, given the strategic waste recycling facilities so as they can be spread evenly across Kent. nature of the choices that will be made through the MWDF. • Need to investigate the effects of the ban on privately registered pickups and 4x4's to KCC Community Waste Disposal Sites for the collection and recycling of green waste. The consequence of additional burning with the release of carbon dioxide and any little potash residue perhaps recycled, as well as any additional "fly tipping" in the countryside which might occur. Water Topic Paper None Response noted • Support statements 1.6.2. as both mineral workings and landfill have the potential to disrupt greatly both surface run off the refilling of ground aquifers not only in terms of quantity but also in terms of quality. • A water grid from other regions should be given consideration. • Water storage at mineral extraction sites should be considered where there is a shortage of storage for surplus water. • An assessment should be carried out of how greater use could be made of recycled waste water its collection and distribution.

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Scoping Report - Introduction 1

Revision Schedule

Scoping Report – Air Quality March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August Draft for Mark Fessey Steve Smith Jeremy Richardson 2009 Consultation Consultant Associate Technical Director Ian Brenkley Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Scott Wilson 6-8 Greencoat Place London SW1P 1PL Tel: +44 (0)20 7798 5000

Table of Contents

1 Air Quality ...... 2 1.1 Introduction...... 2 1.2 Background...... 2 1.3 What’s the sustainability context?...... 2 1.4 What’s the current and (likely) future sustainability baseline? ...... 3 1.5 What are the key sustainability issues?...... 9 1.6 What decision-making criteria should make up the SA framework?...... 9 1.7 What further data is required? ...... 10

List of Tables

Table 1: Average annual concentrations 2007 ...... 5 Table 2: Number of day when one or more of specified pollutants recorded moderate concentrations or higher ...... 6 Table 3: The sub-county baseline ...... 8 Table 4: Key sustainability issues...... 9

List of Figures

Figure 1: Total number of days with pollutant concentrations recorded “moderate” or above for Kent and the UK ...... 6 Figure 2: Modelled Annual Nitrogen Dioxide (NO2) pollution and location of AQMAs (now out of date) ...... 7

Scoping Report – Air Quality 1 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1 Air Quality

1.1 Introduction

1.1.1 This is Topic Paper 1 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of air quality; describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to air quality in Kent and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 The primary driver for national, regional and local air quality management is the protection of human health, although the impact of certain pollutants on wildlife habitats and vegetation is also a concern. Air quality has generally improved over recent years although the County still contains some of the worst air pollution locations in the UK. Furthermore, it is increasingly recognised that air quality does not impact on the population equitably, but rather certain communities or vulnerable groups within the community are likely to be at risk.

1.2.2 A European Commission Study calculated that poor air quality may result in more than 32,000 premature deaths in the UK each year1 and a health impact assessment of the Government’s Air Quality Strategy suggests that the strategy will save thousands of life-years annually2. These statistics demonstrate the importance of good planning to help bring about improved air quality. Emissions from industrial sources are well regulated and are relatively minor compared to those from motor vehicles. Influencing patterns, mode and individual choice of transport will be important in achieving further improvements in air quality. The focus of this topic paper will be air pollution, whilst water pollution is considered in the Water Topic Paper and noise pollution is considered briefly as part of the consideration of the ‘health’ baseline.

1.3 What’s the sustainability context?

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering air quality in this SA. This context review meets a requirement of the SEA Directive.3

1.3.2 International action is essential to reduce air pollution and it is because of this that, since 1979, the UK has been a party to the UNECE Convention on Long Range Transboundary Air Pollution. At the EU level the Air Quality Framework Directive (96/62/EC) sets a strategic framework for tackling air quality consistently by setting European-wide limit values for 12 air pollutants in a series of daughter directives. Furthermore, the National Emission Ceiling Directive (NECD) sets ceilings for each EU Member State for emissions of ammonia, nitrogen

1 http://news.bbc.co.uk/1/hi/health/4283295.stm (accessed 05/09) 2 Defra et al (2007). The Air Quality Strategy for England, Scotland, Wales and Northern Ireland, Volume 2, [online] available: http://www.defra.gov.uk/environment/airquality/strategy/pdf/air-qualitystrategy-vol2.pdf (accessed 02/09). 3 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes.

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oxides, sulphur dioxide and volatile organic compounds (VOCs).4 For some pollutants there are additional targets that the UK is obliged to meet.

1.3.3 The Government’s air quality strategy sets out plans to improve and protect air quality in the UK.5 The strategy sets health-based ambient air quality objectives for nine main pollutants:

Benzene; 1,3-butadiene; carbon monoxide (CO); Lead; nitrogen dioxide (NO2); Ozone; Particles (PM10); sulphur dioxide (SO2); polycyclic aromatic hydrocarbons.

1.3.4 Government guidance6 on minerals planning identifies impacts relating to air quality as a ‘principle environmental impact’ of minerals working.7 Related guidance sets out the principles to be followed in considering the environmental effects of mineral working.8

1.3.5 The Regional Spatial Strategy (RSS)9 identifies tackling areas of poor air quality and avoiding deterioration in existing air quality as a key environmental challenge facing the region. Policy NRM9 seeks to sustain the current downward trend in air pollution in the region, including through reducing the environmental impacts of transport.

1.3.6 Local authorities have statutory duties for local air quality management under the Environment Act 1995. They are required to carry out regular reviews and assessments against eight of the national objectives, but not for ozone as it is affected by pollutants from outside the UK. Where it is found that objectives are unlikely to be met, authorities must designate Air Quality Management Areas (AQMAs) to tackle the problem and produce Air Quality Action Plans that set out measures to reduce pollution (that can also be incorporated into the Local Transport Plan). Air quality is also managed by local authorities through their responsibilities for land use planning, local transport and controlling industrial pollution sources. There are also two

pollutants (NO2 and SO2) with specific objectives aimed at protecting vegetation and ecosystems. Local authorities do not have statutory responsibility for these objectives.

1.3.7 The Kent Local Transport Plan (LTP) proposes direct and indirect measures, which are likely to improve air quality within the AQMAs. These include measures that promote alternatives to the private car, restrain car use, address pollution and promote the free flow of traffic.10

1.4 What’s the current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to air quality in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent to other geographical areas, as well as considering how the baseline varies at

4 HM Government (2002) The National Emission Ceilings Regulations 2002 [online] available at: http://www.opsi.gov.uk/si/si2002/20023118.htm (accessed 02/09). 5 DEFRA (2007). The Air Quality Strategy for England, Scotland, Wales and Northern Ireland [online] available at: http://www.defra.gov.uk/environment/airquality/strategy/pdf/air-qualitystrategy-vol1.pdf (accessed 02/09). 6 CLG (2006). Minerals Planning Statement 1: Planning and Minerals [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/mineralspolicystatement5 (accessed 02/09) 7 Note that dust, noise and vibration/blasting/flyrock are also identified as ‘principle environmental impacts’ of minerals working in MPS1, however, these issues have been scoped out of requiring explicit consideration through this sustainability appraisal as a result of being more site specific, rather than strategic. 8 CLG (2006). Minerals Planning Statement 2: Controlling and mitigating the environmental effects of minerals extraction in England [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/mps2 (accessed 02/09) 9 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09) 10 KCC (2006). Local Transport Plan for Kent 2006 – 2001 [online] available at: http://www.kent.gov.uk/publications/transport-and- streets/ltp-provisional-plan.htm (accessed 02/09)

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the sub-county scale, within three sub-regional areas defined in Kent by the RSS. This section meets a key requirement of the SEA Directive.11

Current baseline12

1.4.2 The Kent and Medway Air Quality Monitoring Network (KMAQMN) was formed in 1997 in order to coordinate air quality monitoring across the County. It draws on data from a network of over 30 monitoring stations to provide continuous monitoring of Kent’s performance against regional, national and international air quality targets. The following summarises trends associated with a number of pollutants deemed to be particularly relevant to minerals and waste planning.

1.4.3 Carbon monoxide (CO): CO emissions are associated with combustion sources, particularly road transport. Over the last 10 years no site in Kent has exceeded the EU air quality standards for CO. The significant reduction in CO concentrations in Kent and in the UK as a whole has been attributed to the use of vehicles with clean burn engines and catalytic converters.

1.4.4 Ozone (O3): Sunlight plays a key role in ozone formation. Over the last ten years, the highest annual mean ozone concentrations in Kent coincided with periods of long hot summers. In 2007, there were no incidents of “high” air pollution due to ozone recorded in Kent and all monitoring sites met the ozone objective. This is attributed mainly to the limited sunny weather. However, there were a large number of days with ozone concentrations falling in the “moderate” band.

1.4.5 Particulate matter (PM10): Concentrations are particularly high in the west of the County as a result of the dense network of major roads. Dover Docks is also identified as a significant contributor to

PM10 concentrations. A proportion of the PM10 concentrations in Kent come from non-local sources (mainly from London and mainland Europe).

1.4.6 In 2007 all monitoring sites met the annual mean PM10 Objective. However compared to 2006, in 2007 there were a larger number of days when concentrations reached “moderate” or above for

PM10 in a number of sites in the network including at Gravesham Industrial Background and Dartford St Clements Roadside. The elevated PM10 concentrations at Gravesham reflect emissions from the local industrial processes which include bulk storage of aggregates and wood shredding.

1.4.7 Nitrogen dioxide (NO2): Over the last ten years, the majority of the sites have seen very little

variation in NO2 concentrations. In 2007, as with previous years, many of the network roadside sites

failed to meet the annual mean NO2 objective. Dartford Bean Interchange and Dartford St Clements sites exceeded the hourly mean NO2 objective. In these sites there is a significant local source of NO2 when compared to the other Kent and Medway sites. 2007 provided some of the most intense

wintertime hourly NO2 pollution episodes across southeast England for many years mainly caused by calm, cold weather conditions which allow for a build up of pollutants due to a lack of dispersion.

1.4.8 Sulphur dioxide (SO2): The major SO2 sources in Kent are the power and other industrial activities in the northern part of the county as well as the shipping activities in the vicinity of Folkestone and

Dover. In 2007, all air quality monitoring sites met all the SO2 objectives. The introduction of pollution abatement equipment at power stations has helped to reduce SO2 emissions so now

moderate SO2 days are rare. Only the newly installed monitoring station at Dover Docks, with 30 exceedences, approached the objective limit of 35 exceedences in the year. This station has

significantly higher SO2 concentrations than any other monitoring station in the county network indicating the significance of shipping activities on SO2 concentrations.

11 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected” 12 Unless otherwise stated, information gathered from - Kent & Medway Air Quality Monitoring Network (2007) Annual Report [online] available at: http://www.kentair.org.uk/documents/KMAQMN%202007%20Annual%20Report.pdf (accessed 03/09)

Scoping Report – Air Quality 4 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1.4.9 From Table 1 it is possible to identify those sites that are performing poorly in terms of the pollutants under consideration. Table 2 shows the trends over time for pollution at a select number of monitoring sites. Finally Figure 1 shows the trend for a key air quality index.

Table 1: Average annual concentrations 200713

CO PM10 NO2 O3 SO2 Site -3 -3 -3 -3 -3 (mgm ) (µgm ) (µgm ) (µgm ) (µgm ) Roadside Ashford Roadside 28 34 Canterbury Roadside 46 Chatham Roadside 26 34 Dartford Bean Interchange Roadside 30 56 Dartford St Clements Roadside 39 58 Dartford Town Centre Roadside 31 54 Dover Old Town Hall Roadside 38 Dover Centre Roadside 34 Gravesham A2 Roadside 28 48 Maidstone A229 Kerbside 0.6 31 51 Swale Ospringe Roadside 24 24 Swale Ospringe Roadside 32 Tunbridge Wells A26 Roadside 31 48 Thanet Birchington Roadside 24 37 Thanet Ramsgate Roadside 29 25 Tonbridge Roadside 50 Canterbury 23 18 Dover Langdon Cliff 7 Dover Docks 48 17 Gravesham Industrial Background 34 31 Chatham Luton Background 0.2 23 26 44 8 Swale Sheerness 30 25 2 Tunbridge Wells Town Centre 23 Thanet Airport 18 Folkestone Suburban 23 24 48 4 Thanet Margate Background 21 Maidstone Rural 21 18 47 4 Rochester Stoke 23 18 46 6 Thanet Rural 37

13 Kent & Medway Air Quality Monitoring Network Annual Report 2007 [online] available at: http://www.kentair.org.uk/documents/KMAQMN%202007%20Annual%20Report.pdf (accessed February 2009)

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Table 2: Number of day when one or more of specified pollutants recorded moderate concentrations or higher14

1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 Chatham Luton 61 26 59 24 41 45 86 57 47 42 44 Background Chatham Roadside 14 1 3 1 8 1 12 3 3 7 7 Folkestone Suburban 26 38 85 37 42 51 72 38 49 59 49 Maidstone A229 5 11 15 5 30 6 9 13 15 Kerbside Maidstone Rural 52 37 92 62 100 45 33 57 44 Rochester Stoke 72 44 66 39 64 52 70 60 37 53 42 Thanet Rural 1 11 37 16 24 41 19 9 27 4 Kent Overall rural 72 23 43 38 57 46 70 41 26 46 30 indicator Kent Overall urban 34 22 38 18 27 26 50 26 27 30 29 indicator UK Rural Indicator 42 29 48 27 34 32 64 44 40 57 24 UK Urban Indicator 40 24 33 21 25 20 50 23 22 41 24

Figure 1: Total number of days with pollutant concentrations recorded “moderate” or above for Kent and the UK15

14 Kent & Medway Air Quality Monitoring Network Annual Report 2007 [online] available at: http://www.kentair.org.uk/documents/KMAQMN%202007%20Annual%20Report.pdf (accessed February 2009) 15 Ibid.

Scoping Report – Air Quality 6 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1.4.10 All the indicators show a peak in 2003, mainly attributable to the hot summer in that year, which contributed to elevated levels of pollutants. In both Kent and the UK, rural sites have more days with elevated concentrations than urban sites. This is attributed to gradually increasing ozone levels across the UK.16

17 1.4.11 Presently 35 AQMAs have been declared in Kent for NO2 and/or particulate PM10 and SO2, with further areas coming forward following the third round of review and assessments. AQMAs have been declared along sections of the main road network including the: A2; M2; A20; M20; A25; M25; M26; A28; and A228. AQMAs have alse been declared at some town centres including at: Canterbury; Dartford; Dover; Gravesend; Maidstone; Tonbridge; and Tunbridge Wells. Furthermore, AQMAs have also been declared at Dover Eastern Docks due

to the increased SO2 emissions from shipping and the Northfleet Industrial Area due to the 18 PM10 emissions leaking from equipment used in their industrial processes.

1.4.12 Figure 2, taken from the Local Transport Plan, shows modelled NO2 in Kent. This map is somewhat out of date, as it does not show the most up to date set of AQMAs, but it gives an interesting picture of air pollution across the County nonetheless.

Figure 2: Modelled Annual Nitrogen Dioxide (NO2) pollution and location of AQMAs (now out of date)19

16 Ibid. 17 KCC (2009) [per comms]. 18 KCC (2008) Local Transport Plan for Kent 2006-2011, Delivery Report (Final Version) [online] available at: http://www.kent.gov.uk/static/publications/ltp-kent-dr-2008.pdf (accessed 03/09) 19 KCC (2006) Local Transport Plan for Kent 2006-2011 [online] available at: http://www.kent.gov.uk/publications/transport-and- streets/ltp-provisional-plan.htm (accessed 03/09)

Scoping Report – Air Quality 7 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1.4.13 Road transport is a key source of many air pollutants, particularly in towns and cities. The Local Transport Plan (LTP) for Kent identifies that between 1982 and 2003 the number of nationally licensed cars rose by 70% in the UK, and that traffic growth across Kent is higher than the national trend. Emissions of key air pollutants from road transport have fallen by about 50% over the last decade, despite increases in traffic, and are set to reduce by a further 25% or so over the next decade. This is mainly a result of progressively tighter vehicle emission and fuel standards agreed at European level and set in UK regulations.20 Emissions of the majority of metals have remained relatively stable between 2005 and 2006 with some increases relating to changes in fuel use.21

Future baseline

1.4.14 A number of positive trends are evident in the baseline data. In terms of the air quality impacts of road traffic, pollution ‘per km’ is set to decrease as regulations on engine and efficiency are tightened. Similarly, EU Directive 2005/33/EC on the sulphur content of marine fuels limits the maximum level of sulphur in diesel sold within the EU to 1.5% from 2010 onwards, down from 4.5% at present. However, the levels of development planned for Kent will lead to significant increases in car journeys along some routes, and so there will be the potential for air quality to worsen in some areas. Similarly, there is the potential for pollution from shipping to become more or less of an issue at some ports, as shipping patterns change.

Current and future situation in sub-county areas

1.4.15 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These areas were identified primarily on economic grounds, but provide a useful spatial framework to consider other elements of the sustainability baseline. Table 3 considers current and possible future baseline conditions in each of these sub-areas.

Table 3: The sub-county baseline

East Kent and Ashford22 The A299 running along the North Kent coast is a major transport corridor, with the heaviest traffic flows between Faversham and Herne bay, before traffic splits to access the different Thanet towns. The A28 passes north to Margate, and along this road an AQMA has been designated at Birchington. The A256 running south from Margate past Ramsgate is also a heavily used road. The M20, running past Ashford to Folkestone, has the heaviest traffic flows in the sub-area. Both this road, and the A2 which runs from Canterbury to Dover, pass through the Kent Downs, which include sensitive chalk downland habitats. At Dover, the ferries and the large volume of commercial traffic passing through the town creates particular air quality issues and have resulted in the designation of an AQMA. Kent Thames Gateway23 The M25 and M2, as they pass through the Kent Thames Gateway, carry heavier traffic flows than any other routes in the county. As a result of heavy traffic flows, diffuse NO2 pollution is high across the sub- area. There are also areas of PM10 pollution as a result of heavy traffic flows on the M25 and M2/A2, particularly around Dartford and Gravesend town centres.

20 DEFRA (2005) Air Quality Strategy [online] available at: http://www.defra.gov.uk/environment/airquality/publications/stratevaluation/index.htm (accessed 03/09) 21 DEFRA (2008). Statistical release – UK emissions of air pollutants – 2006 results [online] available at: http://www.defra.gov.uk/news/2008/080313a.htm (accessed 03/09). 22 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 23 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2.

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Rest of Kent24 The M25 and the section of the M20 to the west of Maidstone, carry some of the heaviest traffic flows in the county. Diffuse NO2 pollution is likely to be high at Maidstone and along the route running north from Maidstone to the Medway towns. Maidstone has declared an urban wide AQMA; an AQMA has been declared on the A26 in Tunbridge Wells; 6 AQMAs have been declared in Tonbridge and Malling; and Sevenoaks has 10 AQMAs, with all motorways declared.

1.5 What are the key sustainability issues?

1.5.1 Table 4 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 4: Key sustainability issues

Key Issue Discussion

Traffic on the motorway The increased development at existing centres in the county is likely to put and A-road network is the further pressure on the road network, and lead to new and worsened cause of the majority of occurrences of poor air quality. designated AQMAs

There remain instances Non-traffic related AQMAs have been designated at Dover Eastern Docks where point source air and Northfleet Industrial Area, demonstrating that there is a need to pollution is a strategic consider the cumulative effects of polluting activities concentrating in one issue area.

1.6 What decision-making criteria should make up the SA framework?

1.6.1 The Southeast Regional Sustainability Framework includes the objective:

“To reduce air pollution and ensure air quality continues to improve”

1.6.2 It is helpful to take account of established regional sustainability objectives. However, bearing in mind the scope of influence of the Kent MWDF it is not thought that air quality is an issue of such likely significance that it requires explicit consideration through appraising the plan against an air quality related sustainability objective. Rather, it is proposed to include a sub-objective relating to air pollution under the transport related objective (see Transport Topic Paper), in recognition of the fact that the vast majority of air pollution is transport related. The following sub-objective is proposed:

• Ensure that minerals and waste development does not contribute to poor air quality

24 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area.

Scoping Report – Air Quality 9 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1.7 What further data is required?

1.7.1 Data collection and the establishment of the evidence base is an important component of the SA. However, there are cases where the evidence / data may not exist or is not ‘fit-for- purpose’. In these cases it is important that these gaps are highlighted early in the evidence gathering stage so that there is an opportunity to recruit data through consultation. The following have been identified as data gaps / issues:

• Monitoring/modelling of local emissions from major infrastructure or growth drivers/activities including road transport and aviation

Scoping Report – Air Quality 10 March 2010

Revision Schedule

Scoping Report – Biodiversity Topic Paper March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Consultant Associate Technical Director Ian Brenkley Consultant

03 March 2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Scott Wilson 6-8 Greencoat Place London SW1P 1PL Tel: +44 (0)20 7798 5000 This document has been prepared in accordance with the scope of Scott Wilson's Fax: +44 (0)20 7798 5001 appointment with its client and is subject to the terms of that appointment. It is addressed to and for the sole and confidential use and reliance of Scott Wilson's client. Scott Wilson www.scottwilson.com accepts no liability for any use of this document other than by its client and only for the purposes for which it was prepared and provided. No person other than the client may copy (in whole or in part) use or rely on the contents of this document, without the prior written permission of the Company Secretary of Scott Wilson Ltd. Any advice, opinions, or recommendations within this document should be read and relied upon only in the context of the document as a whole. The contents of this document do not provide legal or tax advice or opinion.

Table of Contents

1 Biodiversity...... 3 1.1 Introduction...... 3 1.2 Background...... 3 1.3 What’s the sustainability context?...... 4 1.4 What’s the current and (likely) future sustainability baseline? ...... 6 1.5 What are the key sustainability issues?...... 22 1.6 What decision-making criteria should make up the SA framework?...... 22 1.7 What further data is required? ...... 23

List of Tables

Table 1: Regional distribution of international designations ...... 7 Table 2: Habitat Action Plan objectives for Priority Habitats in Kent ...... 9 Table 3: The sub-county baseline ...... 20 Table 4: Key sustainability issues...... 22

List of Figures

Figure 1: Natura 2000 habitat in Kent...... 8 Figure 2: BAP beech and yew woodland by authority and JCA ...... 13 Figure 3: Calcareous grassland by authority and JCA ...... 13 Figure 4: Acid grassland by authority and JCA ...... 14 Figure 5: Heathland by authority and JCA...... 14 Figure 6: Lowland meadow by authority and JCA ...... 14 Figure 7: Area of Semi-natural habitat by region...... 15 Figure 8: Habitat connectivity in England ...... 17 Figure 9: Biodiversity Opportunity Areas in Kent...... 19

Scoping Report - Biodiversity March 2010 2 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1 Biodiversity

1.1 Introduction

1.1.1 This is Topic Paper 2 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of biodiversity; describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to biodiversity and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 Biodiversity is the term given to the diversity of life on Earth and this includes the plant and animal species that make up our wildlife and the habitats in which they live. Biodiversity is important for its intrinsic value, but it is also vital for the ecosystem services it provides. These include not only services such as flood defence and clean water for which it is possible to elicit an economic value, but also less tangible but nonetheless important cultural, aesthetic, health and wellbeing benefits.

1.2.2 The focus of strategic decision making is on the diversity of semi-natural habitats (habitats which have been modified by man but retain many natural features), and the UK BAP priority habitats in particular. This diversity is much less rich than 50 years ago, and remains under pressure from a significant range of threats. It is important to note, however, that a positive approach to conservation can ensure that development occurs in a way that protects biodiversity and allows ecosystems to function, and, indeed, can result in development positively influencing to the biodiversity baseline.

1.2.3 Minerals and waste planning must give consideration to a wide range of potential pathways by which biodiversity impacts may occur, both direct (e.g. land use change) and indirect (e.g. pollution). However, it is important to realise that some issues relating to biodiversity are outside the scope of the KMWDF. Furthermore, it is important to consider how minerals and waste planning can present opportunities as well as risks. Projects can design in biodiversity from the outset and, furthermore, there is the potential to plan for projects that allow for biodiversity benefits during later stages of the project life-cycle. Strategic decisions can seek to maximise such opportunities, in particular through directing projects to particular areas.

Scoping Report - Biodiversity March 2010 3 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1.3 What’s the sustainability context?

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering biodiversity in this SA. This context review meets a requirement of the SEA Directive.1

1.3.2 The UK is a Party to the Convention on Biological Diversity (CBD), a principal objective of which is the conservation of biodiversity. Following implementation of the CBD member states of the European Union have committed to halting biodiversity loss by 2010 and putting biodiversity ‘on the course to recovery’.2 Commitment to the CBD also led to the preparation of the 1994 UK Biodiversity Action Plan (UK BAP), which identifies our most threatened habitats and species and includes action plans with ambitious targets for their recovery. A Biodiversity Strategy for England was subsequently published in 2002.3 The Strategy sets out the UK Government’s vision for biodiversity in terms of ensuring that biodiversity considerations become embedded in all the main sectors of economic activity, public and private. This message is re-emphasised in more recent Government guidance relating to biodiversity, which also has an emphasis on the value of biodiversity for health and well-being.4 The Natural Environment and Rural Communities Act 2006 also seeks to make biodiversity a natural and integral part of policy and decision-making, and places a Duty on public authorities to have regard to the conservation of biodiversity in exercising their functions.5

1.3.3 The Government has recognised the importance of having a diverse, healthy and resilient natural environment by announcing a new cross-government Public Service Agreement 28 (PSA) to “secure a healthy natural environment for today and the future” (October 2007). Related to the PSA, Defra has developed the ‘Ecosystem Approach’, which seeks to provide a framework for looking at whole ecosystems in decision making with an emphasis on valuing ecosystem services.6 Furthermore, an ecosystems approach should:

• be holistic, recognising the interconnectedness of natural and human systems; • respect environmental limits, taking into account ecosystem functioning; • consider an appropriate spatial scale, recognising the cumulative nature of impacts; and • promote adaptive management, which can respond to environmental change over time.

1.3.4 As part of the approach the Government has given consideration to how best to reconcile conserving a list of priority species (as required by the UK BAP) with the wider agenda of maintaining ecosystem services. The proposed UK approach focuses on maintaining, creating and restoring functional combinations of habitats. Healthy habitats in mosaics will deliver both ecosystem services and also homes for priority species. Some functions and services will arise only when the conditions are right at the landscape scale, for example within distinct

1 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes. 2 European Commission (2006). Communication on “Halting the loss of biodiversity by 2010 – and beyond [online] available at: http://ec.europa.eu/environment/nature/biodiversity/comm2006/index_en.htm (accessed 02/09) 3 Defra (2002). Working with the grain of nature: A biodiversity strategy for England [online] available at: http://www.defra.gov.uk/wildlife-countryside/biodiversity/action-uk/e-biostrat.htm (accessed 02/09) 4 ODPM (2005). Planning Policy Statement 9: Biodiversity and Geological Conservation [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/pps9 (accessed 02/09) 5 Defra (2007). Guidance for Public Authorities on Implementing the Biodiversity Duty [online] available at: http://www.defra.gov.uk/wildlife-countryside/biodiversity/key-docs.htm (accessed 02/09) 6 Defra (2007). Conserving Biodiversity – The UK Approach [online] available at: http://www.defra.gov.uk/wildlife- countryside/pdf/biodiversity/conbiouk-102007.pdf (accessed 02/09)

Scoping Report - Biodiversity March 2010 4 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

topographical units such as catchments. This idea has been taken forward at the regional scale through the promotion of an ecological network approach to rebuilding biodiversity for the 21st Century. In particular, it promotes a holistic approach of promoting synergies between the ecological network and other land-management schemes. The Branch Project is an example of a scheme, which ‘advocate[s] the need for change in spatial planning and land use systems to allow wildlife to adapt to climate change’7.

1.3.5 Government guidance on minerals planning identifies impacts relating to “internationally or nationally designated, protected or sensitive species and plant and wildlife habitats’’ as a potential environmental impact of minerals working.8 However, the guidance also points out that mineral workings often provide the opportunity in their restoration and after-use to create new wildlife habitats, with forestry and woodland being one potentially successful option. Furthermore, Government guidance on biodiversity and planning states, in relation to minerals and waste planning, that:

“active phases can be very beneficial for biodiversity and geological conservation. Specific habitats that benefit specialist species can be created in an active quarry and previously unknown or unrecorded geological features can be uncovered. Mineral and Waste Documents should therefore include policies which ensure that biodiversity and geology is conserved and enhanced during any active phases in addition to those relating to restoration schemes.”

1.3.6 Policy NRM5 of the Regional Spatial Strategy (RSS)9 promotes pursuing opportunities to achieve a net gain in biodiversity across the region, particularly through valuing and protecting areas of habitat and recognising the way that they support one another and function together in the wider landscape context. The Policy promotes making the most of opportunities for biodiversity improvement, including through the connection of sites, large-scale habitat restoration and re-creation focused particularly on areas of strategic opportunity for biodiversity improvement. The Policy also seeks to ensure appropriate access to areas of wildlife importance, whilst also stating the important role of green infrastructure in reducing pressure on more sensitive locations.

1.3.7 On the topic of Green Infrastructure, it is worth noting that the South East Green Infrastructure Framework (2009)10 is a key document. The framework identifies the key functions of green infrastructure in the South East as relating to: conservation and enhancement of biodiversity, including the need to mitigate the potential impacts of new development; creating a sense of place and opportunities for greater appreciation of valuable landscapes and cultural heritage; increasing recreational opportunities, including access to and enjoyment of the countryside and supporting healthy living; improved water resource and flood management and sustainable design; making a positive contribution to combating climate change through adaptation and mitigation of impacts sustainable transport, education and crime reduction; and production of food, fibre and fuel. It is notable that Greening the Gateway Kent and Medway (GGKM) is highlighted as a case-study of regional importance - see Box 1.

7 http://www.branchproject.org/about/ (accessed 05/09) 8 CLG (2006). Minerals Planning Statement 1: Planning and Minerals [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/mineralspolicystatement5 (accessed 02/09) 9 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09) 10 Natural England (2009). South East Green Infrastructure Framework. Available [online] at http://www.naturalengland.org.uk/regions/south_east/ourwork/greeninfrastructureframework.aspx (accessed 02/10)

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1.4 What’s the current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to biodiversity in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent to other geographical areas, as well as considering how the baseline varies at the sub-county scale, within three sub-regional areas defined in Kent by the RSS. This section meets a key requirement of the SEA Directive.11

Current baseline

Habitats and designated sites

1.4.2 In relation to biodiversity, the Regional State of the Environment Report identifies that the South East has:

• over 30% of England’s broadleaved, mixed and yew woodland, making it the most highly wooded region; • over 40% of England’s lowland heath resource, more than any other region; • over 16% of the lowland calcareous grassland resource; • over 60% of England’s vegetated shingle resource, over 10% of the intertidal mudflats, 16% of coastal lagoons and over 15% of coastal and floodplain grazing marsh, more than other regions; • 692 SSSIs, many of internationally importance (there are 86 Natura 2000 sites) and a total of over 35,000ha of semi-natural habitat; • areas of intertidal habitat have already been lost to sea level rise, in the South East there have been significant losses of saltmarsh across 12 Special Protection Areas; and • Over 60% of agricultural land in Kent is under Environmental Stewardship.

1.4.3 Extensive areas of habitat in the South East are designated as being of international importance – see Table 1.12

11 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected” 12 Special Protection Areas (SPAs) and Special Areas of Conservation (SACs) are established under the EC Birds Directive and Habitats Directives respectively and together form part of the Europe-wide Natura 2000 network. Areas of wetland in the East of England are also designated internationally under the RAMSAR Convention.

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Table 1: Regional distribution of international designations13

1.4.4 Kent contributes significantly to the value of the regional biodiversity resource. Figure 1 shows the location of Natura 2000 habitat in Kent. It can be seen that Natura 2000 habitat is concentrated around the coast, particularly around the Thames Gateway (much within Medway UA), The Isle of Thanet and the Stour Estuary and Dungeness. A separate assessment process, known as Habitats Regulations Assessment, will be undertaken to ensure that the MWDF will not impact upon the Natura 2000 network.

1.4.5 Figure 1 also shows the location of the 101 Sites of Special Scientific Interest (SSSIs) within Kent, which cover a total area of 33,163 hectares - covering 8.5% of the county. As of February 2009, 93% of the area of SSSI in the county was meeting the Public Service Agreement (PSA) target of being in either favourable (73%) or unfavourable recovering (20%) condition. In the wider South East, 89% of SSSI is meeting the PSA target (46% favourable; and 43% unfavourable recovering). There are also 456 local wildlife sites in Kent and Medway which contain large tracts of priority habitat. LWSs cover approximately7% of the County.

1.4.6 Kent is home to 28 UK BAP priority habitats, which are now the focus of Habitat Action Plans (HAPs) produced by the Kent Biodiversity Partnership. Each HAP sets out the steps needed to secure a healthy future for the habitat and for the wildlife that depends on the habitat for their survival. Table 2 lists the 28 priority habitats, and includes an incomplete list of objectives that have been set as part of the HAP for each one. Some objectives have been removed from consideration here because they are of less relevance to the Kent MWDF. These generally related to raising awareness and securing appropriate management of habitat. It is also important to note that Phase 1 habitat survey data is available for Kent. It may be important to draw on detailed data such as this as part of the appraisal. A final point to note is that restored, and unrestored quarries, with long term management plans can provide excellent opportunities for BAP habitat creation. A key document is ‘Nature after Minerals’.14

13 Natural England (2008) State of the Natural Environment 2008 [online] available at: http://www.naturalengland.org.uk/publications/sone/default.aspx (accessed 03/09) 14 RSPB et al. (2009). Nature after Minerals. Available [online] @ http://www.afterminerals.com/projectinfo.aspx (accessed 01/10)

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Figure 1: Natura 2000 habitat in Kent

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Table 2: Habitat Action Plan objectives for Priority Habitats in Kent15

Priority Habitat Kent HAP Objectives Ancient &/or Ensure no net loss of ancient &/or species-rich hedgerows. Species Rich Continue to encourage the positive management, restoration and re-creation of hedgerows. Priority should be given Hedgerows to: ancient &/or species-rich hedgerows; hedgerows which reconnect other habitats; hedgerows that form a key feature of the landscape character, e.g. Low Weald, in particular where these have been removed due to agricultural intensification. Built-Up Areas & Maintain and enhance the current extent and quality of natural and semi-natural habitats within built-up areas & Gardens gardens. Raise the profile of positive planning for biodiversity in accordance with planning policy guidance/statements. Inform and influence the planning of existing and new public open space by encouraging the adoption of appropriate accessible natural green space standards (ANGSt) in all urban areas to ensure that biodiversity is adequately considered within open space strategies required by PPG17. Promote the importance of biodiversity as a component of the Sustainable Communities agenda. Cereal Field Maintain, enhance and create the area of cereal field margins being positively managed for wildlife. Margins Conserve and enhance key populations of arable weeds. Chalk Rivers Conserve the characteristic flora, fauna and physical habitat features of chalk rivers including their winterbourne stretches. Review the need and potential for restoration of flows, water quality and habitat diversity of Kents chalk rivers in consultation with local communities and organisations, and implement restoration where appropriate. Coastal & To maintain the extent and quality of existing areas of semi-natural grazing marsh. Floodplain Grazing To bring all existing areas of semi-natural grazing marsh into appropriate management. Marsh To create new habitat from arable land, especially where it will link existing areas of grazing marsh. Coastal Saltmarsh Maintain the extent of the saltmarsh resource in Kent (subject to evolution through natural processes). Maintain, enhance and restore the quality of coastal saltmarsh.

15 Kent Biodiversity Action Plan [online] available at: http://www.kentbap.org.uk/habitats/ (accessed 03/09)

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Coastal Sand Maintain quality and extent of existing coastal sand dunes. Dunes Ensure positive management of all coastal sand dunes in Kent. Coastal Vegetated Ensure no net loss of coastal vegetated shingle, unless subject to natural coastal changes. Shingle Restore coastal vegetated shingle to favourable condition or unfavourable recovering condition with the proviso that patterns of coastal evolution may erode shingle from the coastline. Restore open fen communities to suitable wetland areas. Restore natural coastal processes as far as is possible to all areas of the coast. Littoral & Maintain the extent and quality of littoral and sub-littoral chalk habitats unaffected by coastal defence and other Sublittoral Chalk engineering works. Allow natural coastal processes to dictate, where possible, the geomorphology of the littoral and sub-littoral environment. Ensure that human activities continue to be managed to minimise their effects on littoral and sub-littoral chalk habitats and species. Lowland Beech & Maintain the total current extent and condition of semi-natural lowland beech and yew woodland as identified by the Yew Woodland 2003 Kent Habitat Survey. Identify priority areas for increasing the area of this habitat through planting new woodlands and altering the structure of existing woodlands with a significant non-native component. Lowland Maintain current extent and quality of lowland calcareous grassland in Kent. Calcareous Ensure positive management of all lowland calcareous grassland in Kent. Grassland To create (or re-create) lowland calcareous grassland in Kent. Lowland Dry Acid Maintain the extent of all existing acid grassland sites. Grassland Increase the overall area extent of acid grassland and reduce habitat fragmentation. Secure appropriate management of all SSSI and Local Wildlife Site (SNCI) acid grassland. Where possible, secure the appropriate management of non-designated acid grassland. Lowland Fens Maintain the extent and quality of all existing fen sites. Ensure sufficient water is available to maintain, and where appropriate enhance, fen habitat. Ensure that, wherever possible, the management of flood risk works with, maintains and enhances natural systems,

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for example through the reconnection of water courses with their natural floodplains. Resist culverting, canalisation, diversion or other alterations of springs, headwaters and other water courses where this would potentially or actually damage fen habitat. Create new, strategically important wetlands as part of the major river systems in the county. Where appropriate, seek restoration to conservation wetland, including fen habitat, as a condition of aggregate extraction in floodplains. Lowland Heath Maintain the extent of all existing heathland sites. Significantly increase the extent of heathland, particularly at or close to existing sites at Dartford and Hothfield, and in the Blean and the High Weald. Lowland Meadow Maintain the extent and quality of all lowland meadow sites. Increase the overall extent of lowland meadows and reduce habitat fragmentation. Secure the appropriate conservation management of all existing/recreated lowland meadow SSSIs and SNCIs. Where possible secure the appropriate management of non-designated lowland meadows. Lowland Wood- Ensure that the current area of wood-pasture in Kent is actively managed through suitable grazing and tree Pasture & management. Parkland Create new areas of wood-pasture and parkland in Kent where there is greatest opportunity and where this would not compromise nature conservation objectives for other habitats. Maritime Cliff & Maintain quality and extent of existing maritime cliff and slope. Slope Ensure positive management of all maritime cliff and slope in Kent. Marine To promote an integrated cross-sectoral, ecosystem approach to sustainable marine resource management in Kent and regionally. Mixed Maintain the existing area of ancient, semi-natural woodland plus the area of semi-natural woodland that is not Broadleaved ancient. Woodland & Increase the area of semi-natural woodland on ancient woodland sites by restoring native-species cover in existing Plantations coniferous plantations. Develop a programme to restore and, where appropriate, reintroduce populations of BAP and Kent Red Data Book (RDB) woodland butterflies. Develop opportunities for all to enjoy woodland biodiversity.

