Constraints Analysis

CONSTRAINTS ANALYSIS

January 2020

EVIDENCE BASE DOCUMENT CONSULTATION DRAFT LOCAL PLAN 2018-2033 (Regulation 18) 1 All maps reproduced by permission of Ordnance Survey on behalf of Her Majesty’s Stationery Office. © Crown Copyright & Database Right 2019. Unauthorised reproduction infringes Crown Copyright and may lead to prosecution or civil proceedings. All Rights Reserved. 100021846. CONTENTS

Purpose of study ...... 3

Scope of study ...... 3

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

Section 2: Green Belt ...... 18

Section 3: Area of Outstanding Natural Beauty ...... 26

Section 4: Designated Heritage Assets ...... 32

Section 5: Locations at Risk of Flooding ...... 38

Section 6: Common Land and Inalienable Land ...... 45

Section 7: Noise ...... 49

Section 8: Air Quality ...... 54

Section 9: Transport ...... 56

Conclusions ...... 61

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

2. This process commenced in May 2017, when the Constraints Analysis was first published as part of the Regulation 18 Issues and Options Consultation evidence base. This version, published January 2020, updates that initial assessment, taking account of relevant changes in national policy and local circumstances.

3. This analysis has informed the plan-making process, including the selection of potential site allocations, in line with the principles set out in paragraph 11 of the NPPF, which states:

a) plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;

b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:

i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or

ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

4. A footnote to NPPF paragraph 11 lists examples of specific policies in the Framework which may affect the overall scale, type or distribution of development. Those which are applicable to Mole Valley are listed in paragraph 5, below.

Scope of study 5. The starting point of the study was to examine those constraints which are identified in the footnote to NPPF paragraph 11. These are the “specific policies” which para 11 states may affect the overall scale, type or distribution of development. Of those listed, the following are currently found within Mole Valley:

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

6. In addition to the above, the study examines the following constraints which it is considered are of sufficiently wide-ranging influence that they can legitimately be considered to have a potential impact on strategic options for development:  Areas of Inalienable Land – i.e. Common Land and inalienable land controlled by the National Trust  Noise, focussing on road noise within the M25 corridor and aircraft noise 3

 Air Quality  Transport and Accessibility

7. The study examines each of the above constraints and explains the extent to which they have shaped preferred strategic options for the scale, type and distribution of development.

Section 1: Nature Conservation: European Sites and SSSIs 8. This section of the Constraints Analysis considers the extent to which land designated for its nature conservation importance acts as a strategic constraint on development. The need to avoid significant effects on European Sites is considered first, focussing on the Mole Gap to Reigate Escarpment Special Area of Conservation, much of which lies within the District, and the Thames Basin Heaths Special Protection Area, which lies to the west and south.

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

11. MVDC recognises its obligations under the Habitats Regulations to assess whether proposals in the Local Plan are likely to have a significant effect on European sites, either individually or in combination with other plans or projects. Based on published Appropriate Assessments and other relevant studies, the 2017 version of this Constraints Analysis identified that sites most likely to be relevant to the emerging Local Plan were the Mole Gap to Reigate Escarpment Special Area of Conservation (SAC) and the Thames Basin Heaths Special Protection Area (SPA).

12. The Mole Gap to Reigate Escarpment SAC stretches for eight miles between Leatherhead and Reigate, taking in significant areas of Norbury Park, Box Hill and Headley Heath (see map 1). The area within the SAC is characterised by a mosaic of chalk downland habitats, ranging from open chalk grassland to scrub and various types of semi-natural woodland on the scarp and dip slopes of the North Downs. One of its most important features is the stand of Box scrub which is unique in the UK. There are also large but fragmented areas of nationally significant calcareous grassland, which support an important assemblage of orchid species. Also nationally significant are the stands of Beech and Yew dominated woodland. The site also supports a significant area of dry heathland and acid grassland at Headley Heath. Further species interest includes Great Crested Newt and Bechstein’s Bat.

13. The Thames Basin Heaths SPA lies outside Mole Valley, to the north and west. The SPA includes several sites which are a rare example of lowland heathland and home to important ground-nesting bird species. Natural England has identified that the cumulative effect of housing growth in Districts and Boroughs surrounding the SPA poses a threat to these habitats, the key risks being cat predation, dog walking and disturbance due to recreational use.

14. Policy NRM6 of the South East Plan set out a policy framework for protection of the SPA, which established a zone of influence at a 5km linear distance from the SPA boundary, within which mitigation measures are required in connection with new residential development. An additional buffer zone was identified between 5-7km from the SPA boundary, within which it was identified that residential developments of 50+ dwellings may have an impact on recreational pressure within the SPA.

15. Mole Valley lies on the outer periphery of the 5km zone of influence, although a larger part of the District lies within the 5-7km buffer zone, including land to the north of Leatherhead and Fetcham. These zones are identified on Map 2. MVDC is not a signatory to the Thames Basin Heaths SPA Delivery Framework and the impact of development within the 5km and 5-7km zones is considered on a case by case basis.

Map 1: Mole Gap to Reigate Escarpment Special Area of Conservation

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

16. Early work on identification of strategic options drew on the 2017 Constraints Analysis, taking account of known issues at the Mole Gap to Reigate Escarpment SAC and the Thames Basin Heaths SPA, namely:  Potential impact on habitat due to increased recreational usage (both sites);  Potential impact on habitat due to maintenance (and risk of cessation) of grazing (SAC);  Potential impact on habitat due to increased air pollution (SAC);  Potential disturbance to roosting populations of Bechstein’s bats (SAC).

17. Early in 2018, MVDC commissioned a joint study with Tandridge District and Reigate and Banstead Borough Councils, completed in June 2018. This focussed on traffic-related air pollution and its effect on the SAC. Overall, the study concluded that growth to 2033 would not have a significant in-combination effect on the SAC and the three Councils’ Local Plans would not prevent the SAC achieving its conservation objectives. However, some targeted measures were recommended to monitor air quality in a specific section of the highway network, in partnership with other local authorities, land managers and strategic highways authorities.

18. The conclusions of this report have informed the HRA process and its recommendations for mitigation measures.

19. MVDC also shared emerging work on strategic options informally with Natural England, in order to identify potential issues at an early stage. These discussions informed the brief for HRA of the emerging Regulation 18 draft Local Plan.