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Mudflats Maintain at least the present extent and general distribution of Kent's mudflats. Raise awareness, amongst key decision-makers, of the importance of mudflats as an ecological resource. Old Orchards Seek to minimise the loss of traditional old orchards. Maintain those traditional old orchards remaining in (or restore them to) favourable managed condition. To increase the use of orchards as community orchards. Targeted planting of new trees. Reedbeds Maintain the overall extent of existing reedbed sites. Create new, strategically important wetlands – to include reedbeds – as part of the major river systems in the county. Where appropriate, seek restoration to conservation wetland – including reedbeds – as a condition of aggregate extraction in floodplains. Ensure that any future proposals for coastal realignment do not result in net loss of reedbed habitat. Sabellaria To maintain the distribution and quality of any S. alveolata reefs found around the Kent coast. alveolata Reefs Saline Lagoons Maintain the current quality and extent of saline lagoons in Kent. Seagrass Beds Maintain extent and distribution of seagrass beds in Kent waters. Standing Open Maintain the condition of open waters currently judged as in favourable condition within important sites/landscapes Water (SSSI, SNCI, AONB). Maintain the condition of all other high-quality sites where feasible. Initiate action to restore to favourable condition (typical plant and animal communities present) sites that have been damaged or neglected, particularly within important sites and landscapes. Increase the abundance of standing open water habitats where appropriate, particularly wildlife-friendly ponds. Wet Woodland Maintain the total current extent of wet woodland. Identify priority areas for increasing the area of this habitat through the creation of new woodlands and altering the water management of land near potential areas.

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1.4.7 Figures 2 - 9 show the distribution of a range of lowland BAP habitats across the South, East and Midlands of England. From these maps it is possible to gain an appreciation of the importance of the habitat resource found in the South East and Kent.16

Figure 2: Proportion of the national resource of BAP beech and yew woodland by authority (left) and JCA (right)

Figure 3: Proportion of the national resource of calcareous grassland by authority (left) and JCA (right)

16 Figures 2 – 9 obtained from www.natureonthemap.org.uk (accessed 02/09). N.B. The thematic maps show the proportion of the national resource split into four bands.

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Figure 4: Proportion of the national resource of acid grassland by authority (left) and JCA (right)

Figure 5: Proportion of the national resource of heathland by authority (left) and JCA (right)

Figure 6: Proportion of the national resource (lowland meadow) by authority (left) and JCA (right)

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1.4.8 The Kent Biodiversity Action Plan (BAP)17 includes targeted actions for 85 UK BAP species, and 28 UK BAP Priority Habitats within Kent. The Kent BAP includes a number of objectives to halt the loss or decline of these species and habitats.

Biodiversity in the wider countryside

1.4.9 As shown by Figure 7, less than half of the semi-natural habitat in the South East is found within designated sites. This statistic highlights the importance of also considering biodiversity outside designated sites.

Figure 7: Area of Semi-natural habitat by region18

1.4.10 Hedgerows, trees and woodland are important natural features in Kent’s landscape. Although Kent has proportionately less woodland cover than the South East as a whole a high proportion of its woodland is ancient. Kent has about 10% of the national resource of ancient woodland.19 It is important to note that ancient woodland inventories are available, some of which have recently been revised (e.g. Ashford Borough20 and Tunbridge Wells Borough21).

1.4.11 In terms of biodiversity in the wider countryside, it is important to take account of the findings of local level landscape character assessments, from which it is possible to identify local sensitivities.

17 Kent Biodiversity Action Plan. [www.kentbap.org.uk]. Accessed 11.10.2007. 18 Natural England (2008). State of the Natural Environment 2008 [online] available at: http://www.naturalengland.org.uk/publications/sone/default.aspx (accessed 02/09) 19 Kent and Medway Structure Plan (2006) Protecting and enhancing our natural environment [online] available at: http://www.kmsp.org.uk/towards-adoption-of-plan.html (accessed 05/09) 20 A revision of the ancient woodland inventory for Ashford Borough, Kent (2009) [online] available at: http://www.ashford.gov.uk/PDF/A%20Revision%20of%20the%20Ancient%20Woodland%20Inventory%20for%20Ashford%20Borough ,%20Kent.%204950Kb%20PDF.pdf (accessed 02/10) 21 A revision of the ancient woodland inventory for Tunbridge Wells Borough, Kent (2007) [online] available at: http://www2.tunbridgewells.gov.uk/pdf/Tun_Wells_AWI_report_Oct_07__Pt_1Forewards1.pdf (accessed02/10)

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Habitat connectivity22

1.4.12 Figure 8a shows that the South East is characterised by a high density of fragmented habitat patches. These patches will often be separated by relatively inhospitable land-uses such as intensive agriculture, but may be close enough that they are able to remain functionally linked nonetheless. If patches are not functionally linked then the landscape will not be ‘permeable’ to species movement, a trait of the landscape that will be vital to ensure adaptation to climate change. Figure 8b shows the 100 largest functional habitat networks in England and highlights those that are of particular strategic importance.

22 Catchpole, R.D.J. (2008). England Habitat Network – Natural England Briefing Note [online] available at: http://www.rogercatchpole.net/ (accessed 02/09)

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Figure 8: Habitat connectivity in England

(A) Distribution of UK BAP priority habitat (B) The 100 largest habitat networks in England for grassland, heathland, woodland and mire, fen and bog. Grey areas indicate large urban settlements. Strategic habitat network linkages in England. Black ‘bed-springs’ represent the strongest networks.

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1.4.13 Figure 9 shows the results of another study which took account of the existing pattern of BAP and other important habitat to identify biodiversity opportunity areas (BOAs) within Kent. Targeted action within these areas, either in terms of buffering or linking habitat patches or increasing the ‘permeability’ of the surrounding landscape, has the potential to result in large scale functioning ecological networks, which will allow BAP species and habitats to thrive and be resilient to climate change.

1.4.14 Following on from a consideration of habitat connectivity and habitat creation to make the most of biodiversity opportunities, it is important to note that wetland recreation within former minerals extraction sites can lead to conflicts with aviation, due to the risk of bird strike.

Future baseline

1.4.15 Natural England, as part of the consideration of the ‘State of the Natural Environment’ in the South East state that their priority will be to meet the following challenges:

• Promote green infrastructure policies in all spatial plans and disseminate best practice, particularly in areas of growth • Develop a targeted, evidence based approach to delivery of Higher Level Stewardship • Deliver the 2008-09 target of 89% of SSSI’s being in favorable or recovering condition • Develop recommendations for Marine Protected Areas (MPAs) in the Eastern English Channel by 2011 as a contribution to the UK government’s aims to implement an ecologically coherent network of well managed MPAs around our coast by 2012 • Develop a Regional Habitat Creation Programme to meet the pressures along the coast • Ensure that planning and transport proposals contribute to the conservation and enhancement of the natural environment • Further develop programmes that link health and biodiversity • Build on the regional assessment of greenspace deficiency and work to increase opportunities to better engage people with their local greenspace

Current and future situation in sub-county areas

1.4.16 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These areas were identified primarily on economic grounds, but provide a useful spatial framework to consider other elements of the sustainability baseline. Table 3 considers current and possible future baseline conditions in each of these sub-areas.

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Figure 9: Biodiversity Opportunity Areas in Kent23

23 Kent Wildlife Trusts pers comms

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Table 3: The sub-county baseline

East Kent and Ashford24

Important considerations in East Kent include the East Kent Downs and Woodlands, including the particularly important downlands around Dover and Folkestone; the Blean Woodlands near to Canterbury; the Low Weald Woodlands; Romney Marsh (40% of the UK's coastal vegetated shingle resource - a UK BAP priority habitat - is found at Dungeness); and the Lower Stour Marshes. The RSS highlights that the lower catchment of the River Stour between Deal, Sandwich and south Ramsgate and parts of the former Wantsum Channel include protected wetland and other habitats that are fragmented. It is stated that there is potential in this area to: • create new natural habitats as alternatives to agriculture on marginal land • improve visitor facilities and access • create a tourist attraction

Kent Thames Gateway25

Important considerations in the Kent Thames Gateway include the North Kent Marshes; the ‘Kent Thameside Green Corridors; the Medway Gap and North Kent Downs; and the central North Downs. The Thames Gateway Parklands vision was launched in 2008 – see Box 1. The Greater Thames CHaMP identified that over the next 100 years there will be significant losses of intertidal habitat in the Greater Thames Catchment. In order to mitigate for some of this loss there are proposals set out in TE2100 Draft Plan and Thames Region Habitat Creation Program to create intertidal habitat on the Hoo Peninsula.26 The Thames Gateway also has an important resource of brownfield sites, which can be biodiversity rich. These are often seen as providing prime opportunities for development, consideration needs to be given to such factors as the impact on biodiversity. Brownfield sites can often have greater biodiversity than intensively managed farmland or other greenfield sites. For example, it has been found that some brownfield sites in Kent support nationally and internationally important invertebrate communities.

Rest of Kent27

The RSS states that a key spatial planning principle in this area is that biodiversity must be protected and enhanced and that the quality and character of the rural environment must be maintained and enhanced.

24 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 25 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2. 26 Environment Agency consultation response (2009) 27 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area.

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Box 1: The Thames Gateway Parklands Vision

The Parklands Vision is a holistic plan to regenerate and develop urban and rural open spaces which are connected together to create an accessible and coherent landscape throughout the entire Thames Gateway. The Parklands vision builds on the special qualities of the Estuary landscape as a starting point. These include the river and its landscapes, its history, culture and heritage, its location and its strategic assets. Opportunities to restore and enhance large scale landscapes have been identified in collaboration with partners and local organisations. A simple ‘Parklands model’ has been developed which shows how these landscapes could be connected to communities. By looking closely at the city, towns and villages, opportunities to link communities to the Estuary have been explored, and opportunities for landscape to permeate urban areas from the ‘outside’ have been identified. Opportunities for heritage-led regeneration have been identified as well as opportunities to create a new high quality public realm in urban areas. Ways in which landscapes can be connected have been investigated. This is based on the work that has been undertaken on the ‘green grids’ in South Essex, East London and North Kent. Environmental improvements to transport corridors have been made as well as proposals about the nature of the Thames Estuary Path. This will in turn connect to existing adjacent large scale landscapes – the Lea Valley Regional Park in East London, Thames Chase, the River Roach and River Crouch complex, the Kent Downs and the East London Green Grid. Within the Thames Gateway, Greening the Gateway Kent and Medway (GGKM) is a sub-regional partnership of 22 organisations with complementary interests in the economic, social and environmental regeneration of Dartford, Gravesham, Medway and Swale. GGKM has developed the North Kent Parklands Business Plan to identify nine strategic green infrastructure projects, costing £31m, across North Kent in support of the wider Thames Gateway Parklands programme.

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1.5 What are the key sustainability issues?

1.5.1 Table 4 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 4: Key sustainability issues

Key Issue Discussion

Ambitious BAP Although the Council may not be a lead partner in the delivery of most BAP targets have been targets, it is important to realise that minerals and waste planning can have a set, including the significant effect in terms of facilitating or hindering the achievement of BAP recreation of objectives and targets. In particular, it will be important that development does not habitats and lead to the further fragmentation of important habitats. It may also be possible to ensuring habitats increase the connectivity between important habitat patches by incorporating are less fragmented habitat creation as part of new development. It will be important that land that has / more connected. the potential to be used to increase ecological connectivity in the future is identified, and this opportunity value is not lost through inappropriate development.

Other landscape The Thames Gateway Parklands Vision is perhaps the flagship project scale projects are underway, but also, throughout the county other organisations will be underway with implementing programmes. Furthermore, there is a need to take close account biodiversity of Coastal Habitat Management Plans. conservation and access to biodiversity as central components.

1.6 What decision-making criteria should make up the SA framework?

1.6.1 The South East Regional Sustainability Framework includes the following objectives relating to biodiversity:

“To conserve and enhance the region’s biodiversity” “To protect and enhance the region’s countryside and historic environment”

1.6.2 It is helpful to take account of established regional sustainability objectives. However, bearing in mind the scope of influence of the Kent MWDF it is thought that there is a need to tailor these objectives, so that they are most suited to capturing the likely significant effects of the plan. Taking account of the key sustainability issues identified in Section 1.5 above, it is thought that the most appropriate sustainability objective for use in this SA is:

Ensure that development will not impact on important elements of the biodiversity resource and where possible contributes to the achievement of the Kent Biodiversity Action Plan and other strategies

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1.6.3 When appraising the effects of the plan in terms of this objective, the following sub-objectives should also be taken into account:

• Add to the biodiversity baseline by creating opportunities for targeted habitat creation (which, ideally, contributes to local or landscape scale habitat networks). • Avoid hindering plans for biodiversity conservation or enhancement • Support increased access to biodiversity

1.7 What further data is required?

• Achievement of BAP targets. • Better evidence on the extent, distribution and condition of some habitats, especially outside of designated sites. • Evidence on environmental capacity and cumulative impacts from multiple pressures. • More evidence on the impacts of pressures, including climate change, on the natural environment; identifying areas most vulnerable to climate change. • Better evidence on the distribution, use and valuation of ecosystem services, including the socio-economic benefits arising from people accessing the natural environment. • There is a need to understand the needs of species populations protected under the Habitats Directive beyond the maintenance of favourable conservation status of the Natura 2000 network. If this does not happen then there is a risk that development could be stopped late in the planning process due to licenses not being granted.

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Revision Schedule

Scoping Report – Climate Change and Flood Risk March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Consultant Associate Technical Director Ian Brenkley Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Table of Contents

1 Climate change and flood risk...... 2 1.1 Introduction...... 2 1.2 Background...... 2 1.3 What’s the sustainability context?...... 2 1.4 What’s the current and (likely) future sustainability baseline? ...... 5 1.5 What are the key sustainability issues?...... 13 1.6 What decision-making criteria should make up the SA framework?...... 13 1.7 What further data is required? ...... 14

List of Tables

Table 1: Kent potential renewable energy capacity...... 8 Table 2: The sub-county baseline ...... 11 Table 3: Key sustainability issues...... 13

List of Figures

Figure 1: Total carbon dioxide emissions (tonnes per capita) ...... 6 Figure 2: A comparison of emissions from different sources (tonnes per capita)...... 7 Figure 3: Indicative flood map of Kent ...... 8 Figure 4: Present day flood risk in the South East ...... 9

Scoping Report – Climate change and flood risk 1 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1 Climate change and flood risk

1.1 Introduction

1.1.1 This is Topic Paper 3 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of climate change and flood risk; describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to climate change and flood risk and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 This topic paper will consider the potential for strategic decisions relating to minerals and waste development to impact on objectives relating to both mitigation of and adaptation to climate change. Planning in such a way as to minimise unsustainable transport patterns is clearly one key mechanism through which the Kent MWDF can influence climate change mitigation objectives. These aspects are more fully considered in Transport Topic Paper. However, the Kent MWDF can also influence climate change mitigation objectives in other ways, including through reducing the amount of biodegradable waste sent to landfill and promoting the generation of renewable energy.

1.2.2 The Kent MWDF must also ensure that development occurs in such a way that resilience to the adverse effects of climate change is improved. Of primary importance for the Kent MWDF will be ensuring that the spatial approach to development minimises flood-risk. Government guidance on flood risk emphasises that, although flooding cannot be wholly prevented, its impacts can be avoided and reduced through good planning and management.1 It is the accepted view of Government that, as a consequence of climate change, flood risk is here to stay.2

1.3 What’s the sustainability context?

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering climate change and flood risk in this SA. This context review meets a requirement of the SEA Directive.3

1.3.2 The Kyoto Protocol (1997) sets legally binding measures to achieve the objectives of the United Nations Framework Convention on Climate Change (UNFCCC). Under the Kyoto Protocol the UK is committed to reducing greenhouse gas emissions by 12.5% below base year (1990) levels over the period 2008-12. The UK has committed itself to exceeding Kyoto

1 Communities and Local Government (2006). Planning Policy Statement 25: Development and Flood Risk [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/pps25floodrisk (accessed 02/09) 2 In August 2007, Sir Michael Pitt was asked by Ministers to conduct an independent review of the flooding emergency that took place in June and July 2007. His interim report Learning lessons from the 2007 floods is available at: http://archive.cabinetoffice.gov.uk/pittreview/thepittreview.html (accessed 02/09) 3 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes.

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targets, most recently through the Climate Change Act 2008, which commits to an 80% reduction in GHGs by 2050 against a 1990 baseline.

1.3.3 Government guidance emphasises that tackling climate change is a key priority for the planning system and sets out how planning should contribute to reducing emissions and stabilising climate change, while also taking into account the unavoidable consequences. In providing for development, planning authorities should “secure the highest viable resource and energy efficiency and reduction in emissions” and “deliver patterns of urban growth and sustainable rural developments that help secure the fullest possible use of sustainable transport for moving freight, public transport, cycling and walking; and, which overall, reduce the need to travel, especially by car”. In making decisions about their spatial strategies, planning authorities should ensure that the “spatial distribution, location and design [of new development is] planned to limit carbon dioxide emissions”.4 This approach is re-iterated in Minerals Policy Statement 1 which advocates minerals to be sourced locally in order to reduce carbon emissions of transportation over long distances by road. Where bulk transportation of minerals is concerned this should be by rail, sea and inland waterways wherever practicable.5

1.3.4 Furthermore, Climate Change and Sustainable Energy Act 2006 promotes a wide range of measures for addressing climate change, covering such relevant topics as microgeneration, energy efficiency and community energy schemes. It also sought to make amendments to the Renewables Obligation. The Renewable Obligation requires licensed electricity suppliers to source a specific and annually increasing percentage of the electricity they supply from renewable.6 The current level is 9.1% for 2008/09 rising to 15.4% by 2015.

1.3.5 In relation to flood risk, the Government’s flood strategy advocates integrating planning with groundwater, surface run-off and urban flooding considerations.7 Government guidance aims to direct development away from areas at highest risk (taking account of future climate change).8 Guidance seeks to reduce flood risk though:

• safeguarding land from development that is required for current and future flood management e.g. conveyance and storage of flood water, and flood defences; • reducing flood risk to and from new development through location, layout and design, incorporating sustainable drainage systems (SUDS); and • using opportunities offered by new development for flood storage and conveyance through surface water management and green infrastructure.

1.3.6 Catchment Flood Management Plans CFMPs are an important element of flood risk management. CFMPs aim to communicate the factors that contribute to flood risk within a catchment both now and in the future so that recommendations can be made for managing flood risk over the next 50 to 100 years.

1.3.7 On the 21 April the Government published the draft Flood and Water Management Bill for consultation.9 The need for the Bill has arisen partly from the need to transpose the EU Floods

4 CLG (2007). Supplement to Planning Policy Statement 1: Planning and Climate Change [online] available at http://www.communities.gov.uk/publications/planningandbuilding/ppsclimatechange (accessed 02/09). 5 Minerals Policy Statement 1: Planning and Minerals, Communities and Local Government (2006) 6 Great Britain (2006). The Renewables Obligation Order 2006 [online] available at: http://www.opsi.gov.uk/si/si2006/uksi_20061004_en.pdf (accessed 02/09). 7 DEFRA, DfT, ODPM and HM Treasury (2005). Making Space for Water: Taking forward a new Government strategy for flood & coastal erosion risk management [online] available at: http://www.defra.gov.uk/Environ/Fcd/policy/strategy.htm (accessed 02/09) 8 DCLG (2006). Planning Policy Statement 25: development and flood risk [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/pps25floodrisk (accessed 02/09) 9 Defra (2009) draft Flood and Water Management Bill [online] available at: http://www.defra.gov.uk/environment/water/flooding/flow/index.htm (accessed 0

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Directive. One major implication of the Bill is a new requirement on developers to put SuDS in place wherever practicable and meet national standards relating to drainage.

1.3.8 Shoreline Management Plans (SMPs) aim to identify the best approaches to managing risks from flooding and coastal erosion along a particular stretch of coastline over the next 100 years. A key recommendation that the strategies make is which areas should be defended and which should not. SMPs should ensure:

• future development does not take place in unsuitable areas at risk from flooding, coastal erosion and cliff instability; • development is restricted in possible areas of managed realignment; and • development does not affect the natural balance of the coastline to the extent that erosion is caused elsewhere or that further or improved coastal defences have to be built or maintained.

1.3.9 Integrated Coastal Zone Management (ICZM) involves taking an integrated or joined up approach towards the many different interests in both the land and marine components of the coast. The principles of ICZM are embedded throughout relevant proposals in the Marine and Coastal Access Bill introduced to the House of Lords on 4 December 2008.

1.3.10 Government guidance on minerals planning emphasises the importance of ensuring that mineral extraction proposals do not have a significant adverse impact on flood flows or flood storage capacity, do not increase the risk of flooding at other properties or locations and, where practicable, should increase flood storage capacity.10

1.3.11 The Regional Spatial Strategy (RSS)11 identifies both reducing greenhouse gas emissions / improving security and diversity of supply and tackling increased risk of flooding (due to development in flood plains, changing patterns of rainfall, extreme weather, storms, rising sea levels and agricultural run off) as key environmental challenges facing the region. Policy CC2 states the aim of reducing the region’s carbon dioxide emissions by at least 20% below 1990 levels by 2010 and by at least 25% below 1990 levels by 2015, primarily through:

• improving the energy efficiency and carbon performance of new and existing buildings; • reducing the need to travel and ensuring accessibility to sustainable modes of transport; • promoting land use that acts as carbon sinks; • encouraging development and use of renewable energy; and • reducing the amount of biodegradable waste landfilled.

1.3.12 Policy NRM11 seeks to promote and secure greater use of decentralised and renewable or low-carbon energy in new development, including, in particular, passive solar design, solar water heating, photovoltaics, ground source heat pumps and in larger scale development, wind and biomass generated energy. Policy NRM12 promotes the development of combined heat and power schemes.

1.3.13 Policy NRM4 promotes the use of Strategic Flood Risk Assessment, which take account of flood risk, as well as the vulnerability of different types of development. Planning authorities

10 CLG (2006). Minerals Planning Statement 1: Planning and Minerals [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/mineralspolicystatement5 (accessed 02/09) 11 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09)

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should also take account of River Basin Management Plans, Catchment Flood Management Plans, Shoreline Management Plans and Surface Water Management Plans in developing their strategies. Where locationally specific flood risk and land management options such as flood storage, managed realignment and set back from coastal defences are identified, land should be safeguarded for these purposes and appropriate land management practices should be encouraged.

1.3.14 In the Kent Thames Gateway sub-county area Policy KTG1 states that there should be high standards for the design and sustainability of new communities, and for improvement of the existing urban areas, reflecting the riverside and historic character of the area. This may lead to increased potential for waste management options that also lead to the generation of heat and/or power. Policy KTG6 also identifies that many of the major development sites in the sub- region are in whole or in part within the coastal and fluvial flood zone. The supporting text identifies that the Environment Agency is developing a long term plan for flood risk management throughout the Thames Estuary. This plan ‘Thames Estuary 2100’ will take six years to complete, and renewal and possible enhancement of flood defences in the sub-region will be implemented between 2015 and 2035. The ‘Green Grid’ and green space outside the urban areas may also provide opportunities for flood storage as part of the Thames Estuary 2100 solutions.

1.3.15 Finally, many local authorities have completed Strategic Flood Risk Assessments (SFRA), and a regional SFRA has also been completed – see Box 1.

1.4 What’s the current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to climate change and flood risk in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent to other geographical areas, as well as considering how the baseline varies at the sub-county scale, within three sub-regional areas defined in Kent by the RSS. This section meets a key requirement of the SEA Directive.12

1.4.2 Kent’s emissions of greenhouse gasses (GHGs) are above the South East regional average on per capita basis, but in line with the national average. The main sources of emissions are:13

• 42% industrial and commercial; • 29.5% domestic; • 26.5% road transport; and • 2% land use change.

1.4.3 Figure 1 shows how carbon dioxide emissions in Kent compare to the regional and national picture. From Figure 1 it is also possible to see how emissions vary between the Kent local authorities. There is something of a mixed picture in Kent, with the three eastern-most districts

12 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected” 13, KCC (2006) Select Committee on Climate Change Report [online] available at: http://www.kent.gov.uk/publications/council-and- democracy/sel-com-climate-change-oct06.htm (accessed 03/09)

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performing the best, and the districts within the Kent Thames Gateway (with the exception of Medway UA) performing the worst.

Figure 1: Total carbon dioxide emissions (tonnes per capita)14

1.4.4 Figure 2 shows the national picture of emissions broken down according to source, i.e. domestic; transport; industrial and commercial; or land use, land use change and forestry

(LULUCF). From Figure 2 it is particularly notable that Kent performs very well in terms of CO2 emissions from domestic sources. In terms of emissions from industrial and commercial sources, it is evident that Gravesham, Tonbridge and Malling and Swale perform poorly compared to other authorities in the county and the wider South East.

14 Defra (2008) E-Digest Climate Change Statistics [online] available at: http://www.defra.gov.uk/environment/statistics/globatmos/galocalghg.htm (accessed 03/09)

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Figure 2: A comparison of emissions from different sources (tonnes per capita)15

15 Ibid.

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1.4.5 Kent must act to mitigate climate change. Particular areas for action, which require consideration at strategic levels of spatial planning, include energy and transport. Table 1 shows the Kent potential renewable energy capacity by 2010 and by 2016.

Table 1: Kent potential renewable energy capacity16

Biomass Biomass Onshore Small scale Landfill anaerobic Solar Total wind hydro gas thermal digestion Installed capacity 7 2.5 75 3.2 0.3 23 111 (MW) by 2010 Installed capacity 17 7.5 100 5.6 0.3 23 154 (MW) by 2016

1.4.6 Waste accounts 0.3% of KCC emissions, however waste can also be used for energy production. Energy can be produced from biomass waste, such as agricultural, forestry or wood waste or residue as well as biodegradable municipal, commercial and industrial waste. The waste to energy facilities that could come forward in Kent by 2016 include anaerobic digestion plans fuelled by sewage, farm slurry or putrescible waste and combined heat and power (CHP) plants fuelled by landfill gas, municipal or industrial solid waste.17

1.4.7 Due to its geographic location and the long coastline, Kent is expected to be affected from climate change more than other parts of the South East. A key issue that must be taken account of within this SA is the increased flood risk associated with climate change. Presently, there are areas in Kent that are at risk from both coastal and fluvial flooding – see Figure 3.

Figure 3: Indicative flood map of Kent18

16 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09) 17 Ibid. 18 KCC (2006) Select Committee on Climate Change Report [online] available at: http://www.kent.gov.uk/publications/council-and- democracy/sel-com-climate-change-oct06.htm (accessed 03/09)

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1.4.8 Figure 4 shows how flood risk in Kent compares to that experienced elsewhere in the region.

Figure 4: Present day flood risk in the South East19

1.4.9 Box 1 includes information taken from the Strategic Flood Risk Assessment for the South East.20

19 Halcrow (2008) Regional Flood Risk Appraisal for South East England [online] available at: http://www.southeast- ra.gov.uk/documents/sustainability/rfra_nov08.pdf (accessed 03/09) 20 Ibid.

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Box 1: Information from the Regional SFRA

Kent encompasses most of the catchments of the River Darent, the River Medway and the Great Stour. Several of the main towns suffer from fluvial flooding, including Ashford. A number of Kent’s main towns including Sevington, South Willesborough, Tonbridge, Aylesford, Maidstone, Canterbury, Sandwich, Dover and Whitstable experience fluvial flooding which is often extensive and causes considerable damage. The Royal Military Canal caused flooding in Folkestone and Hythe in 2000/2001. In many cases this has led to flood alleviation schemes which have helped improve the situation although flooding has not always been eliminated. Regulation of flow in the River Medway by sluice gates and a flood storage area at Leigh helped reduce, although did not eliminate, flooding in Tonbridge during 2000. The Aldington reservoir, one of the reservoirs built to protect Ashford, has overtopped its banks causing flooding in Mersham and Ashford. Defences along the River Darent include gates on residential properties. Fluvial flooding in the Maidstone gap is expected to increase with sea level rise. The Romney, Walland and Stour marshes are prone to both fluvial flooding from the numerous drains and small streams and, tidal flooding due to being low-lying land. In the Kent Thameside area, historic flooding indicates that large areas of the River Darent floodplain, the Dartford Marshes, the Swanscombe Peninsula and the Shorne Marshes to the west of Gravesend are subject to tidal flooding, of which the 1953 tidal surge was particularly severe. The towns of Dover, Canterbury, Sandwich and Whitstable suffer from tidal flooding. Groundwater flooding occurs to the south-east of Canterbury in the area of the Nailbourne and Petham Bourne – the streams have been diverted but high groundwater causes water to appear above the surface along the original watercourses. The streams themselves can cause flooding during times of groundwater- augmented flow. Groundwater flooding is prevalent within the Borough of Maidstone area, particularly east of Maidstone, including from springs in the chalk. However, surface water flooding is also common, particularly in the south where the underlying geology is clay, but there are incidents across the whole borough, mainly as a result of blockage of gullies and ditches. Dover and Folkstone are very prone to thunderstorms with pluvial flash flooding. In Yalding flooding in 2000 was caused principally by rainfall falling onto already saturated catchments. Hamstreet is susceptible to flooding from Speringbrook Sewer and an improvement scheme is planned to increase protection.

1.4.10 Over 50,000 properties are currently at risk of flooding. In addition, a proportion of the population are likely to be particularly vulnerable, for example, as a result of being less able to quickly evacuate in the event of a flood.21 It is expected that patterns of flood-risk will change substantially as a result of climate change, with the overall effect of the area at risk expanding, particularly at the coast due to sea level rise (and possibly more extreme weather events).

Future baseline

1.4.11 Although there is uncertainty in climate change predictions the following changes are likely to have taken place in the South East by 2080:22

• An increase in annual average daily temperature of 2-6 degrees; • A 30-60% decrease in summer precipitation; • A 15-30% increase in winter precipitation.

1.4.12 This means that the South East is likely to experience, in the future, a warmer climate, with drier summers and wetter winters, which means that extreme events such as floods and droughts are likely to become less predictable and possibly more frequent. In addition, there is concern about sea-level changes leading to inundation of low-lying coastal areas.

21 Ibid. 22 UKCIP (2003) Regional Scenarios for the South East [online] available at: http://www.ukcip.org.uk/index.php?option=com_content&task=view&id=76&Itemid=189 (accessed 03/09)

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Current and future situation in sub-county areas

1.4.13 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These areas were identified primarily on economic grounds, but provide a useful spatial framework to consider other elements of the sustainability baseline. Table 2 considers current and possible future baseline conditions in each of these sub-areas. Table 2 focuses on flood risk only. In terms of climate change mitigation, this is an agreed priority everywhere, and there are very few spatial implications. As a result, there is no further discussion of spatial variation in the baseline.

Table 2: The sub-county baseline

East Kent and Ashford23

The following information is taken from the Regional SFRA which identifies Ashford as an area requiring detailed analysis, as a result of high flood risk and high levels of proposed development.24 Ashford lies at the confluence of five designated Main Rivers, the principal ones being the Great Stour and East Stour. The physical geography of the catchment is dominated by the chalk of the North Downs, which forms both the main topographical feature and results in the baseflow dominated nature of many of the river channels. Flow in the Great Stour and East Stour is influenced by the operation of the Hothfield and Aldington Flood Storage Reservoirs during flood events. Historically, Ashford has been particularly vulnerable to fluvial flooding since runoff from the higher ground converges into the town via the East Stour, the Great Stour, Ruckinge Dyke, Whitewater Dyke and Aylesford Stream; all designated ‘main’ rivers. Ashford has suffered several fluvial flood events over the last 50 years, both within the town and, particularly, to the south of the town. Schemes to alleviate the flooding included improvements to the Aylesford Stream and construction of two reservoirs upstream of Ashford in Aldington and Hothfield. Since their construction Aldington reservoir has overtopped its banks causing flooding to dwellings in Mersham and Ashford. There has been some historical groundwater and surface water flooding, associated with the fluvial flood events. Ashford was designated as a Growth Point by the Sustainable Communities Plan, which indicated that 31,000 new homes should be built by 2031, and 28,000 new jobs created. The proposed locations include Town Centre Riverside, International Station and ‘Canal District’ in Willesborough Dykes. Ashford has a high proportion of its area within the flood zones although the flood defences have helped reduce the risk. However there is also a residual risk associated with the reservoirs, for which failure has already occurred, and the town has a history of surface and groundwater flooding. The Sequential Test should be followed before locating development in the area protected by the defences, due to the residual risk of failure and the aim to avoid committing future generations to the maintenance of defences. According to the Ashford SFRA, Ashford Borough Council’s current policy is to have no development in the floodplain or defended 100 year outline, although the undefended outline may be developable providing mitigating measures are applied, such as good emergency access routes and appropriate ground floor uses (e.g. car parking rather than residential), and the creation of local like-for-like floodplain compensation to balance space lost due to development in the floodplain.

23 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 24 Halcrow (2008) Regional Flood Risk Appraisal for South East England [online] available at: http://www.southeast- ra.gov.uk/documents/sustainability/rfra_nov08.pdf (accessed 03/09)

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Kent Thames Gateway25

The following information is taken from the Regional SFRA, which identifies the Kent Thames Gateway as an area requiring detailed analysis, as a result of high flood risk and high levels of proposed development.26 The Thames Gateway area, particularly the low lying areas behind the defences, is at risk from tidal flooding, which may cause rapid inundation of land. Within Thames Gateway, the Medway and onwards around the coast are at greatest risk as the defences provide a lower standard of protection. The South East Plan Proposed Changes has allocated 52,140 new homes by 2026 within Kent Thames Gateway. Development is focussed on regenerating brownfield areas which are commonly exindustrial and thus tend to be located near a waterway; of the 25 major sites proposed in the development plans within Kent Thameside, 16 lie within the flood risk zone. Due to the protection afforded by the tidal defences, it is likely that there will be significant growth due to development pressures. The outcomes of the Kent Thameside SFRA highlight the significant challenges for spatial planning in these areas. The land alongside the Thames Estuary is afforded a standard of protection (SoP) of 1 in 1000 at least till 2030, and the existing and proposed developments benefit from the presence of these defences. However, comparing defence levels with sea level rise based on current PPS25 climate change predictions, it is estimated that without any further improvements the standard of protection will fall to between 1:100 and 1:200 by 2115. The land alongside Medway is afforded a SoP of 1:200 based on current flood risk estimates. Based on current climate change estimates, this level is expected to fall to 1:50 by 2030 and further deteriorate over the next 100 years. In view of the consequences resulting from a breach or overtopping of tidal and coastal defences it is important that a high standard of protection is not viewed as an enabler for development and any proposals adhere to the requirements of PPS25. It is acknowledged that in order to adequately manage the risk of flooding to existing developments, the defences will need to be maintained, refurbished, and upgraded or set-back and replaced in a sustainable manner where required with land released or safeguarded to make space for flood waters. Within the Thames Gateway, areas should also be safeguarded to make space for water storage as identified in Thames Estuary 2100 (TE2100). Medway Estuary and Swale SMP and the Isle of Grain to South Foreland SMP cover this area. Their main recommendations are managed re-alignment and maintenance of defences respectively. The North Kent Rivers CFMP Marshes unit identifies that without the existing flood defences this area would be at great risk from the Estuary.

Rest of Kent27 Details of strategic flood risk issues in the Rest of Kent are described in the baseline section above. A finer level of detail would require drawing on district level Strategic Flood Risk Assessments.

25 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2. 26 Halcrow (2008) Regional Flood Risk Appraisal for South East England [online] available at: http://www.southeast- ra.gov.uk/documents/sustainability/rfra_nov08.pdf (accessed 03/09) 27 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area.

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1.5 What are the key sustainability issues?

1.5.1 Table 3 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 3: Key sustainability issues

Key Issue Discussion

Kent is not performing well Climate change mitigation is an accepted national and international in terms of CO2 emissions priority, and this simply reinforces the importance of action being taken from industry and through the Kent MWDF. There is the potential to promote energy from commerce, and transport. waste options, and also other technologies that increase the energy efficiency of minerals and waste operations (for example, wastewater treatment is an energy intensive process).

There is extensive flood Patterns of both coastal and fluvial flood risk are likely to change as a risk in Kent, and this result of sea level rise, changing rainfall patterns and also development situation is set to become and changing land use. worse with climate change.

1.6 What decision-making criteria should make up the SA framework?

1.6.1 The Southeast Regional Sustainability Framework includes the objective:

“To address the causes of climate change through reducing emissions of greenhouse gases” “To ensure that the South East is prepared for the impacts of climate change” “To reduce the risk of flooding and the resulting detriment to public wellbeing, the economy and the environment” “To increase energy efficiency, security and diversity of supply and the proportion of energy generated from renewable sources in the region”

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To address the causes of climate change through reducing emissions of greenhouse gases through energy efficiency and energy generated from renewable sources To reduce the risk of flooding and the resulting detriment to public wellbeing, the economy and the environment

1.6.3 When appraising the effects of the plan in terms of these objectives, the following sub- objectives should also be taken into account:

• Recover energy from waste where possible • Promote sustainable design and construction of facilities and support wider efforts to reduce the carbon footprint of minerals and waste operations • Ensure that development does not lead to increased flood risk on or off site • Seek to mitigate or reduce flood risk through developments that are able to slow water flow and promote groundwater recharge

1.7 What further data is required?

• Strategic priorities for climate change adaptation

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Revision Schedule

Scoping Report – Community and Well-being March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Consultant Associate Technical Director Ian Brenkley Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Table of Contents

1 Community and Well-Being ...... 2 1.1 Introduction...... 2 1.2 Background...... 2 1.3 What’s the sustainability context?...... 2 1.4 What’s the current and (likely) future sustainability baseline? ...... 4 1.5 What are the key sustainability issues?...... 13 1.6 What decision-making criteria should make up the SA framework?...... 14 1.7 What further data is required? ...... 15

List of Tables

Table 1: Overall deprivation scores and ranks for Kent local authorities (IMD 2007)...... 7 Table 2: The sub-county baseline ...... 13 Table 3: Key sustainability issues...... 13

List of Figures

Figure 1: Distribution of population aged 75+ in Kent...... 5 Figure 2: IMD scores of county and unitary authorities ...... 6 Figure 3: Overall deprivation within Kent (IMD 2007)...... 7 Figure 4: Health deprivation within Kent...... 8 Figure 5: Rural and urban areas in the South East ...... 10 Figure 6: Life expectancy in Kent ...... 11 Figure 7: Percentage of people disabled / permanently sick in Kent (2001) ...... 11

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1 Community and Well-Being

1.1 Introduction

1.1.1 This is Topic Paper 4 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of community and well-being; describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to community and well-being in Kent and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 Government is clear that a key element of sustainable development involves seeking to ensure a better quality of life for everyone. Spatial planning has a key role to play in achieving this through facilitating the development of sustainable communities, which can be defined as places that will stand the test of time, where people want to live, and enable people to meet their aspirations and potential.

1.2.2 The community and well-being baseline (or, it might be said, the sustainability of communities) varies substantially at a range of scales, as demonstrated by a host of indicators including the Index of Multiple Deprivation (IMD). The Kent MWDF, through its spatial policies, has the potential to influence the current situation. SA seeks to appraise a plan from a social justice perspective and so is inherently interested in promoting equality and seeking to reduce existing imbalances in terms of such things as social inclusion and health.