20. The HRA is published as part of the evidence base for the Regulation 18 consultation and therefore its contents are not repeated in detail here. It will be updated if required to inform the contents of the Regulation 19 Draft Plan.

21. The HRA considers the implications of the emerging Local Plan for all Natura 2000 sites within a 10km radius. Using a source-pathway-receptor model, the screening process determined that the HRA should focus on the following European sites:  Mole Gap to Reigate Escarpment SAC.  Thames Basin Heaths SPA.  South-West London Water Bodies SPA / Ramsar.  Richmond Park SAC.

22. It identified the following impact pathways as being relevant to the draft Local Plan:  Atmospheric pollution.  Recreational pressure.  Loss of functionally linked land.  Water quality.  Water quantity, level and flow.

23. Following consideration of these impact pathways at each of the four sites listed in para 21, the HRA confirmed that the two sites of most relevance to the Local Plan are the Mole Gap to Reigate Escarpment SAC and the Thames Basin Heaths SPA. At these sites, identified Likely Significant Effects of the Regulation 18 plan are as follows:  Recreational pressure on Mole Gap to Reigate Escarpment SAC and Thames Basin Heaths SPA.  Loss of functionally-linked land for the Bechstein’s bat population and great crested newt population of Mole Gap to Reigate Escarpment SAC.  Air quality impacts on Mole Gap to Reigate Escarpment SAC.

24. The HRA makes recommendations to mitigate likely significant effects on European sites. These have been incorporated in the draft policies contained in the Regulation 18 draft Local Plan and where relevant in the draft Infrastructure Delivery Plan.

Summary: European Sites

MVDC is obliged under the Habitats Regulations to assess whether proposals in the Local Plan are likely to have a significant effect on European sites, either individually or in combination with other plans or projects.

This has been done informally through early engagement with Natural England on emerging strategic options and formally through the Habitats Regulation Assessment (HRA) process and supporting technical studies.

The HRA is published separately. It makes recommendations for mitigation of likely significant effects on European sites which have been incorporated in the draft policies contained in the Regulation 18 draft Local Plan and where relevant in the draft Infrastructure Delivery Plan.

SSSIs, Irreplaceable Habitats and other relevant designations 25. Although NPPF para 11 only identifies European Sites and SSSIs as the specific designations which indicate that development should be restricted, the Framework also recognises that LPAs should “take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries” (NPPF para 171). Therefore, while it is recognised that a distinction should be made between the hierarchy of international, national and locally designated sites (para 171), it is also considered appropriate to recognise the interrelationships between areas of land designated at different levels and for different reasons.

26. In several locations within Mole Valley, there is a network of interrelated sites which together give a wider picture of the constraints that could have a bearing on strategic options. Therefore, the maps which follow illustrate the extent of European sites and SSSIs alone (Map 3) and in combination with all local nature conservation designations (Map 4).

27. Map 4 includes areas of Ancient Woodland, which is classified as an irreplaceable habitat in the NPPF (para 175c) and is one of the constraints which is specifically highlighted in NPPF paragraph 11 as influencing the scale, type and distribution of planned development.

28. In appraising specific proposed sites, MVDC has also had regard to Natural England’s map of Priority Habitats and the obligation to promote the “conservation, restoration and enhancement” of such habitats under NPPF para 174b).

Map 3: Sites of Special Scientific Interest

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

Ashtead, Leatherhead, Fetcham and Bookham

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

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

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

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

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

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

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

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

North Downs 37. Within the North Downs, very extensive tracts of land are designated SSSI and/or SAC and there are also several very large blocks of Ancient Woodland. The areas designated for their nature conservation importance take in a significant proportion of the countryside north of Dorking and south of Ashtead, Leatherhead, Fetcham and Bookham. The largest designated areas are towards the south and take in the steep scarp slope of the North Downs, most of which is designated SSSI and/or Special Area of Conservation. All the areas within the Mole Gap to Reigate Escarpment SAC are within this tract of countryside.

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

Dorking 39. There are several small pockets of ancient woodland around the southern and eastern fringes of Dorking. Larger designated areas comprise a Local Nature Reserve and SNCI at Inholms Lane and the Glory Woods, which is a block of Ancient Woodland extending into the built up area and designated as a Site of Nature Conservation importance.

Greensand Hills 40. The Greensand ridge formed by very resistant rocks of the Lower Greensand, in particular the Hythe Beds, have produced prominent escarpments that form an arc around the northern edge of the Low Weald, running parallel to and just south of the chalk escarpment of the North Downs. This stretch of the Greensand has become the most closely identified with the term "Greensand Ridge", and it includes the second highest point in south-east England, Leith Hill in Surrey. There are very extensive areas of ancient woodland and some large SSSIs on the plateau of the Greensand Hills in and around Leith Hill. When the expanses of Ancient Woodland are taken into account, a significant proportion of this area of countryside is designated for its nature conservation importance and it includes significant areas managed by the National Trust for their nature conservation value.

Wooded Weald 41. These are lower lying areas where alternating clays and sandstones occur where as these rocks are not as hard as the greensand where as result of fluvial erosion has flattened these areas into a series of hills and vales. This more fragmented landscape as a result of its topography is characterised by pockets of very rural land with densely wooded pockets. In the lower-lying areas south of the Greensand Hills, the land covered by nature conservation designations reflects this topography and is more fragmented, with a scattering of ancient woodland and SNCIs and fewer SSSIs. This largely rural area is known as the Wooded Weald and there is an extensive network of locally designated sites set within shallow valleys surrounded by low ridges, with several long, thin sites forming linkages between blocks of ancient woodland and other designations.

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

Low Weald 43. The Weald is a large clay valley which was once covered with thick inhospitable forest, and its name, Old English in origin, signifies woodland. The underlying geology shapes the landscape as the softer sandstones and clays form a gentler rolling landscape. The Weald was used for centuries, possibly since the Iron Age, for transhumance of animals along droveways in the summer months. Over the centuries, deforestation for the shipbuilding, charcoal, forest glass, and brickmaking industries has left the Low Weald with only remnants of that woodland cover, but with evidence of this historic industrial activity. The woodland cover that remains represents a significant and historic ecological resource alongside the historic changes. In the portion of the Low Weald in the south east of the District, the countryside is generally more open, but is spotted with irregular blocks of woodland and a network of tributaries and gills of the River Mole. The network of designated sites is less extensive than elsewhere, but due to the historical context in ecological terms the area is noted for these remaining areas of ancient woodland and gill woods, many of which are scattered and small in size.

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

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

Summary: Nature Conservation Designations

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

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

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

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

 The Greensand Hills, south west of Dorking.

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

There are further areas where there is a very extensive network of smaller nature conservation sites, including some nationally important sites and areas of Ancient Woodland (an irreplaceable habitat) and Priority Habitats. Throughout the District, nature conservation has been a key consideration in the selection of proposed site allocations.

Where potential sites are closely related to one or more areas covered by nature conservation designations and/or priority habitats, the potential impact on biodiversity has been considered during site appraisal. Site-specific evidence has been obtained where required and suitable safeguards are incorporated into site allocation policies, where relevant.

Biodiversity Opportunity Areas 46. As part of its remit to protect biodiversity in Surrey in alignment with DEFRA’s Biodiversity 2020 Strategy, the Surrey Local Nature Partnership has identified several Biodiversity Opportunity Areas (BOAs). These are extensive areas where there is a spatial concentration of already recognised and protected sites as well as other areas of priority habitat, which are not yet officially designated. They represent areas where improved habitat management and efforts to restore and re-create priority habitats will be most effective in enhancing connectivity to benefit recovery of priority species in a fragmented landscape.

47. Map 5 (below) illustrates the extent of BOAs across Surrey. Those which include land within Mole Valley are as follows:  TBL02 Clandon to Bookham Parkland  TBL04 Ashtead & Epsom Woodland, Princes Coverts & Horton Country Park  ND02 North Downs Scarp and Dip; Guildford to the Mole Gap  ND03 North Downs Scarp; Mole Gap to Reigate  WG08 Leith Hill, Wotton, Abinger & Holmwood Greensand Ridge  LW03 Wallis Wood  LW06 Newdigate Woodland  LW04 Vann Lake  LW05 Glovers Wood & Edolph’s Copse  RO5 River Mole & tributaries 15

 RO6 River Wey & tributaries

Map 5: Biodiversity Opportunity Areas

48. As can be seen from the map, BOAs cover a substantial geographical area. Designation of an area as a BOA does not in principle preclude development. However, they indicate opportunities to enhance biodiversity, as the Local Plan progresses.

Summary: Biodiversity Opportunity Areas

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

Draft Local Plan policies include a requirement for new development to enhance biodiversity. Specific proposals can draw on guidance in the Policy Statement for each BOA.

Section 2: Green Belt 49. NPPF Paragraph 14 includes designation of land as Green Belt among the constraints which may indicate that development should be restricted. Map 6 (below) illustrates the existing extent of the Green Belt in Mole Valley. About 76% of the land within the District boundaries is currently designated as Green Belt This represents about 83% of the land outside the existing built up areas and larger villages. Therefore this is a significant consideration for Mole Valley’s emerging Local Plan.

50. The NPPF emphasises that the essential characteristics of Green Belts are their openness and their permanence (NPPF para 133). Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through preparation or updating of a Local Plan (NPPF para 136). It therefore falls to MVDC to analyse as part of the Local Plan review process whether “exceptional circumstances” exist to suggest that any changes are required to the existing Green Belt boundary.

Map 6: Green Belt

51. In February 2017, the Government published “Fixing Our Broken Housing Market” – a White Paper addressing the shortage of new housing to meet existing and future demand. The White Paper reiterated that Green Belt boundaries should be amended only in exceptional circumstances when plans are being prepared or revised. However, it elaborated on an approach which local authorities should take to consider whether exceptional circumstances exist.

52. The NPPF was updated in July 2018 and February 2019, to include the following requirements, which are closely aligned with the White Paper proposals:

Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This will be assessed through the examination of its strategic policies, which will take into account the preceding paragraph, and whether the strategy:

a) makes as much use as possible of suitable brownfield sites and underutilised land; b) optimises the density of development in line with the policies in chapter 11 of this Framework, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and c) has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground. (NPPF February 2019, paragraph 137)

Brownfield and underused land: 53. During the early stages of Local Plan preparation, MVDC undertook a Brownfield Land Availability Assessment which considered the availability of brownfield land to meet development needs. As part of the process of preparing that assessment, site submissions were invited from owners of brownfield land – including a range of public bodies. MVDC also drew on a detailed analysis of all previously developed land which is not already in residential use.

54. The Brownfield Land Availability Assessment identified a number of previously developed sites which could be allocated to help meet the District’s development needs, particularly for housing. However, the capacity of identifiable sites was assessed as being approximately 2900 homes, which represents about 43% of total objectively assessed needs. On the whole, brownfield sites in Mole Valley tend to be small in scale and the vast majority are in active use and not known to be available for development. There are no substantial tracts of underused or surplus public sector land. Privately-owned land tends to be redeveloped quickly when it becomes available and the opportunities to identify sites for future development are limited.

55. During the 2017 Issues and Options Consultation, MVDC sought views on a series of brownfield options, which had the potential to increase the capacity of previously developed land through a variety of policy approaches:  Town centre redevelopment  Reallocate commercial and retail land  Mixed use redevelopment  Rural employment sites  Increase suburban densities

 Reallocate recreation land

56. Based on the results of the consultation, MVDC decided in November 20171 to progress with four options, based on the above:

 Town centre redevelopment  Limited reallocation of commercial and retail land  Mixed use redevelopment  Targeted increases in suburban densities

57. These agreed options were judged to strike an appropriate balance between making as much use as possible of brownfield and underutilised land, while still safeguarding important assets such as public open space, retention of sufficient employment land to support a vibrant urban and rural economy and the attractive character of well-established suburban residential areas.

58. It was estimated that these four brownfield options would in combination provide an additional 1200 dwellings, over and above the brownfield capacity which had been identified at the time of the Issues and Options Consultation. The site allocations proposed in the Regulation 18 Draft Plan achieve this objective.