1.2.3 Furthermore, it is increasingly acknowledged that, because we live in such a diverse society it is important to give consideration to the potential for certain socio-economic groups to suffer from inequality. It is the aim of this topic paper to ensure that the SA of the Kent MWDF does not only take account of spatial patterns of deprivation and social inclusion, but also considers effects in terms of a comprehensive range of socio-economic groups. Similarly, it is increasingly realised that health is a complex and important topic that requires a degree of specialist attention. As a result this topic paper will also seek to ensure that all potentially significant health effects (ways in which minerals and waste planning could potentially influence patterns and trends in the population) are considered through this SA.

1.3 What’s the sustainability context?

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering community and well-being in this SA. This context review meets a requirement of the SEA Directive.1

1.3.2 Government defines sustainable communities as:2

1 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes.

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“…places where people want to live and work, now and in the future. They meet the diverse needs of existing and future residents, are sensitive to their environment, and contribute to a high quality of life. They are safe and inclusive, well planned, built and run, and offer equality of opportunity and good services for all.”

1.3.3 As such, sustainable communities embody the principles of sustainable development by:

“balancing and integrating the social, economic and environmental components of the community, meeting the needs of existing and future generations and respecting the needs of other communities in the wider region or internationally to make their own communities sustainable.”

1.3.4 Social inclusion is actively pursued through spatial planning in recognition of the fact that many interlinked factors are important in ensuring that individuals and communities are able to fully participate in society. Economic factors such as income, poverty and unemployment can be compounded by factors such as poor housing, high crime, discrimination, bad health and family breakdown. A combination of problems can create a vicious cycle and lead to social exclusion. To summarise;

“Social exclusion can happen as a result of problems that face one person in their life. But it can also start from birth. Being born into poverty or to parents with low skills still has a major influence on future life chances.”3

1.3.5 In particular, Government guidance promotes the development of cohesive and socially inclusive communities through ensuring accessibility to jobs and services and mixes of housing tenures, with good provision of affordable housing in particular. An overriding aim is that everyone has the opportunity for a decent home in locations that reduce the need for travel.4

1.3.6 The Health Act 1999 places a duty of partnership between the health agencies and local authorities to “secure and advance the health and welfare of the people” .5 Government aims to simultaneously improve the health of everyone, whilst also focusing efforts on improving the health of the worst off in particular. The actions which are required can be divided into three inter-related levels by individuals, communities, and the Government in partnership. It has four priority areas: cancer, heart disease and strokes, accidents and mental health.6

1.3.7 The public health White Paper, ‘Choosing Health’ (2004), signalled a change in direction by the NHS, away from a focus on treating illness and towards linking health to wider social and economic factors. These wider aspects explain many of the profound differences in health between affluent and deprived communities.

1.3.8 Government guidance on minerals planning states the importance of accounting for the value of the wider countryside and landscape, including opportunities for recreation, including quiet recreation, and as far as practicable maintaining access to land. The RSS also recognises that workings and the transport of minerals have health and other social impacts, such as noise and dust. Furthermore, it recognises that minerals workings can have more general community impacts, and so promotes effective communication with local communities throughout the

2 ODPM (2003). Sustainable Communities: Building for the future [online] available at: http://www.communities.gov.uk/publications/communities/sustainablecommunitiesbuilding (accessed 02/09). 3 Social Exclusion Unit (no date). London, Department of Communities and Local Government. 4 DCLG (2005). Planning Policy Statement 1: Delivering Sustainable Development [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/planningpolicystatement1 (accessed 02/09). 5 Great Britain (1999). Health Act 1999 [online] available at: http://www.opsi.gov.uk/acts/acts1999/ukpga_19990008_en_1 (accessed 02/09). 6 Ibid.

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planning, operation and restoration of mineral sites, including setting out clear timescales for the operation and restoration phases and adhering to these as far as possible.

1.3.9 The Waste Framework Directive (91/156/EEC) (WFD) requires Member States of the EU to establish a network of disposal facilities, with Article 4 of the Directive seeking to ensure that waste is recovered or disposed of without endangering human health and without using processes or methods which could harm the environment, and in particular:

• without risk to water, air, soil and plants and animals; • without causing a nuisance through noise or odours; and • without adversely affecting the countryside or places of special interest.

1.3.10 Policy S1 of the Regional Spatial Strategy (RSS)7 seeks to promote healthy communities, identifying how the planning system can lead to preventative measures to address the causes of ill health, including:

• community access to amenities such as parks and open spaces; • mixed and cohesive communities, with a particular focus on access to housing; and • healthier forms of transport, incorporating cycle lanes and safe footpaths.

1.3.11 Policy SP4 of the RSS8 promotes regeneration and efforts to improve social inclusion and reduce inequalities (including health inequalities) focused on East Kent and the Kent Thames Gateway.

1.4 What’s the current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to community and well-being in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent to other geographical areas, as well as considering how the baseline varies at the sub-county scale, within three sub-regional areas defined in Kent by the South East Plan. This section meets a key requirement of the SEA Directive.9

7 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09) 8 Ibid. 9 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected”

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Current baseline

Population

1.4.2 The following are notable population trends:10

• Kent has the largest population in the South East region with 1,394,700 people in 2007. • The population rose by 11,800, an increase of 0.85 percent between 2006 and 2007. • Over a ten year period (1997-2007) population has risen by 91,60011 (+7%). • The number of households increased from 532,000 in 1997 to 585,400 in 200712. • Between 2006 and 2007, Tonbridge & Malling had the largest absolute population increase (in percentage terms – Canterbury saw the largest increase), while none of the twelve local authorities experienced a population decline.

1.4.3 Kent has a smaller proportion of middle aged people compared to England, particularly in the age group 20-39 years. On the other hand Kent has an older age profile than the national average with greater proportions of people aged 50+ years than the England average. Wards with predominately young populations are found mainly in Ashford and Dartford districts, while wards with predominately older populations are mainly found in Thanet, Shepway, Canterbury and Dover (coastal towns). These distributions create issues relating to access to key services, vulnerability, personal safety and affordability that will exacerbate social exclusion if not planned for adequately. Figure 1 shows the distribution of older people in the county.13

Figure 1: Distribution of population aged 75+ in Kent14

10 Kent County Council: 2007 Mid Year Population Estimates [online] available at: http://www.kent.gov.uk/publications/community- and-living/2007-my-population-est.htm (accessed February 2009) 11 KCC (2009). Personal communication. 12 KCC (2009). Personal communication. 13 KCC (2006). Local Transport Plan for Kent 2006 – 2001 [online] available at: http://www.kent.gov.uk/publications/transport-and- streets/ltp-provisional-plan.htm (accessed 02/09) 14 KCC (2009) Per Comms

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Deprivation and social inclusion

1.4.4 The Indices of Multiple Deprivation (IMD) 2007 measure deprivation within localities under the following sub-domains: Figure 2: IMD scores of county and 1. Health deprivation and disability unitary authorities 2. Barriers to Housing Services 3. Income deprivation 4. Employment deprivation 5. Education, Skills and Training deprivation 6. Crime 7. Living Environment deprivation

1.4.5 In addition, an overall deprivation score is calculated by combining the seven deprivation scores and assigning each sub-domain a different weighting.15 In terms of ‘overall’ deprivation, Kent ranks 104th out of 149 county and unitary authorities nationally – see Figure 2. In 2004 Kent was ranked 106th. The fall of two places suggests that deprivation levels in Kent have slightly increased relative to other counties and unitary authorities in England. Of the county councils (excluding unitary authorities) in the South East region, Kent is the 2nd most deprived. East Sussex is the most deprived.

1.4.6 Thanet district is the most deprived local authority district area within Kent. Thanet is ranked 65th out of 354 local authorities in England (1 being worst). This places Thanet 20 positions higher than in the 2004 Index, meaning deprivation levels have increased relative to other authorities in England. Ten of the 12 local authorities in Kent have moved up the deprivation ranking since 2004. Only Dartford and Canterbury have moved down. Sevenoaks is now Kent’s least deprived district and is ranked 295th out of 354 authorities in England. In 2004, Tonbridge & Malling was the least deprived, although Sevenoaks was a very close second. The deprivation rank of Kent districts shown in Table 1 illustrates the extreme social and economic differences across the county.

15 The weight of each of the domains is as follows: Income 22.5%; Employment 22.5%; Health 13.5%; Education 13.5%; Housing 9.3%; Crime 9.3%; and Living Environment 9.3%

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Table 1: Overall deprivation scores and ranks for Kent local authorities (IMD 2007)16

Kent Rank National rank LA Name Score (out of 12) (out of 354) Thanet 27.61 1 65 Swale 22.10 2 116 Shepway 21.35 3 123 Gravesham 20.37 4 142 Dover 19.12 5 153 Dartford 16.65 6 186 Canterbury 16.17 7 198 Ashford 14.37 8 227 Maidstone 12.99 9 248 Tunbridge Wells 11.45 10 273 Tonbridge and Malling 10.95 11 281 Sevenoaks 10.34 12 295

1.4.7 Figures 3a and 3b considers how overall deprivation varies spatially at a finer scale – that of the ‘Lower Super Output Areas’ (LSOAs). LSOAs are the smallest geographical unit for which population data is routinely collected and analysed. The colour contained of each area relates to the rank of the LSOA compared to the either the county (3a) or national (3b) picture. Both figures show a similar trend, although Figure 3b gives a clearer picture of where the pockets of most extreme deprivation are located.

Figure 3: Overall deprivation within Kent (IMD 2007)17

16 KCC (2008) The Pattern of Deprivation in Kent based on The Indices of Deprivation 2007 [online] available at: http://www.kent.gov.uk/NR/rdonlyres/2681A1ED-94A1-4345-8578- 49F7D6CBD4E2/13176/deprivationinkentreport2007.pdf?bcsi_scan_F6892CABA15785B4=0&bcsi_scan_filename=deprivationinkentr eport2007.pdf (accessed 02/09) 17 Ibid.

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1.4.8 In terms of more specific, sub-domains of deprivation highlighted by the IMD:

• Kent areas suffer less from health deprivation and disability than from any other type of deprivation. There are more Kent LSOAs in England’s least 20% deprived on this domain than there are on any other sub-domain. The pattern of health deprivation across Kent is very distinct. East Kent suffers from much higher levels of health deprivation and disability than West Kent. This deprivation is not constrained to the urban areas, although Kent areas which are also in England’s top 20% deprived (Figure 4b) are all found in urban locations. The great majority of LSOAs in West Kent are amongst the 20% least deprived in England.18 Figure 4: Health deprivation within Kent19

• Kent areas suffer the most from barriers to housing and services deprivation. 21.6% of Kent LSOAs are within England’s top 20% deprived, which is the highest of all domains.20 Deprivation related to barriers to housing and services is concentrated in rural areas. • The pattern of income deprivation across Kent is very similar to the pattern of the overall IMD data, with the areas of Kent suffering the most from income deprivation being coastal towns and other urban locations further inland. Those areas suffering the least from income deprivation are found in the west of the county and in rural locations. 11% of Kent’s LSOAs are within England’s top 20% deprived for this domain. Likewise, a large number of areas that are in Kent’s bottom 20% deprived are also within England’s least 20% deprived illustrating the large contrast that exists within Kent. 21 • In terms of education, skills and training deprivation, many of the areas which are in Kent’s top 20% deprived are also within England’s top 20% deprived, showing the

18 The ‘health deprivation and disability domain’ identifies areas with relatively high rates of people who die prematurely or whose quality of life is impaired by poor health or who are disabled, across the whole population. 19 KCC (2008) The Pattern of Deprivation in Kent based on The Indices of Deprivation 2007 [online] available at: http://www.kent.gov.uk/NR/rdonlyres/2681A1ED-94A1-4345-8578- 49F7D6CBD4E2/13176/deprivationinkentreport2007.pdf?bcsi_scan_F6892CABA15785B4=0&bcsi_scan_filename=deprivationinkentr eport2007.pdf (accessed 02/09) 20 Barriers to housing refers to a number of factors, including the percentage of population which have made applications for homeless assistance, levels of access to suitable/affordable housing and ease of access to local services.. 21 The Income Deprivation domain captures the proportion of the population experiencing income deprivation in an area.

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polarisation that exists. 17.3% of Kent LSOAs are within England’s top 20% deprived for this domain.22 • The areas of Kent suffering the most from crime deprivation are the towns. Towns across the whole of the county are affected, but parts of Gravesham and Thanet particularly so. 8.7% of all Kent LSOAs are also within England’s top 20% deprived.23 • There is also no particular pattern to the living environment deprivation – the most deprived areas on this domain are found in both urban and rural locations. However, the Kent areas within England’s top 20% deprived are concentrated within the Thanet Towns of Margate and Ramsgate, the Swale towns of Sittingbourne and Faversham and parts of the Isle of Sheppey, and other town locations across the county.24

1.4.9 As well as considering the spatial variation of deprivation and social exclusion, it is also important to consider whether certain demographics are particularly likely to suffer. This can be an important consideration for spatial planning, as demographic groups may be associated with living in certain areas, and undertaking certain types of work. The following are ‘vulnerable groups’ that require explicit consideration:25

• Gypsy and Traveller communities have significantly poorer health and more self-reported symptoms of ill-health than other UK-resident, BME groups and economically disadvantaged white UK residents. Maternal health and infant health are particularly problematic. • Refugees and asylum seekers are often living in poor accommodation, have limited access to services and face prejudice and hostility. • Migrant workers often live in poor accommodation, work very long hours, face isolation and exclusion and have many problems accessing services. Urban / rural26

1.4.10 85% of the county is defined as rural, equivalent to 19% of the rural South East and 3% of rural England. Kent has the largest rural population of any county in the South East, with 29% of the population (392,067) living in rural areas. This figure is considerably higher than the figures for the South East (22%) and for England (19%).

1.4.11 Approximately 178,000 (13%) of Kent’s population currently lives in rural towns and fringe locations, 140,000 (11%) lives in villages and 73,000 (5%) lives in hamlets and isolated dwellings. The pattern of rural settlements in Kent is denser than other parts of the rural South East with more people living in hamlets, villages and particularly more in small town and fringe areas.

22 The Education, Skills and Training Deprivation Domain captures the extent of deprivation in these categories in a local area. The indicators fall into two sub domains: one relating to education deprivation for children/young people and one relating to lack of skills and qualifications among the working age adult population. 23 This Crime Domain measures the incidence of recorded crime for four major crime themes (burglary, theft, criminal damage and violence). 24 The Living Environment Deprivation Domain focuses on deprivation with respect to characteristics of the living environment. It comprises two sub-domains: the 'indoors' living environment which measures the quality of housing and the 'outdoors' living environment which contains two measures about air quality and road traffic accidents. 25 EEDA (2007). SEA, SA, EqIA, Rural and Urban Proofing for the East of England Regional Economic Strategy – scoping report: the regional community. 26The Kent Rural Delivery Framework- Kent Rural Evidence Base [online] available at: http://www.kentruralnetwork.org.uk/kent-rural- framework/kent-rural-evidence- base/Rural%20community.pdf?bcsi_scan_F6892CABA15785B4=0&bcsi_scan_filename=Rural%20community.pdf (accessed February 2009)

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1.4.12 Figures 5a and 5b show the distribution of urban areas in Kent and the regional classification of urban/rural areas. Proximity to higher order settlements, and associated services and facilities is one major cause of rural deprivation, but it is not the only one. Another major issue is the affordability of housing, with prices being pushed up by wealthy people from towns and cities wanting to move to the countryside, retire to the countryside, or buy second homes.

Figure 5: Rural and urban areas in the South East27

Health

1.4.13 The RSS identifies that the South East is considered to be the least deprived and the healthiest of all the English regions. The region has a comparatively low percentage of people with limiting long term illness: 14.8% compared to 22.1% in the least healthy region.

1.4.14 The average life expectancy within Kent is 79.7 years, significantly above the national average. Indeed, life expectancy in all Primary Care Trust (PCT) areas in Kent is above the national average. However, disparities within Kent are evident (see Figure 6), with life expectancy in the West Kent PCT (80.2 years) significantly higher than that of Eastern and Coastal Kent PCT (79.2 years).28

27 Images of the South East [online] available at: http://www.go-se.gov.uk/gose/ourRegion/aboutTheSE/imagesSE/ (accessed February 2009) 28 Kent Public Health Report (published 2009) [online] http://www.kent.gov.uk/publications/council-and-democracy/kent-public-health- report.htm (accessed 03/09)

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Figure 6: Life expectancy in Kent29

1.4.15 Figure 7 shows the percentage of people classed as disabled or permanently sick in Kent. Swale has the highest percentage of those who are disabled or permanently sick in Kent, at 3.6%, which is above the average for England as a whole (3.1%). Thanet and Dover are slightly below the England average at 3.0%. The Kent County Council area average of 2.6% is just above that of the South East Region’s figure of 2.4%. Tonbridge and Malling District has the lowest percentage at 2.0%.

Figure 7: Percentage of people disabled / permanently sick in Kent (2001)30

29 Ibid. 30 KCC (2006). Local Transport Plan for Kent 2006 – 2001 [online] available at: http://www.kent.gov.uk/NR/rdonlyres/8A1D434D- 1870-4A7C-B664-A35FE8F44A4E/0/app2accessibility1.pdf (accessed 02/09)

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1.4.16 As a final point relating to health it is important to note issues relating to noise. In the decades between 1984/85 to 2004/05 in England and Wales, the number of complaints about noise from road works, construction and demolition increased three and a half times, and complaints about noise from industrial and commercial premises nearly doubled over the same period (although this may partially reflect a public tendency to complain more). In addition to causing annoyance and sleep disturbance, persistent environmental noise can have negative impacts on health, for example, contributing to heart disease, hearing impairment and poor mental health. Some evidence suggests that the negative effects of noise may be more profound in children as chronic exposure to noise can lead to poorer reading ability and reduced memory.31

Future baseline

1.4.17 The Regional Spatial Strategy seeks to focus development in the region in such a way that it brings about the regeneration of currently deprived areas. The Government defines regeneration as ‘a set of activities that reverse economic, social and physical decline in areas where market forces will not do this without support from the government’.32 However, experience has proven that a key challenge of regeneration has been to generate the desired community benefits alongside physical development and renewal. The provision of the correct hard infrastructure (e.g. roads and sewers) and community infrastructure (e.g. schools) is key, but perhaps an even greater challenge is to ensure that projects also lead to jobs and training for local people, and that regeneration does not lead to further polarisation, but that benefits are able to spread to neighbouring communities.

1.4.18 In the Thames Gateway there is an emphasis on creating a renaissance for the entire sub- region, which does have the potential to stimulate all towns (large and small) as well as more rural areas. In particular, the plans to develop the gateway as an ‘Eco-region’33 along similar principles to those that have been proposed for Eco-towns34, should ensure that sustainable communities are created that have community well-being and cohesion, as well as community- led governance, at their heart. In East Kent and Ashford there is a focus on regeneration of coastal towns, which should have the potential to tackle some of the most extreme pockets of deprivation in Kent, although the approach for the sub-region is not as integrated and holistic as is the case for the Thames Gateway. In general, it is safe to assume that the regional pattern of deprivation is not static, and is likely to shift over time.

Current and future situation in sub-county areas

1.4.19 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These sub-areas were identified primarily on economic grounds.35 Policies are developed in the Plan for two of these areas to meet the following overarching objectives, which also have clear implications for communities:

• East Kent and Ashford – regeneration (East Kent) and growth area (Ashford) • Kent Thames Gateway – growth and regeneration

31 Sustainable Development Commission (2008) Health, place and nature [online] available at: http://www.sd- commission.org.uk/publications.php?id=712 (accessed 05/09) 32 BERR & CLG (2007) The Review of sub-national economic development and regeneration [online] available at: http://www.hm- treasury.gov.uk/sub-national_economic_development_regeneration_review.htm (accessed 03/09) 33 HM Government (2008) Thames Gateway Eco-region: a prospectus [online] available at: http://www.communities.gov.uk/publications/thamesgateway/ecoregion (accessed 03/09) 34 Government is currently consulting on draft principles for Eco-towns – see: http://www.communities.gov.uk/housing/housingsupply/ecotowns/ (accessed 03/09) 35 See a further discussion of the process of identifying sub-areas in the Economy and Employment Topic Paper

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1.4.20 Table 2 considers current and possible future baseline conditions in each of these sub-areas.

Table 2: The sub-county baseline

East Kent and Ashford36

All the urban areas of East Kent require regeneration to some degree, with the greatest changes likely to take place in Dover and Canterbury in the near future (as opposed to Folkestone and Hythe, where opportunities are more limited or constrained). The rural area of Romney Marsh is also suffers relatively extreme deprivation. Health deprivation in Kent is very much focused on the districts of Shepway, Dover and Thanet.

Kent Thames Gateway37

Most of the large towns in this area are amongst the 20% most deprived in Britain. The eastern half of Sheppey, which is a deeply rural area, also shows up as being particularly deprived. Sheppey also stands out in terms of health and education/skills deprivation. Crime deprivation is very much focused in the Kent Thames Gateway.

Rest of Kent38

Extreme deprivation (deprivation within the 20th percentile nationally) only exists in very small pockets within town centres. Indeed, extensive areas are amongst the least deprived (beyond the 80% percentile) nationally. The RSS identifies that a key spatial planning principle in this area is that the importance of the countryside as a resource to attract visitors and provide a healthy recreational environment must be recognised and strengthened.

1.5 What are the key sustainability issues?

1.5.1 Table 3 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 3: Key sustainability issues

Key Issue Discussion

Clear spatial Much deprivation is focused in the Kent Thames Gateway and the towns of East variation across Kent, although it is important to realise that there will be smaller pockets of Kent in terms of deprivation elsewhere, and also that the baseline is not static, but rather has the income, potential to change and shift as money is invested in the regeneration of certain employment and areas. health deprivation

Particular issues of Rural areas in Kent are shown by the Index of Multiple Deprivation as suffering rural deprivation from particular issues of access to housing and services, but there are also rural areas that suffer from other forms of deprivation more typically associated with urban areas, particularly Sheppey and Romney Marsh.

36 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 37 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2. 38 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area.

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Deprivation and It is more difficult to establish a baseline for such deprivation, and therefore vulnerability predict how strategic spatial decisions might potentially impact on groups such amongst particular as Gypsies and Travellers or migrant workers, but it is important to at least flag socio-economic up potential issues so that they can be addressed at a lower level of decision- groups making.

Potential for At the Examination in Public into the Partial Review of the South East Plan localised community (Policy MP3 - Aggregates) a number of local authorities presented evidence of impacts local community impacts associated with the proximity of quarries and also lorry movements.

1.6 What decision-making criteria should make up the SA framework?

1.6.1 The South East Regional Sustainability Framework includes the following objectives relating to community and well-being:

“To improve the health and well-being of the population and reduce inequalities in health” “To reduce poverty and social exclusion and, by improving their performance, close the gap between the most deprived areas in the South East and the rest of the region” “To create and sustain vibrant communities which recognise the needs and contributions of all individuals” “To improve accessibility to all services and facilities including the countryside and the historic environment” “To encourage increased engagement in cultural activity across all sections of the community in the South East and promote sustainable tourism” “To raise educational achievement levels across the region and develop the opportunities for everyone to acquire the skills needed to find and remain in work” “To reduce crime and perceptions of disorder”

1.6.2 It is helpful to take account of these established regional sustainability objectives. However, bearing in mind the scope of influence of the Kent MWDF it is thought that there is a need to tailor these objectives, so that they are most suited to capturing the likely significant effects of the plan. Taking account of the key sustainability issues identified in Section 1.5 above, it is thought that the most appropriate sustainability objective for use in this SA are:

Support efforts to create and sustain sustainable communities, particularly the improvement of health and well-being

1.6.3 When appraising the effects of the plan in terms of these objectives, the following sub- objectives relating to community and well-being should also be taken into account:

• Help to redress spatial inequalities highlighted by the Index of Multiple deprivation and other indicators. • Help to tackle more hidden forms of deprivation and exclusion, such as that which is experienced by residents of rural areas and particular socio-economic groups within communities.

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1.7 What further data is required?

• There are relatively good data available for many trends in the socio-economic baseline. However, some trends are more difficult to show spatially, such as rural deprivation (as ‘rich and poor’ can live in close proximity) and deprivation experienced by ‘other’ equalities groups that will be integrated within communities (rather than forming spatially discrete communities).

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Revision Schedule

Scoping Report – Employment and the Economy March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Consultant Associate Technical Director Ian Brenkley Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Table of Contents

1 Employment and the Economy ...... 3 1.1 Introduction...... 3 1.2 Background...... 3 1.3 What’s the sustainability context?...... 3 1.4 What’s the current and (likely) future sustainability baseline? ...... 7 1.5 What are the key sustainability issues?...... 13 1.6 What decision-making criteria should make up the SA framework?...... 13 1.7 What further data is required? ...... 14

List of Tables

Table 1: Employment opportunities at waste facilities...... 10 Table 2: The sub-county baseline ...... 11 Table 3: Key sustainability issues...... 13

List of Figures

Figure 1: GVA per Head and Total GVA in Kent 1995-2006 ...... 7 Figure 2: Employment deprivation within Kent ...... 8 Figure 3: Ward level unemployment rates, February 2009 ...... 9 Figure 4: Salaries in Kent ...... 9

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1 Employment and the Economy

1.1 Introduction

1.1.1 This is Topic Paper 5 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of the economy and employment; describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to the economy and employment in Kent and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 The South East is widely recognised as one of the most successful regions in the UK, and its economic performance is therefore central to the UK’s current and future economic well being. However there are disparities within the region, with variations in economic performance and concentrations of social exclusion. Some parts of Kent have seen economic buoyancy on a par with London and the wider South East. However, much of Kent performs below the regional average, and many of the pockets of greatest economic underperformance are found in Kent. For example, a number of the coastal towns have clearly suffered as a result of relative isolation from London and the wider South East. Although this paper concerns Kent, it is important to acknowledge that the county is not a self-contained economy, and the success of London and the wider South East, as well as the wider national and international economy, has a significant bearing.

1.3 What’s the sustainability context?

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering economy and employment in this SA. This context review meets a requirement of the SEA Directive. 1

1.3.2 Government guidance on sustainable development stresses the importance of a strong, stable and productive economy and requires planning authorities to ensure that the necessary infrastructure is provided to support new and existing economic development.2 Accessibility to jobs and services are also addressed as a means of achieving social cohesion and inclusion and it is recognised that economic development can deliver environmental and social benefits.

1.3.3 Other relevant Government guidance promotes the importance of an economy built on innovation, including the need for improved funding of science; incentives for knowledge transfer and innovation-driven regional strategies and clusters;3, increased research;4 the

1 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes. 2 ODPM (2005). Planning Policy Statement 1: Delivering Sustainable Development [online] available at: http://www.communities.gov.uk/documents/planningandbuilding/pdf/planningpolicystatement1.pdf (accessed 02/09) 3 DfT (2003). Competing in the global economy: the innovation challenge [online] available at: http://www.berr.gov.uk/files/file12093.pdf (accessed 02/09). 4 HM Treasury (2004). Science and Innovation investment framework 2004-2014 [online] available at: http://www.hm- treasury.gov.uk/spending_sr04_science.htm (accessed 22 September 2008).

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development of new technologies; more efficient ways of working; and raised skills levels to create a more flexible and productive workforce5. A recent White Paper seeks to broaden innovation policy to include more than the traditional focus on science, technology and research. It acknowledges the need to recognise new sources of innovation. The role of creating market demand is highlighted, noting the traditional emphasis on supply-side measures.6 Innovation, skills and market demand are all key considerations for waste management.

1.3.4 Government guidance on minerals planning includes a number of important implications relating to the consideration of economic impacts.7 First, it states the importance of enabling the minerals industry, so far as is practicable, to secure productivity growth and high and stable levels of employment. There is a particular focus on maximising the potential for minerals waste to be used for recycling or in-site restoration, but if not required for these purposes and where practicable identify a market for its potential use.

1.3.5 There is also a focus on protecting locations from unnecessary sterilisation, including through preventing incompatible development close by to potential minerals sites, and also safeguarding facilities such as wharves, ports and depots, especially where there are good transport links. Also in locational terms, the guidance states that consideration should be given to the possibility of combining storage, handling and transport sites with those for the processing and distribution of recycled and alternative aggregate material.

1.3.6 Region-wide policies of relevance in the Regional Spatial Strategy (RSS)8 include:

• Policy RE2, which supports the development of nationally and regionally important sectors and clusters, including through safeguarding of land in appropriate locations; and • Policy RE6, which seeks to address sub-regional economic disparities including through addressing the underperformance of the East Kent and Kent Thames Gateway.

1.3.7 The RSS has identified a number of sub-regions within the South East. The over-riding factor that has lead to these sub-regional boundaries being drawn up is economic growth and regeneration. In particular, the RSS states that:

“The South East is a particularly large and diverse region. This means that perhaps more than any other region it does not have towns, cities and rural areas that share similar characteristics. Different parts of the region often have distinctive set of issues that need to be addressed through joint working across local authority boundaries. This Plan responds to this challenge by identifying nine sub-regions, defined according to the functional relationships between key settlements and their surrounding areas, and driven by the need to apply a consistent set of policies across their areas. Policies for these areas have been developed to overcome any ‘strategic policy deficit’ that demands co-ordination of planning activity at a regional and sub- regional scale... Sub-regions have been identified where they show strong economic potential or particular regeneration needs.”

5 DTI (2004). Making globalisation a force for good [online] available at: http://www.berr.gov.uk/whatwedo/europeandtrade/trade- policy/t-i-white-paper/page23431.html (accessed 02/09). 6 DIUS (2008). Innovation Nation [online] available at: http://www.dius.gov.uk/publications/scienceinnovation.pdf (accessed 02/09). 7 CLG (2006). Minerals Planning Statement 1: Planning and Minerals [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/mineralspolicystatement5 (accessed 02/09) 8 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09)

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1.3.8 The RSS also designates a number of ‘Regional Hubs’, which will be the focus of investment in the economy and housing, as well as multi-modal transport. The following Kent settlements have been designated as Regional Hubs:

• Ashford • Maidstone • Canterbury • Medway Towns • Dover • Tonbridge / Tunbridge Wells • Ebbsfleet

1.3.9 Furthermore, Ebbsfleet and the Medway Towns have been designated as being diamonds for growth as a result of being capable of stimulating prosperity, with further growth being unlocked through targeted investment in infrastructure.

1.3.10 The following policies aim to guide the economic growth and regeneration of the sub-regional areas and regional hubs within Kent:

East Kent and Ashford9

• Policy EKA1 promotes the importance of exploiting the potential for housing and business at locations served by the CTRL domestic services, especially at Ashford. • EKA5 supports the growth of the gateway towns, including activity associated with freight handling and tourism, and seeks to support the cross Channel routes, particularly the ports of Dover and Ramsgate. • EKA6 promotes high quality proposals for intensifying or expanding the technology, knowledge and scientific sectors.

Kent Thames Gateway10

• Policy KTG2 identifies that the development of the economy in Kent Thames Gateway will be dynamic and widely based, to provide employment for the community as a whole. Provision will be made for the expansion of the existing economic functions of the area and for the introduction of new office, manufacturing and service functions on a large scale, with an emphasis on higher value activity including knowledge industries and research and development. • In particular: • major sites in Thameside with access to M25 and the national rail network will continue to develop a mix of employment uses, including regional distribution and manufacturing; • major sites identified in Medway will be developed to their full potential, building on the existing high technology aerospace and automotive sectors and attracting new high value activity, or accommodating the expansion of transport, energy, distribution and manufacturing; • in Sittingbourne the employment and occupation structure will be diversified though expansion of the service and science sectors; • in Sheppey, provision has been made for the expansion of the distribution, transport and manufacturing sectors; and

9 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 10 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2.

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• provision will be made for the continued presence and expansion of viable riverside employment uses, especially those using the river for transport. • The economy of the Kent Thames Gateway differs from most other sub-regions in the South East in the relatively high proportions of jobs in manufacturing and distribution, and the presence of ports and power generation. These are essential functions for the region, London and the nation. Policy KTG1 will help ensure that provision is made for their future capacity and viable operation as well as new types of jobs to diversify the local economy. This will also help reduce over dependency on jobs outside the area although the sub-region will continue to need to take advantage of the jobs which London provides as a global city and financial centre.

Maidstone

• Policy AOSR7 relates to the ‘Maidstone Hub’, stating that there should be new provision for employment of sub-regional significance, with an emphasis on higher quality jobs to enhance its role as the county town and a centre for business; and support high quality proposals for intensifying or expanding the technology and knowledge sectors at established and suitable new locations. Finally, it seeks to ensure that development at Maidstone complements rather than competes with the Kent Thames Gateway towns and does not add to travel pressures between them.

Tonbridge and Tunbridge Wells

• Policy AOSR8 relates to Tonbridge and Tunbridge Wells, and similarly states support for high quality proposals for intensifying or expanding the technology and knowledge sectors at established and suitable new locations.

1.3.11 The Regional Economic Strategy for the South East 2006-2016 sets out to achieve the goal of global competitiveness through smart growth and sustainable prosperity. The strategy is to invest in success, lift underperformance and support quality of life. Three key challenges are identified in the RES, in addition to targets and aims for the achievement of these objectives are:

• The Global Challenge of maintaining competitiveness in the face of intensifying international competition; • Smart Growth through higher productivity and bringing more of the resident SE population into economic growth, thus maintaining higher levels of prosperity per head across the SE without increasing the region’s ecological footprint; • Achievement of Sustainable Prosperity by recognising that long-term regional economic prosperity can only be secured through the principles of sustainable development.

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1.4 What’s the current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to employment and the economy in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent to other geographical areas, as well as considering how the baseline varies at the sub-county scale, within three sub-regional areas defined in Kent by the RSS. This section meets a key requirement of the SEA Directive.11

Current baseline

Economic Activity

1.4.2 Gross Value Added (GVA) is taken to be indicative of the state of the economy. It is defined by the Office for National Statistics as “the difference between output and intermediate consumption for any given sector/industry, that is, the difference between the value of goods and services produced and the cost of raw materials and other inputs which are used up in production”. As Figure 1 below shows, Kent has seen consistently rising levels of both total GVA added and GVA per capita over a ten year period. This is indicative of a growing and strengthening local economy.

Figure 1: GVA per Head and Total GVA in Kent 1995-200612

25,000

Source: Office for National Statistics © Research & Intelligence, Kent County Council

20,000

15,000

GVA per £ millions head £m 10,000

Total Gross Value Added (GVA) £m 5,000

- 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 Year

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Employment

1.4.3 The Index of Multiple Deprivation (IMD) 2007 includes a sub-domain of ‘employment deprivation’ (which it defines as involuntary exclusion of the working age population from the world of work). Figures 2a and 2b show the spatial distribution of employment deprivation within Kent. Figure 2b compares each area (known as Lower Super Output Areas, LSOAs) to the national picture, and so it is possible to see which areas are the most deprived, i.e. they fall within the bottom 20% of LSOAs nationally in terms of employment deprivation. A number of Kent LSOAs are within England’s top 20% deprived. Those in the top 20% deprived nationally represent 10% of all Kent LSOAs. These areas are mainly on the Isle of Sheppey and Thanet but also can found in Dover, Folkestone, Dartford, Gravesend and Sittingbourne. There is a clear east/ west divide in Kent with regards to the level of employment deprivation. The Kent LSOAs which are in Kent’s top 20% deprived tend to be found in East Kent, along with concentrations in and around Dartford and Gravesend.

Figure 2: Employment deprivation within Kent13

1.4.4 Figure 3, which looks at unemployment rates as at February 2009, shows even more clearly how unemployment is focused in the Kent Thames Gateway, East Kent, with the towns of Maidstone and Ashford and the coastal areas of Shepway and Dover standing out as areas with higher than the county average unemployment in ‘the rest of Kent’.

13 KCC (2008) The Pattern of Deprivation in Kent based on The Indices of Deprivation 2007 [online] available at: http://www.kent.gov.uk/NR/rdonlyres/2681A1ED-94A1-4345-8578- 49F7D6CBD4E2/13176/deprivationinkentreport2007.pdf?bcsi_scan_F6892CABA15785B4=0&bcsi_scan_filename=deprivationinkentr eport2007.pdf (accessed 02/09)

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Figure 3: Ward level unemployment rates, February 200914

1.4.5 Figure 4 suggests that, in Kent, average salaries are not low, but that there are some areas (particularly Thanet, Canterbury and Swale) where a high percentage of people are occupied in low waged jobs.

Figure 4: Salaries in Kent15

1.4.6 In terms of the potential for minerals and waste development to contribute significantly to local employment, there is some information available in terms of waste facilities, but less for

14 KCC (2009) Personal Communication. 15Commission for Rural Communities (2008) State of the Countryside Report [online] available at: http://www.ruralcommunities.gov.uk/projects/stateofthecountryside/overview (accessed 03/09)

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minerals facilities. To begin with, it has recently been reported that the new major energy to waste facility at Allington Quarry in Kent will generate approximately 50 permanent jobs16. However, this is perhaps somewhat of an exceptional case, due to the scale and high-tech nature of this operation. Table 1 shows the number of jobs that are typically associated with different types of waste management facility.

Table 1: Employment opportunities at waste facilities17

Type of facility Employees Composting - 25,000 tonnes per year, green waste Site Manager, Assistant Manger plus three site only operatives Composting - 25,000 tonnes per year plant Site Manager, Assistant Manager plus three site composting waste containing kitchen/catering waste operatives covered by the Animal By-products Order (there are no sites of this type and scale in the UK) Anaerobic digestion - throughput circa 5,000 tpa Site Manager, plus 2 other workers. Anaerobic digestion - throughput circa 40,000 tpa Site Manager and foreman, plus 3 other workers Recycling facility - 50,000 tonnes per year If no hand-picking less than 10 operatives; if hand picking potentially 50 or more operatives on shift rotation Mechanical and biological treatment of mixed waste 2/3 at any one time, shift system if 24 hour plant - typical 50,000 tonnes per year operation – (more if manual picking operations) Pyrolosis and gasification plant - 50,000 tonnes per 2–3 workers at any one time, shift system if 24 hour year] operation Thermal treatment plant - 50,000 tonnes per year] 2/3 workers at any one time, on a shift system if 24 hour operation Thermal treatment plant - 250,000 tonnes per year Site Manager, Assistant Manager plus 10 on three shift system Landfill - 250,000 tonnes per year Site manager, environmental manager, marshall, compactor driver, plant operatives (eg. dozer/shovel drivers etc), litter pickers, ancillary staff.

Landfill gas plant - 2000 m3 throughput of landfill Usually controlled by telemetry. Maintenance staff gas per hour] on routine call-out, as necessary.

Leachate treatment plant - 100 m3/day plant] 1 or 2 operatives part or full time or plant may be fully automated Civic amenity site 2–4 workers Waste transfer site - 120,000 tonnes per annum Site manager and foreman, plus two other workers

1.4.7 It can be seen that the majority of facilities are not labour intensive and any new operations are unlikely to generate significant employment numbers. However, potential minerals operations in the region should help safeguard jobs and may provide new employment opportunities which will have economic benefits for local communities and the wider area.

16 Information taken from scheme promoter’s website - http://www.kentenviropower.co.uk/default.asp (accessed 05/09) 17 ODPM (2004) Planning for Waste Management Facilities: A research study [online] available at: http://www.communities.gov.uk/documents/planningandbuilding/pdf/148385.pdf (accessed 03/09)

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Future baseline

1.4.8 The RSS expects 50,000 jobs to come forward in East Kent and Ashford and 58,000 jobs to come forward in the Kent Thames Gateway (2006-2026), whilst it predicts that 15,000 jobs will come forward in the Rest of Kent by 2016.