59. A number of additional brownfield sites have also come forward within the rural areas as part of the Modest Expansion of Rural Villages, which has further increased the use of brownfield land to meet the District’s identified need for development.

Optimising density: 60. In making an assessment of brownfield capacity, MVDC has sought to be ambitious in optimising the proposed density of development. This is particularly the case in town centre sites – notably in Leatherhead, where a number of sites are proposed for redevelopment as part of the Transform Leatherhead project. As Local Plan preparation has progressed, appropriate and achievable ways to maximise density have continued to be explored, particularly within town centres and through the limited redevelopment of employment sites.

61. MVDC has also identified locations around town and local centres, close to public transport hubs and along main transport routes, where higher density development can be secured. This includes a proposed policy framework for Development Opportunity Areas and opportunities for mixed use development at Dorking Railway Station.

62. However, even with the most ambitious density assumptions which are considered to be reasonably achievable, there would remain a significant shortfall between the amount of suitable and available brownfield land and the scale of MVDC’s identified development needs.

Exploring options with other authorities:

63. MVDC continues to explore options to work with other authorities under the duty to cooperate, to establish whether some of the identified development requirement can be met through cross-boundary cooperation. This process commenced with consultation on MVDC’s Duty to Cooperate Scoping Statement in February 2017, alongside preparation of

1 MVDC Executive Meeting November 2017

evidence base documents. The Scoping Statement identifies housing delivery as a key cross-boundary strategic issue, which will be a focus for ongoing engagement under the duty to cooperate. It also identifies that “One of the challenges for MVDC is to identify potential options for a proportion of Mole Valley's objectively assessed housing needs to be met through cross-boundary co-operation, particularly where the land within adjacent districts/boroughs lies outside the Green Belt and /or is less constrained than land within Mole Valley.”

64. It must be recognised at the outset, however, that the Green Belt is also a significant constraint in the majority of neighbouring authorities, who have to address the same issues as Mole Valley. This includes the three authorities that MVDC partnered with to produce the Strategic Housing Market Assessment in 2016 (Epsom & Ewell Borough Council, Elmbridge Borough Council and the Royal Borough of Kingston upon Thames).

65. The other three neighbouring authorities in Surrey (Guildford, Waverley and Reigate and Banstead) are also significantly constrained by Green Belt and/or AONB designations. All three Boroughs’ recently-adopted Local Plans include release of Green Belt land, indicating a lack of options to meet objectively assessed needs on land outside the Green Belt.

66. Looking south, the Borough of Crawley is highly constrained by a very tight boundary around the existing built up area. Crawley’s adopted Local Plan for the period to 2030 seeks to maximise densities, but also relies on housing provision in adjoining authorities to meet a proportion of objectively assessed need. Going forward, a recent Regulation 18 consultation on Crawley’s revised Local Plan for 2020-2035 identifies an unmet housing need of some 6,475 dwellings, with the Borough Council intending to continue relying on cross-boundary provision. This both indicates the lack of opportunity for MVDC’s needs to be met in Crawley and an continued requirement for other Sussex authorities – including Horsham – to contribute to Crawley’s unmet needs.

67. Although Horsham lies outside the Green Belt, it includes areas which are significantly constrained for other reasons, notably the South Downs National Park which takes in the southern part of the District. Horsham District Council adopted a District Planning Framework in November 2015 which includes proposals for 800 new homes per annum. This includes development proposals to help meet the objectively assessed needs of adjacent authorities (notably Crawley and coastal authorities). Horsham DC’s Local Plan review is underway, with a Regulation 18 Consultation due to take place early in 2020, providing an opportunity for continued dialogue on cross-boundary issues as both plans progress.

68. The 2017 Constraints Analysis indicated that it appeared unlikely that unmet housing needs could be met through cross-boundary cooperation. This conclusion has not changed as a result of ongoing plan-making since 2017. While cross-boundary dialogue will be maintained, it continues to appear highly likely that MVDC will have to consider options to release Green Belt land if objectively assessed housing needs are to be met in full.

Other Issues

69. Looking beyond the approach set out in the NPPF, there are a number of other issues which have established that options including release of Green Belt land need to be considered.

Housing mix

70. The SHMA identified a significant need for smaller dwellings (3 bedrooms or fewer), accounting for 91% of MVDC’s identified residential development needs. There can be practical difficulties with delivering smaller dwellings on a significant scale within the existing built up areas, particularly where those areas are currently characterised by much more spacious, low density development.

71. There are also a variety of specialist housing needs which the Local Plan has to address, including housing for older people (including affordable extra-care housing), plots for self and custom build, a variety of affordable housing options and sites to cater for gypsies, travellers and travelling showpeople. Larger-scale sites are more capable of incorporating those uses which generate lower land values without compromising the overall viability of development. Since a very high proportion of the rural areas in Mole Valley are within the Green Belt, rejecting all Green Belt options as a matter of principle would seriously limit the options available to meet such needs.

Countryside beyond the Green Belt

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

73. The transport network is similarly poor within much of the area that is beyond the Green Belt. Most existing villages are served by rural lanes and have very limited access to public transport. The exception is the A24 corridor south of Capel where there are more frequent bus services. There are no railway stations in this area; the nearest station at Ockley lying within the Green Belt. Many (but not all) of the parts of the District which are within the Green Belt benefit from better access to local services and sustainable transport options. Therefore, in terms of promoting sustainable development, release of Green Belt land has advantages over more isolated locations, in the area beyond the Green Belt.

74. A high proportion of the Countryside Beyond the Green Belt is also affected by other constraints considered elsewhere in this analysis; notably the Area of Great Landscape Value, areas affected by aircraft noise and extensive heritage and nature conservation interests.

75. These issues are set out in greater depth in a separate evidence paper on the Countryside Beyond the Green Belt, published January 2020 as part of the evidence base to the Regulation 18 consultation. The evidence paper concludes that the Countryside Beyond the Green Belt is not a suitable location for larger-scale strategic development, which would make a meaningful contribution to District-wide housing demand. This is therefore a factor which supports the existence of exceptional circumstances to merit changes to the Green Belt in order to meet the District’s identified development needs.

Rural Villages

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

Conclusion 77. There are a number of factors which, in combination, indicate that there are exceptional circumstances to justify changes to the Green Belt boundary in order to meet identified development requirements. These are discussed above and summarised in the box which follows.

78. At the same time, Paragraph 11 of the NPPF lists the Green Belt as one of a number of constraints which indicate that development should be restricted. This paragraph indicates that these constraints may amount to a strong reason for restricting the overall scale, type or distribution of development in the plan area.

79. In order to strike an appropriate balance between meeting objectively assessed needs in full and continuing to safeguard the openness and permanence of the Green Belt for the benefit of current and future generations, MVDC has undertaken further analysis of Green Belt areas in the form of a Green Belt Review, published January 2020 alongside this Constraints Analysis. This focusses on the extent to which all parts of the Green Belt continue to serve one or more of the following five purposes, as set out in paragraph 134 of the NPPF:

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

80. The Green Belt Review has provided a tool to inform the selection of sites to meet MVDC’s identified development needs, while minimising the loss of Green Belt land which performs strongly against the above purposes. The potential suitability of a site for development has been informed by the findings of the Green Belt Review, alongside Sustainability Appraisal and other site-specific evidence-gathering. Through the identification of sites MVDC has sought to strike an appropriate balance between meeting the Local Housing Need for Mole Valley in full and continuing to safeguard the openness and permanence of the Green Belt for the benefit of current and future generations.

Summary: Green Belt

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

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

 A shortfall in capacity to meet objectively assessed development needs on previously developed land and/or through significantly higher density development, even after options for maximising the capacity of previously developed land have been thoroughly explored;

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

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

 Sustainability issues and other significant policy constraints within the Countryside Beyond the Green Belt;

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

Given the above circumstances, it would not be appropriate for MVDC to rule out all Green Belt land from strategic development options as a matter of principle.

Strategic options have aimed to strike an appropriate balance between meeting objectively assessed needs while safeguarding the openness of the Green Belt and upholding the principle that the Green Belt should have a strong degree of permanence. This has been informed by further analysis of Green Belt areas focussed on the extent to which all parts of the Green Belt continue to serve one or more of the five purposes of including land within it.

Section 3: Area of Outstanding Natural Beauty 81. The Surrey Hills was one of the first landscapes to be designated as an Area of Outstanding Natural Beauty in 1958. Designation seeks to protect and enhance natural beauty whilst recognising the needs of the local community and economy. The Surrey Hills AONB designation links together a chain of varied upland landscapes including the North Downs, traditionally the day trip destination for southeast London. Rising near Guildford as the narrow Hog’s Back, the ridge of the downs stretches away to the Kent border, an unmistakable chalk landscape of swelling hills and beech-wooded combes with a steep scarp crest looking south to the Weald. The whole AONB takes in 25% of land in Surrey. As it stretches east/west across the county and links with the protected landscapes of the Kent Downs AONB to the east and the South Downs National Park to the south and west, it could be considered as being of regional significance.

82. The NPPF confirms that “Great weight should be given to conserving and enhancing landscape and scenic beauty in … Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues.” (NPPF para 172)

83. NPPF para 11 recognises that the AONB designation means that development should be restricted.

84. Planning policy within the Surrey Hills AONB is also informed by the Surrey Hills AONB Management Plan, the latest version of which is for the period 2020-2025. The Management Plan is a statutory management plan for the District and Borough Councils within the AONB and has been adopted by MVDC. It highlights the special qualities and enduring significance of the AONB, presents a vision for its future and sets out agreed policies and actions to support that vision. Because the AONB is located in the busy South East of England, it is hugely popular with visitors including those travelling out from Greater London. Therefore the Management Plan faces the challenge of preservation alongside the role of the designation as it seeks to protect and enhance natural beauty whilst recognising the needs of the local community and economy.

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

Map 7: Area of Outstanding Natural Beauty

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

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

Summary: AONB

MVDC considers that it would be inappropriate in principle to plan for strategic-level development in the form of urban extensions or substantial expansion of rural villages within the AONB. This level of additional built development would not be compatible with the principle that great weight should be given to conserving landscape and scenic beauty.

Where there are existing settlements adjoining or within the AONB, the scope for smaller-scale development on the edge of such settlements has been carefully considered. In this context “smaller-scale” development refers to individual sites that would provide fewer than 100 dwellings, or an equivalent scale of development for other uses. There are a small number of proposed housing site allocations of this scale within the AONB at Mickleham, Westhumble, Westcott and south west Dorking. In these locations, it appears to MVDC that there is an opportunity for limited residential development to meet the District’s identified needs and support the vitality of rural communities, without detrimental effect on the landscape and scenic beauty of the AONB. The majority are for the delivery of modest additions to rural villages, in locations where the whole village is washed over by the AONB and therefore development in the AONB is inevitable if this element of the plan is to be delivered.

It is recognised that development of these sites will require a careful design approach to ensure that the overall quality of the landscape is conserved.

Proposed site allocations also include additional gypsy and traveller pitches on two small sites within the AONB on the edge of Dorking. Again, it appears to MVDC that this small-scale development is capable of being accommodated in these specific locations, without detrimental impact on the landscape and scenic beauty of the AONB.

Area of Great Landscape Value and AONB Boundary Review

88. Parts of the countryside adjacent to the AONB are covered by a County-level designation known as the AGLV (Area of Great Landscape Value). The extent of the AGLV is shown on Map 8, overleaf. It covers a total area of 116km2, which is 45% of the District. 89. The AGLV has its origins in the first Surrey County Plan (1958). When the AONB was designated in the same year, all of the AGLV was incorporated in the new designation.