Current and future situation in sub-county areas

1.4.9 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. Policies are developed in the RSS for two of these areas to meet the following overarching economic growth and regeneration objectives:

• East Kent and Ashford – regeneration (East Kent) and growth area (Ashford) • Kent Thames Gateway – growth and regeneration

1.4.10 Table 2 considers current and possible future baseline conditions in each of the sub-areas.

Table 2: The sub-county baseline

East Kent and Ashford18 The sub-area plays a nationally significant role as a key gateway to mainland Europe, but is relatively remote from London and the remainder of the region and includes some of the least economically buoyant areas in the South East. All the urban areas of East Kent require regeneration to some degree, with Dover and Canterbury likely to see the quickest and most significant changes, particularly as they have the infrastructure already in place or more easily deliverable. The introduction of new high-speed domestic rail services will be a key factor in supporting the growth of Ashford and stimulating the regeneration of the coastal towns, which will need to develop their own strength and specialisms. Key socio-economic challenges identified for this sub-area in the RSS include: • delivering a sufficient supply of housing to meet the needs of the future population and support its economic regeneration and growth; • ensuring that each area makes a positive and distinctive contribution to the future success of the sub-region; • accommodating and successfully spreading the benefits of Ashford’s growth; • promoting further growth at Dover; • developing Canterbury’s role as a historic centre of learning and commerce with strong links between university research and business and promote housing growth for sustainable communities; • regenerating other urban areas and coastal towns whilst respecting environmental constraints; and • maximising the benefits of international and domestic links provided by CTRL. The RSS states that in the past 20 years an additional 39,000 jobs have been generated in this area. However, a higher value is needed for the future that takes into account the impact of the strategic sites and other potential for growth arising from Ashford’s Growth Area status and the objectives for the regeneration of the coastal towns. Employment deprivation is focused on the towns, but also effects extensive rural areas in Shepway and Thanet, as well as small patches of rural areas in Dover and Canterbury Districts. In Romney Marsh – the

18 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale.

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most sparsely populated area in South East England - two of the largest economic drivers in recent times – Dungeness Nuclear Power Station and the potato industry - have both experienced a downturn in the early 21st century with decommissioning of an installation in the former case and loss of contracts to a major supermarket in the latter. Levels of unemployment on Romney Marsh are 100% greater than the average for rural Kent.19 Kent Thames Gateway20 Traditional employment in the Thames Gateway has been based around heavy industries such as cement and paper manufacturing, and agriculture, although both have declined over recent decades. Service industry employment is concentrated in the Bluewater shopping and leisure centre, the principal towns and in locations further afield including the Medway Towns, Lewisham or Bexleyheath. Unemployment in the area as at February 2009 is 3.9% in comparison with the Kent average of 3.2%21 although levels are significantly higher in parts of Swale and Gravesham. Employment deprivation is very much focused on Sheppey, as well as, to a lesser degree, the more rural, western half of Swale District. Since the 1980’s the fundamental theme in this area has been regeneration of large previously developed sites, improvement of poor urban environment and stimulus to the economy. The Thames Gateway is now identified as a major Growth Area, with the aim to transform the scale and character of the economy, raising its growth rate above that of the region as a whole and strengthening its international competitiveness. Particular aims are to: • expand the existing economic base; • deliver sufficient decent homes and provide a well integrated mix to meet the needs of the future population of this major Growth Area and support its economic regeneration and growth; • create a safe and healthy environment with well designed public and green spaces and a ‘sense of place’. • provide adequate infrastructure and services to support sustainable growth. This includes good public and other transport both locally and linking to other centres; and • promote the right links with the wider regional, national and international community. In this collaboration, across the boundary with London will be particularly important.

Rest of Kent22 The RSS identifies that a key spatial planning principle in this area must be to support, improve and diversify local economies.

19 Kent Downs & Marshes Local Action Group Local Development Strategy (draft, 2007) 20 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2. 21 KCC (2009). Personal communication. 22 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area.

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1.5 What are the key sustainability issues?

1.5.1 Table 3 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 3: Key sustainability issues

Key Issue Discussion

Local disparities in The Kent MWDF should seek to have a direct positive impact on local economic economic activity activity and employment opportunities, including through creating jobs to meet the skills and aspirations of local people. Ambitious plans for The Kent MWDF must support and not hinder wider efforts to diversify economic economic activity, particularly in East Kent and the Kent Thames Gateway. regeneration

1.6 What decision-making criteria should make up the SA framework?

1.6.1 The South East Regional Sustainability Framework includes the following objectives relating to employment and the economy:

“To ensure high and stable levels of employment so everyone can benefit from the economic growth of the region” “To sustain economic growth and competitiveness across the region by focusing on the principles of smart growth: raising levels of enterprise, productivity and economic activity” “To stimulate economic revival in deprived areas” “To develop a dynamic, diverse and knowledge-based economy that excels in innovation with higher value, lower impact activities” “To develop and maintain a skilled workforce to support long-term competitiveness of the region”

Support economic growth and diversification

1.6.3 When appraising the effects of the plan in terms of this objective, the following sub-objectives should also be taken into account:

• Support the development of a dynamic, diverse and knowledge-based economy that excels in innovation with higher value, lower impact activities • Stimulate economic revival and targeted employment generation in deprived areas

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1.7 What further data is required?

• Most recent economic indicator data following the global economic downturn and associated credit crunch

Scoping Report – Employment and Economy 14 March 2010

Revision Schedule

Scoping Report - Heritage March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Consultant Associate Technical Director Ian Brenkley Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Table of Contents

1 Heritage ...... 3 1.1 Introduction...... 3 1.2 Background...... 3 1.3 What’s the sustainability context?...... 3 1.4 What’s the current and (likely) future sustainability baseline? ...... 5 1.5 What are the key sustainability issues?...... 11 1.6 What decision-making criteria should make up the SA framework?...... 12 1.7 What further data is required? ...... 12

List of Tables

Table 1: National distribution of designatd heritage assets ...... 6 Table 2: Breakdown of designated heritage features ...... 6 Table 3: Heritage at Risk 2008 ...... 8 Table 4: The sub-county baseline ...... 10 Table 5: Key sustainability issues...... 11

List of Figures

Figure 1: Kent County conservation areas and district boundaries ...... 7 Figure 2: Historic parks and gardens and landscape character areas ...... 7 Figure 3: Towns surveyed as part of the Kent Historic Towns Survey ...... 9

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1 Heritage

1.1 Introduction

1.1.1 This is Topic Paper 6 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This paper provides a background to the consideration of heritage; describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to heritage and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 The historic environment includes the physical evidence of past human activity. It is all around us as part of everyday life, and it is therefore dynamic and continually subject to change. It is not limited to the built environment and archaeological sites, but includes landscapes, both urban and rural and as an example of its great diversity, marine heritage sites around the coast. These environments are fragile and require protection, but also have an enormous potential to contribute to a sense of place and identity and add to the quality of our daily lives through understanding and appropriate management and access. Government guidance emphasises that protection of the historic environment should account for character and local distinctiveness – reflecting the fact that heritage conservation is more than a purely designation based issue.1

1.3 What’s the sustainability context?

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering heritage in this SA. This context review meets a requirement of the SEA Directive.2

1.3.2 The Government’s vision for the historic environment is for a future which recognises the economic and social aspects of the historic environment, such as its economic potential in regeneration schemes; its role in promoting understanding and enjoyment of place; and promoting the engagement of people in decisions which affect their communities.3

1 ODPM (2005). Planning Policy Statement 1: Delivering Sustainable Development [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/planningpolicystatement1 (accessed 02/09) 2 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes. 3 English Heritage (2001) The Historic Environment: A Force for the Future [online] available at: http://www.culture.gov.uk/reference_library/publications/4667.aspx (accessed 02/09)

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1.3.3 Government guidance relating specifically to the historic environment states that:

“The physical survivals of our past are to be valued and protected for their own sake, as a central part of our cultural heritage and our sense of national identity. They are an irreplaceable record which contributes, through formal education and in many other ways, to our understanding of both the present and the past. Their presence adds to the quality of our lives, by enhancing the familiar and cherished local scene and sustaining the sense of local distinctiveness which is so important an aspect of the character and appearance of our towns, villages and countryside. The historic environment is also of immense importance for leisure and recreation.”4

1.3.4 Guidance highlights the importance of protecting the listed buildings and their settings; considering the quality of conservation areas as a whole that is more than the sum of its individual buildings; considering Registered Parks and Gardens as a material planning consideration; and that local authorities must take full account of the wider costs of transport choices, including impacts on the historic environment.5 Separate guidance focuses on the need to reconcile development pressures with the interests of archaeology, emphasising the principle of early assessment to ensure that remains are not needlessly destroyed, that development proposals take into account archaeological interest and that important remains are preserved in situ.6 More recently, the Heritage Protection White Paper put forward proposals to integrate the existing consent regimes for historic assets and place greater emphasis on enhancement of the undesignated historic environment.7 Government guidance on minerals planning identifies impacts relating to ‘archaeological and heritage features’ as a potential ‘principle environmental impact’ of minerals working. However, guidance also highlights that small quarries can play an important role in providing historically authentic building materials.

1.3.5 There is a growing realisation that minerals extraction can produce unique archaeological information but that it requires specific techniques, approaches and management strategies. The quarrying of aggregates, particularly 'soft aggregates', has made a major and unique contribution to our understanding of the past and that given the pressures of the economy and regulation by necessity the industry will go on doing so and more specifically the sterilization of aggregate resources by preservation in situ, whilst desirable, is unlikely to be acceptable in most cases in the face of such pressures. River valleys offer opportunities to study large tracts of potentially well-preserved, buried landscapes and associated archaeological remains at particular points in time, as well as offering the prospect of assessing how landscapes have evolved over millennia. However, river valleys are also dynamic environments in which processes of erosion and deposition act to bias the archaeological record and thus present particular challenges for its interpretation.

1.3.6 Policy BE6 of the Regional Spatial Strategy (RSS)8 relates to management of the historic environment, highlighting the importance of local and regional distinctiveness and sense of place and encouraging proposals that make sensitive use of historic assets through regeneration, particularly where these bring redundant or under-used buildings and areas into appropriate use. Policy AOSR8 relates to Tonbridge and Tunbridge Wells. Amongst other

4 Government (1994) Planning Policy Guidance 15: Planning and the historic environment [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/ppg15 (accessed 02/09) 5 Ibid. 6 Government(1990) Planning Policy Guidance 16: Planning and archaeology [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/ppg16 (accessed 02/09) 7 dCMS (2007). Heritage Protection for the 21st Century [online] available at: http://www.culture.gov.uk/reference_library/consultations/1156.aspx (accessed 02/09) 8 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09)

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things it seeks to ensure that, at Tunbridge Wells, priority is given to conservation of the urban and natural environment, and the setting of the town. At Tonbridge, on the other hand, there is a need to concentrate development on substantial regeneration sites in and near to the town centre.

1.4 What’s the current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to heritage in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent to other that of other geographical comparators, as well as considering how the baseline varies at the sub-county scale, within three sub-regional areas defined in Kent by the RSS. This section meets a key requirement of the SEA Directive.9

Current baseline

1.4.2 It is widely recognised that the South East has a rich and diverse historic environment. This is a tremendous asset as an expression of the region’s history, heritage and culture, lying at the heart of local and regional character and sense of place. The historic buildings and landscapes that characterise the region add much to the quality of life that underpins the region’s economy, with both the rural landscape and the urban fabric influencing investment decisions. The historic environment is part of the wider environment of the region that is a key ‘draw’ of the area.

1.4.3 The RSS highlights the following assets of particular importance in Kent:10

• the historic city of Canterbury; • maritime heritage including naval dockyards and seaside built heritage; • the organically developed landscapes and countryside; • an outstanding archaeological heritage from prehistoric finds reflecting the development of agriculture, through Roman centres such as Canterbury through major Saxon and medieval ecclesiastical and urban centres; • the network of historic market towns and villages with their medieval churches and other historic buildings; • stately homes and historic parks and gardens; and • the defence heritage of the region which has always acted as a front line of defence.

1.4.4 Table 1 shows the national distribution of designated heritage assets, whilst Table 2 shows the breakdown within Kent. Figures 1 and 2 show the distribution of Conservation Areas and Registered Historic Parks and Gardens respectively. Finally Table 3 gives the county breakdown for Heritage at Risk.

9 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected” 10 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09)

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Table 1: National distribution of designated heritage assets11

Table 2: Breakdown of designated heritage features12

District No of Listed No of Scheduled No of No of registered Buildings Ancient Monuments Conservation historic parks Areas and gardens Ashford 2,399 38 43 6 Canterbury 1,872 52 105 2 Dartford 183 12 6 0 Dover 1,904 48 57 6 Gravesham 304 9 24 2 Maidstone 2,006 27 41 5 Sevenoaks 1,631 25 40 17 Shepway 897 64 21 2 Swale 1,453 21 49 4 Thanet 1,009 13 20 1 Tonbridge & 1,310 25 59 4 Malling Tunbridge Wells 2,237 11 27 13 Kent 17,205 345 489 62 South East 75,855 2,642 2,102 365

11South East Historic Environment Forum (2008) Heritage Counts: South East Web Report [online] available at: http://www.english- heritage.org.uk/hc/upload/pdf/HC_SE_2008_Web_report_web_20081029151118.pdf?1235401548 (accessed 02/09) 12 Ibid.

Scoping Report - Heritage 6 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

Figure 1: Kent County conservation areas and district boundaries13

Figure 2: Historic parks and gardens and landscape character areas14

13 Kent Landscape Information System [online] available at: http://extranet7.kent.gov.uk/klis/default.asp (accessed 02/09) 14 Ibid.

Scoping Report - Heritage 7 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

Table 3: Heritage at Risk 200815

District Grade I Grade II* Grade II Unlisted (Scheduled Scheduled Monuments) Monuments Ashford 1 0 2 0 Canterbury 2 1 1 0 Dartford 0 0 0 0 Dover 1 1 0 2 Gravesham 1 1 0 0 Maidstone 1 4 3 0 Sevenoaks 0 0 0 1 Shepway 2 0 2 3 Swale 1 8 0 2 Thanet 1 1 0 0 Tonbridge & 1 0 0 0 Malling Tonbridge Wells 0 1 0 0 Kent 11 16 8 7 South East 50 54 27 38

1.4.5 As a first line of defence it is useful to know the location of designated heritage assets and an appreciation of spatial trends when planning at the strategic level. For example:

• the South East has more Registered Parks and Gardens than any other region, and Kent has almost twice as many as any other county in the region; • within Kent, Registered Parks and Gardens are concentrated in a central belt, associated with the North Downs, Wealden Greensand and High Weald Landscape Character Areas; • conservation areas are more evenly spread, with some district authorities also designating rural conservation areas; • Kent has more than 440 scheduled monuments16; • the South East has more listed buildings than any other region other than the South West, and Kent has significantly more that any other South East county; • Kent has 17,205 listed buildings, of which, only 1,100 are found in Medway, Dartford and Gravesham, with Shepway and Thanet also having a relatively low density; and • Kent has almost twice as many heritage assets at risk than any other county in the South East, although Kent has also removed far more entries from the heritage at risk register than any other county.

15South East Historic Environment Forum (2008) Heritage Counts: South East Web Report [online] available at: http://www.english- heritage.org.uk/hc/upload/pdf/HC_SE_2008_Web_report_web_20081029151118.pdf?1235401548 (accessed 02/09) 16 http://www.kent.gov.uk/leisure-and-culture/heritage/explore-kents-past/heritage-resources.htm (accessed 05/09)

Scoping Report - Heritage 8 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1.4.6 However, protection of the heritage resource also requires an understanding of the heritage value of wider landscapes and townscapes and the non-designated features within them. Methodologies are in development that aim to help to characterise the wider historic environment, often known as Historic Landscape Characterisation (HLC). HLC can help to identify the significance of present day landscape features, and establish levels of sensitivity. Where landscape features have been lost, it can help to identify where these might be re- instated and ensure that development works with, and reflects, local distinctiveness. Historic Landscape Characterisation has always been an element of established approaches to landscape characterisation (see Landscape Topic Paper), but it is now recognised that there is a need for a stand-alone approach.

1.4.7 Furthermore, there is the need to take a separate approach to the characterisation of historic townscapes. The Kent Historic Town Survey has characterised the towns shown in Figure 3.

Figure 3: Towns surveyed as part of the Kent Historic Towns Survey

Future baseline

1.4.8 In terms of designated historic features it might be assumed that there will continue to be strict protection provided by law and planning policy, and that when the Heritage Protection Bill eventually passes through parliament this will only serve to strengthen regimes. The Bill also aims to bring heritage conservation into the 21st century, promoting a more proactive and holistic approach. This aim will be supported by development of a new Policy Planning Statement which is clear and up to date and brings together planning policy on all aspects of the historic environment – the built environment, archaeology and landscape.17 The increasing emphasis on the use of HLC and the characterisation of historic townscapes as part of the evidence base to inform spatial planning will also allow for a more informed debate about how heritage conservation can most appropriately be achieved alongside wider objectives such as growth, regeneration and climate change adaptation. HLC and other bespoke studies are likely

17 See [online] http://www.english-heritage.org.uk/server/show/nav.8380 (accessed 02/09)

Scoping Report - Heritage 9 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

to continue to highlight specific opportunities for heritage-led regeneration in the county’s towns and cities, particularly those on the coast.

Current and future situation in sub-county areas

1.4.9 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These areas were identified primarily on economic grounds, but provide a useful spatial framework to consider other elements of the sustainability baseline. Table 4 considers current and possible future baseline conditions in each of these sub-areas.

Table 4: The sub-county baseline18

East Kent and Ashford19

Within East Kent and Ashford there is a high density of conservation areas within the districts of Dover, Swale and Canterbury. There is a lower density apparent in Shepway, East Ashford and Thanet, although there are conservation areas associated with many of the coastal towns. Canterbury and Swale have designated extensive Rural Conservation Areas. There is a high density of Registered Parks and Gardens associated with the central belt of this area, and there are also several within Thanet. Virtually all of the coastal towns in this area are seeking to follow heritage-led regeneration, recognising that this can be the most successful approach to improving the public realm and strengthening character and distinctiveness. For example, Whitstable is seeking to capitalise on the tourism potential created by its fishing heritage, Margate is seeking to capitalise on the seaside town urban fabric as a setting for contemporary art, and in Folkestone there are plans to regenerate the old town as a ‘creative quarter’.20 For more information on the historic landscape, see the Landscape Topic Paper.

Kent Thames Gateway21

Conservation areas are spread sparsely in the Thames Gateway, and there is only a handful of Registered Parks and Gardens. The RSS identifies that a key aim in this area must be to focus development at the urban areas and protect and enhance the heritage and natural environment. English Heritage has identified more than 100 "historic hubs" in the Thames Gateway - towns, cities and villages that have, often overlooked, historic assets that have the potential to act as a catalyst for revitalising the whole area. In relation to this programme, English Heritage state that “Identifying and then regenerating historic hubs provides an economic, geographic and civic focus for new places. Even more importantly, it prioritises improving quality of life for the communities that are already there… the Thames Gateway's Georgian and Victorian high streets and medieval ports were all but lost under layers of grime and dereliction. But now, through investment in its historic hubs, the area is rediscovering its soul.”22 For more information on the historic landscape, see the Landscape Topic Paper.

18 Note that there is little spatial information available to describe the baseline in terms of buried archaeology. However, having said this it is recognised that river valley are of particular importance as they are often associated with a rich buried archaeological resource and are also the focus of aggregates extraction. 19 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 20 English Heritage (2007) Coastal Towns Report [online] available at: http://www.helm.org.uk/upload/pdf/Coastal-Towns- Report3.pdf?1236090870 (accessed 02/09) 21 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2. 22 English Heritage (2008) Growing Places: Heritage and a Sustainable Future for the Thames Gateway [online] available at: http://www.english-heritage.org.uk/server/show/nav.1300 (accessed 02/09)

Scoping Report - Heritage 10 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

Rest of Kent23

There is a fairly regular spread of Conservation Areas, with a higher density in Tonbridge and Malling (which appears to include areas designated as rural conservation area), and some extensive conservation areas associated with Royal Tunbridge Wells and Sevenoaks. There is a high density of Registered Parks and Gardens throughout this area, with the exception of the eastern extreme. For more information on the historic landscape, see the Landscape Topic Paper.

1.5 What are the key sustainability issues?

1.5.1 Table 5 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 5: Key sustainability issues

Key Issue Discussion

The need to take The value of the built and buried archaeological resource varies considerably account of designated throughout the county. It may be possible to steer development away from heritage assets and sensitive areas. their settings as well as undesignated assets

The need to take This should be informed by landscape assessment and, where available, account of wider historic landscape character assessment. historic character

The need to facilitate This is a particular focus for the coastal towns of East Kent and within the heritage-led Thames Gateway. However, it is recognised that the MWDF can only have a regeneration limited effect.

23 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area.

Scoping Report - Heritage 11 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1.6 What decision-making criteria should make up the SA framework?

1.6.1 The Southeast Regional Sustainability Framework includes the objective:

“To protect and enhance the region’s countryside and historic environment”

1.6.2 It is suggested that this objective should be taken forward and applied to the Kent MWDF through this SA. It is suggested that, as well as being used as the basis for predicting and evaluating heritage impacts at the assessment stage, this objective will also be used to identify effects on the topic of ‘landscape’.

1.6.3 When appraising the effects of the plan in terms of this objective, the following sub-objective relating to heritage should also be taken into account:

• To protect important heritage assets and their settings, as well as take account of the value of the character of the wider historic environment

1.7 What further data is required?

• It will be useful for the Kent Historic Environment Record to be drawn upon to further highlight key sustainability issues that can be addressed through the MWDF

Scoping Report - Heritage 12 March 2010

Revision Schedule

Scoping Report - Housing March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Consultant Associate Technical Director Ian Brenkley Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Scott Wilson 6-8 Greencoat Place London SW1P 1PL Tel: +44 (0)20 7798 5000 T This document has been prepared in accordance with the scope of Scott Wilson's Fax: +44 (0)20 7798 5001 appointment with its client and is subject to the terms of that appointment. It is addressed to and for the sole and confidential use and reliance of Scott Wilson's client. Scott Wilson www.scottwilson.com accepts no liability for any use of this document other than by its client and only for the purposes for which it was prepared and provided. No person other than the client may copy (in whole or in part) use or rely on the contents of this document, without the prior written permission of the Company Secretary of Scott Wilson Ltd. Any advice, opinions, or recommendations within this document should be read and relied upon only in the context of the document as a whole. The contents of this document do not provide legal or tax advice or opinion.

Table of Contents

1 Housing...... 3 1.1 Introduction...... 3 1.2 Background...... 3 1.3 What’s the sustainability context?...... 4 1.4 What’s the current and (likely) future sustainability baseline? ...... 4 1.5 What are the key sustainability issues?...... 8 1.6 What decision-making criteria should make up the SA framework?...... 9 1.7 What further data is required? ...... 9

List of Tables

Table 1: The sub-county baseline ...... 8 Table 2: Key sustainability issues...... 8

List of Figures

Figure 1: Net Housing Completions in KCC Area 2000-08 ...... 5 Figure 2: Barriers to housing and services in Kent...... 6 Figure 3: Local authority boundaries in Kent ...... 6

Scoping Report - Housing 2 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1 Housing

1.1 Introduction

1.1.1 This is Topic Paper 7 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of housing; describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to housing and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 The South East is a high demand housing area that has to manage the needs arising from, and implications of, considerable levels of demographic change and economic growth. The latest sub-national population projections (2006-based), indicate that the number of new households in the South East will grow by an average of 39,000 per annum to 2031. As a result it is predicted that the population of the South East will have increased by 28% by 2031, compared to a 2006 base year. This is a faster rate of growth than is predicted for any other region.1

1.2.2 Historically, the supply of housing in the South East has not matched the demographic-based need / demand. Since 2003 the level of supply has begun to increase reaching nearly 34,600 in 2006/07, but this stills fall short of the demand. As a result, affordability of housing across the region has continued to worsen, (or at least this was the case up until the recent downturn in house-prices).2

1.2.3 For the South East, this indicates a need to focus on strategic solutions to addressing the need and demand for more housing, whilst also taking an innovative approach towards preventing, minimising and mitigating adverse impacts. Kent is fairly typical of the wider South East in terms of housing demand and supply issues. The implications of addressing these issues for the Kent MWDF are, broadly speaking, twofold. Firstly, both minerals workings and waste facilities represent land-uses that are not compatible with housing and so can limit the land available for housing, and vice-versa. However, that said, there is also a need to ensure that minerals workings and waste facilities are located in relatively close proximity to housing. Waste facilities should be located close to areas of high population density in order to ensure that waste is managed as close to source as possible, whilst the location of some minerals workings, as well as mineral importation points, may need to consider the location of housing growth as these are the areas where materials are often required for construction.

1 CLG (2009) Household projections to 2031 [online] available at: http://www.communities.gov.uk/publications/corporate/statistics/2031households0309 (accessed 03/09) 2 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09)

Scoping Report - Housing 3 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1.3 What’s the sustainability context?

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering housing in this SA. This context review meets a requirement of the SEA Directive.3

1.3.2 The Government’s key housing policy goal is to ensure that everyone has the opportunity of living in a decent home, which they can afford, in a community where they want to live. Government guidance seeks to deliver on the commitment to improving the affordability and supply of housing in all communities by a step-change in housing delivery, achieved through a more responsive approach to land supply at local level. The guidance also states that 60% of new housing should be on previously developed land and seeks to ensure that the planning system delivers:4

• High quality housing that is well-designed and built to a high standard; • A mix of housing, both market and affordable, particularly in terms of tenure and price, to support a wide variety of households in all areas, both urban and rural; • A sufficient quantity of housing taking into account need and demand and seeking to improve choice; • Housing developments in suitable locations, which offer a good range of community facilities and with good access to jobs, key services and infrastructure; and • A flexible, responsive and efficient supply of land.

1.3.3 The Regional Spatial Strategy (RSS)5 identifies that the scale of demand and need for housing in the region, together with the importance of the South East to the national economy and its interrelationship with London necessitate that the RSS sets out a housing provision that makes a sufficient response to these strategic needs. The RSS has gone some way towards this goal but at 32,700 dwellings per year for the South East, the level that is set is still significantly below the forecast growth in households.

1.3.4 At the time of writing the latest revision of the RSS (early summer 2008) it was felt that short term changes to market conditions would not have the effect of helping alleviate worsening housing affordability in the longer term. Indeed, the RSS acknowledged that housing levels significantly higher than the level of housing provision set in the Policy H1 should be aspired to.6

1.4 What’s the current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to housing in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the

3 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes. 4 Communities and Local Government (2006). Planning Policy Statement 3: Housing [online] available at: http://www.communities.gov.uk/documents/planningandbuilding/pdf/planningpolicystatement3.pdf (accessed 02/09). 5 GOSE (2009). The Final South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/10) 6 The NHPAU has recently advised the Government on a range of housing targets for each region (“Meeting the Housing Requirements of an Aspiring and Growing Nation” June 2008).

Scoping Report - Housing 4 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

situation in Kent to other geographical areas, as well as considering how the baseline varies at the sub-county scale, within three sub-regional areas defined in Kent by the RSS. This section meets a key requirement of the SEA Directive.7

Current baseline

1.4.2 Housing supply in the South East has been lagging behind the rate at which new households are forming, leading to worsening affordability. Between 2001 and 2006 the building of around 28,800 net additional dwellings per year contributed less than 1% per year to the existing stock. Numbers of vacant houses are relatively low, at around 2.3% of total stock - the lowest of any English region, meaning that the existing housing stock is already tight and cannot absorb the need for additional homes. In the South East about 208,4008 households remain on Local Authority Housing waiting lists, with 7,680 homeless households listed as being in temporary accommodation. In the meantime, there has been a 70% increase in average house prices, an 88% increase in lower quartile house prices, and a nearly 30% increase in the average deposit of first time buyers. In the South East the ratio between lower quartile house prices and lower quartile incomes in 2007 was 8.9, compared to 5.8 in 2001.9

1.4.3 The number of net additional dwellings completed in 2007/08 in Kent was 7,41410 - the highest number of units completed in almost 20 years. Average net completion rates have been above 6,000 dwellings per annum since 2004/5 but were only 4,150 net additional dwellings in 2000/01 (see Figure 1).

Figure 1: Net Housing Completions in KCC Area 2000-081

7 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected” 8 South East England Regional Assembly (2007) Regional Monitoring Report, Chapter 05 Housing [online] available at: http://www.southeast-ra.gov.uk/documents/monitoring_success/2007/rmr_2007_C5.pdf (accessed 05/09) 9 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09) 10 KCC (2008) Kent – KCC Area Housing Information Audit 2007/2008 [online] available at: http://www.kent.gov.uk/NR/rdonlyres/1EEFDC9A-6D06-421B-BCE0-DC77C8F5D778/0/hia2008kentkccadoptedkmspreport.pdf (accessed 05/09).

Scoping Report - Housing 5 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1.4.4 Deprivation related to barriers to housing and services, as measured by the Index of Multiple Deprivation 2007, is concentrated in rural areas. This is partially related to the distance people live from services in rural areas, but also because of difficulty people in rural areas have entering owner-occupation. Many residents of rural Kent are being out-priced by town-dwellers looking to move to the country or city workers buying rural properties in Kent as second homes. Nearly all of the areas in Kent’s top 20% deprived are also within England’s top 20% deprived, as shown by the similarity between Figures 2a and 2b. 21.6% of Kent Lower Super Output Areas (the geographical units used as the basis for Figure 2) are within England’s top 20% most deprived, which is more than is the case for any other type of deprivation. This indicates that barriers to housing and services is a major issue in Kent.

Figure 2: Barriers to housing and services in Kent

Future baseline

1.4.5 The RSS allocates housing to each local authority in Kent. Figure 3 shows the local authority boundaries.

Figure 3: Local authority boundaries in Kent

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1.4.6 The 2009 Plan requires that, between 2006 and 2026, 56,700 houses are delivered in Ashford and East Kent, 52,140 houses in the Kent Thames Gateway and 28,880 in the rest of Kent. More specifically, it allocates the following minimum housing delivery requirement to each of the local authorities in Kent:

• Ashford – 22,700 • Canterbury – 10,200 • Dartford – 17,340 • Dover – 10,100 • Gravesham – 9,300 • Maidstone – 11,080 • Medway (Unitary Authority) – 16,300 • Sevenoaks – 3,300 • Shepway – 5,800 • Swale – 10,800 • Thanet – 7,500 • Tonbridge and Malling – 9,000 • Tunbridge Wells – 6,000

Current and future situation in sub-county areas

1.4.7 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These sub-areas were identified primarily on economic grounds.11 Policies are developed in the RSS for two of these areas to meet the following overarching objectives, which also have clear implications for housing:

• East Kent and Ashford – regeneration (East Kent) and growth area (Ashford) • Kent Thames Gateway – growth and regeneration

1.4.8 Table 1 considers current and possible future baseline conditions in each of these sub-areas.

11 See a further discussion of the process of identifying sub-areas in the Economy and Employment Topic Paper

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Table 1: The sub-county baseline

East Kent and Ashford12 The Core Strategy for this sub-area set out in the South East Plan (2008) promotes the provision of new housing at the main urban areas throughout East Kent, particularly through urban expansions, and seeks to support growth and a broad balance between jobs and housing. This applies particularly to Ashford where the strategy considerably increases the rate of house building. Furthermore, Dover was identified as a national Growth Point in the Housing Green Paper 2007. The RSS identifies that a key challenge is delivering a sufficient supply of housing to meet the needs of the future population and support its economic regeneration and growth. Locations served by domestic services on the Channel Tunnel Rail Link (CTRL) will increase their attraction for commercial and residential development, particularly at Ashford, Dover and Ramsgate. Folkestone and Canterbury will also benefit. Dover was identified as a National Growth Point in the second round of designations in 2008. Kent Thames Gateway13 The RSS identifies that a key challenge is to deliver sufficient numbers and a well integrated mix of decent homes to meet the needs of the future population of this major Growth Area and support its economic regeneration and growth. The RSS identifies that a key aim in this area must be to focus development at the urban areas and protect and enhancing the heritage and natural environment. Locations served by domestic services on the Channel Tunnel Rail Link (CTRL) will increase their attraction for commercial and residential development, particularly at Ebbsfleet. Concentrations of new dwellings, employment and services will be at major regeneration locations, particularly: • at Thameside, notably at the strategic sites of Eastern Quarry, North Dartford, Ebbsfleet and the Thames riverside; and • new development will also be directed so as to revitalise Sittingbourne/Sheppey in Swale, where some greenfield land has also been released.

Rest of Kent14 Maidstone is identified in the RSS as a New Growth Point and given ‘hub’ status. Tonbridge and Tunbridge Wells are also assigned hub status.

1.5 What are the key sustainability issues?

1.5.1 Table 2 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 2: Key sustainability issues

Key Issue Discussion

Large numbers of A step-change in housing delivery is being planned for, particularly in East Kent houses are and Ashford, and the Kent Thames Gateway. The key challenges that this allocated to be built presents for the Kent MWDF are to ensure that minerals and waste development in the county does not act as a constraint to housing, and also the necessary aggregates are available for building, and that the necessary waste infrastructure is in place.

12 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 13 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2. 14 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area.

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1.6 What decision-making criteria should make up the SA framework?

1.6.1 The Southeast Regional Sustainability Framework includes the objective:

“To ensure that everyone has the opportunity to live in a decent, sustainably constructed and affordable home suitable to their need”

1.6.2 It is helpful to take account of established regional sustainability objectives. However, bearing in mind the scope of influence of the Kent MWDF it is thought that there is a need to tailor this objective, so that it is most suited to capturing the likely significant effects of the plan. Taking account of the key sustainability issues identified in Section 1.5 above, it is thought that the most appropriate sustainability objective for use in this SA is:

Ensure that the delivery of housing targets is supported

1.6.3 When appraising the effects of the plan in terms of this objective, the following sub-objectives should also be taken into account:

• Ensure that minerals and waste development does not act as a constraint to housing • Ensure that the necessary aggregates are available for building, and that the necessary waste infrastructure is in place

1.7 What further data is required?

• Predictions of the minerals resources that are likely to be required to meet house- building targets in the south east

Scoping Report - Housing 9 March 2010

Revision Schedule

Scoping Report – Land and Geology March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Consultant Associate Technical Director Ian Brenkley Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Table of Contents

1 Land and Geology...... 3 1.1 Introduction...... 3 1.2 Background...... 3 1.3 What’s the sustainability context?...... 3 1.4 What’s the current and (likely) future sustainability baseline? ...... 5 1.5 What are the key sustainability issues?...... 12 1.6 What decision-making criteria should make up the SA framework?...... 12 1.7 What further data is required? ...... 13

List of Tables

Table 1: The sub-county baseline ...... 11 Table 2: Key sustainability issues...... 12

List of Figures

Figure 1: Provisional agricultural land classification ...... 6 Figure 2: Soilscape...... 6 Figure 3: Digital elevation model ...... 6 Figure 4: Nationally important SSSI geological sites in Kent...... 7 Figure 5: Regionally Important Geological Sites (RIGS) in Kent ...... 7 Figure 6: Bedrock geology in Kent ...... 7 Figure 7: Extent of Green Belt in the South East...... 8 Figure 8: Amounts by region by type of previously-developed land ...... 9 Figure 9: Regional distribution of PDL in the South East...... 10 Figure 10: Kent housing completions on PDL and greenfield land...... 10

Scoping Report – Land and Geology 2 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

1 Land and Geology

1.1 Introduction

1.1.1 This is Topic Paper 8 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of land and geology, describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to land and geology and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 The Kent MWDF must seek to make efficient use of resources and to protect existing resources from all forms of degradation. This topic paper recognises that both minerals and waste development can be relatively ‘land hungry’, both as a result of direct land-take, and also the sterilisation of land, and, as a result, specifically considers issues relating to land as a natural resource. Furthermore, in addition to impacts on the quantity and quality of land available for other uses, waste and, in particular, minerals development can impact upon the geological resource, which, in places, can be highly valued. Related to this are impacts on the coastal environment, which will also be considered within this topic paper. Of course, another key resource that must be protected through the Kent MWDF is the county’s mineral resource, and as such implications for the minerals resource are considered in a separate, stand-alone topic paper.

1.3 What’s the sustainability context?

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering land and geology in this SA. This context review meets a requirement of the SEA Directive.1

1.3.2 Government guidance on minerals planning2 identifies impacts relating to ‘nationally protected geological and geomorphological features’ as a ‘principal environmental impact’ of minerals working.3 Guidance promotes efficient use of land and also emphasises the opportunities that exist for after uses of mineral workings, including the achievement of targets set out in the UK Geodiversity Action Plans. Guidance also refers to protecting the coastal environment from increased erosion or vulnerability to flooding. This message is echoed in guidance relating specifically to Coastal Planning, which also notes that in most circumstances the minerals

1 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes. 2 CLG (2006). Minerals Planning Statement 1: Planning and Minerals [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/mineralspolicystatement5 (accessed 02/09) 3 Note that ‘land instability’ is also identified as ‘principle environmental impacts’ of minerals working in MPS1, however, these issues have been scoped out of requiring explicit consideration through this sustainability appraisal as a result of being site specific, rather than strategic.

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planning issues at the coast are similar to those inland.4 The Regional Spatial Strategy (RSS)5 identifies ‘the maintenance of the coastline as an environmental, economic and recreational resource at the same time as responding to climate change pressures and rising sea levels’ as a key environmental challenge for the South East. Policy NRM8 promotes an integrated approach to the management and planning of coastal areas, taking account of the dynamic nature and character of the coast and the need for collaboration between organisations. The Policy promotes an approach that does not prejudice other uses and functions in the coastal area.

1.3.3 Government guidance on planning for waste management recognises the need to protect green belts, but also recognises that the particular locational needs of some types of waste management facilities may be suited to Green Belt locations.6 Policy W17 states that waste management facilities should not be precluded from the Green Belt.

1.3.4 Policy SP5 of the RSS states that the existing broad extent of Green Belts in the region is appropriate and will be retained and supported and the opportunity should be taken to improve their land-use management and access as part of initiatives to improve the rural urban fringe. The RSS reaffirms the need to maintain the five functions of Green Belt set out in national guidance, i.e.7

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

1.3.5 Policy LF10 promotes specific initiatives to manage the Green Belt countryside as a multifunctional resource. This Policy applies only to the area of North West Kent around Sevenoaks, but it is felt that it has implications for other areas of Kent with Metropolitan Green Belt. It refers to the Green Arc (South West) initiative, which is a partnership designed to secure greater investment in landscape enhancement, improved access and conservation across a crucial part of the Metropolitan Green Belt. This area of the Green Arc is outside of Kent (primarily in Surrey), but there is also a ‘South East London and Kent’ Green Arc initiative.