90. County Plan Reviews in 1971 and another in the early 1980s resulted in further areas being designated, effectively as extensions to the AONB boundary. The AGLV takes in a number of areas which have their own inherent landscape quality and are significant in conserving the landscape setting of certain settlements. 91. It is recognised that local designations such as the AGLV do not carry the same weight in national policy as the AONB itself. However, there are particular local circumstances which lead MVDC to believe that the landscape importance of the AGLV should continue to be recognised as a strategic-level constraint on development for plan-making purposes. 92. In October 2013, the Surrey Hills AONB Board formally requested that Natural England consider modifying the AONB boundary. This followed two separate studies undertaken in 2007 and 2013, which indicated that there is a case for reviewing the AONB boundary and that such a review would potentially incorporate parts of the AGLV into the AONB. There has not been a review of the Surrey Hills AONB boundary since it was first designated in 1958. A key purpose of the review will be to establish whether land currently designated as AGLV should be “upgraded” and included in the AONB designation. 93. Natural England had indicated that it would undertake a review of the Surrey Hills AONB boundary in 2018. Their review would consider the whole AONB boundary, following Natural England’s agreed methodology for such reviews. 94. However, in May 2018, DEFRA launched a review into England’s National Parks and AONBs, known officially as the Landscapes Review and chaired by Julian Glover. This is a wide-ranging review, exploring how these protected landscapes meet the needs of the 21st century, whether there is scope for the current network of AONBs and National Parks to expand, how access can be improved, how those who live and work in them can be better supported and examining their role in growing the rural economy. 95. A report on the Glover Review was published in September 2019. It confirms that variation of the Surrey Hills AONB boundaries is one of 19 AONB/National Park proposals currently before Natural England. It also highlights that the current statutory process is complex, under-resourced and time-consuming, meaning that progress is extremely slow. The Landscapes Review includes suggestions for reform of the designation process2, and at the time of writing the Government’s response is awaited.

2 DEFRA Landscapes Review, Final Report, Proposal 22

Map 8: Area of Great Landscape Value

96. The current strategic landscape policy (CS13) in the Mole Valley Core Strategy 2009 safeguards the AGLV until such time as an AONB boundary review has been completed. A similar position was included in Reigate and Banstead Borough Council’s Core Strategy, adopted 2014, Waverley Borough Council’s Part 1 Local Plan, adopted 2018 and Guildford Borough Council’s Local Plan, adopted 2019. Therefore MVDC’s approach provides cross- boundary consistency with these adjoining authorities and has also been tested through a series of post NPPF Local Plan Examinations. 97. Against this background, MVDC remains of the view that it is appropriate to continue safeguarding the AGLV for its landscape value, at least until such time as the Surrey Hills AONB boundary review has been completed. The AGLV takes in some very rural parts of Mole Valley where there has been little development or landscape change since the designation was first established. They remain areas of great landscape value and it would not be appropriate to consider these areas for strategic-scale development until such time as their potential inclusion in a review AONB boundary has been properly considered.

Summary: AONB Review and the AGLV

The Area of Great Landscape Value designation will be retained by MVDC at least until such time as the Surrey Hills AONB boundary review has been concluded. This will ensure that areas which are of AONB quality are not “lost” to large scale development in advance of those reviews.

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

Proposed site allocations include some smaller-scale sites within the AGLV at Ockley, Buckland and Betchworth, as part of the modest expansion of rural villages and provision of gypsy and traveller sites. It appears to MVDC that there is an opportunity for limited development in these specific locations, to deliver the District’s identified needs, without detrimental effect on the AGLV. However, it is recognised that development of these sites will require a careful design approach to ensure that the overall quality of the landscape is conserved.

Section 4: Designated Heritage Assets 98. Mole Valley District has a rich heritage with an extensive network of heritage assets. There are 28 Conservation Areas wholly or partly within the district and just over 1000 Listed Buildings; a higher than average number across Surrey Districts and Boroughs. In addition, there are 27 Scheduled Ancient Monuments in Mole Valley and five gardens on the register of Parks and Gardens. The National Trust is almost certainly the largest landowner in the District.

99. The NPPF (paras 184-185) requires that local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of existing and future generations. In developing this strategy, local planning authorities should take into account:  the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation  the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring  the desirability of new development making a positive contribution to local character and distinctiveness; and  opportunities to draw on the contribution made by the historic environment to the character of a place

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

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

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

103. This analysis focuses on those heritage assets which have the greatest influence on shaping strategic options – either because of their influence on the character of an area , their intrinsic significance or of the large extent of the designated land and/or its setting. 32

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

Map 9: Heritage Assets 33

Ashtead, Leatherhead, Fetcham and Bookham 105. Within the built up area of Ashtead is a significant block of open land which incorporates a cluster of designated heritage assets, notably the Grade II* listed Ashtead Park House (now part of City of London Freemen’s School), Grade II Registered Ashtead Park (which also includes a Site of High Archaeological Potential) and the Ashtead House Conservation Area. There is a further Grade II* listed building (Ashtead Park Farm House), off Farm Lane, just outside the Registered Park and north of the Conservation Area.

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

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

108. West of Bookham, the Little Bookham Conservation Area is an example of a Conservation Area which extends outside the built up area, into the more sporadically developed and open land between Effingham and Bookham. The Conservation Area focusses around two distinct clusters of listed buildings whose rural surroundings make a significant contribution to their setting.Development on the edge of Bookham would have to be carefully designed to take account of this heritage asset.

109. There are no very extensive designated heritage assets within the land north of Leatherhead, Fetcham and Bookham, but notable smaller assets within this area include a Scheduled Ancient Monument at Pachesham Farm, north west of Leatherhead Business Park and a particularly important group of listed buildings at Slyfield (Grade I listed) close to the District boundary north of Bookham. North Downs 110. Much of this area is chalk downland and only sparsely developed. However, it includes a number of heritage assets which are extensive in terms of the amount of land included in the designation and the extent of their landscape setting.

111. The former medical rehabilitation facility at Headley Court is focussed on a Grade II listed building and there are also several sites of archaeological potential in the vicinity.

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

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

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

115. All of the above heritage assets are within the North Downs landscape, within a distance of 2.5km from the edge of the built up areas to the north. Taken together, they form a belt of former country house estates which is part of the historic landscape of this part of the North Downs. Constraints to development would not only apply to land close to these heritage assets, the views into and from this string of heritage assets would be a constraint at a greater distance.

116. At a smaller scale, but also covering a wide geographical area, the scarp slope of the Downs is noted for a series of defensive installations in the form of pill boxes. Dorking 117. In the centre of the District, the town of Dorking has a large historic core, with an extensive Conservation Area including an Area of High Archaeological Potential. In the heart of the Conservation Area is the Grade II* listed St Martin’s Church, the spire of which is a prominent landmark. Views of the spire are available throughout the town and from the surrounding landscape and are highlighted in the Dorking Conservation Area Appraisal and Management Plan as a feature which merits safeguarding.