4 Government (1992). Planning Policy Guidance 20: Planning and Coastal Areas [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/planningpolicyguidance13 (accessed 02/09) 5 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09) 6 ODPM (2005). Planning Policy Statement 10: Planning for Sustainable Waste Management [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/planningpolicystatement10 (accessed 02/09) 7 Government (1995). Planning Policy Guidance 2: Green Belts [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/ppg2 (accessed 02/09)

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1.3.6 Government waste planning guidance also promotes the re-use of previously-developed land, and redundant buildings where possible and also identifies ‘land stability’ as a key locational criterion. Government guidance on biodiversity and geological conservation sets out the objective of taking a strategic approach to the conservation, enhancement and restoration of geology through the form and location of development.8 Finally, Government guidance on sustainable development in rural areas indicates that high quality agricultural land should where possible be protected from irreversible damage.9

1.3.7 In relation to soils, the European Commission adopted a Thematic Strategy for Soil in 2006 as required under the Sixth Environment Action Programme. The overall objective is the protection, sustainable use and (where necessary) restoration of soil, with a focus on maintaining the full range of soil functions. The First Soil Action Plan for England (2004-2006) takes this further by setting out the objective of maintaining the quantity, diversity and quality of the nation’s soils. A draft Soil Strategy for England was prepared and issued for consultation in March 2008, and will succeed the First Soil Action Plan for England.

1.4 What’s the current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to land and geology in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent to other that of other geographical comparators, as well as considering how the baseline varies at the sub-county scale, within three sub-regional areas defined in Kent by the South East Plan. This section meets a key requirement of the SEA Directive.10

Current baseline

1.4.2 Figure 1 shows the provisional agricultural land classification map of Kent, whilst Figures 2 and 3 give further context to this important information, by showing the county the ‘soilscape’ and digital elevation model.

8 ODPM (2005). Planning Policy Statement 9: Biodiversity and Geological Conservation [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/pps9 (accessed 02/09) 9 ODPM (2004). Planning Policy Statement 7: Planning and Rural Areas [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/pps7 (accessed 02/09) 10 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected”

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Figure 1: Provisional agricultural land classification11

Figure 2: Soilscape12

Figure 3: Digital elevation model13

11 Kent Landscape Information System [online] available at: http://extranet7.kent.gov.uk/klis/default.asp (accessed 02/09) 12 Ibid. 13 Ibid.

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1.4.3 Figures 4 and 5 show the spatial distribution of important geological sites in Kent. It would seem that there may be a high density associated with the Wealden Greensand bedrock in the vicinity of Maidstone, to the south of the chalk downs. Figure 6 gives an overview of Kent’s geology. Also relating to geology, it is important to note that major landslips are common along inland escarpments and parts of the coast. A large slip can be observed at Folkestone Warren, where massive chalk has slipped on underlying Gault Clay. Here twelve major landslips have occurred since 1765, the most notable being in 1915 when the coastal railway line was displaced.14

Figure 4: Nationally important SSSI geological Figure 5: Regionally Important Geological Sites sites in Kent15 (RIGS) in Kent16

Figure 6: Bedrock geology in Kent17

14 Natural England [online] available at: http://www.english-nature.org.uk/Special/geological/sites/area_ID19.asp (accessed 03/09) 15 Kent Regionally Important Geological Sites Group [online] available at: http://www.kentrigs.org.uk/index.html (accessed 03/09) 16 Ibid. 17 Kent Geologists Group [online] available at: http://www.kgg.org.uk/kentgeo.html (accessed 03/09)

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1.4.4 It is also important to take account of the sensitive and dynamic nature of Kent’s long and diverse coastline, particularly the areas of soft coastline (cliff and estuarine). Natural geomorphological activity at such locations is complicated by the fact that Kent is experiencing sea level rise as a result of a combination of isostatic readjustment, subsidence of the coast, and climate change. The annual sea level rise in southern England is approximately 6mm, of which 4.5mm is attributed to climate change. This has significantly increased the risk of coastal flooding, and it is thought that approximately 10% of Kent’s population is now at risk. Significant amount of money is, therefore, invested annually for coastal defence (£18 million in 2003/04). The Kent coast is covered by two Shoreline Management Plans and eight coastal strategies.18

1.4.5 The Green Belt can also be considered as a spatial constraint because it represents a spatial extent of land that should be kept open in order to achieve the purposes of Green Belt set out in PPG2. Figure 7 shows that Green Belt comprises the majority of Sevenoaks, Tonbridge and Malling and Gravesham Districts, as well as a proportion of Tunbridge Wells and Dartford Districts.

Figure 7: Extent of Green Belt in the South East

18 Kent Coastal Network, Kent Coastal Fact Sheets-Ports [online] available at: http://www.coastalkent.net/facts.php (accessed February 2009)

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1.4.6 As well as avoiding unnecessary sterilisation of the best and most versatile agricultural land, there is also a need to make use of previously developed land (PDL) wherever possible. Figure 8 shows that, in the South East, the majority of PDL is currently in use with planning permission for redevelopment.

Figure 8: Amounts by region by type of previously-developed land19

1.4.7 Figure 9 shows PDL in the South East. It can be seen that the majority of PDL is concentrated in the western half of Kent, although in East Kent there are concentrations associated with the coastal towns and Canterbury, as well as several former minerals workings to the west of Deal. The greatest concentrations of PDL are:

• To the north of the North downs, around Gillingham and Sittingbourne (former residential, commercial and industrial); • To the south of the North Downs around Maidstone (former residential, commercial and industrial); • The northern shore of the Isle of Sheppey (mainly former residential); • The Dartford area (including land and buildings that remain vacant); and • The High Weald around Tunbridge Wells (mainly former residential).

19 DCLG (2008). Previously-developed land that may be available for development: England 2007 [online] available at: http://www.communities.gov.uk/documents/corporate/pdf/945914.pdf (accessed 03/09).

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Figure 9: Regional distribution of PDL in the South East 20.

1.4.8 Figure 10 shows that the percentage of housing completions on previously developed land in Kent has increased considerably in recent years.

Figure 10: Kent housing completions on PDL and greenfield land21

20 English Partnerships and Office of the Deputy Prime Minister (2004) The National Land Use Database of Previously Developed Land (NLUD – PDL) – 2004 National and South East Regional Summary [online] available at http://www.nlud.org.uk/draft_one/key_docs/pdf/reg_summ_sm/South%20East%20Regional%20Report.pdf (accessed 02/09) 21 KCC (2008) Kent Housing Completions 1996/07 by Greenfield & Previously Developed Land as a % [online] available at: http://www.kent.gov.uk/NR/rdonlyres/2F379FCA-BF35-435F-8347-0074850C0324/12442/kentdistrictspdlandgrncompletions.pdf (accessed February 2009)

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Future baseline

1.4.9 There is a clear trend in relation to development on brownfield land, and it is important to consider how this trend will continue into the future. It is likely that in some parts of the county the resource of previously developed land will become increasingly scarce in coming years, although this is less likely to be the case in the Thames Gateway, where the industrial legacy has left more extensive areas of PDL, much of which requires decontamination prior to re-use.

1.4.10 There could also be policy developments that influence the degree to which high quality agricultural land and Green Belt act as locational constraints to development. Policy SP5 of the RSS identifies that the existing broad extent of Green Belts in the region is appropriate, but that selective reviews of Green Belt boundaries are required north east of Guildford and possibly to the south of Woking, and to the south of Oxford. The Policy also states that smaller scale local reviews are likely to be required in other locations and should occur through the current Local Development Framework processes, so that no further reviews are required to at least 2031. In terms of agricultural land, there are no plans by Government to increase the value that agricultural land is given compared to alternative land-uses, but it must be considered that this could be a possibility in the future in order to meet objectives of national food self-sufficiency.

Current and future situation in sub-county areas

1.4.11 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These areas were identified primarily on economic grounds, but provide a useful spatial framework to consider other elements of the sustainability baseline. Table 1 considers current and possible future baseline conditions in each of these sub-areas.

Table 1: The sub-county baseline

East Kent and Ashford22 The health of the coastal environment is an important spatial consideration in this area. Policy EKA7 of the RSS promotes the coordinated development, management and use of the coastal zone including consideration of valuable habitats and environments (natural and built), the development and management of public access, recreation and tourism potential, and identification and management of development and commercial opportunities. This will be within the context of flood protection management and coastal defence measures contained in Catchment Management Plans, Shoreline Management Plans and Coastal Defence Strategies. A particular focus will be given to the catchment of the Lower Stour for the extension and creation of wetland and other habitats, and for improved access for visitors. There are extensive areas of high quality agricultural land associated with the North Kent Plains Landscape Character Area, to the north of the Kent Downs. Kent Thames Gateway23 In the Kent Thames Gateway sub-county area Policy KTG1 states that there is a need to make full use of previously developed land before greenfield sites. The Policy also states that there is a need to protect from development the Metropolitan Green Belt and the AONB. In the Thames Gateway there are areas of high quality agricultural land, but also areas where the quality is poor.

22 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 23 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2.

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Rest of Kent24 A considerable part of the north west of this area lies within the Metropolitan Green Belt. There are extensive areas of good quality agricultural land.

1.5 What are the key sustainability issues?

1.5.1 Table 2 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 2: Key sustainability issues

Key Issue Discussion

Make effective use It will be important to make use of previously developed land in preference to of previously greenfield sites where possible. However, it is also important to recognise that developed land this is a dwindling resource, and that there may be alternative uses that must be considered, including housing and nature conservation / green infrastructure.

Avoid the loss of the The loss of agricultural land is not currently promoted through policy as an county’s best and absolute constraint on development, but must be a material consideration most versatile nonetheless. agricultural land

Avoid development The sensitivity at the coastline varies considerably, and there is also a need to that would conflict take account of the uncertainty that climate change creates, in terms of with coastal understanding future coastal environments. geomorphology.

1.6 What decision-making criteria should make up the SA framework?

1.6.1 The Southeast Regional Sustainability Framework includes the objective:

“To improve efficiency in land use through the appropriate re-use of previously developed land and existing buildings, including re-use of materials from buildings, and encourage urban renaissance” “To protect and enhance the region’s countryside and historic environment”

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Make efficient use of land and avoid sensitive locations

1.6.3 When appraising the effects of the plan in terms of this objective, the following sub-objectives relating to land and geology should also be taken into account:

• Make best use of previously developed land • Avoid locations with sensitive geomorphology

1.7 What further data is required?

• Contaminated land data

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Revision Schedule

Scoping Report - Landscape March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Consultant Associate Technical Director Ian Brenkley Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Table of Contents

1 Landscape ...... 3 1.1 Introduction...... 3 1.2 Background...... 3 1.3 What’s the Sustainability Context? ...... 4 1.4 What’s the current and (likely) future sustainability baseline? ...... 5 1.5 What are the key sustainability issues?...... 17 1.6 What decision-making criteria should make up the SA framework?...... 17 1.7 What further data is required? ...... 18

List of Tables

Table 1: Key characteristics of Joint Character Areas in Kent ...... 8 Table 2: The sub-county baseline ...... 16 Table 3: Key sustainability issues...... 17

List of Figures

Figure 1: Joint Character Areas in Kent (and the wider South East)...... 7 Figure 2: ‘Finer scale’ character areas in Kent ...... 12 Figure 3: Magnitude and direction of landscape change 1999 - 2003...... 13 Figure 4: Long-term landscape change: analysis of 1990-1998 and 1999-2003 assessments.... 14 Figure 5: Tranquillity in Kent...... 15

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1 Landscape

1.1 Introduction

1.1.1 This is Topic Paper 9 of 14 and is a component of the Scoping Report for the the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of landscape; describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to landscape and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 Landscape is more than just a visual backdrop; it is a framework within which we can better understand the links between environmental and socio-economic systems, and is an invaluable natural economic and cultural resource that helps us define our sense place and who we are. A short but comprehensive description of landscape is:

“an area, as perceived by people, whose character is the result of action and interaction of natural and/or human factors.” 1

1.2.2 Nationally, the most valued landscapes might be found in the countryside, where semi-natural landscapes result from a long interaction of natural and socio-economic factors. However, landscape is a subjective concept that can be used in different situations and at a range of scales.

1.2.3 Healthy landscapes are crucial to providing high quality ecosystem services. Poor natural environments are characterised by simplified land use, lack of diversity (from habitats and species, to culture and local identity) and fragmented, incoherent patches semi-natural habitats. Increasingly, it is recognised that to allow natural and semi-natural systems to function fully and remain resilient to environmental change we need to plan more at a “landscape scale”. In practice, many of the principles of landscape-scale planning, or at least conservation, are already established in the uplands and on the coast. However, in many parts of lowland England, that is not true. As well as being ecologically less resilient, a landscape of disconnected fragments is also less likely to be valued by people as it lacks the aesthetic appeal, opportunities for recreation and historical and other features linked to a sense of local identity.2

1 European Union (2000). The European Landscape Convention [online] available at: http://www.coe.int/t/dg4/cultureheritage/Conventions/Landscape/florence_en.asp#TopOfPage (accessed 02/09). 2 Adapted from Natural England (2008). State of the Natural Environment 2008 [online] available at: http://www.naturalengland.org.uk/publications/sone/default.aspx (accessed 02/09)

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1.3 What’s the Sustainability Context?

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering landscape in this SA. This context review meets a requirement of the SEA Directive.3

1.3.2 In 2006, the UK ratified the European Landscape Convention (ELC), which aims to encourage public authorities to adopt policies and measures at local, regional, national and international level for protecting, managing and planning landscapes throughout Europe.4 It covers all landscapes, from the outstanding to the ordinary, that determine the quality of people’s living environment. The text provides for a flexible approach to landscapes whose specific features call for various types of action, ranging from strict conservation through protection, management and improvement to actual creation. According to Natural England: 5

“The ELC argues that the protection, management and planning of all landscapes in Europe is a task, not just for governments, but for all sectors of civil society, entailing rights and responsibilities for everyone. It promotes understanding of and a commitment to use landscape as a spatial framework to aid decision making, and recognition that the importance, qualities and functions of all landscapes needs to be further embedded in policies and the working practices of Government and other organisations.”

1.3.3 Natural England is leading on the implementation of the ELC in England, and has recently published a draft policy document on landscape, which states that::6

“Our response to the changes facing English landscapes will need to consider both their landscape character and the ecosystem goods and services they provide. This will increasingly require a multi-functional approach to landscape management. Putting [these] principle[s] into practice will therefore require a much better understanding of the diverse ways in which different landscapes matter, as well as to whom they matter.”

1.3.4 Government guidance on minerals planning identifies impacts relating to landscape character and visual intrusion into the local setting and the wider landscape as two potential ‘principle environmental impacts’ of minerals working.7 The concept of defining the value of local landscape character had already been established in earlier government guidance.8 Further information is available within local landscape character assessments (LCAs).

1.3.5 Policy C4 of the Regional Spatial Strategy (RSS)9 relates to landscape and countryside management. Outside nationally designated landscapes, positive and high quality management of the region’s open countryside is promoted, with a focus on enhancing diversity and local distinctiveness, informed by landscape character assessment. Positive land management is particularly needed around the edge of London and in other areas subject to most growth and change. Furthermore, Policy C5 relates to managing the rural-urban fringe,

3 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes. 4 European Union (2000). The European Landscape Convention [online] available at: http://www.coe.int/t/dg4/cultureheritage/Conventions/Landscape/florence_en.asp#TopOfPage (accessed 02/09). 5 Natural England (2009) All landscapes matter: draft policy for consultation [online] available at: http://www.naturalengland.org.uk/Images/alllandscapesmatter_tcm6-8361.pdf (accessed 02/09) 6 Ibid. 7 CLG (2006). Minerals Planning Statement 1: Planning and Minerals [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/mineralspolicystatement5 (accessed 02/09) 8 ODPM (2005). Planning Policy Statement 1: Delivering Sustainable Development [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/planningpolicystatement1 (accessed 02/09). 9 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09)

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emphasising the importance of multifunctional landscapes. The RSS also identifies maintaining tranquil areas as a key environmental challenge facing the region.

1.3.6 Finally, the Kent Downs and High Weald Areas of Outstanding Natural Beauty (AONB) Management Plans set out policy relating to the protection and conservation of the Kent Downs and the High Weald respectively. The management plans seek to prevent inappropriate development and promote good design integrated with the AONB’s special character where development is acceptable. In relation to minerals the RSS states that only in exceptional circumstances would extraction or processing be permitted in locations of special landscape importance such as the AONBs, or internationally or nationally designated areas of nature conservation importance.

1.4 What’s the current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to landscape in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent other areas, as well as considering how the baseline varies at the sub-county scale, within three sub-regional areas defined in Kent by the RSS. This section meets a key requirement of the SEA Directive.10

Current baseline

1.4.2 In relation to landscape, the Regional State of the Natural Environment Report identifies that the South East has:11

• more Areas of Outstanding Natural Beauty than any other region (33%); • some of Englands finest landscapes, but that these are diverging from their valued character or suffering from management neglect; and • the highest number of commons in England at 22% of the total – a significant cultural heritage;

1.4.3 The Kent Downs AONB consists of the eastern half of the North Downs covering nearly a quarter of Kent, stretching from the white cliffs at Dover up to the Surrey and London borders. In addition, the highest areas of the Greensand ridge in Kent, together with a spit of ragstone escarpment above the Romney Marsh, are also within the Kent Downs. It is a landscape dramatic chalk escarpments, secluded dry valleys, ancient woodlands and traditional orchards. The area has networks of tiny lanes, historic hedgerows, locally distinctive villages and many sites of historic and cultural interest to explore.

1.4.4 The High Weald AONB is an historical countryside of rolling hills draped by small, irregular fields, abundant woods and hedges, scattered farmsteads and sunken lanes. Other features incluse flower-rich meadow, patches of heathland, hop gardens, orchards, sandstone outcrops,

10 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected” 11 Natural England (2008). State of the Natural Environment 2008 [online] available at: http://www.naturalengland.org.uk/publications/sone/default.aspx (accessed 02/09)

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steep wooded ravines (called gills) with their secret streams, and 'hammer' ponds; remnants of the Wealden iron industry. The word 'weald' means wilderness or forest: the High Weald was once an untamed, wooded area, with patches of wild grassland and heathland. By Domesday (1086) the High Weald remained the most densely wooded area of England and now boasts the highest proportion of ancient woodland in the country.

1.4.5 However, rather than being limited to just the best and most beautiful areas, it is increasingly understood that a consideration of landscape must seek to value and appreciate the diversity of all landscapes. Before the value of landscapes can be evaluated they first have to be characterised. In the 1990s the country was divided into 159 ‘Joint Character Areas’ (JCAs). Character was defined as a particular combination of physical influences (geology, topography, soils) with cultural and historical influences. Seven Joint Character Areas (JCAs) have been identified in Kent. These are shown in Figure 1, which also depicts the boundaries of the sub- regional areas defined within the RSS. The fact that, in Kent, the boundaries of Joint Character Areas and sub-regional policy areas show no correlation (with the exception of the Kent Thames Gateway) demonstrates that landscape is no longer the overriding factor determining spatial issues and priorities as it might have been in the distant past. Rather, taking the example of East Kent, it is clear that the spatial framework for policy has been determined taking more account of the ‘city region’ model (i.e. identifying those towns and their surrounding hinterlands that require regeneration as a result of economic isolation from London). However, the value of landscape as a spatial framework for planning should not be underestimated. For example, within East Kent, it will be important to consider how spatial constraints, opportunities and priorities vary from north to south, between the different character areas.

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Figure 1: Joint Character Areas in Kent (and the wider South East)

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1.4.6 Table 1 summarises some of the key characteristics of each of the seven JCAs.

Table 1: Key characteristics of Joint Character Areas in Kent12

Greater Thames Estuary

• Extensive open spaces dominated by the sky within a predominantly flat, low-lying landscape. The pervasive presence of water extends inland. • Strong feeling of remoteness and wilderness persists on the salt marshes, grazing marsh & mudflats. • Open grazing pastures patterned by a network of ancient and modern reed-fringed drainage ditches and dykes, numerous creeks with few hedges or fences. • Modern day pattern of local parishes reflects the historical layout of settlements, surrounded by farmland on the higher ground inland. • Various major developments including ports, waste disposal, marine dredging, urbanisation, mineral extraction and numerous other industry-related activities. • Contrast and variety within the Estuary is provided by Sheppey. The higher ground between Sheerness, Minster and Leysdown on the north of the island is a dense urban area with caravans, huts and bungalows at the eastern end. The rest of the landscape is predominantly inaccessible grazing marsh. Trees are rarities marking the location of isolated churches and farmsteads on pockets of higher land.

North Kent Plain

• An open, low and gently undulating landscape characterised by high-quality, fertile, loamy soils dominated by agricultural land uses with sparse or absent trees and hedges. • Orchards and horticultural crops to the east predominate and are enclosed by poplar or alder shelter belts and scattered small woodlands. • Extensive areas of grazing marsh and reed beds. • Discrete but significant area of woodland on the higher ground around Blean to the North of Canterbury. Blean supports the largest area of continuous woodland in Kent, with ancient trees found amongst enclosed pasture and arable fields. • Dispersed settlement pattern surrounded by a dense network of narrow lanes is typical. • Settlement growth and urbanisation have been primary influences which have markedly changed the local landscape character. Urbanisation and large settlements are often visually dominant. • Canterbury is a settlement of significant historical interest and medieval prosperity is also reflected in small market towns such as Wingham and Fordwich. • Geologically, an outlier of the Chalk and, historically, an island separated from the mainland by a sea channel, Thanet forms a discrete and distinct area that is characterised by its unity of land use arising from the high quality fertile soils developed over chalk. Much of the coastline of Thanet is heavily

12 Natural England [online] available at: http://p1.countryside.gov.uk/LAR/Landscape/CC/SEL/index.asp (accessed 03/09)

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developed with tall buildings and structures evident in the open farmed landscape. • Underlying the area at great depth are Coal Measures, evident through former colliery sites, spoil heaps and colliery villages which are a locally unique. • The North Kent Plain is a major communications corridor,

The North Downs

• Dramatic and distinctive Chalk downland with a continuous and steep scarp giving extensive views across Kent and Surrey. The broad dip slope gradually drops north and east. • Land use includes pockets of traditional downland grazing and ridgetop woodlands, but the south- eastern end of the Downs becomes increasingly open and intensively farmed as it widens before ending abruptly at the distinctive chalk cliffs of Dover. • In the east, the lower dip-slope is characterised by high quality, fertile, loamy soils that support extensive tracts of cereals, root and other horticultural crops. • The North Downs are a rural landscape with scattered flint-walled farmhouses and large houses. Towards London the character becomes more urban influenced. • Lanes follow the lines of old drove roads in many places.

Wealden Greensand

• Large belt of Greensand typified by its scarp/dip-slope topography and extensive woodland patches. In Kent the dramatic wooded topography is less evident and the Greensand becomes less distinctive. • Although sunken lanes and hidden valleys are a feature of the area around Sevenoaks and Maidstone, the landscape here, being less wooded, does not give such an impression of intimacy as the greensand outside of Kent, unless contained by remaining hedgerows and shelterbelts. • The area is also more marked by modern human influence with major towns such as Maidstone, Sevenoaks and Ashford and numerous communication routes. Notable among the latter are the M25 and M26 near Sevenoaks and the M20 and rail lines around Ashford which follow the vale below the North Downs scarp. • Generally the Kent Wealden Greensand in the east has a sandy and heathy feel and the landscape is relatively more open with mixed farming. The central area of the belt near the Medway, where lighter loams occur, is a major fruit growing area with orchards and associated windbreaks, plus chestnut coppice for hop poles. Hop growing is particularly common around Maidstone. Further east, however, both orchards and hops are being replaced by arable fields. • At its south eastern extreme the Greensand forms a notable scarp, formally a sea cliff, giving extensive views over Romney Marshes. Panoramic views across the Low Weald are frequent and extensive from the Greensand ridge above the scarp face.

Low Weald

• The Low Weald is a broad low-lying clay vale which runs around three sides of the High Weald

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through Kent, Sussex and Surrey, bounded for much of its length by the Wealden Greensand. • The heavy clay soils are notoriously difficult to cultivate so that permanent pasture is the main farming use. Settlements and arable farming is associated with lighter soils on higher ground. • Hop growing and orchards are still a distinctive land use in the east. • Low Weald generally includes an abundance of ponds, stream valleys and wet woodlands. • The well-wooded character restricts views and parts of the Low Weald feel quite remote for Kent. • Rural in character with dispersed farmsteads. Small settlements often include mainly timber and brick- built traditional buildings where not now dominated by recent urban development. • The Kentish Low Weald is traversed by numerous narrow lanes with broad verges and ditches; these are continuous with the drove roads of the North Downs.

Romney Marsh

• A flat, open and agricultural landscape, with distinctive drainage dykes, marshes and open skies. • A high-quality agricultural land of extensive arable fields and some traditional open wet pasture land. • Narrow, straight roads and widely dispersed settlements with distinctive churches combine with the overall open character to provide a sense of remoteness. • The area's high nature-conservation value is concentrated in the wet grazing marshes, dykes, mudflats and the less extensive but distinct sand-dunes and shingle ridges of Dungeness. • Within the Marshes as a whole, Walland Marsh is particularly distinctive as it contains the greatest surviving concentration of small fields, dykes and unimproved pasture. • The Napoleonic Royal Military Canal runs along the base of a degraded former cliff line. • 20th century development is evident in the towns along the coastal strip. • The landscape displays a sharp contrast between the shingle coastal promontories, the extensive open, low-lying agricultural land behind and the inland backdrop of well-wooded rising ground.

High Weald

• The High Weald character area lies at the core of the Wealden anticline. The Greensand, Chalk and Wealden Clay to the north, south and west surround the sandstones and clays which underlie the forested ridges of the High Weald. • The central sandstone core is strongly dissected by many major rivers with steepsided valleys, several of which are heavily wooded. • Even more enclosed than the Low Weald. The mosaic of small hedged fields and sunken lanes, together with the wooded relief and comparative inaccessibility, provides a rare sense of remoteness. • The cultivation of fruit and hops is still a characteristic feature in Kent. • Local building materials characterise the area but recent `suburbanisation' of farmstead buildings is eroding the distinctive local style in many places.

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1.4.7 The JCA descriptions also highlight recent pressures that have acted to erode landscape character. From examining these pressures it is possible to better understand how the Kent MWDF might impact upon landscape.

1.4.8 A number of the JCA descriptions highlight that the landscape is sensitive to new roads, road improvement schemes or increased traffic on local roads, particularly where roads tend to be narrow rural lanes (e.g. High Weald) and where tranquillity is currently high (e.g. the North Downs).

1.4.9 More open landscapes within Kent are particularly vulnerable to development that leads to a high visual intrusion, such as waste facilities with associated pylons etc. and minerals workings. Other minerals or waste related development, though on a smaller scale, could lead to a loss of remoteness and erosion of local character by suburban type development using non-traditional styles and materials.

1.4.10 Relating to the impact of minerals working, it is stated that:

• the visual intrusion of mineral extraction operations and old landfill sites within former sand pits has significantly affected certain parts of the Greensand; • in the North Downs chalk pits and quarries have dramatically altered the appearance of the landscape; • in the North Kent plain many disused mineral workings and landfill sites would benefit from restoration; and • in the Greater Thames Estuary post 1945 waste disposal sites and spoil heaps have impacted on the character of the landscape.

1.4.11 Within the overall picture provided by JCA descriptions it is possible to distinguish variations in landscape character and further work has been undertaken to characterise more local variation. Figure 2 depicts the distribution of these lower level character areas, which were identified through a study focusing on Kent only. This map is included for illustrative purposes only, with more information available online. In particular, the Kent and Medway Structure Plan Supplementary Planning Guidance 1: Landscape Character sets out priorities for landscape action.

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Figure 2: ‘Finer scale’ character areas in Kent13

1.4.12 Subsequent to the identification and description of JCAs, the Countryside Quality Counts Project classified each according to the degree of change inconsistent with landscape character experienced in recent years. The Countryside Quality Counts (CQC) project has measured landscape change by assessing change in landscape character for two periods, 1990-1998 and 1999-2003. CQC uses JCAs as the geographical framework for reporting and assesses both the magnitude and the direction of landscape change, using four categories: maintained, enhancing, neglected and diverging (see Figures 3 and 4).14

1.4.13 The CQC surveys of change in landscape character highlight that:

• The Wealden Greensand JCA has seen a long-term erosion of character since; • The High Weald, Low Weald, North Kent Downs and Greater Thames Gateway JCAs have seen a positive reversal of previous erosional trends in more recent years • The North Kent Plain continues to suffer from long-term neglect; and • The character of Romney Marsh JCA has been the most stable in Kent over the long- term.

13 KCC (2004) The landscape assessment of Kent [online] available at: http://extranet7.kent.gov.uk/klis/home.htm (accessed 03/09) 14 See http://countryside-quality-counts.org.uk/ [online] (accessed October 2008)

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Figure 3: Magnitude and direction of landscape change 1999 - 200315

Magnitude of landscape change 1999-2003 Direction of landscape change 1999-2003

15 Natural England (2008). State of the Natural Environment 2008

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Figure 4: Long-term landscape change: analysis of 1990-1998 and 1999-2003 assessments16

16 Ibid.

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1.4.14 The map of tranquillity in Kent (see Figure 5) is clearly determined by proximity to major settlement and transport routes, and therefore also shows some correlation with map of JCAs. Tranquillity is primarily a function of noise pollution.

Figure 5: Tranquillity in Kent17

1.4.15 Finally, parkland remains an important and distinctive landscape feature. While some parklands were laid out in the medieval period, many were created or heavily modified in the 17th, 18th and 19th centuries. As well as being of cultural and historic environment value, parks today provide the location of much of England’s remaining wood-pasture. The Heritage Topic Paper describes spatial distribution of parks and gardens across Kent.

Future baseline

1.4.16 Natural England, as part of the consideration of the ‘State of the Natural Environment’ in the South East state that their priority will be to meet the following challenges:

• Better conserve and enhance the natural environment within protected landscapes through appropriate investment. • Promote the principles of the European Landscape Convention and work to develop the evidence base to better understand the drivers of landscape character change. • Promote green infrastructure policies in all spatial plans and disseminate best practice, particularly in areas of growth.

17 CPRE [online] available at : http://www.cpre.org.uk/campaigns/landscape/tranquillity/national-and-regional-tranquillity-maps/county- tranquillity-map-kent (accessed 03/09)

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Current and future situation in sub-county areas

1.4.17 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These areas were identified primarily on economic grounds, but provide a useful spatial framework to consider other elements of the sustainability baseline. Table 2 considers current and possible future baseline conditions in each of these sub-areas.

Table 2: The sub-county baseline

East Kent and Ashford18

Five JCAs cut across this area, demonstrating that there is substantial landscape variation. The implication of this is that planning for east Kent must take account of spatial variation in the environmental, cultural and historical baseline, and associated local constraints and opportunities. Tranquillity is associated with Romney Marsh, the River Stour wetlands to the north and west of Sandwich, and Downs to between Ashford, Canterbury and Dover.

Kent Thames Gateway19

It is unsurprising that the issues that require addressing through strategic planning have strong links to the underlying coastal landscape character of the area. There are opportunities to positively plan regeneration so that local distinctiveness is maintained and enhanced. Policy KTG7 of the RSS identifies that in the Kent Thames Gateway ‘green initiatives will be particularly important in order to transform the environment and image of the Gateway. Provision should be made for green grid networks, recreation and public access, and enhancement of landscapes, habitats, heritage and the environment. Countryside initiatives should complement the areas for growth, and recognise that it is a predominantly working landscape. They should define the important points of separation between settlements and the urban edges to be actively managed, and identify the connections between the urban ‘green grid’ and the rural area.

Rest of Kent20

Within this area there is the transition between four JCAs. Much of this is a rural landscape, and so the JCA descriptions will give a useful indication of what traditional land-uses are distinctive and should be preserved and promoted. The RSS states that a key spatial planning principle in this area is that biodiversity must be protected and enhanced and that the quality and character of the rural environment must be maintained and enhanced

18 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 19 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2. 20 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area.

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1.5 What are the key sustainability issues?

1.5.1 Table 3 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 3: Key sustainability issues

Key Issue Discussion

Protecting the integrity of It will be important that the North Downs and High Weald AONBs are the most valued and afforded the highest degree of protection. sensitive landscapes

Change in landscape Signs of change inconsistent with countryside character have been character identified to differing degrees in several areas. Care must be taken not to further damage the distinctiveness.

Specific impacts associated Minerals and waste operations can have significant impacts in some with minerals and waste landscapes. It will be important that impacts are minimised and mitigated, development including through appropriate restoration.

Loss of tranquillity Along with a loss of the distinctiveness of the landscape character there has been a noticeable decrease in the tranquillity of landscapes and landscapes that are genuinely ‘wild and remote’.

Contributing to landscape A number of programmes are under-way, and it will be important that scale approaches to minerals and waste developments do not hinder planned activity. environmental improvement and regeneration

1.6 What decision-making criteria should make up the SA framework?

1.6.1 The Southeast Regional Sustainability Framework includes the objective:

“To protect and enhance the region’s countryside and historic environment”

1.6.2 It is suggested that this objective should be taken forward and applied to the Kent MWDF through this SA. It is suggested that, as well as being used as the basis for predicting and evaluating landscape impacts at the assessment stage, this objective will also be used to identify effects on the topic of ‘heritage’.

1.6.3 When appraising the effects of the plan in terms of this objective, the following sub-objectives relating to heritage should also be taken into account:

• Protect the integrity of the AONBs, their settings as well as other particularly valued or sensitive landscapes

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• Take account of the constraints, opportunities and priorities demonstrated through landscape characterisation assessments and other studies at the landscape scale.

1.7 What further data is required?

• Tranquillity trend data • More refined evidence on the condition of landscapes and changes in landscape character. • A common monitoring framework and indicators for protected landscapes (National Parks and AONBs). • Evidence on the condition of, and cultural significance of, common land and Registered Parks and Gardens

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Revision Schedule

Scoping Report – Minerals Topic Paper March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Consultant Associate Technical Director Ian Brenkley Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Table of Contents

1 Minerals ...... 3 1.1 Introduction...... 3 1.2 Background...... 3 1.3 What’s the sustainability context?...... 3 1.4 What’s the current and (likely) future sustainability baseline? ...... 6 1.5 What are the key sustainability issues?...... 12 1.6 What decision-making criteria should make up the SA framework?...... 12 1.7 What further data is required? ...... 13

List of Tables

Table 1: The sub-county baseline ...... 10 Table 2: Key sustainability issues...... 12

List of Figures

Figure 1: Population, households and land-won construction aggregates sales in Kent ...... 7 Figure 2: Construction aggregate sales and GVA in Kent...... 8 Figure 3: Construction Aggregate Sales and Housing Completions in KCC Area 2000-08 ...... 9

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1 Minerals

1.1 Introduction

1.1.1 This is Topic Paper 10 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of minerals in SA; summarises some of the key policy that sets the context for the consideration of minerals in this SA; and describes the current and likely future situation for those elements of the baseline in Kent that are of relevance. It then summarises the key sustainability issues as they relate to minerals and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 The South East is the most populous English region and subject to significant growth pressures. Meeting growth and regeneration aspirations ‘will require an adequate supply of minerals and minerals-related products to support a major housing programme, deliver key infrastructure projects and provide the everyday products that we all use’1. Planning policy must also balance the environmental impact arising from minerals extraction, processing and transport with the requirements of the economy for minerals and manufactured products. It will be the role of the Topic Paper to consider what sustainability issues exist relating to the need for minerals. It will be the role of other papers to consider the potential ‘environmental impacts’ that must be balanced’.

1.3 What’s the sustainability context?2

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering minerals in this SA. This context review meets a requirement of the SEA Directive.3

1.3.2 Development proposed in the Regional Spatial Strategy (RSS)4 will impose considerable demands on the provision of minerals and construction materials across the region. This applies particularly to construction aggregates, the provision of which also has to contribute to London’s need.

1.3.3 The approach set out in the RSS is to meet identified and justified needs for mineral supply in the region, but to do so by making significantly more efficient use of natural resources; consideration of more difficult and sensitive sites; a significant increase in supplies of secondary and recycled materials; and an increase in imports of marine-dredged aggregates. Over the Plan period, it is expected that there will be a gradual change in the mix of these elements of supply, as construction efficiencies and recycling play an increasing part, therefore gradually decoupling minerals supply from economic growth.

1 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09) 2 All information sourced from the Regional Spatial Strategy Proposed Changes, unless stated otherwise. 3 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes. 4 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09)

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1.3.4 Additional minerals recycling facilities will be required in the region to process construction and demolition waste (as specified by Policy W15). Since recycling facilities are concerned with the re-use of already extracted primary materials and will prevent the unnecessary exploitation of finite reserves, this should be regarded as a waste management activity. In identifying sites for recycling facilities mineral planning authorities should take into account:

• the need for recycling operations to be located within a viable catchment area close to the origins of the waste material and to the subsequent markets; • the ability for such recycling operations to be enclosed in an industrial building, although acknowledging that at present most are sited in the open; and • the need to provide an indication of typical site sizes, acknowledging the need for materials storage before and after processing.

1.3.5 The RSS states that all partners must work towards the aim of achieving a modal shift in the transport of minerals. Mineral planning authorities should consider the need for wharves and depots, leading to the identification and safeguarding of sites, taking account of:

• capacity to supply imported material to the region; • proximity to markets; • value of the specialist infrastructure; and • adequacy of existing or potential environmental safeguards.

1.3.6 Import and processing facilities, especially in waterfront locations, are often under pressure for development for other higher value uses such as housing. It is important, however, that these resources are not sterilised or lost as they make an important contribution towards meeting Kent's mineral needs.5 It is important to emphasise the importance of mineral importation, particularly marine importation, considering both the extent of Kent’s coastline and estuarial frontage and number of import points. Imports contribute not only to Kent’s minerals needs but those of the wider region and London.

1.3.7 Minerals Policy Statement 16 states the importance and benefits of local minerals supply. Local land-won aggregates can support the local economy and help reduce carbon emissions by minimising transportation distances. Although self-sufficiency of supply is in theory desirable, in practice it may be unachievable at either regional or local level in the South East for minerals such as aggregates or gypsum. Local sand and gravel extraction cannot meet all the requirements of the South East. Construction also requires crushed rock but the geology of the region is such that hard rock resources are very limited (Kent, however, does have hard rock resources). In short, minerals can only be extracted where they are found and therefore the local geology has a fundamental influence on the scope for self sufficiency in minerals. An element of regional primary production should be used to supply London where natural resources are limited, but the Capital would be expected to increase significantly supplies from recycling and secondary sources.

1.3.8 The RSS states that mineral planning authorities should ensure that provision is made for sufficient supplies of aggregates, clay, chalk, silica sand and gypsum to be extracted and processed. Some non-aggregate minerals worked and processed in the South East have

5 KCC (2008) Minerals and Waste Annual Monitoring Report [online] available at: http://www.kent.gov.uk/NR/rdonlyres/618A7EEA- C096-4CEE-B031-2C2807A943E3/0/kentamr08.pdf (accessed 02/09) 6 Minerals Policy Statement 1: Planning and Minerals, Communities and Local Government (2006)

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regional or national importance. In Kent the following minerals are of regional or national significance:

• Clay - Unlike other non-aggregate minerals, clay occurs widely throughout the South East, it’s most significant use being in the manufacture of bricks, tiles and related construction materials. The Weald and Wadhurst clays of the High Weald and the gault of the Low Weald are the principal regional clay resource, although in Kent the majority of sites have now been worked out. It is possible that, in Kent, further reserves may need to be identified. In order to maintain brick and tile manufacture within the region, it may be important to maintain the high quality clay reserves for this specialist use. • Chalk - Although chalk is worked for a range of end-uses, its regional significance is as the major raw material for cement. Given the anticipated future supply patterns, there is unlikely to be any need to secure substantial new production capacity or reserves in the South East. However, producers will become increasingly reliant upon importation by sea (from European operations) and by road/rail from their other UK core works. Therefore, suitable wharves and rail distribution sites should be protected from inappropriate development. • Silica Sand - Silica sand, or industrial sand, is a sparsely distributed and valuable mineral resource which is an essential raw material in many UK manufacturing industries. Current extraction in Kent is focussed in the area between Aylesford and Addington in Mid Kent.7 Future silica sand production in the region is likely to be confined to the Lower Greensand of Kent and Surrey, with the major extraction site located between Bletchingley and Godstone.