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

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

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

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

Greensand Hills and Wooded Weald 122. Within this largely rural area, there is a significant number of listed buildings. Although many of these are small, domestic-scale properties, they are scattered throughout the area and make a rich contribution to the character of villages and hamlets in this part of the District.

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

124. Almost all the villages in this area have Conservation Areas at their heart, all of which take in areas of open land around each village which contribute to their historic setting. In the 35

case of Coldharbour and Ockley, these also include areas with high archaeological potential, notably the Anstiebury Camp at Coldharbour, which is also a Scheduled Ancient Monument.

125. The route of the Stane Street Roman Road is also designated as a long, narrow Site of High Archaeological Potential which extends from the southern District boundary, through Ockley and north to the southern edge of Dorking. Low Weald 126. This area also has a substantial number of listed buildings, both within the villages and scattered throughout the rural area. A high proportion of these are buildings that serve or once served agricultural purposes.

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

Summary: Designated Heritage Assets

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

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

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

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

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

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

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

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

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

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

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

Heritage issues have been considered when selecting potential development sites. Suitable safeguards are incorporated into site allocation policies, where relevant.

Section 5: Locations at Risk of Flooding 128. Paragraph 155 of the NPPF states that ‘inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk (whether existing or future).Where development is necessary in such areas, the development should be made safe for its lifetime without increasing flood risk elsewhere’.

129. Based on the above, a sequential, risk-based approach has been applied to location of development. The aim has been to steer development to areas with the lowest probability of flooding.

130. During the early stages of plan preparation, MVDC commissioned a joint Level 1 Strategic Flood Risk Assessment (SFRA), in partnership with Reigate & Banstead Borough Council and Tandridge District Council. This is published separately and therefore its contents are not repeated here.

131. Close collaboration has also been maintained with Surrey County Council (Lead Local Flood Authority) and the Environment Agency, including input into SCC’s Flood Risk Management Strategy and the development of Flood Alleviation Schemes within the District by both SCC and the EA.

132. A sequential test formed part of the process of selecting proposed sites, avoiding development in Flood Zones 2 and 3 as far as possible. The process followed is detailed in the Sequential Test Evidence Document, published January 2020. A Level 2 Strategic Flood Risk Assessment examined 15 potential sites which included land in Flood Zones 2 or 3, or are at risk from other forms of flooding. The Level 2 SFRA also examined the cumulative impacts of development on flood risk and took into account the impacts of climate change.

133. On the majority of sites examined through the Level 2 SFRA, development can be directed to areas in Flood Zone 1 low risk of flooding. In the very few instances where this is not possible, the Level 2 SFRA provides information to support application of the Exception Test, to ensure that development can be delivered safely, if it is concluded that there are sustainability reasons for including the proposed site in the Plan.

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

Map 10: Risk of Fluvial Flooding

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

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

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

138. In Fetcham, properties in the around Cannon Way and Cannon Grove are susceptible to flooding and there was significant property flooding in the 2013/14 flood event. Although much of this area is within Flood Zone 2, there are indications that this may be reviewed (i.e. that the level of flood risk has increased) as a result of ongoing remodelling work. In this part of Fetcham there are issues with both fluvial and surface water flooding. Funding for Property Level Protection has recently become available from the Environment Agency, to support residents in this area with measures to reduce flood risk to their homes.

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

North Downs

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

Dorking

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

Greensand Hills and Wooded Weald

142. This area is mostly within the River Wey catchment with the south western most corner covered by the River Arun CFMP. Within the Greensand Hills, areas at risk of flooding are

generally small and dispersed. There are some very small areas at risk of fluvial flooding, along the Tillingbourne which flows west through Abinger Hammer.

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

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

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

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

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

148. A significant flood alleviation scheme has been undertaken around the Upper River Mole catchment to provide flood relief to the Crawley and Gatwick area. Further Flood Alleviation measures are under development in the Crawley Villages area.

Map 11: Risk of Surface Water Flooding

Surface Water Flooding 149. Areas at medium to high at risk of surface water flooding are shown on Map 11 (above).

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

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

North Downs

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

Dorking

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

154. In general, there are very few reported incidents of surface water flooding of a significant scale in the more rural areas. The exception is in the village of Brockham, where surface water flooding is a significant issue in the area south of Brockham and around Strood Green.

Summary: Flooding

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

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

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

 Parts of Bookham (surface water);

 The Pixham area of Dorking (fluvial);

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

 Areas around Charlwood and Hookwood (fluvial).

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

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

Proposed site allocations have been subject to a sequential test, which directs development to areas at low risk of flooding. On a small number of sites, the Exception Test has been applied, based on guidance in the Level 2 SFRA. Sites allocated in the Local Plan will also be subject to site-specific Flood Risk Assessment where required, at planning application stage.

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

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

Map 12: Common and Inalienable Land

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

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

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

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

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

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

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

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

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

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

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

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

Summary: Common Land and Inalienable Land

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

Section 7: Noise 163. Paragraph 11 of the NPPF does not include noise within the list of constraints which might indicate that development should be restricted. However, paragraph 180 states that planning policies and decisions should take into account likely effect on health, living conditions and the natural environment as well as the potential sensitivity of the site to impacts that could arise from the development. In doing so they should:

a) mitigate and reduce to a minimum potential adverse impacts resulting from noise from new development – and avoid noise giving rise to significant adverse impacts on health and the quality of life; b) identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason.

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

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

166. This section focusses on significant noise sources which have a constraining influence over a significant area of land in Mole Valley and therefore have an impact on strategic options for development. The first is road noise in the M25 area around Leatherhead and Ashtead. The second is aircraft noise associated with Gatwick Airport. M25 road noise 167. In the north of the District, the M25 motorway enters Mole Valley close to the District boundary and turns south through the gap between Leatherhead and Ashtead. In this area, the motorway and its associated slip roads are a significant noise source, very close to the existing built up area. The A24 Leatherhead Bypass passes through the same corridor.

168. In order to inform the plan-making process, MVDC commissioned Southdowns Environmental Consultants to undertake a Strategic Noise Assessment of this M25 corridor (published 2017). The assessment used computer modelling to examine the influence of road noise on currently undeveloped land within 250m of the motorway, in the Leatherhead and Ashtead area.