1.3.9 It is recognised that there are other minerals worked in the region which contribute to the local economy and character, but which are worked on a smaller scale and have less impacts than those extracted on a larger scale. These can play an important role in providing historically authentic building materials in the conservation and repair of cultural and historic buildings and structures.8 The contribution of these minerals should be dealt with appropriately in mineral development documents.

1.3.10 Despite the presence of more than sufficient landbanks to meet policy requirements and enough operational sites, the annual production of primary land-won aggregates in Kent has been below the regional apportionment target for some time. Production rates are affected by the commercial and operational decisions of mineral operators. Policy M2 of the RSS requires Kent to make provision for the production of 1.4mtpa of secondary and recycled aggregate by 2016. The annual production of secondary and recycled aggregates in Kent for 2007 was 1,294,636 tonnes - equivalent to more than 90% of the target for Kent in the RSS. This represents a 91% increase over the level of production in 2004.

1.3.11 In terms of after-uses of minerals workings, the RSS states that in some cases, restoration to an agricultural or equivalent use would be appropriate, whilst in other cases another positive use may be appropriate, such as a recreation resource or the development of wildlife habitats.9 Waste Strategy 2007 describes how other types of after-use may ‘have a place’, including inert landfilling. Whatever the after-use, it will be essential that it is established to a high standard with appropriate aftercare and management.

7 KCC (2009) Personal communication. 8 Minerals Policy Statement 1: Planning and Minerals, Communities and Local Government (2006) 9 Lafarge Aggregates Ltd consultation response (2009)

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Partial Review of the South East Plan - Policy MP3 (aggregates)

1.3.12 On 2 March 2009, the South East England Regional Assembly (now the South East England Partnership Board) submitted to the Secretary of State their review of Policy M3 of the South East Plan - the amount of primary aggregates (sand, gravel and crushed rock) that each minerals planning authority (county and unitary councils) should provide. Public consultation on the draft Review closed on 26 June 2009 and an Examination in Public (EiP) was then held between 6 and 8 October 2009. The Report of the EiP was submitted to the Secretary of State on 27 November 2009. The next stage is that GOSE will prepare the Secretary of State’s Proposed Changes to Policy M3 for public consultation next year. Key findings of the EiP Panel Report include:

• The reduction in regional provision of land-won sand and gravel proposed by SEEPB (from 12.18 mtpa to 9.01 mtpa) was judged by the Panel Report to be too much. They have proposed a revised figure to the Secretary of State of 11.12 mtpa. The revised apportionment to Kent is 1.63 mtpa of sand and gravel and 0.78 mtpa of crushed rock. • An appropriate approach for determining strategic apportionment is to take account of both the location of construction demand (40% weighting) and the location of international environmental designations (60% weighting). This is more appropriate than a ‘past sales’ approach to apportionment. Housing is a reasonable proxy for ‘construction demand’. These apportionments should be further tested through the KMWDF. In particular, there will be a need to take further account of evidence of how environmental constraints vary at the local level. • Policy MP5, which relates to wharf and rail facilities should be reviewed at the earliest opportunity to reflect concerns that 1) some of wharves not in use may not be suitable in the future; and 2) that wharves capable of accepting sea-borne crushed rock are concentrated on the north Kent coast and the Isle of Grain which are remote from many parts of the region thus raising a number of issues regarding the onward transportation of the material, particularly if this is by road.

1.4 What’s the current and (likely) future sustainability baseline?10

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to minerals in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent to other geographical areas, as well as considering how the baseline varies at the sub-county scale, within three sub-regional areas defined in Kent by the South East Plan. This section meets a key requirement of the SEA Directive.11

10 All information sourced from the Regional Spatial Strategy Proposed Changes, unless stated otherwise. 11 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected”

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Current baseline

1.4.2 Kent is rich in minerals, containing chalk, clays, brickearth, ragstone and a variety of sands and gravels. Construction aggregates – sand, gravel and ragstone – are the main types of mineral found and extracted in Kent, and are used for the production of concrete, mortar and asphalt, amongst other things. Silica (or industrial) sand is also used in many industrial processes, including glass manufacture, the production of foundry castings, ceramics, chemicals manufacture, and water filtration. Brickearth is used in the production of stockbricks. Clay is also used in the production of bricks, as well as being used for sea defences and engineering processes, such as lining landfill sites. Chalk is used in the building industry and in the production of cement and paper, as well as being used for agricultural purposes, such as liming.

1.4.3 Significant amounts of minerals are imported via rail and wharf facilities. Minerals imported into Kent serve markets elsewhere in the wider south east, in particular London. Furthermore, an increasingly significant proportion of Kent's construction aggregate need is met by the recycling or re-use of wastes, such as that arising from construction and demolition. Ensuring that appropriate provision is made for land-won, imported and secondary and recycled minerals is a key issue for the Minerals Development Framework.12

1.4.4 Despite a steady increase in population and number of households, and a rising rate of housing construction, in this period, sales of land-won construction aggregates have remained significantly below the level of sales in 2001, although they have increased slightly since the sharp drop seen in 2002. This is demonstrated in Figure 1.

Figure 1: Population, households and land-won construction aggregates sales in Kent13

12 KCC (2008) Minerals and Waste Annual Monitoring Report [online] available at: http://www.kent.gov.uk/NR/rdonlyres/618A7EEA- C096-4CEE-B031-2C2807A943E3/0/kentamr08.pdf (accessed 02/09) 13 Minerals and Waste Annual Monitoring Report (2007/08) [online] available at: http://www.kent.gov.uk/NR/rdonlyres/618A7EEA- C096-4CEE-B031-2C2807A943E3/0/kentamr08.pdf (accessed February 2009)

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1.4.5 Figure 2 suggests that, at least over the short term, there is no direct relationship between sales of locally-won construction aggregate and change in Gross Value Added (GVA). Sales of construction aggregates dropped substantially in 2002 and have increased slightly since then. Imports of construction aggregates have remained relatively stable, with slight fluctuations since 2003, although there was a sharp increase in sales in 2007. This sits alongside a consistent but moderate increase in GVA throughout the period.

Figure 2: Construction aggregate sales and GVA in Kent14

1.4.6 Figure 3 shows that there may be some correlation between housing completions and construction aggregate sales, although this is not necessarily a directly proportional relationship. The relationship between housing completions and imported construction aggregates appears weak until 2005/06 although their patterns of change have become more related since then with substantial increases in both in the last year.

14 Ibid.

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Figure 3: Construction Aggregate Sales and Housing Completions in KCC Area 2000-0815

1.4.7 It was reported in the 2007 AMR that, in Kent, as of 31 December 2006, there were twelve wharves, predominately clustered in Kent Thameside, and four rail depots, predominately clustered in the centre of the County, around Ashford and Maidstone. This remained the position at 31 December 2007. No existing wharves or rail depots were lost to alternative development in the monitoring period.

1.4.8 During the 2007/2008 period no applications were permitted to release additional mineral reserves. However, a variation of conditions at Allens Bank, Lydd, allowed for 700,000 tonnes of material to be sold on the open market rather than being restricted to use associated with the construction of the Channel Tunnel Rail Link.

Future baseline

1.4.9 The above consideration of the current baseline shows a number of trends to be apparent, although it is not possible to say with confidence that these trends will continue, as there are many factors that can influence supply and demand of minerals. The RSS states that the structure and distribution of the minerals industry in the South East is changing, reflecting national trends which are likely to affect future patterns of supply. Overall, the number of extraction sites is declining and the manufacture of products such as cement, bricks and plasterboard is becoming concentrated in fewer, bigger plants which supply larger areas, often on a regional or national scale. Some minerals are increasingly being imported for use in the region while manufactured products are also being imported from abroad to supply regional needs. The use of alternatives to natural minerals and the availability of synthetic materials may also influence future regional demand.

15 Ibid.

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Current and future situation in sub-county areas

1.4.10 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These areas were identified primarily on economic grounds, but provide a useful spatial framework to consider other elements of the sustainability baseline. Table 1 considers current and possible future baseline conditions in each of these sub-areas.

Table 1: The sub-county baseline16

East Kent and Ashford17 Aggregate Mineral Quarries – sand and Secondary and Recycled Aggregate Processing gravel: Sites: • Ashford (2) • Ashford (2) • Canterbury (4) • Swale (1) • Swale (3) • Thanet (2) • Shepway (3) • Canterbury (3) Aggregate importing wharves: • Dover (1) • Thanet (1) • Shepway (2) • Shepway (1) Other minerals sites: • Canterbury (1) • Brick Clay - Dover (1); Ashford (1); • Dover (1) • Chalk - Dover (1); Ashford (2); Canterbury (1); Aggregate importing rail depots: • Specialist gravel – Canterbury (2); Shepway (1); • Ashford (2) • Clay – Swale (2)

There has been a small coal mining operation in east Kent since the end of the 19th Century. The coal occurs in Upper Carboniferous rocks and represents a continuation, under the English Channel, of the more extensive coalfield of northeast France and northwest Belgium. These rocks do not outcrop at the surface but occur at depth. Coal was originally discovered in 1896 at the foot of Shakespeare Cliff, Dover, but its extraction was found to be uneconomic at this location. Later exploration and the sinking of shafts between Dover and Canterbury led to the opening of a number of collieries (e.g. Snowdon, Tilmanstone). However, Kent Coal is friable (crumbly) and unsuitable for domestic use; extensive works also had to be employed to contain water flows in the mines. The commercial exploitation of the coalfield lasted less than a century, with Betteshanger the last of the collieries closing in 1989. The coal mining operations within east Kent are likely to have left an environmental legacy which has the potential to cause land stability and other public safety risks.18

16 Ibid. 17 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 18 The Coal Authority consultation response (2009)

Scoping Report - Minerals 10 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

Kent Thames Gateway19 Aggregate Mineral Quarries – sand and Secondary and Recycled Aggregate Processing gravel: Sites: • Dartford (2) • Swale (7) Aggregate importing wharves: • Gravesham (1) • Gravesham (6) • Dartford (3) • Swale (2) Other minerals sites: • Dartford (1) • Brick Clay – Swale (2); • Chalk – Gravesham (1); Dartford (2); • Clay – Swale (1);

Rest of Kent20 Aggregate Mineral Quarries – sand and gravel: Secondary and Recycled Aggregate Processing • Sevenoaks (4) Sites: • Maidstone (2) • Tonbridge and Malling (5) • Tonbridge and Malling (7) • Ashford (1) Aggregate Mineral Quarries – crushed rock: • Maidstone (1) • Maidstone (1) • Sevenoaks (1) • Tonbridge and Malling (1)# Other minerals sites: Aggregate importing rail depots: • Brick Clay - Tonbridge and Malling (1); Ashford (1); Tunbridge Wells (2); Maidstone • Tonbridge and Malling (1) (1); Sevenoaks (1); • Ashford (1) • Chalk – Ashford (2); Maidstone (1); Tonbridge and Malling (1) • Silica sand - Tonbridge and Malling (4); Sevenoaks (a); Ashford (1) • Clay - Tonbridge and Malling (1)

19 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2. 20 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area.

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1.5 What are the key sustainability issues?

1.5.1 Table 2 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 2: Key sustainability issues

Key Issue Discussion

Ensure that demand The approach set out in the RSS is to meet identified and justified needs for in the region can be mineral supply in the region, but to do so by making significantly more efficient met use of natural resources; consideration of more difficult and sensitive sites; a significant increase in supplies of secondary and recycled materials; and an increase in imports of marine-dredged aggregates. Self-sufficiency should be an aspirational aim. There is a need to safeguard mineral reserves and minerals importation facilities. One consideration relates to the employment role played by minerals and waste development.

Achieve a modal Consider the need for strategically located wharves and rail depots, leading to shift in the transport the identification and safeguarding of sites. of minerals Consider proximity to markets.

Through careful Consider the proximity to sensitive receptors and pathways by which receptors location, seek to could be impacted by minerals operations. Seek to maximise the benefits of minimise the restoration of minerals sites. negative effects of Consider the benefits of local land-won aggregates. minerals operations and maximise positive effects

Marine dredged There has been an increase in marine dredged aggregates from the English aggregates Channel, which will have implications for minerals importation to Kent.

1.6 What decision-making criteria should make up the SA framework?

1.6.1 The Southeast Regional Sustainability Framework does not include any objectives that relate specifically to achieving sustainable minerals operations. Rather, it can be seen that there are a number of objectives that have a more indirect relationship to this topic, through identifying what must be achieved if minerals operations are to be undertaken sustainably. Therefore, no sustainability objective relating specifically to sustainable minerals operations is proposed here. Rather, there will be an emphasis on ensuring that the evidence and key issues presented in this topic paper feed into the SA through an explicit consideration of minerals related issues as part of the assessment against other sustainability objectives. To ensure that this occurs, a number of the sustainability objectives outlined in the other topic papers have been assigned sub-objectives relating specifically to minerals.

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1.7 What further data is required?

• Predictions of likely future minerals extraction requirements

Scoping Report - Minerals 13 March 2010

Revision Schedule

Scoping Report – Rural Topic Paper March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Assistant Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Assistant Consultant Associate Technical Director Ian Brenkley Assistant Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Table of Contents

1 Rural Areas ...... 3 1.1 Introduction...... 3 1.2 Background...... 3 1.3 What’s the sustainability context?...... 3 1.4 What is current and (likely) future sustainability baseline?...... 5 1.5 What are the key sustainability issues?...... 15 1.6 What decision-making criteria should make up the SA framework?...... 15 1.7 What further data is required? ...... 15

List of Tables

Table 1: The sub-county baseline ...... 14 Table 2: Key sustainability issues...... 15

List of Figures

Figure 1: National urban/rural classification by local authority, 2005 ...... 6 Figure 2: Sparse and ‘less sparse’ rural areas in the South East...... 6 Figure 3: Index of deprivation in rural areas, 2007 ...... 8

List of Boxes

Box 1: Living in the countryside – a ten year perspective ...... 9 Box 2: Economic well-being in the countryside – a ten year perspective...... 10 Box 3: Key actions proposed in the Kent Rural Delivery Framework ...... 12

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1 Rural Areas

1.1 Introduction

1.1.1 This is Topic Paper 11 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of rural areas; describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to rural areas and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 Extensive parts of Kent are rural, punctuated only by the small towns and villages that contribute to the particular character of the county, and which provide essential homes, jobs and services for the local population. These settlements are highly accessible to those living and working in the region’s urban areas, which can lead to a number of pressures, particularly related to demand for housing. The problems of housing affordability and lack of accessible services can combine to lead to pockets of rural deprivation.

1.2.2 Planning policy must therefore balance the need to protect the countryside and retain the charm and heritage of the county’s enviable patchwork of smaller settlements whilst making sure that they continue to serve the needs of both their locality and the wider region. It is important that there is an explicit consideration of the effects of the Kent MWDF on rural areas, including small towns and villages, as some facilities will be suited to locations in rural, rather than more densely populated, locations.

1.3 What’s the sustainability context?1

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering rural areas in this SA. This context review meets a requirement of the SEA Directive.2

1.3.2 Government guidance on the topic of rural areas has a focus on the particular needs of rural economies. In particular, it sets the objective of developing competitive, diverse and thriving rural enterprise that provides a range of jobs and underpins strong economies.3 At the same time, it sets the objective of ensuring good quality, sustainable development that respects and, where possible, enhances local distinctiveness and the intrinsic qualities of the countryside. Rural authorities are tasked with taking due care when determining the location of employment sites in rural areas.

1 All information sourced from the Regional Spatial Strategy, unless stated otherwise. 2 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes. 3 ODPM (2004). Planning Policy Statement 7: Planning and Rural Areas [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/pps7 (accessed 02/09)

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1.3.3 The Regional Spatial Strategy (RSS)4 sets out to achieve four key aims for rural areas:

• Sustainable rural communities which are inclusive, tackle disadvantage and provide a range of affordable housing, access to essential services, and support for local community-based activities and decisions. • Sustainable rural economies including a profitable land-based economy, as well as the rural-based manufacturing and service economy, and high quality tourism. • Sustainable rural environments which celebrate and enhance character and distinctiveness; accept change and development which respect that character; provide for a wide range of recreation and retreat. • Sustainable natural resources where they are used more prudently with more thought given to alternative energy sources, and the most valuable are protected and conserved.

1.3.4 In terms of housing, the RSS recognises that much specific policy is directed towards the towns, and so it is important that housing growth in rural areas is not artificially constrained. The RSS states the importance of planning for and managing the provision of housing to enhance the viability of rural settlements and promote a rural renaissance, thereby meeting the long term needs of rural communities.

1.3.5 The RSS also recognises that minerals extraction often has special significance for rural areas, whereas the import of material via wharves and depots impacts more in urban areas.

1.3.6 The Regional Economic Strategy (RES)5 identifies a number of economic priorities for rural areas. Of particular relevance are the objectives to:

• stimulate enterprise and nurture new and existing businesses, making use of networks, collaborations and co-operatives, centres of excellence and hubs of specific activity; • support locally focused community-based businesses that make use of the natural environment and heritage assets or that use environmental technologies; • exploit the potential for real premium products through ‘added value’; develop and adopt good quality standards; become closer to markets and make best use of opportunities in London and other urban and rural markets on the doorstep. • build on existing and develop models of good practice and create new opportunities in the land-based sector for new uses of land, new premium products and processes and new opportunities arising from climate change; • ensure provision of sites for rural enterprise, particularly existing rural building; • ensure an adequate supply of affordable houses to maintain vibrant rural communities that can maintain a working population; • target new employment activities where there are recognised concentrations of rural deprivation; • develop opportunities for the land-based sector to grow crops for energy and fuels;

4 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09) 5 SEEDA (2006) The Regional Economic Strategy [online] available at: http://www.seeda.co.uk/Publications/Regional_Economic_Strategy/ (accessed 03/09)

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• explore the potential opportunities for the land-based sector to continue to manage and maintain the quality landscapes and biodiversity of the region, particularly in fragile livestock and woodland regimes; • explore potential opportunities for the land-based sector to contribute to the management of water catchment areas, protection of aquifers and water storage; and • support small rural towns to become ‘capitals’ of their surrounding hinterlands

1.4 What is current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to rural areas in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent to other geographical areas, as well as considering how the baseline varies at the sub-county scale, within three sub-regional areas defined in Kent by the RSS. This section meets a key requirement of the SEA Directive.6

Current baseline

1.4.2 This section presents information taken from the ‘State of the Countryside 2008’ Report.7 Much of the data refers to rural communities in general, rather than issues specific to Kent. However, information that is less likely to be relevant to Kent has been removed. Figure 1 shows that much of Kent either has ‘significant’ rural elements, with Sevenoaks and Dover having the strongest rural elements. Figure 2 shows that the vast majority of rural areas in Kent are best described as ‘less sparse’. The State of the Countryside Report highlights a range of interesting distinctions between baseline conditions in ‘sparse’ versus ‘less sparse’ rural areas. Boxes 1 and 2 also present information from the State of the Countryside Report. Information has been drawn out from the report that is of particular relevance to Kent, but in order to pick up on further local issues Box 1 also includes information from the Kent Rural Delivery Framework.

6 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected” 7 Unless otherwise stated, information taken from – Commission for Rural Communities (2008) State of the Countryside Report [online] available at: http://www.ruralcommunities.gov.uk/projects/stateofthecountryside/overview (accessed 03/09)

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Figure 1: National urban/rural classification by local authority, 20058

Figure 2: Sparse and ‘less sparse’ rural areas in the South East9

8 Commission for Rural Communities (2008) State of the Countryside Report [online] available at: http://www.ruralcommunities.gov.uk/projects/stateofthecountryside/overview (accessed 03/09) 9 Images of the South East [online] available at: http://www.go-se.gov.uk/gose/ourRegion/aboutTheSE/imagesSE/ (accessed 03/09)

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Population • The population of rural England continues to rise at a faster rate than in the country as a whole. Most of this increase is due to internal migration by people moving out of cities. • People continue to leave rural areas at around age 20. • The median age for rural residents is nearly six years older than in urban areas. • Internal migration continues at a high level, although the rate has fallen in the last two years. • Migration from overseas has increased dramatically for rural areas over the last four years, but numbers are still below those for cities. Access to services • For most types of services the number of outlets continues to decline in both urban and rural areas, but rural areas are more vulnerable to the effects • Supermarkets continue to see an increase in the number of outlets (but there is no equivalent data for smaller food shops). • The level of access to an hourly or better bus services that had risen steadily between 1998 and 2004 has slowed and slightly reversed in the last two years. • Use of broadband is higher in those rural areas with high levels of commuting, and lowest in sparse rural areas. Transport • Rural residents travel greater distances and more of their travel is by car. • Car ownership relates closely to income, but in rural areas, people with low incomes are more likely to own cars than in urban areas. The growth of car ownership for those in the lowest fifth of incomes continues in rural areas. • During 2006 urban traffic levels fell by 2% but traffic grew by 1% on rural roads. Housing and homelessness • Housing affordability remains a major issue in rural areas, especially for lower quartile prices and incomes. • Second homes and cash house purchases are more common in rural areas, and much more common in coastal areas. Health • Although rural populations show better health outcomes, comparative data showing prevalence of disease shows higher levels for rural populations, due to their relatively higher age profile. Community Cohesion • Indicators tend to show strong communities in rural areas on most measures but this picture is not universal. • Levels of crime are generally lower than in urban areas, although rates are rising in some areas and for some forms of crime.

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Disadvantage • The 2007 Index of Multiple Deprivation shows rural areas to have, on average, less concentrated deprivation than urban areas. • Only 2.4% of areas with scores within the worst 20% of deprived areas rural. • The data also highlights the fact that rural deprivation tends not to be concentrated in particular parts of the country, unlike urban areas. • Fuel poverty is more common in sparse rural areas. • Levels of people with a disability are found to be higher in rural areas than in urban areas. This poses particular issues for those providing services in rural areas.

Figure 3: Index of deprivation in rural areas, 200710

10 Commission for Rural Communities (2008) State of the Countryside Report [online] available at: http://www.ruralcommunities.gov.uk/projects/stateofthecountryside/overview (accessed 03/09)

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Box 1: Living in the countryside – a ten year perspective11

Rural areas continue to fare better on most measures of quality of life than urban areas in England. Rural areas are characterised by having an older age profile, more people moving in than moving out, fewer homeless people, more healthy lifestyles, better educational achievement, lower crime, and less deprivation than urban areas. But they also have worse access to services, worse housing affordability, and the greater numbers of older people mean that illness is more prevalent for many diseases. We have also found that sparse and remote areas often fare worse on indicators, and when mapped, there are areas that show up consistently as offering a poorer quality of life. Rather perversely, many of these areas are those favoured for retirement and second homes, which can exacerbate some of the problems such as poor housing affordability that occur there. We also know that much deprivation in rural England is not picked up by even small area analysis – 2.4% of the most deprived 20% of Lower Level Super Output Areas are in rural areas, but about 15% of deprivation measured at the individual level is found in rural areas. So, much rural deprivation will not be identified even by small area mapping and analysis. That said, many rural areas are thriving and polarisation both between areas, and within areas seems to be more of an issue than widespread deprivation and disadvantage. The picture given is that rural areas are not universally better off than urban areas, and that we should not assume that because rural areas are better off, on average, that there is no need to take action to address problems there. Over the ten State of the countryside reports that have been produced, some of the most serious issues – of housing affordability, access to services, and a lack of public transport – have continued as major issues. While few would argue that there is no need for action to address the issues that rural disadvantage poses, there is often a lack of priority and focus given to them given that urban deprivation is more visible. While urban disadvantage tends to be concentrated in particular areas where localised action can be taken to address poor quality of life and limited opportunities, geographically targeted solutions are less likely to be effective in rural areas where disadvantage can be hidden and is more dispersed.

Economic Well-being • Rural households have higher gross incomes than those living in urban England, but this masks gradients across the rural/urban geography and within rural areas. • 18% of households in rural areas were below the ‘poverty line’ in 2006/07 compared to 19% in urban areas. When we take housing costs into account the rural percentage rises to 19%. Sparse rural areas have proportions on low incomes that are similar to urban areas. • The percentage of rural residents in poverty has risen from 16% to 18% between 2004/05 and 2006/07. After housing costs are taken into account the increase is from 16% to 19%. This is a faster percentage rise than in urban areas (1%). • While people living in rural areas, on average earn more than those in urban areas, there are more low paid jobs, and wages for jobs located in rural areas are lower than for urban areas, and lowest in the peripheral areas such as Northumberland and Cornwall (the difference is explained in part by commuting patterns). Employment • In 2007 the most rural districts supported the highest rate of employment. The average employment rate declines with increased degree of urban character • There are important local differences; many rural areas have relatively low rates of employment

11 Ibid.

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• Net commuting to urban areas represents 17% of all employment for rural residents • Employment in agriculture has fallen by about 7% since 1999, and by 39% for full-time farm workers. For the Knowledge Intensive Business sector there have been increases of up to 22% in rural areas between 1998 and 2005. Box 2: Economic well-being in the countryside – a ten year perspective12

Many spatial and economic studies have reinforced the inadequacy of the label ‘The Rural Economy’ to describe economic activity and health in rural England – multiple ‘Rural Economies’ is a more appropriate label. Since the first State of the countryside report in 1999, the Commission for Rural Communities (CRC) has tried to reflect the value of and need for detailed assessment and description of the dynamics of rural economies at local level. The CRC has stressed the importance of rural:urban interdependencies, two- way flows of goods, services, people and ideas that reinforce economic and social activity in both rural and urban communities. The contribution made by rural areas to some of the Government’s core targets for ‘economic growth’ has increased over the last ten years. Taken collectively, England’s rural economies have achieved levels of growth and outputs that have matched or exceeded those achieved even in our core cities outside of London. Levels of new enterprises have exceeded those in urban areas. Employment rates exceed the English and urban averages, with more rural authorities having achieved the target of full employment. On the other hand, sparse rural settlements and peripheral rural districts remain amongst the least prosperous economies in England, with lowest levels of GVA, employment, productivity, VAT registration rates and highest rates of households on less than 60%, of the English median household income. Benefit claimant rates, proportions of employees on low wages, and economic inactivity rates are also highest in these sparse settlements and peripheral districts. Such areas are also more likely to be characterised by lowest levels of business revenue per worker, and of districts failing to reach rates of ‘full employment’ levels. Despite this, these rural settlements and districts often support the highest rates of growth within the same measures, suggesting convergence with other rural areas and the English average. Convergence has also been apparent in the types of businesses and employment, with declines in the rurally-distinct business sectors of farming and the more rapid growth in the banking and other financial and business services, usually associated with urban areas. Despite convergence between urban and rural economies and the spread of better performance across many rural areas, a persistent problem relates to the location of England’s poor performing areas. Whilst urban areas can identify and count on public recognition and support for neighbourhoods of economic and social disadvantage, in many rural districts dispersal of disadvantage contributes to persistence of problems and slower change.

Land use and development • Demand for new development is significantly higher (per household) in rural areas than urban areas and the countryside has seen a greater number of new houses built in it than the urban fringe in recent years. • The value of agricultural land rose sharply during 2007, mainly due to increases in the prices of agricultural commodities and to high demand for ‘lifestyle’ rural properties with land. Farming and forestry • 2007 saw significant changes in agricultural commodity prices and in elements of agricultural policy which are likely to have a visible impact on the way England is farmed.

12 Ibid.

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• The doubling in the price of wheat, coupled with the removal of the requirement for farmers to set-aside land will result in an increase in the proportion of land that is cultivated for arable crops. • A sharp rise in UK milk prices during 2007 has returned profitability to dairy farming, encouraging investment in more intensive grassland management. This is tempered by the high cost of fertiliser, a result of rising energy prices. The sight of unused agricultural land will become rarer. • Continuing demand by consumers for high quality differentiated foods is maintaining interest in organic farming, farmers’ markets and other marketing and accreditation initiatives. • Over half of agricultural land now receives payments to provide environmental benefits (the majority of this under the Environmental Stewardship scheme). • These changes have resulted in many farmers being more optimistic about the prospects for their businesses, with fewer planning to give up farming. However, the average age of farmers continues to rise. • The area of woodland in England remains stable and is dominated by broadleaved woodland in private ownership. However, there is growing interest in the role of England’s woodland and forestry in mitigating climate change, both as a store of atmospheric carbon and a source of renewable energy in the form of woodfuel. Environmental quality • The character of large parts of England’s countryside is changing as a result of built development particularly in the lowlands and areas beside major transport corridors. Comparison of the levels of visual and noise intrusion since the 1960s shows that rural areas have become much busier (with a three-fold increase in the ‘disturbed’ areas in the most rural districts). • Air quality in rural areas is generally good although levels of ozone (which is naturally occurring but toxic) can be higher than in urban areas, where the ozone is broken down by nitrogen oxides emitted by vehicles. Climate change • Rural areas have a significantly higher carbon production rate per person than urban areas. This is principally due to generally higher income and per capita consumption and because of the higher emissions from heating homes and transport in rural areas. • Large reserves of stored carbon are contained in organic material in soils and in woodland. Land drainage in areas such as the Fens is leading to the release of high levels of carbon dioxide whereas wooded areas such as the Weald are ‘sequestrating’ (locking up) carbon dioxide. • A full overview of the contribution of rural land use to climate change needs to take account of the impact of imported foods and timber (in terms of both production and transport). • The English countryside is capable of providing significant quantities of energy from renewable sources including wind and biomass. But there is growing public debate about the wisdom of diverting land from food to energy production.

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Box 3: Key actions proposed in the Kent Rural Delivery Framework

The report highlights that the key external drivers of change in rural kent are continued globalisation of markets, increasing competition, agricultural policy reforms, escalating house prices, an ageing population, increasing water scarcity, and climatic change.

Key actions promoted to foster and grow the rural economy include: • developing Kent’s rural knowledge economy; • working with rural businesses and communities to build a strong entrepreneurial culture; • facilitating the new agriculture revolution; • increase the proportion of rural businesses involved in added-value activities; and • focusing on the market to grow demand for Kentish products.

With regard the rural economy it is important to point out that Kent is well positioned to further develop its rural knowledge economy, particularly in the ‘accessible rural areas’ close to major metropolitan centres, which have locational advantages given their high proportions of resident highly-skilled knowledge workers.

However, it is also important to note that many rural areas contain pockets of economic disadvantage that are masked by the presence of a large number of retired residents and commuters, many of whom work in relatively high paid occupations in London, urban Kent and the rest of the South East.

Like in many rural areas, average unemployment in rural Kent is low (2%) – although this conceals small areas of high unemployment often in more remote rural parts such as Romney Marsh with over 4% unemployed.

Key actions promoted to support and strengthen rural communities include: • creating cohesive and dynamic rural communities; • developing an innovative and entrepreneurial approach to rural services; • improving rural access and transport; • increasing the provision of affordable housing to meet local needs; and • addressing rural disadvantage and support independence.

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Future baseline

1.4.3 Although the rural environment is often regarded as a relatively stable part of our society, it is changing and in many respects the pace of change is accelerating. In many instances it is likely that the future will involve a continuation of the trends that have been highlighted in the preceeding baseline section. However, in other instances there may be significant developments that have a fundamental influence on the baseline that are more unpredictable. For example, although it is clear that the issue of tackling rural affordability is likely to be tackled through house building programmes in rural areas, what is less certain is what impact this will have on the character of rural settlements and the strength of communities.

1.4.4 There are also many unknowns in terms of the future of land management in the countryside. The environmental implications of the current improvement in the fortunes of farming are unknown, but intensification in the way farmland is managed is likely to put pressure on environmental quality. Furthermore, the ramifications on rural England of a warming climate, and of the policies that will be introduced to mitigate this, are not clear. Climate change poses particular challenges for rural communities, both in terms of the sustainability of people’s car- reliant lifestyles and in the way landscapes and biodiversity will adapt. The food versus fuel debate (the conflicting demands for land to be used to grow food or renewable energy) that has emerged recently is just the first of a new set of sustainability issues that will shape the countryside’s contribution to society.

Current and future situation in sub-county areas

1.4.5 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These areas were identified primarily on economic grounds, but provide a useful spatial framework to consider other elements of the sustainability baseline. Table 1 considers current and possible future baseline conditions in each of these sub-areas.

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Table 1: The sub-county baseline

East Kent and Ashford13

Romney Marsh is thought of as the most sparsely rural area in the South East. The other significant feature is high levels of in-migration from higher age bands (aged 45+). This is contributing to a growing and ageing population: 28% of the population is over the age of 60, more than 7% higher than the national average. Local employment is primarily dominated by low wage industries and there is a very high house- price to average income ratio. Most residents describe the housing market on Romney Marsh as highly competitive, characterised by a lack of social housing, few affordable or long-term private rental options and expensive private homes. New housing developments are happening, but most people believe that they are out of sync with local needs, either being too large and expensive for people on local incomes, or too small for family homes. There is a strong view that a lack of community input into planning decisions is also resulting in many new developments over-burdening existing services and infrastructure.14 Aside from Romney Marsh, there are also some deeply rural areas within Dover District associated with the Stour Marshes.

Kent Thames Gateway15 Sheppey is one of the most deeply rural areas in the South East, with much of the island characterised by sparse town and fringe settlements. The other more rural part of the Gateway is to the south of the A2 in Dartford and Gravesend. Rest of Kent16 This is the most rural of the three sub-areas, being characterised by extensive areas of ‘less sparse hamlets and isolated dwellings. The RSS identifies that a key spatial planning principle in this area must be to sustain local communities through sensitive development of market and affordable housing to help maintain rural vitality and improve access to local services and employment.

13 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 14 Commission for Rural Communities (2006) Romney Marsh Case-Study [online] available at: http://www.ruralcommunities.gov.uk/files/CRC09RomneyMarsh.pdf (accessed 03/09) 15 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2. 16 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area.

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1.5 What are the key sustainability issues?

1.5.1 Table 2 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 2: Key sustainability issues

Key Issue Discussion

There is a need to take Sustainability issues associated with rural communities will be closely tied account of locally specific to geography, for example whether the area is coastal, within and AONB rural sustainability issues or within easy commuting distance of a Principal Urban Area.

Many of the most pressing Issues are particularly apparent in the two most extensive areas effects of rurality are felt in characterised as being sparsely populated and rural - Romney Marsh and the most sparsely the Isle of Sheppey. populated rural areas.

1.6 What decision-making criteria should make up the SA framework?

1.6.1 The Southeast Regional Sustainability Framework includes the objective:

“To protect and enhance the region’s countryside and historic environment”

1.6.2 This objective is not sufficient to take account of all potential rural sustainability issues that could be associated with the implementation of the Kent MWDF. Therefore it is proposed that the following sub-objective be included under the objectives relating to community and economy that have been put forward within the corresponding topic papers.

• Take account of locally specific issues associated with rurality.

1.7 What further data is required?

• There is a need for a finer grain of analysis, which picks up on disparities within towns and villages. • Rural housing affordability in Kent is an important issue where data is limited. • Information on the importance of the tourism and recreation sector to the rural economy.

Scoping Report – Rural Areas 15 March 2010

Revision Schedule

Scoping Report - Transport March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Assistant Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Assistant Consultant Associate Technical Director Ian Brenkley Assistant Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Table of Contents

1 Transport...... 3 1.1 Introduction...... 3 1.2 Background...... 3 1.3 What’s the sustainability context?...... 3 1.4 What’s the current and (likely) future sustainability baseline? ...... 5 1.5 What are the key sustainability issues?...... 17 1.6 What decision-making criteria should make up the SA framework?...... 17 1.7 What further data is required? ...... 18

List of Tables

Table 1: The sub-county baseline ...... 15 Table 2: Key sustainability issues...... 17

List of Figures

Figure 1: Average Daily 24 Hour Flows at ATC Sites 1999 to 2007...... 6 Figure 2: Average inter-urban traffic flows, 2007...... 7 Figure 3: Automatic Traffic Count sites, 2007 ...... 7 Figure 4: Peak hour (7am to 10am) weekday inbound flow ...... 8 Figure 5: 24 hour weekday two way flow...... 8 Figure 6: Freight Vehicles (HGVs) passing through Dover ...... 9 Figure 7: Freight Tonnages passing through the Channel Tunnel ...... 9 Figure 8: Total Number of Passengers, Cars & HGVs using Eurostar, Ports and Le Shuttle ...... 10 Figure 9: Casualties on roads for which KCC is responsible, 1990 - 2007...... 10 Figure 10: Reduction by district in casualties on highways for which KCC is responsible ...... 11 Figure 11 Development over time of the county’s rail network...... 12

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1 Transport

1.1 Introduction

1.1.1 This is Topic Paper 12 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of transport in SA (and this SA in particular), describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to transport and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 National transport policy has changed from a strategy of predict and provide on road building and deregulation of public transport to one that supports sustainable development through integrating the transport system to provide a choice of travel and transport modes. Integration of transport means achieving a better relationship between land uses to reduce travel distances and allow multi purpose trips, as well as supporting initiatives to encourage alternatives to the private car and heavy goods vehicles.

1.2.2 Both minerals operations and waste management can result in significant movement of heavy goods, although different aspects of both will have very differing transport requirements. For example, in terms of minerals, aggregates are often transported for short distances from the quarry by road; whereas higher priced minerals are often transported internationally, often via ports and rail. There are economic and environmental advantages in transporting large amounts of heavy materials by rail or water provided that there is the network capacity and adequate loading and reception facilities (this issue is also considered in the Minerals Topic Paper).

1.3 What’s the sustainability context?

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering transport in this SA. This context review meets a requirement of the SEA Directive1.

1.3.2 National guidance on sustainable development has a focus on transport, stating that transport programmes and land use policies should be integrated to help reduce growth in the length and number of motorised journeys and encourage alternative means of travel which have less environmental impact.2 Government guidance relating specifically to transport also promotes the integration of planning and transport at the national, regional, and local levels to promote

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more sustainable transport choices for both people and for moving freight; and enhance accessibility by public transport. Of particular relevance to minerals and waste, it states that:3

• land use planning should facilitate a shift in transport of freight to rail and water; • attention should be paid to the value of disused transport sites; and • traffic management should be designed to reduce environmental/social impacts.

1.3.3 In terms of the capacity of transport infrastructure, the Highways Agency cautions that the MWDF should not rely upon the provision of any additional capacity on the Strategic Road Network (SRN) in the future. Furthermore, direct access shall not be taken from the SRN. The Highways Agency highlight that ‘[w]hilst individually, small minerals and waste sites are unlikely to produce a significant impact on the SRN, when examined in combination either with other potential sites, their individual impacts will be compounded and they may then become materially significant. The transportation of waste in particular has the potential to generate a significant number of HGV trips, a large proportion of which are likely to use the SRN. Therefore, the HA is supportive of measures which seek to ensure close proximity between waste disposal sites and sources of waste. In addition, the MWDF should seek to promote transportation of waste by rail or waterborne modes wherever this may be possible.

1.3.4 Government guidance on minerals planning identifies impacts relating to ‘traffic’ as a potential ‘principal environmental impact’ of minerals working, and promotes:4

• recognition of the need to improve transportation within and from sites so as to minimise impacts to nearby receptors; • taking account of the benefit of supplying minerals locally; and • transport by rail and water where feasible, including through identifying and safeguarding potential loading and unloading depots and wharves.

1.3.5 The Regional Spatial Strategy (RSS)5 identifies a number of challenges, many of which are beyond the scope of the Kent MWDF to influence, with the exception perhaps of the key challenge of reducing impacts of the transport system on the environment. Policy T1 of the RSS is particularly important as it sets out the key requirement that development is located and designed in such a way that reduces average journey length and road casualties.

1.3.6 Specifically for Kent, the RSS sets out to improve the transport infrastructure within and to the Thames Gateway to maximise regeneration potential, East Kent to support economic regeneration and Ashford to support development. Specifically, Policy EKA8 considers the linkages between infrastructure provision and development in East Kent, whilst Policy KTG1 considers the forecast growth in car and freight traffic in the Thames Gateway. The RSS includes support for land side infrastructure to maintain and enhance the role of the ports of Dover (EKA5 makes specific reference to ‘reinstat[ing] … the rail link to the Western Docks’), Ramsgate and the Medway Ports, as well as the Channel Tunnel. The RSS also designates a number of ‘Regional Hubs’, which will be the focus of investment in the economy and housing, as well as multi-modal transport. The following Kent settlements have been designated as

3 ODPM (2001). Planning Policy Guidance 13: Transport [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/ppg13 (accessed 02/09) 4 CLG (2006). Minerals Planning Statement 1: Planning and Minerals [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/mineralspolicystatement5 (accessed 02/09) 5 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09)

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Regional Hubs: Ashford; Canterbury; Dover; Ebbsfleet; Maidstone; Medway Towns; Tonbridge; and Tunbridge Wells.

1.3.7 In relation to minerals, the RSS recognises that the management of transport demand is an important issue for the South East where much of the primary road network operates at, or above, capacity and because there is a shortage of freight paths on the rail network. However, regional policy is to encourage a modal shift to increase the proportion of minerals and manufactured products transported into and within the region by rail and sea. To achieve this, constraints will need to be overcome, and existing and new depot and wharf sites to handle materials in bulk will need to be safeguarded.

1.3.8 In terms of Kent’s ‘international gateways’, the Kent Local Transport Plan (LTP) 2 states that the major Kent ports and Channel Tunnel perform a pivotal gateway function to allow the movement of goods and people to and from Europe and also play a vital role in supporting the local, regional and UK economy. However, the generation of port traffic places substantial pressure on the county’s transport system and environment. If activity at the ports is to be promoted it must be done in a way that does not harm the economic, social and environmental fabric of the county. 6

1.3.9 The County strategy on shipping and inland waterways covers such things as: 7

• support for the development of short sea shipping services as an alternative to land transport and greater use of the Thames and the Medway as well as inland waterways for moving freight and materials; • international traffic through Kent being accommodated within the major international arteries (A2/M2, A20/M20, the CTRL and existing rail routes); • recognition of the importance of Kent’s major deep sea ports and support for the right standard of road and rail access to serve them; • support for proposals for port expansion to be assessed against criteria that includes economic, social and environmental impacts and the need; and • encouragement for freight traffic to move from road onto rail.

1.3.10 Finally, it is important to note that further information can be gained from Local Transport Strategies. KCC suggest that the following strategies are of particular strategic importance for the County: Swale; Ashford; Thanet; Canterbury; Dover; Tunbridge Wells; and Sevenoaks.

1.4 What’s the current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to transport in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent to other that of other geographical comparators, as well as considering how

6 KCC (2006). Local Transport Plan for Kent 2006 – 2001 [online] available at: http://www.kent.gov.uk/publications/transport-and- streets/ltp-provisional-plan.htm (accessed 02/09) 7 Ibid.

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the baseline varies at the sub-county scale, within the three sub-regional areas defined in Kent by the RSS. This section meets a key requirement of the SEA Directive.8

Current baseline

Road Traffic

1.4.2 The Kent Local Transport Plan states that, despite Kent’s towns being relatively small, traffic congestion constitutes a major issue. Traffic congestion problems occur mainly at peak hours and they are more significant in the areas of Maidstone, Canterbury and Tunbridge Wells. Traffic congestion problems also occur on motorways and trunk roads; the congested nature of the M25 and London itself create a blocking effect on Kent’s economy. 9

1.4.3 Figure 1 shows that total traffic in Kent has been rising year-on-year. Note that “All Live sites” reports only those sites where data is available in that given year - not necessarily year-on- year. “Constant data throughout” reports those sites that have provided data every year, making a year-on-year comparison possible. The number of sites has risen from 106 in 1999 to 118 in 2005.

Figure 1: Average Daily 24 Hour Flows at ATC Sites 1999 to 20071011

1.4.4 Figure 2 shows a thematic map of the Kent strategic road network, where road widths are diagrammatically proportional to traffic flows.

1.4.5 Figure 3 gives an indication of where in the county traffic is getting worse (most places) and where in the county it may be improving (for example, there may be some indication of improvement around Ashford and Thanet). The five locations that experienced the greatest growth in traffic between 2006 and 2007 (in descending order) are sites: 323 (Kemsley); 1182 (Whitfield); 73 (West Malling); 42 (Pluck’s Gutter); and 702 (Gravesend).

8 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected” 9 KCC (date unknown). Local Transport Plan for Kent 2006 – 2001 [online] available at: http://www.kent.gov.uk/publications/transport- and-streets/ltp-provisional-plan.htm (accessed 02/09) 10 KCC (2008). Kent Travel Report 2007 [online] available at: http://www.kent.gov.uk/static/publications/travel-report-07.pdf (accessed 02/09) 11 “All live sites” reports only those sites where data is available in that given year - not necessarily year-on-year. “Constant data throughout” reports those sites that have provided data every year, making a year-on-year comparison possible. The number of sites has risen from 106 in 1999 to 118 in 2005.

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Figure 2: Average inter-urban traffic flows, 200712

Figure 3: Automatic Traffic Count sites, 200713

12 KCC (2008). Kent Travel Report 2007 [online] available at: http://www.kent.gov.uk/static/publications/travel-report-07.pdf (02/09) 13 Ibid.

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1.4.6 Figures 4 - 5 consider traffic flows for the major urban areas in Kent. Dover and Maidstone stand out as having high flows of both car and HGV traffic.

Figure 4: Peak hour (7am to 10am) weekday inbound flow14

25000

20000

15000 Cars HGVs 10000

5000

r d e rs e ls ord aks ne at f ur tai ridge rt Dov no s sg Wel Ashford Da gbo Margate m nb e ravesen n To dg Canterbury FolkestoneG MaidstoneSeve ti Broa Ra ri Sit nb u T

Figure 5: 24 hour weekday two way flow15

120000

100000

80000

Cars 60000 HGVs

40000

20000

r d ry d e s te ls ne ate a o sen urn tair idge Dove e r Wel v nb Ashfordnterbu Dartfor kest gbo Marg oas o e ol T dg Ca F Gra MaidstoneSevenoaksttin Br Ramsg ri Si nb u T

14 Ibid. 15 Ibid.

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1.4.7 Figures 6 and 7 show that the number of freight vehicles passing through Dover has increased steadily over recent years, whilst the freight tonnage passing through the Channel Tunnel has been decreasing since 1998.

Figure 6: Freight Vehicles (HGVs) passing through Dover16

Figure 7: Freight Tonnages passing through the Channel Tunnel17

16 Ibid. 17 Ibid.

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1.4.8 Figure 8 shows that overall the number of HGVs entering the UK from the Continent through Kent has been increasing.

Figure 8: Total Number of Passengers, Cars & HGVs (millions) using Eurostar, Ports and Le Shuttle 1995 to 200718

1.4.9 Figure 9 shows the trend for road casualties on Kent roads (both Killed or Seriously Injured and slight casualities). It can be seen that there is a clear downward trend. Figure 10 considers the trend at a finer spatial scale. It is notable that Ashford, Shepway and Thanet Districts are not performing so well.

Figure 9: Casualties on roads for which KCC is responsible, 1990 - 200719

18 KCC (2008). Kent Travel Report 2007 [online] available at: http://www.kent.gov.uk/static/publications/travel-report-07.pdf (accessed 02/09) 19 Ibid.

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Figure 10: Reduction by district in casualties on highways for which KCC is responsible 2002 - 200720

Rail21

1.4.10 Kent County domestic rail network serves 99 stations, mainly east-west orientated, which provide easy access to central London and a good interchange with London Waterloo and London Bridge stations. There is a significant level of commuting into Central London, particularly from the western parts of the County. Since the opening of the Channel Tunnel Rail Link (CTRL), international high-speed rail services connect London with Continental Europe through Ebbsfleet and Ashford International Station, reducing significantly the journey time. The development of the County’s domestic and international rail networks since the opening of the Channel Tunnel in 1994 is shown in Figure 11.

20 Ibid. 21 KCC (2006). Local Transport Plan for Kent 2006 – 2001 [online] available at: http://www.kent.gov.uk/publications/transport-and- streets/ltp-provisional-plan.htm (accessed 02/09)

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Figure 11 Development over time of the county’s rail network22

1.4.11 The Channel Tunnel carried some 1.3 million lorries and just over 2 million cars on its shuttles in 2005 with trends similar to Dover’s – lorries increasing and passenger cars falling. The Tunnel also carries Eurostar services and in 2005, a record 7.45m passengers was recorded, due to the improved journey times and reliability of services following the opening of CTRL Phase 1. International rail freight services also uses the Tunnel but the amount of rail freight carried is disappointing at some 1.5m tonnes in 2005, despite the expectations that over 6 million tonnes of freight would be transported by rail annually. Only five of the 35 paths (in each direction) reserved for rail freight are used due to the poor level of service experience in France and the competition with road haulage which usually offers cheaper, faster and more flexible services. Improving the competitiveness of rail freight requires better service quality, more road/rail terminals in the South East and use of the CTRL. It was hoped that freight would use the CTRL from 2007, taking advantage of higher loading gauge on the line. The County Council will encourage more railfreight through the Channel Tunnel by supporting the road/rail terminal proposals at Howbury Park and the use of the CTRL for freight.

1.4.12 Another significant potential rail freight flow is through the Thames-port deep sea container port, where approximately 20% of the freight is currently transported by rail. Other smaller rail freight flows serve the depots in Hothfield, Allington and Cliffe.

22 MVA Consultancy (2008). Delivering the Future: Making the most of Kent’s new high speed rail service [online] available at: http://www.mvaconsultancy.com/publications/Kent's%20new%20High%20Speed%20rail%20service.pdf (accessed 03/09)

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Sea / Waterways23

1.4.13 UK port traffic has been growing steadily at just under 2% per annum over the last twenty years and Kent’s ports are amongst the busiest in the UK.

• The Port of Dover is one of the busiest international ports in Northern Europe, with a significant passenger, car and freight market. It is estimated that the Port of Dover employs over 24,000 people in the South East. There is planned expansion of Dover Port at the Western Docks. • The Port of London Authority covers 150km of coastline of the Greater Thames Estuary; it has 80 terminals, with 18 of them in Kent and is thought to provide 35,300 jobs and handles over 53 million tonnes of freight annually. The PLA incorporates the CdMR Dartford terminal, formerly Thames Europort, which until mid-2009 provided roll- on/roll-off freight services from the port to Rotterdam and Ostend. Due to falling freight volumes these operations, as of 2009, have been relocated to Purfleet. It is understood the Port of London Authority would welcome discussions with Kent County Coucil and Dartford Borough Council regarding the future use of the Dartford terminal.24 • Thamesport (Medway Unitary Authority (UA) area) was built at the turn of the nineties in a strategic position, where the River Medway meets the Thames Estuary. It is the fourth largest container port in the country with the opportunity for further landward expansion and port development subject to the protection of nature conservation interests. Further development at the port depends on improved road links via the A228 and increased rail link capacity. • Medway Ports includes the Port of Sheerness and Chatham Docks (Medway UA), which together saw a total throughput of 3.36 million tonnes in 2003. Sheerness has substantial opportunities to intensify port related activity within existing boundaries and, if required, to expand onto nearby industrial areas, although there are important nature conservation areas adjacent to the port. The Second Swale Crossing was opened in 2006 and has improved road access to the port, but improved rail access and facilities are still required. • Ramsgate restored the car ferry service to Ostend in July 2004 which was suspended in 1998. This is in addition to the freight-only service to Ostend. Due to the intense competition with Dover and the Channel Tunnel existing flows of cars and lorries are much reduced from those in 1996. There is a new catamaran service to Boulogne to be introduced this summer (2009).25 • Folkestone There are currently no cross-Channel passenger or freight services operating from Folkestone Harbour.

23 Sourced from KCC (2006). Local Transport Plan for Kent 2006 – 2001 [online] available at: http://www.kent.gov.uk/publications/transport-and-streets/ltp-provisional-plan.htm (accessed 02/09) & Kent Coastal Network, Kent Coastal Fact Sheets-Ports [online] available at: http://www.coastalkent.net/facts.php (accessed 02/09) 24 Port of London Authority consultation response (2009) 25 KCC (2009) Personal communication.

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Future baseline

1.4.14 Total amounts of traffic on the road in Kent are increasing and do not currently show any sign of levelling off. However, there are significant changes afoot in the county, with significant growth in the Thames Gateway, Ashford and the other towns of East Kent, which will be supported by massive investment in transport infrastructure. Perhaps the most influential change to the transport network will come from the completion of the high speed rail network, which will result in reduced journey times from much Kent, particularly around Ebbsfleet in the Thames Gateway, and for Ashford, Folkestone, Dover and Canterbury, from which trains will travel to London along the High Speed One / CTRL route. The effect of high speed rail is discussed more in the Employment and Economy Topic Paper.

1.4.15 In terms of the transport of minerals there are some clear existing trends, particularly relating to a clear market preference to transport minerals from abroad by ship or HGV via the Channel Tunnel, rather than by making use of rail freight through the tunnel. However, there are moves afoot to encourage greater transport of rail freight from the Continent. There is also some potential and planned expansion of Ports within the region, although some Ports are also constrained by such things as nature conservation and transport infrastructure considerations.

1.4.16 The RSS suggests that the trend is for local minerals production to continue to concentrate on fewer, larger sites leading to distances to markets increasing and, with the region largely dependent on hard rock imported over long distances, pressures on the transport network intensifying. 26 Efforts to maximise the use of local land-won aggregates and well located wharves should deliver benefits in terms of local supply. It is understood, however, that some parts of the region have particularly significant development needs, notably the regional growth areas, that cannot be adequately supplied from available local mineral resources, necessitating intra or extra-regional imports.

Current and future situation in sub-county areas

1.4.17 The RSS defines sub-regional areas, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These sub-areas were identified primarily on economic grounds.27 Policies are developed in the Plan for two of these areas to meet the following overarching objectives, which also have clear implications for transport:

• East Kent and Ashford – regeneration (East Kent) and growth area (Ashford) • Kent Thames Gateway – growth and regeneration

1.4.18 Table 1 considers current and possible future baseline conditions in each of these sub-areas.

26 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09) 27 See a further discussion of the process of identifying sub-areas in the Economy and Employment Topic Paper

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Table 1: The sub-county baseline East Kent and Ashford28

East Kent is served by the A2 and M20 which provide the strategic east to west highway corridors across the County and link the principal urban areas, ports and airports to London, the M25 and other parts of the UK. In congestion terms, the city of Canterbury suffers from the worst congestion in East Kent due to local traffic, especially on the inner ring road and inner radial routes. In response, appropriate measures are included in the LTP Five Year Integrated Programme. Another congested location in East Kent is around the new “town centre” in Thanet at Westwood Cross. The LTP identifies the A254 Ramsgate–Westwood– Margate corridor having the most pressing need for improvement. The RSS identifies that key issues to be addressed are: • new public transport and highway networks at Ashford to support the Growth Area; • improved access and management to Dover to allow management of international traffic, reduce congestion within the town, and support allocated sites to the north of the town; and • improved access to Canterbury to assist the economic contribution of the city to be realised and reduce pressure The RSS Proposed Changes makes reference to ‘East Kent Access’ as a strategic transport infrastructure priority. Finally, it is important to note that there is the potential for the expansion of Lydd Airport. Increased airport related traffic could potentially have implications for minerals operations on Romney Marsh.

Kent Thames Gateway29

The A2/M2 corridor forms the key east/west corridor along the Thames Gateway which provides a strategic link from London and the wider motorway and trunk road network to north Kent, east Kent and the Port of Dover. The A2/M2 corridor is being upgraded in several phases to tackle existing congestion and accommodate future demand. Improvements for the A2 sections between Cobham and the M25 (A282) junction have been implemented by the Highways Agency as well as the widening of parts of the M25, including the section between junctions 1b (Dartford) and 3 (Swanley). In the east of the Thames Gateway area, the A249 links the Port of Sheerness to the M2 and the Highways Agency recently implemented major improvements including the new Swale Crossing. The Channel Tunnel Rail Link (CTRL) includes Ebbsfleet International Station which will provide a key transport hub in the Thames Gateway. In addition to routes from London to continental Europe, from 2009 the CTRL will also be used by high speed domestic services which will improve journey times from key stations in the Thames Gateway, including Gravesend. The RSS identifies that a key challenges are: • to provide adequate infrastructure and services to support sustainable growth; • to promote the right links with the wider regional, national and international community; and • resolving problems of access and congestion, and the capacity of public transport. The RSS goes on to identify that the efficient functioning of the Kent Thames Gateway depends on reliable east-west road and public transport routes, and the growth already planned depends entirely on their timely improvement. Efficient north-south movement by public transport and by road will be of increasing importance even with the existing level of planned growth. Regional and international traffic will be affected by congestion on the transport networks serving development in the Growth Area. Therefore, there are regional and national reasons to improve transport capacity. While the Lower Thames Crossing

28 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 29 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2.

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would form an inter-regional route it would have important implications for the local economy of the sub- region and would support the planned growth in north Kent. Key transport themes for the sub-region are: • A2/A282/M2 corridor schemes to improve connectivity through the area and with London and access from east-west routes to open up development sites; study of Thames Crossing options; and • Crossrail and CTRL related rail improvements and additional capacity.

Rest of Kent30

In West Kent the strategic north-south link is provided by the A21 which links London to Hastings and the south coast. The main east to west strategic links are provided by the M20, A20(T) and M26 which give access to the M25 and routes to other parts of the United Kingdom. In the south of the area the M20 motorway forms a communication corridor for both international traffic, via Kent's major ports, and domestic traffic accessing the rest of the UK, via the M25/M26 corridor. Traffic flows along the M20 corridor vary, ranging from over 40,000 vehicles per day (vpd) in Shepway to over 100,000 vpd in Maidstone Borough. Maintaining good road-based links along this corridor is essential to Kent's economy, and it is also very important to the UK's trade with the rest of the EU and the growth of Kent's gateway function.31 The importance of the M20 corridor is underlined by the impact of any disruption to traffic flows along its length. In the future any measures aimed at maintaining the function of the M20 corridor, or at ensuring any disruption to traffic is minimised, must include a satisfactory alternative to Operation Stack. Kent Police and the Highways Agency enforce Operation Stack when cross-channel services are disrupted, often as a result of industrial action in France, adverse weather conditions in the Channel or other emergency situation. It involves the closure of the M20 motorway in Shepway and the diversion of all non- heavy goods vehicle traffic onto the local road network. The closed section of the motorway is then used as a parking area to accommodate stationary heavy goods vehicles. The impact of Operation Stack is widespread and affects both Kent and the South East region.

30 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area. 31 Sourced from KCC (2006). Local Transport Plan for Kent 2006 – 2001 [online] available at: http://www.kent.gov.uk/publications/transport-and-streets/ltp-provisional-plan.htm (accessed 02/09)

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1.5 What are the key sustainability issues?

1.5.1 Table 2 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 2: Key sustainability issues Key Issue Discussion

Much of the primary road network operates at, or above, capacity and there is a shortage of freight paths on the rail network

There is a need to This should apply to both minerals and waste, although there are many instances adhere to the where transport of materials of considerable distances will be a necessity. proximity principle wherever possible

There is a need to This requires safeguarding and development of key infrastructure at transport increase the amount interchanges, particularly at docks as much of the national minerals resource of waste and, in comes in from abroad by ship. Where possible further opportunities should be particular, minerals sought for transferring minerals and waste by inland waterway and along the transported by rail. coast by sea.

There is a need to There is a need to take account of nearby sensitive receptors and existing reduce the congestion and pollution hotspots, including in towns such as Maidstone and environmental and around the Port of Dover. The Kent MWDF should seek to contribute to making social impacts of roads safer. HGV transport.

The Kent MWDF The RSS sets out to improve the transport infrastructure within and to the must not hinder Thames Gateway to maximise regeneration potential, East Kent to support wider sub-county economic regeneration and Ashford to support development. The Kent MWDF objectives relating to should recognise and support the aims of regional hubs. improving transport.

1.6 What decision-making criteria should make up the SA framework?

1.6.1 The South East Regional Sustainability Framework includes the following objectives relating to transport:

“To improve accessibility to all services and facilities including the countryside and the historic environment” “To improve the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and by promoting policies which reduce the need to travel”

1.6.2 It is helpful to take account of established regional sustainability objectives. However, bearing in mind the scope of influence of the Kent MWDF it is thought that there is a need to tailor these objectives, so that they are most suited to capturing the likely significant effects of the plan. Taking account of the key sustainability issues identified in Section 1.5 above, it is thought that an appropriate sustainability objective for use in this SA is:

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Reduce and minimise unsustainable transport patterns and facilitate the transport of minerals and waste by the most sustainable modes possible

1.6.3 When appraising the effects of the plan in terms of this objective, the following sub-objective should also be taken into account:

• Minimise minerals and waste transport movements, journey lengths and encourage transport by rail and water. • Ensure that minerals and waste transport does not impact on sensitive locations, including locations already experiencing congestion and locations where planned growth or regeneration is reliant on good transport networks.

1.7 What further data is required?

• Areas of sensitivity to road freight

Scoping Report - Transport 18 March 2010

Revision Schedule

Scoping Report – Waste Topic Paper March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Consultant Associate Technical Director Ian Brenkley Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Table of Contents

1 Waste...... 3 1.1 Introduction...... 3 1.2 Background...... 3 1.3 What’s the sustainability context?...... 4 1.4 What’s the current and (likely) future sustainability baseline? ...... 8 1.5 What are the key sustainability issues?...... 16 1.6 What decision-making criteria should make up the SA framework?...... 17 1.7 What further data is required? ...... 17

List of Tables

Table 1: MSW exported from Kent County in 2007/08 ...... 11 Table 2: Waste capacity in Kent in 2007/08 and additional capacity granted by type...... 12 Table 3: The sub-county baseline ...... 14 Table 4: Key sustainability issues...... 16

List of Figures

Figure 1: Population, households and MSW arisings in Kent...... 9 Figure 2: Rate of growth in total GVA and MSW managed in Kent...... 9 Figure 3: Destination of MSW in Kent ...... 10 Figure 4: Future predicted waste recovery ...... 10 Figure 5: MSW recycled and composted by Kent district ...... 11

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1 Waste

1.1 Introduction

1.1.1 This is Topic Paper 13 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of waste; describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to waste and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 Waste has traditionally been seen as an unavoidable by-product of increased prosperity and economic activity. In more recent years the development of new products and materials, and changes in the way they are used has led to a steady growth in the amount and a change in the nature of the waste produced. Subsequently, there has been a shift in thinking regarding how waste should be managed.

1.2.2 Integrated waste management is now seen as best practice. Integrated or sustainable waste management attempts to re-use where possible, else segregate the various components of the waste stream and manage each in an environmentally sound and economically efficient manner, making use of waste as a resource wherever possible. Integrated waste management considers the following practices for waste management:

• Waste reduction - the design, manufacture, purchase, or use of materials (such as products and packaging) to reduce the amount or toxicity of waste generated. • Recycling - materials are collected and used as raw materials for new products. • Composting - a form of recycling where organic wastes are diverted from disposal. • Energy from waste processes - in specially designed facilities reduce the bulk of waste and provides the added benefit of energy recovery. • Landfill - will continue to be, a major component of waste management.

1.2.3 The key focus of this topic paper will be to examine issues related to current (and potential future) patterns of waste production and management, so that implications for the Kent MWDF can be established. By planning for all areas of the waste hierarchy it will be possible for the MWDF to support integrated waste management, allowing those involved in integrated waste management to take the most sustainable approach. Minerals waste is another, specific waste stream with potential environmental implications, and so requires a degree of consideration, although it is an issue of less strategic importance.

1.2.4 This topic paper will also look at the ways in which waste is currently managed in Kent. Disposal of waste has been predominantly to landfill, which has led to environmental problems, including greenhouse gas emissions and liquid pollutants (although modern landfill sites are now much more highly regulated). Increasing concern about the environmental impacts of landfill has led to investigation into alternatives that are more sustainable.

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1.3 What’s the sustainability context?

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering waste in this SA. This context review meets a requirement of the SEA Directive.1

1.3.2 Government guidance on planning for sustainable waste management describes the pivotal role of ‘positive planning’ in providing sufficient opportunities for new waste management facilities of the right type, in the right place and at the right time.2 The UK Waste Strategy (2007) sets out the Government’s vision of a waste collection and treatment infrastructure where:3

• increasing amounts of waste are separated by householders and other producers; • greater value is derived from unwanted products that can be reused; • valuable materials find ready markets as recyclate; • other wastes have electricity and heat recovered where appropriate; • better joining up between municipal and private sectors enables provision of local as well as regional facilities, with plant treating both merchant and municipal wastes; and • properly managed landfill (with capture and use of methane gas emitted) takes those wastes from which no useful value can be extracted economically.

1.3.3 The Regional Spatial Strategy (RSS)4 adopts a ‘resource management’ and ‘zero waste’ approach reflecting the waste hierarchy, which prioritises reduction, re-use, recycling and recovery of value before disposal is considered. This means treating materials that are currently perceived as waste as a resource, with value. It also means taking account of the use of resources as a whole, particularly energy, in managing waste. In addition, new restrictions on the types of waste that can be accepted at landfill sites are creating a need for increased capacity in alternative management methods. The Plan recognises that this also represents an economic development opportunity for the region, consistent with the policy of ‘smart growth’.

1.3.4 The RSS promotes the establishment of resource recovery systems, which will require new infrastructure to recover, reprocess and transform waste material into useful products. This requires a focus on key material streams (e.g. aggregates, food waste, paper and metals), rather than waste origins i.e. household/commercial/construction. The optimal management solution will vary according to the individual material resource streams and local circumstances. In particular, recycling and recovery requires a switch to industrialised waste reception, storage and processing, including a range of facilities and activities such as Materials Recovery Facilities (MRFs), aggregates processing, composting, anaerobic digestion and other energy recovery plants.

1.3.5 Self-sufficiency can be defined as the provision of sufficient waste management capacity to handle the amount of waste arising within an area. Policy W3 of the RSS promotes regional self-sufficiency, whilst Policy W4 promotes sub-regional self-sufficiency, although it is

1 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes. 2 ODPM (2005). Planning Policy Statement 10: Planning for Sustainable Waste Management [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/planningpolicystatement10 (accessed 02/09) 3 Defra (2007). Waste Strategy 2007 [online] available at: http://www.defra.gov.uk/environment/waste/strategy/ (accessed 02/09) 4 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09)

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recognised that there will be instances when it is appropriate to contravene these principles (e.g. hazardous waste). Kent and Medway together form a sub-region, and so it can be seen that sub-regional self sufficiency is not just the responsibility of the Kent MWDF. Furthermore, it is important to recognise that Kent is on the borders of three planning regions, which has implications for the absolute interpretation of regional and sub regional self sufficiency. It is stated that the achievable level of self-sufficiency will depend principally on: the characteristics of the sub-region; the nature of the waste stream; and the type of facility (wider catchment areas are necessary to justify more specialised reprocessing facilities, e.g. MRFs).

1.3.6 Policy W5 sets targets for diversion of waste from landfill, including a requirement that 79% of waste is diverted from landfill by 2015 and 86% by 2025, taking into account Landfill Directive targets for diversion of biodegradable municipal waste and Waste Strategy for England 2007 targets for recovery of municipal solid waste and recycling /composting. Similarly, Policy W6 requires a large increase in the amount of all waste recycled and composted from around nine million tonnes in 2002/3 (35% of all waste) to over 15 million tonnes by 2015 (55%) and almost 20 million tonnes by 2025 (65% of all waste).

1.3.7 Policy W6 promotes the identification of specific sites to allow for recycling, composting, reprocessing and transfer facilities, and safeguarding to protect them from other development since high land prices can hinder the development of waste recycling facilities. Sites should generally be located in or near to urban areas, close to the main sources of waste, although a range of facilities will also be needed to serve rural areas. Consideration should be given to upgrading or expanding existing sites, on the presumption that these sites are suited to community needs, have an established waste management use, may have necessary infrastructure, and may be more likely to gain planning permission. Co-location of facilities (e.g. in resource parks) will enable a more integrated approach to all wastes to be developed (possibly leading to economies of scale), assisting reprocessing and development of markets for recycled materials. Inert waste recycling facilities can be acceptable on some employment sites particularly if the site is in close proximity to sources of waste. In these cases, they will need to operate to higher environmental standards.

1.3.8 Policy W7 sets out waste management capacity requirements for each Waste Planning Authority. The Policy states that in bringing forward and safeguarding sites for waste management facilities, authorities should consider the type, size and mix of facilities that will be required, taking into account:

• activities requiring largely open sites, such as aggregate recycling and open windrow composting; • activities of an industrial nature dealing with largely segregated materials and requiring enclosed premises, such as materials recovery facilities, dis-assembly and re- manufacturing plants, and reprocessing industries; • activities dealing with mixed materials requiring enclosed premises, such as mechanical- biological treatment, anaerobic digestion and energy from waste facilities; and • hybrid activities requiring sites with buildings and open storage areas, including re-use facilities and enclosed composting systems.

1.3.9 The supporting text goes on to state that there is an immediate and acute shortfall in the capacity required to achieve the ambitious targets for recycling, composting and other forms of recovery, including energy recovery, and the overall diversion of waste from landfill. The

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urgency for this is compounded by the long lead-time for many facilities and difficulties in obtaining planning permission.

1.3.10 Policy W10 points out that greater resource recovery requires a small number of large scale specialist facilities serving larger catchments than waste planning areas or even the region as a whole.

1.3.11 Policy W12 encourages the development and demonstration of anaerobic digestion and advanced recovery technologies that will be expected to make a growing contribution towards the delivery of the regional targets over the period of the Plan, assuming that they operate to the required pollution control standards. It is also stated that proposed thermal facilities should, wherever possible, aim to incorporate combined generation and distribution of heat and power. Box 1 considers available energy from waste technologies.

Box 1: Energy from waste technologies

There are two basic techniques for recovering energy from waste in conjunction with combustion. The mass burn process involves waste being incinerated, with the heat released used to raise steam. This is then fed to district heating or used to power a turbine for electricity generation. Ferrous metals can be recovered for recycling from the residue. Residues amount to 20% of the original input and therefore require much less landfill space. The second system is a two stage 'refuse-derived fuel' process. Incoming waste is shredded and screened to remove the incombustible part, including metal for recycling. The products are a fuel fraction which can be burned in industrial boilers; either on site or at a distant location; and a reject fraction which must be landfilled. Anaerobic Digestion is an additional method that creates energy from biodegradable waste without the use of a combustion process. This process converts the organic part of household waste, producing a 'biogas', for use as fuel, a liquid which can be used as a fertiliser and compost suitable for use as a soil conditioner. This technology is relatively unproven and on a small scale. The Government in its Waste Strategy 2007 urges local authorities to assess whether anaerobic digestion can form a part of their waste strategies.

1.3.12 Policy W13 puts forward landfill capacity requirements for the region to meet the continuing but declining requirement, ensuring that landfill gas collection and energy recovery are standard practice at all non-inert landfill sites (as some biodegradable waste will continue to be disposed of and degrade to release methane-rich landfill gas).

1.3.13 Policy W14 highlights that for restoration of waste sites, as well as minerals sites, can help achieve biodiversity targets.

1.3.14 Policy W15 sets out the need for a range of hazardous and other specialist waste facilities in the region, mentioning that there is a particular need to hazardous waste landfill capacity in the south east of the region. It also notes that management of hazardous waste will change significantly in nature over the next few years.

1.3.15 Policy W16 promotes the identification and safeguarding of infrastructure facilities, including sites for waste transfer and bulking facilities, essential for the sustainable transport of waste materials. Use of rail and water-borne transport with appropriate depot and wharf provision should be encouraged wherever possible, particularly for large facilities. Appropriate location of facilities such as at inter-modal terminals where materials can be transferred from road to rail or water, can reduce transport.

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1.3.16 In terms of the location of waste management facilities Policy W17 requires that locations for waste management facilities, give priority to safeguarding and expanding suitable sites with an existing waste management use and good transport connections. The suitability of existing sites and potential new sites should be assessed on the basis of the following characteristics:

• Good accessibility from existing urban areas or major new or planned development. • Good transport connections including, where possible, rail or water. • Compatible land uses, namely: active mineral working sites; previous or existing industrial land use; contaminated or derelict land; land adjoining sewage treatment works; and redundant farm buildings. • Be capable of meeting a range of locally based environmental and amenity criteria.

1.3.17 Waste management facilities should not be precluded from the Green Belt and small-scale waste management facilities for local needs should not be precluded from Areas of Outstanding Natural Beauty where the development would not compromise the objectives of the designation.

1.3.18 This Kent Joint Municipal Waste Management Strategy does not include information on specific sites or the location of waste treatment facilities, however, it does include some policies that are of some relevance. In particular the following:

• Kent County Council will take a pragmatic approach to trading landfill allowances, being willing to trade, but not reliant on trading for compliance or essential income. • Kent will procure landfill capacity to meet the need for the disposal of residual waste for which recovery capacity is not contracted. • Where it is cost-effective, Kent will exceed its statutory targets for diversion of biodegradable municipal waste from landfill in order to preserve landfill void space in the County. • The transfer station network will be improved across Kent to promote the efficient transport of wastes for treatment, recovery and disposal. • The KWP will work to secure composting capacity including in-vessel in the County to enable the authorities in the east of Kent to provide an efficient and costeffective service for managing compostable wastes. • The recycling and composting performance of HWRCs will be improved, reaching 60% by 2012/13, while maintaining high standards of customer service.

1.3.19 Finally, it is important to note that only the saved policies of the Kent Waste Local Plan (adopted March 1998) apply in their entirety. These policies cover the period to 2011, and will continue to apply until such time as it is replaced by the Kent MWDF.

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1.4 What’s the current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to waste in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent to other geographical areas, as well as considering how the baseline varies at the sub-county scale, within three sub-regional areas defined in Kent by the South East Plan. This section meets a key requirement of the SEA Directive.5

Current baseline6

1.4.2 The majority of waste produced in Kent is not MSW, but is in fact within the commercial and industrial (C&I) and construction, demolition and excavation (CDE) waste streams. One study undertaken for KCC suggested that the current amount of C&I waste could currently be between 1,712,000 - 1,866,000 tonnes and the current CDE waste arisings could currently be between 2,600,000 – 2,678,000 tonnes. However, these figures are currently under review. In particular, there is other evidence to suggest that this figure for C&I waste could be as much as 40% too high.

1.4.3 By comparison, MSW arising in Kent peaked at just over 800,000 tonnes in 2004 – see Figure 1. MSW waste arisings will be a particular focus of this paper in recognition of the good data that is available and also strong trends that can be witnessed with regard to past and predicted future arisings.

1.4.4 Historically there has been a relationship between growth in the number of households and growth in MSW arisings. However, Figure 1 suggests that this relationship has faltered in Kent since 2004-05 as MSW arisings have seen a negative rate of growth whilst population and households have continued to grow. A continuing increase in population and households alongside a fall in MSW arisings indicates that the rate of per capita and per household waste production beyond 2005 has fallen.

5 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected” 6 Unless otherwise stated, data sourced from - Minerals and Waste Annual Monitoring Report (2007/08) [online] available at: http://www.kent.gov.uk/NR/rdonlyres/618A7EEA-C096-4CEE-B031-2C2807A943E3/0/kentamr08.pdf (accessed February 2009)

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Figure 1: Population, households and MSW arisings in Kent

1.4.5 Growth in MSW has also traditionally been associated with economic growth. However, Figure 2 shows that this relationship faltered in 2003, when the rate of growth in MSW arisings fell significantly alongside an increasing rate of growth for GVA. Since then the relationship appears to be weaker than previously with both indicators moving in the same direction but with a substantial difference between the two rates of growth.7 This provides only a limited picture as only data to 2005 was available.

Figure 2: Rate of growth in total GVA and MSW managed in Kent

1.4.6 Figure 3 shows the destination of MSW arisings in Kent for recent years. Although the amount of waste deposited in landfill has decreased, landfill is still the main MSW management option. The 2008 44.6% of waste diverted from landfill in 2008 represents a slight increase on the

7 KCC (2008) Minerals and Waste Annual Monitoring Report [online] available at: http://www.kent.gov.uk/NR/rdonlyres/618A7EEA- C096-4CEE-B031-2C2807A943E3/0/kentamr08.pdf (accessed 05/09)

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figure of 44.4% for 2006/07, and a substantial increase compared to 2005/06 when only 28.1% of household waste was diverted from landfill.

1.4.7 Between 1997/98 and 2005/06, the amount of household waste recycled in Kent excluding hardcore increased from 11% to 28% and the amount recycled including hardcore increased from 12% to 32%. Recycling rates have continued to increase since 2005/06.

Figure 3: Destination of MSW in Kent

1.4.8 Figure 4 shows that the amount of MSW being sent for energy recovery was expected to increase substantially between 06/07 and 07/08. However, Figure 3 shows that the amount of energy recovered from waste actually has declined over this time period. This is as a result of the Energy from Waste plant at Allington experiencing technical difficulties during commissioning. However, this is expected to increase again in 08/09. Allington is expected to take substantially more MSW from West and Mid Kent, which should reduce the amount of waste being sent to landfill from these areas.

Figure 4: Future predicted waste recovery

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1.4.9 Between 2004/05 and 2005/06 the percentage of household waste that was recycled and composted increased in every district in Kent. This percentage increased further between 2005/06 and 2006/07 (April to September) in all districts except Thanet where it decreased. The district with the highest recycling rate in 2006/07 (April to September) was Canterbury with 46% - see Figure 5.

Figure 5: MSW recycled and composted by Kent district8

1.4.10 The RSS identifies Kent and Medway as having the largest deficit in recycling (including construction and demolition waste) and composting capacity of any Waste Planning Authority in the South East. However, the RSS also points out that there is currently a large surplus of recovery facilities. Kent exports a total of 26% of its waste, the majority of which is landfill - see Table 1. It is also notable that Kent only manages about 36% of its own green waste (see Kent MWDF Annual Monitoring Report for further discussion).

Table 1: MSW exported from Kent County in 2007/08

Total MSW Tonnage MSW % of waste Material tonnage exported stream exported managed by KCC Green waste 54,836 85,528 64.11 Recyclables 38,602 225,635 17.11 Landfill 112,238 424,000 26.47 Total 205,676 798,922 25.74

1.4.11 Residual material continues to be sent from Kent for landfill outside the county, suggesting a lack of capacity within Kent, although the amount exported has reduced since last year. This reflects increased diversion from landfill within Kent and the use of the Allington Energy from Waste facility during its commissioning. In future years the amount of residual material sent for landfilling outside of Kent is likely to drop significantly as this plant becomes fully operational. There will still be a need to landfill a small amount of material which is not suitable for Allington,

8 See http://www.kent.gov.uk/environment/recycling-rubbish-and-waste/managing-waste/facts-and-figures.htm (accessed 05/09)

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such as bulky wastes from Household Waste Recycling Centres. It is expected that this small amount of waste can be landfilled in non-hazardous landfills in Kent.

1.4.12 In 2007/08 it is reported that KCC granted permission for 30 additional waste treatment applications, many of which were for minor amendments to existing permissions9, however, one of which was a joint mineral and waste application. Eight of these applications related to increases in capacity through either new facilities or extensions to existing facilities. These sites are distributed throughout the county, with 3 in Tonbridge and Malling, 2 in Dartford, 2 in Ashford, and 1 in Swale. Table 2 shows the type, the number and the capacity of the existing waste management facilities, as well as the new applications and the capacity granted in 2007/08.

Table 2: Waste capacity in Kent in 2007/08 and additional capacity granted by type

Type of facility Number of sites Capacity Capacity granted in (tonnes) 2007/08 (tonnes) Composting 7 191,847 50,000 Recycling 9 281,099 25,000 C&D Recycling 25 2,098,087 200,000 Metal/ELV Facility 45 895,888 24,960 Treatment 7 226,953 0 Incineration 6 565,555 0 Inert Landfill 16 19,348,404 9,750 Non-Hazardous Landfill 2 5,474,500 0 Hazardous Landfill 2 2,160,906 0 Transfer facility 62 2,164,787 20,000 Wastewater Treatment - - 3,000 Dredging disposal - - 562,500 Other 53 3,304,454 - Total Capacity 234 36,712,480 1,450,210

1.4.13 The majority of new capacity comes from new sites rather than development at existing sites. The permissions granted at existing sites enabling increased capacity relate to composting and dredging disposal. Permissions granted at new sites all relate to waste management methods further up the waste hierarchy than landfill, apart from one permission for a very minor land raise to alleviate land drainage problems.

1.4.14 In terms of the distribution of existing facilities, Transfer Stations are the most numerous and all Districts in Kent have this type of facility. This reflects the economics of the waste management industry where relatively small specialised vehicles collect waste and the waste is then bulk loaded at Transfer Stations into larger vehicles for transport to other waste

9 KCC (2009) Personal communication.

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management facilities. The second most numerous waste activity, again, found in all districts, is Metal/ELV (end of life vehicles) facilities. Whilst fewer in number, recycling sites are found in all Districts apart from Tonbridge and Malling. This is the only district that does not have a Household Waste Recycling Site. The more specialised, less numerous activities are generally the activities of non-hazardous landfill, hazardous landfill, incineration, and treatment. These types of facility are more specialised either by siting requirements or by process and have larger catchment areas. There is an uneven distribution of composting facilities throughout the county, with the districts of Ashford, Dartford, Dover, Gravesham and Thanet not containing any composting sites. Whilst there are 4 sites in the west of the county and 3 in the east, the west of the county has over twice the maximum annual capacity of the east. There is an even more pronounced disparity in the distribution of in-vessel composting.10 There are only two facilities in the county, located in Tonbridge and Malling and in Swale. This points to the need for another facility in the east of the county.

1.4.15 The locational distribution of inert landfills and C&D recycling facilities, both of which receive waste from the construction industry also exhibits significant variation. There are 10 inert landfills in the west of the county and only 6 in the east. The location of C&D recycling facilities is weighted in the other direction with 17 of the sites being in the east of the county and 9 in the west. This highlights the lack of provision in the east of the county for inert disposal.

Future baseline

1.4.16 The RSS identifies that one of the most significant issues facing the region is the growing amount of waste and how to manage it. It is stated that if current trends continue, landfill capacity will be used up within a decade, valuable resource potential will be wasted and waste management and environmental problems created for the future. However, it is noted that, in Kent, waste produced per household may have peaked, and may decrease in the future. However, this does not lessen the urgency to put in place the facilities to ensure that waste is diverted from landfill and used as a resource. Whilst landfill remains the dominant means for disposing of residual MSW this is decreasing with composting and recycling continue to play a greater role. Exports of MSW material for landfilling, composting and recycling continues. Changes in MSW contracts and full commissioning of the Allington Energy from Waste Plant is likely to alter the disposal routes for MSW in Kent and reduce the amount of material being exported outside the county. Information on CI disposal routes, particularly those outside of Kent, is not readily available.

Current and future situation in sub-county areas

1.4.17 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These areas were identified primarily on economic grounds, but provide a useful spatial framework to consider other elements of the sustainability baseline. Table 3 considers current and possible future baseline conditions in each of these sub-areas.

10 This method of composting is required to enable kitchen wastes, and green waste containing kitchen waste, to be composted.

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Table 3: The sub-county baseline11

East Kent and Ashford12 Composting facilities: Treatment sites: Non-hazardous landfill: • Canterbury (1) • Canterbury (2) • Canterbury (1) • Shepway (1) • Thanet (2) Transfer sites: • Recycling sites: Incinerators: • Ashford (6) • Canterbury (1) • Ashford (1) • Canterbury (5) • Shepway (1) • Dover (1) • Dover (10) • Thanet (1) Inert landfill: • Shepway (4) Recycling sites (C&D) • Canterbury (2) • Swale (1) • Ashford (2) • Dover (1) • Thanet (4) • Canterbury (1) • Shepway (1) • Dover (2) • Swale (1) • Swale (2) • Thanet (1) • Thanet (2)

Kent Thames Gateway13 Composting facilities: Treatment sites: Hazardous landfill: • Swale (1) • Swale (3) • Dartford (1) Recycling sites: Incinerators: • Swale (1) • Dartford (1) • Dartford (1) Transfer sites: • Swale (2) • Swale (1) • Dartford (9) Recycling sites (C&D) Inert landfill: • Gravesham (1) • Dartford (3) • Dartford (3) • Swale (5) • Swale (5)

In the Kent Thames Gateway sub-county area Policy KTG1 states that there should be high standards for the design and sustainability of new communities, and for improvement of the existing urban areas, reflecting the riverside and historic character of the area. This may have implications for decisions relating to the type and location of waste management facilities.

11 Unless otherwise stated, data sourced from - Minerals and Waste Annual Monitoring Report (2007/08) [online] available at: http://www.kent.gov.uk/NR/rdonlyres/618A7EEA-C096-4CEE-B031-2C2807A943E3/0/kentamr08.pdf (accessed February 2009) 12 This area comprises the Districts of Thanet, Dover, Canterbury and Shepway, as well as the eastern halves of Ashford and Swale. 13 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2.

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Rest of Kent14 Composting facilities: Treatment sites: Non-hazardous landfill: • Sevenoaks (2) • Tonbridge and Malling (1) • Sevenoaks (1) • Tonbridge and Malling (1) Incinerators: Transfer sites: • Tunbridge Wells (1) • Maidstone (1) • Maidstone (3) Recycling sites: • Sevenoaks (1) • Sevenoaks (5) • Maidstone (1) Inert landfill: • Tonbridge and Malling (5) • Tonbridge and Malling (1) • Ashford (1) • Tunbridge Wells (3) Recycling sites (C&D) • Maidstone (1) • Ashford (1) • Tonbridge and Malling (5) • Maidstone (1) • Sevenoaks (1) • Tonbridge and Malling (4)

A major Waste to Energy Facility has been built at Allington Quarry, near Maidstone. The facility is currently under going testing and commissioning and will be fully operational later in 2009. According to the scheme promoters, the site will receive 325,000 tonnes per year of household waste (max capacity 500,000 tonnes) from the Council areas of Maidstone, Sevenoaks, Tunbridge Wells, Tonbridge and Malling, Dartford, Gravesham and Swale (Kent’s domestic waste production is approximately 800,000 tonnes a year); and generate up to 43 megawatts per hour of electricity. The area of the site is 84 acres, of which 67 acres will be progressively turned into parkland. Up to 291 HGVs will visit the site every day. Ash generated will equate to about 25% of waste by weight. The site has taken approximately 24 months to build, and is now undergoing 6 months of testing and commissioning.15

14 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area. 15 Kent Enviropower [online] available at: http://www.kentenviropower.co.uk/default.asp (accessed 03/09)

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1.5 What are the key sustainability issues?

1.5.1 Table 4 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 4: Key sustainability issues

Key Issue Discussion

Divert waste from Allow for integrated waste management through the coordinated treatment of landfill and seek to different waste streams, allowing waste management as high as possible on the maximise the value waste hierarchy. Ensure that valuable materials find ready markets as recyclate. of waste as a Continue to facilitate maximum recovery of heat and energy from waste, and resource encourage the development and demonstration of anaerobic digestion and advanced recovery technologies (although Kent is currently performing above what is required by the South East Plan). Where possible, support the continued decrease in waste generation.

Put in place the Waste should be managed close to source where possible. Equally, however, facilities and there are issues of deliverability to consider. Deliverability is key to ensuring infrastructure that good waste management. will allow waste There is a need to safeguard sites and facilities to protect them from other management in development since high land prices can hinder the development of waste optimum locations recycling facilities. Co-location of facilities (e.g. in resource parks) will enable a more integrated approach to all wastes to be developed (possibly leading to economies of scale), assisting reprocessing and development of markets for recycled materials.

Make locational Give priority to safeguarding and expanding suitable sites with an existing waste decisions that management use and good transport connections. However, give consideration minimise potential to the fact that sites may be unsuitable for further operations. negative effects Key locational criteria will relate to accessibility and the compatibility of nearby associated with land uses. waste management facilities

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1.6 What decision-making criteria should make up the SA framework?

1.6.1 The South East Regional Sustainability Framework includes the objective:

“To reduce the global, social and environmental impact of consumption of resources by using sustainably and ethically produced, local or low impact products” “To reduce waste generation and disposal, and achieve the sustainable management of waste”

Plan for the correct waste management facilities, in the right place at the right time

1.6.3 When appraising the effects of the plan in terms of this objective, the following sub-objectives relating to waste should also be taken into account:

• Put in place the facilities and infrastructure that will support integrated waste management and move waste management up the waste hierarchy • Minimise potential negative effects associated with waste management facilities • Support self sufficiency where possible

1.7 What further data is required?

• There is a need for more robust data on current and future waste arisings from the Construction & Demolition (C&D) and Commercial & Industrial (C&I) sectors

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Revision Schedule

Scoping Report – Water Topic Paper March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 March 2009 Draft for client Mark Fessey Steve Smith Jeremy Richardson comment Consultant Associate Technical Director Evridiki Kaliakatsou Assistant Consultant

02 August 2009 Draft for Mark Fessey Steve Smith Jeremy Richardson Consultation Consultant Associate Technical Director Ian Brenkley Assistant Consultant

03 March2010 Final Scoping Mark Fessey Steve Smith Jeremy Richardson Report Consultant Associate Technical Director Ian Brenkley Consultant

Table of Contents

1 Water ...... 3 1.1 Introduction...... 3 1.2 Background...... 3 1.3 What’s the sustainability context?...... 3 1.4 What’s the current and (likely) future sustainability baseline? ...... 5 1.5 What are the key sustainability issues?...... 13 1.6 What decision-making criteria should make up the SA framework?...... 14 1.7 What further data is required? ...... 14

List of Tables

Table 1: The sub-county baseline ...... 13 Table 2: Key sustainability issues...... 13

List of Figures

Figure 1: Resource availability status for units of surface water and/or surface water combined with groundwater in completed CAMS, March 2008 ...... 6 Figure 2: Resource availability status for units of groundwater only in completed CAMS, March 2008...... 6 Figure 3: Predicted water supply / demand balance in Kent ...... 7 Figure 4: Source Protection Zones...... 12

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1 Water

1.1 Introduction

1.1.1 This is Topic Paper 14 of 14 and is a component of the Scoping Report for the Sustainability Appraisal (SA) of the Kent Minerals and Waste Development Framework (MWDF). This document provides a background to the consideration of water; describes the ‘sustainability context’ within which the MWDF is being prepared; and describes the current and likely future situation for those elements of the ‘sustainability baseline’ in Kent that are of relevance. It then summarises the key sustainability issues as they relate to water and identifies how these issues should be taken account of in the SA of the Kent MWDF.

1.2 Background

1.2.1 Two related issues will be discussed in this topic paper, namely, water quality and water availability, although it is water quality issues that must be the focus of attention when considering the potential impacts of waste and minerals development. Poor water quality can directly impact human health as well as flora and fauna. Nationally, the primary cause of poor water quality is a combination of agricultural runoff, untreated drainage from built up areas and roads, and discharge from wastewater treatment works. In terms of water availability, pressures are becoming increasingly acute as a result of regional growth in housing, population and per capita usage of water. Climate change will only add to these pressures (see the Climate Change and Flood Risk Topic Paper or further discussion). Finally, this paper also includes a consideration of issues relating to coastal and estuarine waters.

1.3 What’s the sustainability context?

1.3.1 Set out below is a summary of key implications from the Plans, Policies, Strategies and Initiatives (PPSIs) that set the context for considering water in this SA. This context review meets a requirement of the SEA Directive.1

1.3.2 The Government’s water strategy sets out a vision for the water sector in 2030.2 The Strategy addresses a range of water-related issues including managing water demand through increased water efficiency and reduced water wastage; enhancing future water supply through new infrastructure; addressing water quality through tackling pollution; managing surface water runoff through sustainable drainage; and managing river and coastal flood risk.

1.3.3 The Environment Agency (EA) is responsible for making sure there is enough water available for everyone’s needs, without damaging the environment. Their work is directed by the Water for people and the environment - Water resources strategy for England and Wales (2009).3 The EA’s framework for the regulation and management of groundwater is addressed by Groundwater Protection, Policy and Practice (GP3)4 which sets out the EA’s strategy for

1 Annex I (a) of the SEA Directive requires that the responsible authority considers the relationship between their plan and other relevant plans and programmes 2 DEFRA (2008). Future Water: The Government’s water strategy for England [online] available at: http://www.defra.gov.uk/environment/water/strategy/pdf/future-water.pdf (accessed 02/09) 3 Environment Agency (2009) Water for people and the environment Water Resources Strategy for England and Wales. 4 Environment Agency (2008) Underground, under threat – the State of Groundwater report [online] available at: http://www.environment-agency.gov.uk/research/library/publications/40741.aspx (accessed 02/09)

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groundwater management. The EA recognises the reasonable needs of abstractors and consumers as well as the need to adhere to the requirements of the Water Framework Directive.

1.3.4 A key driver, in terms of water quality, is the EU Water Framework Directive (WFD), which requires that all inland and coastal waters reach ‘good ecological status’ by 2015.5 The WFD expands the scope of water protection to all waters, surface waters and groundwater, and seeks to achieve ‘good ecological status’. The main output from the WFD is a River Basin Management Plan for each of the 11 River Basin Districts for England and Wales. These plans will set out how we will achieve the environmental requirements of the WFD. Kent falls within the South East and Thames RBMPs.

1.3.5 Catchment Abstraction Management Strategies (CAMS) will also contribute to achievement of WFD objectives. The principal aim of CAMS is ‘to provide a framework for resource availability assessment and produce a licensing strategy which aids the sustainable management of water resources on a catchment scale.’ CAMS contributes to achieving a sustainable balance between the water needs of abstractors and of the environment. By providing an indication of the availability of water resources within river catchments, CAMS highlight any areas where future resource development may take place. They also identify any areas where current levels of licensed abstraction exceed the resources available.

1.3.6 A major objective of the Water Framework Directive (2000/60/EC) is the long-term progressive reduction of contaminant discharges to the aquatic environment in urban wastewater (UWW). Sewage sludge is also a product of wastewater treatment and the Urban Waste Water Treatment Directive (91/271/EEC) aims to encourage the use of sludge whenever appropriate. Potentially toxic elements and organic contaminants largely transfer to the sewage sludge during waste water treatment with potential implications for the use of sludge although some may be emitted with the effluent water.6 Waste water reuse is a topical issue in Kent, as the EA have recently commissioned some work to look at the Aylesford - Medway effluent recycling scheme which shows the scheme to have high potential.

1.3.7 Also of relevance is the Groundwater Directive (2006/118/ EC), otherwise known as the Groundwater Daughter Directive, which prohibits the direct or indirect pollution of groundwater. In relation to groundwater, the Environment Agency state:7

“It is necessary to prevent or limit the input of pollutants into groundwater and implement measures to reverse any significant trends in pollutants. The ‘prevent or limit’ objective is the first line of defence for groundwater, and will drive action on point source pollution as well as the widespread pollutants such as nitrate that are causing deteriorating trends.“

1.3.8 The Environment Agency has defined Source Protection Zones for 2000 groundwater sources such as wells, boreholes, and springs used for public drinking water supply. These zones show the risk of contamination from any activities that might cause pollution in the area. The classifications work as follows: Zone 1 – Inner Zone protection: any pollution that can travel to the borehole within 50 days from any point within the zone is classified as being in zone 1; Zone 2 – Outer Protection Zone: the outer zone covers pollution that takes up to 400 days to travel to the borehole, or 25% of the total catchment area – whichever is the biggest; Zone 3 – Total Catchment: the total catchment is the total area needed to support removal of water from

5 European Union (2000). EU Water Framework Directive [online] available at: http://ec.europa.eu/environment/water/water- framework/index_en.html (accessed 02/09). 6European Commission (2001) Pollutants in urban Wastewater and Sewage Sludge [online] available at: http://ec.europa.eu/environment/waste/sludge/sludge_pollutants.htm (accessed 05/09) 7 Environment Agency (2008). Draft River Basin Management Plans [online] available at: http://www.euwfd.com/ (accessed 02/09)

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the borehole, and to support any discharge from the borehole; Zone 4 – Zone of Special Interest: defined where local conditions mean that industrial sites and other polluters could affect the groundwater source even though they are outside the normal catchment area.8

1.3.9 Government guidance on planning and pollution control states that the planning system plays a key role in determining the location of development which may give rise to pollution, either directly or indirectly but that planning must also be sure to integrate closely with wider pollution control regimes.9 Government guidance on minerals planning identifies both impacts relating to ‘groundwater’ and ‘surface water’ as ‘principal environmental impacts’ of minerals working.10 The guidance promotes consideration of the potential for mineral developments, individually or cumulatively, to affect the flow, quality and quantity of surface and groundwater supplies and the water table. It promotes the use of best available options to prevent pollution from leachate.

1.3.10 The Regional Spatial Strategy (RSS)11 identifies both maintaining an adequate water supply and encouraging water efficiency; and maintaining and improving water quality and meeting EU Habitats and Water Framework Directive standards as key environmental challenges facing the region. Policy NRM2 promotes the maintenance of water quality through the use of water cycle studies, groundwater vulnerability maps and groundwater source protection zone maps.

1.4 What’s the current and (likely) future sustainability baseline?

1.4.1 This section takes a snap-shot of the current sustainability 'baseline' as it relates to water in Kent, as well as considering how the baseline has evolved over time and how it might continue to evolve under a business as usual scenario. There is also an emphasis on comparing the situation in Kent to other geographical areas, as well as considering how the baseline varies at the sub-county scale, within three sub-regional areas defined in Kent by the RSS. This section meets a key requirement of the SEA Directive.12

Current baseline13

1.4.2 This section will focus first on issues relating to water resource availability and then consider the issue of water quality. In terms of water quality there is a clear need to examine the baseline closely due to the role of MWDF in directing sewage effluent discharges, as well as the possibility of other minerals and waste operations resulting in water pollution. Water resource availability is a key issue relating to some minerals and wastes operations, but not all. For example, it is known that licenses for minerals washing in the Upper Stour account for about half of all the non-PWS (public water supply) groundwater abstraction licenses. This baseline consideration will focus primarily on trends in public water supply, as this is the form of abstraction that has the greatest influence on water stress (which in turn may be worsened by

8 Information available on [http://www.environment-agency.gov.uk/maps/info/groundwater/] 9 ODPM (2004). Planning Policy Guidance 23: Planning and Pollution Control [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/planningpolicystatement23 (accessed 02/09) 10 CLG (2006). Minerals Planning Statement 1: Planning and Minerals [online] available at: http://www.communities.gov.uk/publications/planningandbuilding/mineralspolicystatement5 (accessed 02/09) 11 GOSE (2008). The Secretary of State’s Proposed Changes to the South East Plan [online] available at: http://www.gose.gov.uk/gose/planning/regionalPlanning/ (accessed 02/09) 12 An important element of the SEA Directive requirements is the provision of information on “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme” and “the environmental characteristics of areas likely to be significantly affected” 13 Unless otherwise stated, information from: Environment Agency (2008). Draft River Basin Management Plans [online] available at: http://www.euwfd.com/ (accessed 02/09)

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minerals and waste facilities). Furthermore, public water supply is of relevance to waste planning because it will be correlated the volume of wastewater that requires treatment.

1.4.3 The first cycle of CAMS provided the first comprehensive baseline of water availability in England and Wales. CAMS classified water availability according ‘resource availability status’ at low flows, taking account of the relative balance between the environmental requirements for water and how much is licensed for abstraction already; whether water is available for further abstraction; areas where abstraction may need to be reduced. Figures 1 and 2 show the resource availability status for the majority of CAMS in England. Figure 1 illustrates the status for surface water and/ or where surface water interacts significantly with groundwater. Figure 2 shows the status for groundwater, which does not feature in figure 2.

Figure 1: Resource availability status for units of surface water and/or surface water combined with groundwater in completed CAMS, March 200814

Figure 2: Resource availability status for units of groundwater only in completed CAMS, March 200815

14 DEFRA (2008). Future Water: the Government’s water strategy for England [online] available at: http://www.defra.gov.uk/environment/water/strategy/pdf/future-water.pdf (accessed 05/09). 15 DEFRA (2008). Future Water: the Government’s water strategy for England [online] available at: http://www.defra.gov.uk/environment/water/strategy/pdf/future-water.pdf (accessed 05/09).

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1.4.4 When considering future water / supply balance there is a need to take account of:

• the net demand for water abstraction taking account of population growth as well as increased efficiencies; • the need to decrease abstractions to take account of the Water Framework Directive; and • the need to allow for extra headroom to ensure adequate supplied in dry years, which are likely to become increasingly extreme in the future.

1.4.5 Figures 3a and 3b show two possible future supply demand balance scenarios for Kent. It can be seen that there is potential for supply and demand to become increasingly unbalanced over time, with the severity of the problem to a large degree dependent on levels of growth. These data do not account for the aspiration of the Environment Agency and government to keep total demand for water in the Thames Gateway the same between 2005 and 2016.16

Figure 3: Predicted water supply / demand balance in Kent17

3a – assuming population growth of 10.4% to 2030 3b – assuming population growth of 17% to 2030

1.4.6 Water supply constraints work described in the RSS has identified potential constraints in some districts, suggesting that, significant new development should be directed to areas where water supply can be guaranteed (or should be phased so that supporting infrastructure can be put in place before development commences). The districts currently identified are:

• Canterbury • Maidstone

1.4.7 Kent’s per capita domestic water consumption is estimated to be at 164 litres per day, which is about 10% above the national average (150 litres per day).18 Most water used by Kent consumers is supplied by the following companies: Southern Water; South East Water (now incorporating Mid Kent Water); Sutton & East Surrey Water; Thames Water; and Folkestone & Dover Water Services. These companies supply more than 450 million litres of water per day

16 Towards Water Neutrality in the Thames Gateway (2007) Environment Agency [online] available at http://publications.environment- agency.gov.uk/pdf/SCHO1107BNMC-e-e.pdf?lang=_e (accessed 02/10) 17 Consumer Council for Water (2006) Kent’s Water Supply Water, Water Every Where, Nor Any Drop To Drink [online] available at: Chairman Consumer Council for Water (Southern Region) [online] available at http://www.ccwater.org.uk/upload/pdf/Long_Article_on_Kents_Water_Supply_Email_version.pdf (accessed 05/09) 18 Consumer Council for Water (2006) Kent’s Water Supply Water, Water Every Where, Nor Any Drop To Drink [online] available at: Chairman Consumer Council for Water (Southern Region) [online] available at http://www.ccwater.org.uk/upload/pdf/Long_Article_on_Kents_Water_Supply_Email_version.pdf (accessed 05/09)

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to Kent’s households, businesses and the public bodies (although only 373 million litres reaches the consumer because of leakages).19

1.4.8 Biological and chemical water quality has been improving fairly consistently in recent years in the South East of England. In 1990 67% of rivers were classified as being in ‘good’ biological quality and 40% classified as being in good chemical quality. These figures had risen to 77% and 65% respectively by 2006, although there has been some fluctuation, and, in the case of biological river quality, the greatest gains were made in the 1990’s, with little further improvement evident in recent years.20

1.4.9 Water resources are increasingly planned for within river basin districts (RBDs). Kent spans two of these areas – the South East RBD and the Thames RBD. In the South East RBD 11% of the surface water bodies (rivers, lakes, estuaries and coast) assessed, and 33% of groundwater bodies, are currently at good status or potential. In the Thames RBD 13% of surface water bodies and 37% of groundwater bodies are achieving good status. Nationally, 17% of river length is at good status or potential now; 49% of coastal waters, 14% of estuaries, 30% of lakes and 42% of groundwaters. These values are based on the Water Framework Directive classifications.

1.4.10 In the Thames RBD the major river catchments are the Medway, Darent & Cray and North Kent; whilst in the South East RBD the major river catchments are the Stour and the Rother.

The Rother Catchment

1.4.11 Currently 10% of river length assessed is achieving good status or potential. By 2015, compliance will double. 12 km of river is not yet assessed – some 3% of total river length.

1.4.12 In general, water resources are fully committed, and there is reliance on water transferred from the Medway via reservoirs. Current use of the groundwater within the Denge Gravels is thought to be unsustainable due to potentially conflicting water level requirements of the Dungeness Special Area of Conservation, together with sea level rise.

1.4.13 Groundwater bodies under this catchment also suffer from high nitrate concentrations caused by urban and agricultural activities as well as some industrial oil and chemical contamination. The aquifer in the Romney Marsh area is suffering from the effects of sewage effluent discharges, and is at risk from nitrates, pesticides and saline intrusion.

The Stour Catchment

1.4.14 Three per cent of river water bodies are achieving good status or potential now. There will be action to prevent deterioration in status, but improvement in status by 2015 cannot currently be predicted. 54 km of river is not yet assessed – representing some 25% of the total.

1.4.15 There is an extensive range of international nature conservation designations in the area. Many of the surface waters in this catchment are candidate artificial or heavily modified water bodies, reflecting the importance of flood risk management, the presence of high value agricultural land and the number of urban areas. Action will be taken to mitigate the impacts of these activities, but it is currently difficult to predict how the biology and water quality will respond.

19 Ibid. 20 Sustainable Development Unit (no date). River Quality East of England [online] available at: http://www.defra.gov.uk/sustainable/government/progress/regional/excel/natural-resources.xls#'River%20quality'!A1 (accessed February 2009).

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1.4.16 Several water bodies including the stretch between Ashford and Canterbury have high phosphate concentrations and have been designated sensitive areas under the Urban Waste Water Treatment Directive. Although their chemical status is currently good, considerable work will be needed to drive improvements to ecology.

1.4.17 There are two principal chalk aquifers – Thanet and East Kent. In addition to levels of nitrates and pesticides, the Thanet Chalk is also impacted by solvent contamination. The impacts of the former coal mine discharges on the chalk groundwater are still evident and the potential future impact on the wetlands and surface water needs to be investigated.

The Medway Catchment

1.4.18 Currently 16 km of river length (4% of waterbodies) in this catchment are achieving good ecological status/potential. The EA suggest that by 2015 this will improve to 28 km, but with additional local input this could increase.

1.4.19 There has been considerable urban development in the last thirty years, mainly on former agricultural land around the commuter centres of Edenbridge, Tonbridge and Royal Tunbridge Wells. Northern parts of this area, particularly around the upper Estuary, bear the legacy of an extensive history of heavy manufacturing industry. Even today, the area north of Maidstone is still characterised by industry with chemical, pharmaceutical and major cement works and paper mills.

1.4.20 There are a number of Sites of Special Scientific Interest (SSSIs) within the catchment. These include the River Beult, a riverine SSSI near Ashford and Bourne Alder Carr, near Sevenoaks, which has one of the best examples of an alderwood characteristic of the Wealden valley. These sites are all sensitive to changes in water flows and levels as stated on the SSSI list of Potentially Damaging Operations.

1.4.21 In the Medway catchment area there is a programme of phosphate stripping at key sewage treatment works to address high nutrient levels. Diffuse pollution from agriculture is also an issue. Partnerships with local authorities and private industry will be pursued in order to improve contamination due to specific harmful substances, particularly around urban areas.

The North Kent catchment

1.4.22 The North Kent catchment area extends along the North Kent coast between Gillingham in the west and Herne Bay in the east. Currently none of the river length in this catchment is achieving good ecological status/potential. The EA are not expecting an improvement by 2015.

1.4.23 The area is made up of the Chalk North Downs and due to the permeable nature of the geology, surface watercourses do not cover a large proportion of the landscape. The existing water features have experienced many pressures. The springs which feature on the north side flow into the Thames Estuary along very modified channels. Urbanisation has resulted in channel modification notably around Sittingbourne, Faversham, Whitstable and Herne Bay and associated sewage treatment works have all limited the ecology of the Chalk springs.

1.4.24 The principal water dependent habitats in this area are grazing marshes and intertidal mud flats. During the 1960s major drainage works were undertaken within the enclosed marshes and this led to the creation of large arable fields and a loss of grazing marshes. However, extensive areas remain and have been designated as being of European importance for biodiversity. The habitat value of the grazing marsh depends largely on careful surface water management.

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1.4.25 Water quality has been recognised as a problem and much of the action in this area will be to improve the groundwater quality through addressing diffuse and point source pollution. Improvements in the surface waterbodies will also be targeted at reducing physical pressures such as culverts, sluices and concrete.

The Medway Estuary

1.4.26 The Medway and Swale Estuaries are characterised by urban development, including the towns of Rochester and Gillingham and are home to industry and ports. Whitstable is located at the mouth of the Swale, a typical Kent seaside town with an active fishing port and designated bathing waters. Murston Lakes connected to the upper Swale, were initially constructed for brickworks, later used for oyster rearing and are now part of Little Murston Nature Reserve. All Hallows Marshes, connecting to the outer Thames Estuary, lie within the North Kent Marshes. These areas provide a valuable habitat for many bird species and as such the majority is designated as a Special Protection Area (SPA).

1.4.27 Diffuse pollution from agricultural land resulting in high nutrient concentrations within the ground and surface waters is a key concern. Diffuse pollution from urban areas also leads to the release of specific harmful substances. A major issue for these waterbodies is physical modification to allow many uses including navigation, agriculture and flood defence. As a consequence, waterbodies have been designated as candidate Heavily Modified Water Bodies (HMWB) due flood defence and ports / navigation, with the exception of Murston Lakes which are designated candidate Artificial Water Body (AWB). The status of HMWB / AWB dictates that the objective for this waterbody will be to achieve Good Ecological Potential (GEP). The increased need for capital dredging work represents an additional pressure for the Medway. The coastal waters around the Medway are failing to achieve good chemical status.

1.4.28 Continued development has been identified as a need within this catchment, particularly associated with the key Government growth areas. Future development represents a further pressure on the water environment, but also offers opportunities to improve the physical environment via sustainable methods of planning and development.

South East RBD coastal waters

1.4.29 There are 17 coastal and 20 estuarine (also called ‘transitional’) water bodies in the river basin district. The majority of coastal waters and all of the estuarine waters are not currently achieving good or ‘good potential’ status. The coastal waters around the North Kent Coast are in good chemical status, although the coastal waters of the South Kent Coast are failing to achieve good status, as are the waters of the Stour Estuary.

1.4.30 Also, improvements to sewage discharges and urban diffuse pollution will address eight bathing waters that are at risk of failing new Bathing Water Directive standards. There is also major investment planned to treat discharges that might otherwise affect the importance of the 25 Shellfish Waters.

South East Groundwater

1.4.31 Groundwater provides 72% of drinking water and supports many rivers and wetland habitats. Currently, ten of 30 groundwater bodies in the RBD are at good status overall, and have an objective of good status for 2015. The Thanet Chalk groundwater body is subject to considerable pressures from both urban and rural pollution. Nitrates, pesticides, solvents and hydrocarbons are the principal contaminants and come from a range of sources, including industry, agriculture, amenity, transport, horticulture, drainage and residential land use. The

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Lord of the Manor borehole is the lead water source for this groundwater. It has been so badly impacted by pollution that the supply was temporarily switched off. Now reconnected, treatment has been necessary to remove pesticides from the water before it is supplied. Other boreholes nearby have also been impacted by pollution. Current actions underway to address the situation include Nitrate Vulnerable Zones and Pollution Prevention Campaigns built around the Source Protection Zones. Catchment Sensitive Farming is being extended to cover the Thanet area. However, although these are likely to have some effect, there is concern that alone they may not be adequate to achieve good status. For this reason, Lord of the Manor will be considered as a candidate Water Protection Zone. Also, Romney Marsh is at poor status because of saline intrusion.

1.4.32 The majority of Kent falls within the South East RBD, and is failing to achieve good chemical status. However, the aquifer which underlies the River Stour is achieving good chemical status.

Thames Groundwater

1.4.33 Currently 37% of groundwater water bodies in the Thames RBD are achieving good quantitative status. This is not expected to change by 2015. A small improvement in chemical quality from 20% to 21% is proposed. It is not clear what the ‘overall status’ is.

1.4.34 A number of groundwater bodies currently fail to achieve good status due to elevated levels of nitrate, pesticides, solvents and other contaminants. Groundwater monitoring has highlighted widespread increasing trends in nitrate concentration, but pesticide concentrations show an overall decline. In many cases it is not known what activity or activities are causing failure, nor how long measures that are put in place will take to attain good status. The groundwater associated with the Kent Thames Gateway is achieving good chemical status.

Source Protection Zones (SPZ)

1.4.35 Figure 4 below shows the location of the SPZs in Kent. It can be seen that the SPZs are primarily associated with the chalk geology of the North Downs, but that there are also some smaller SPZs in the vicinity of Tonbridge and Tunbridge Wells.

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Figure 4: Source Protection Zones

Future baseline

1.4.36 The above discussion of the baseline has included the consideration of existing and predicted trends. It is clear that trends in terms of water resources will be influenced by growth and development, climate change and efforts to ensure ‘good quality’ status in-line with the Water Framework Directive. The management of coastal erosion and the management of catchments in order to achieve reduced flood risk is also highlighted by the Environment Agency as having the potential to influence water resources in the future.21

Current and future situation in sub-county areas

1.4.37 The RSS defines sub-regions, three of which fall wholly within Kent: East Kent and Ashford; Kent Thames Gateway; and ‘the Rest of Kent’. These areas were identified primarily on economic grounds, but provide a useful spatial framework to consider other elements of the sustainability baseline. Table 1 considers current and possible future baseline conditions in each of these sub-areas.

21 Environment Agency (2008). Draft River Basin Management Plans [online] available at: http://www.euwfd.com/ (accessed 02/09)

Scoping Report - Water 12 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

Table 1: The sub-county baseline

East Kent and Ashford The RSS identifies that the water companies and the EA accept that, in addition to the new strategic main from Bewl Water to Ashford, a further (preferably local) source of supply should be provided to meet long term needs. The EA believe that by supplementing this new supply source with rigorous water efficiency measures, there will be enough water resource available to meet the proposed level of growth at Ashford. Investment in new water supply in the rest of the sub-area must also be increased and the potential for a new reservoir at Broad Oak near Canterbury should be investigated.

Work has taken place for the Urban Waste Water Treatment Directive in proposing the River Stour between Canterbury and Plucks Gutter, the Little Stour and Wingham River as 'Sensitive Areas (eutrophic)'. These proposals will result in phosphate stripping within seven years of the designation at Canterbury, Herne Bay (May Street) and Dambridge Waste Water Treatment Works. Kent Thames Gateway22 The RSS identifies that issues of particular significance in this area include water resources, waste water treatment and water quality, together with measures to improve water efficiency are essential to the delivery of growth. The current necessity to transfer water across Kent and from neighbouring areas means that new water supplies will be needed. It is likely that water supply and treatment can respond to increased growth but there will be a need for accelerated and increased investment Rest of Kent23 This area spans the South East and Thames ‘RBD’. In terms of groundwater, part of the area is not underlain by a major aquifer, but those groundwater aquifers that are highlighted by the EA tend to be failing to meet chemical quality objectives, but are fairing better in terms of meeting water quantity objectives.

1.5 What are the key sustainability issues?

1.5.1 Table 2 illustrates the key sustainability issues that have arisen from the scoping analysis.

Table 2: Key sustainability issues

Key Issue Discussion

Water scarcity Supply and demand may just about be in balance across Kent currently, but there are some areas where this is not the case and there are problems relating to over-abstraction. Water scarcity is set to become a greater problem in coming as a result of population growth, climate change and the need to comply with the requirements of the Water Framework Directive.

Pollution of Groundwater pollution from a range of sources is evident across much of Kent. groundwater

22 This area comprises the major urban areas of Dartford, Gravesham, Medway and Swale north of A2/M2. 23 The RSS also defines a sub-regional area known as ‘the London Fringe’, which encompasses a small part of North West Kent, including the town of Sevenoaks. For the purposes of this baseline review, the Kent part of the London Fringe has been considered as part of the ‘Rest of Kent’ sub-area.

Scoping Report - Water 13 March 2010 Kent County Council Sustainability Appraisal of the Minerals and Waste Development Framework

Pollution of surface There is clear potential for the MWDF to impact upon water quality as a result of waters (including decisions made regarding the location of wastewater treatment works. Other coastal and minerals and waste operations will have varying potential to lead to significant estuarine) water pollution. The Environment Agency is putting in place many measures to improve the quality of surface waters, and it will be important to take local objectives into account.

1.6 What decision-making criteria should make up the SA framework?

1.6.1 The South East Regional Sustainability Framework includes the objective:

“To maintain and improve the water quality of the region’s rivers, ground waters and coasts, and to achieve sustainable water resources management”

1.6.2 It is thought that this regional objective is also appropriate for use as part of the SA of the Kent MWDF. In particular, it should help to ensure that the appraisal is focused on identifying effects in terms of the issues identifies in Table 3 and elsewhere in this topic paper. It is thought that the following sub-objectives should further help to focus the appraisal:

• Ensure that minerals and waste development seeks to promote the conservation of water resources wherever possible • Avoid pollution of ground or surface waters, particularly in areas identified as being at risk or sensitive

1.7 What further data is required?

• Context and baseline of relevance to sewage sludge disposal • A dissemination of messages from water cycle studies, and possibly more strategic scale studies.

Scoping Report - Water 14 March 2010