169. The aim of the 2017 Southdowns assessment was to identify the extent to which road noise originating from the M25 and adjacent major roads acts as a strategic constraint on residential development within this corridor. It focussed on residential uses, because housing is the largest component of identified development needs and because residential uses are likely to be more sensitive to noise than other uses considered during the plan- making process.

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

171. In order to provide a complete understanding of the noise environment, the study considered three “Zones”, each of which has a different topographical relationship with the M25. All the land within the study area is within the Green Belt and therefore currently 49

safeguarded from development as a matter of principle. However, the study was intended to inform selection of sites, should MVDC decide that exceptional circumstances existed to make changes to the Green Belt boundary (see section 2).

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

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

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

175. In light of this assessment, site-specific noise evidence has been submitted on potential sites in close proximity to the M25. If sites in this area are included in the Local Plan, noise mitigation measures will be required. In practice, this is likely to involve high residential densities in the areas closest to the M25, in order to create a building mass which would maximise noise screening for land in its “shadow”. Housing in almost all areas would also require a high standard of sound proofing and alternative ventilation systems to enable windows to be kept closed.

176. Mitigation measures are also likely to include careful design of enclosed and relatively quiet external amenity spaces – for example spaces enclosed within courtyard developments – in order to provide residents with access to outdoor spaces protected from noise.

177. These mitigation measures are broadly in line with National Planning Policy Guidance, which suggests that noise impacts on residential development may be partially off-set if residents have access to a relatively quiet façade and/or are provided with access to nearby quiet external amenity spaces. Draft site allocation policies incorporate requirements to incorporate mitigation measures on affected sites.

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

179. Map 13 (below) illustrates the extent of the noise contours for Gatwick Airport, published 2018.

Map 13: Gatwick Noise Contours 51

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

181. The level of aircraft noise which constitutes a significant adverse impact is not clearly defined, either in the NPPF or the Noise Policy Statement for England. UK policy has historically identified 57dB LAeq as the threshold at which daytime noise marks the onset of significant community annoyance. The Aviation Policy Framework (2013) specifically recognises that 57LAeq of daytime aircraft noise marks the approximate onset of significant community annoyance. At this level, aircraft noise causes a material change in behaviour and/or attitude, such as having to keep windows closed most of the time, avoiding certain activities during periods of intrusion. Therefore, the 2017 version of this Constraints Analysis identified the 57LAeq daytime noise contour as the minimum area where it could reasonably be assumed that aircraft noise should be regarded as a strategic constraint on development and where it would not be appropriate to plan for a significant level of population growth.

182. The map above shows the whole area included in day time noise contours of 54dB or above. World Health Organisation guidelines indicate a significant risk that open space and amenity areas will be adversely affected by noise levels in excess of 55dB (LAEQ16hr), which implies that a wider area would be significant affected by aircraft noise. Furthermore, the Civil Aviation Authority Survey of Noise Attitudes (2014) found that the degree of annoyance (based on the percentage of respondents highly annoyed) previously occurring at 57 dBA, now occurs at 54 dBA. The Leq 16-hour contours have been plotted down to the lower level of 54 dBA since 2016.

183. There is widespread recognition that the 48LAeq night time contour provides the equivalent threshold for the onset of significant community annoyance at night. In fact, World Health Organisation Community Noise Guidelines (2000) identify 45 LAeq as the threshold required to prevent sleep disturbance. There is also increasing concern about the impact of poor sleep on human health. There is sufficient evidence that this level of noise exposure is harmful to human health that it is considered appropriate to avoid planned development within the 48LAeq night time noise contour. This is a precautionary approach which will help to minimise increases in population within areas adversely affected by night time aircraft noise. In practice, the 48LAeq night time and 54 LAeq day time contours cover very similar geographical areas.

184. Applying the 48LAeq night time and 54LAeq day time noise thresholds significantly increases the area excluded from strategic-scale development for reasons of aircraft noise, compared with the area identified in the 2017 Constraints Analysis. The maps above have therefore been updated to reflect this. Proposed site allocations in the Regulation 18 Local Plan avoid allocation of housing sites within the 48LAeq night time or 54LAeq day time contour.

185. There are areas within the villages of Capel and Charlwood which lie within the noise contours and where infill development on windfall sites may be proposed during the plan period. The draft Local Plan policy framework resists noise-sensitive (including residential) development in areas where aircraft noise levels would have a significant adverse effect on the occupants. The policy allows flexibility for site-specific noise evidence, including proposed mitigation measures, to be submitted and considered through the planning application process. This flexible policy framework will allow the Council to respond to changes in technology and the extent of the noise contours during the plan period.

Summary: Noise

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

Where residential development is proposed in the affected area, significant noise mitigation measures will be required. Site-specific noise evidence has been obtained to establish the broad approach to be taken. A detailed approach would require further, site-specific noise mitigation measures at planning application stage.

In the south east of the District, the 48LAeq night time and 54 LAeq day time noise contours are regarded as indicating an area where aircraft noise is likely to cause significant community annoyance and where any material increase in population should be avoided as a matter of principle. This is consistent with the approach in the Government’s Aviation Policy Framework 2013 and WHO Guidelines.

Section 8: Air Quality 186. National Planning Policy Guidance advises that air quality issues should be taken into account in plan-making, in order to take account of air quality management areas and other areas where there could be specific requirements or limitations on new development because of air quality. Local Plans may need to consider the cumulative impact of smaller development as well as the effect of more substantial development. The appropriate use of mitigation measures can also be a consideration.

187. MVDC undertakes air quality monitoring in order to identify any relevant areas where it is considered that the government’s air quality objectives will be exceeded. To date, monitoring reports have concluded that there are no requirements to proceed to detailed assessments for any pollutants of concern in the Mole Valley District (2019 Air Quality Annual Status Report (ASR)). The Council will continue to maintain and review existing monitoring sites throughout the district with a view, where possible, to increasing spatial coverage and understanding. 188. Potential air quality issues in Mole Valley are most likely to arise from increased road use within and around the district. Mole Valley monitors in these areas for NO2 through the deployment of diffusion tubes. Monitoring locations have been selected to be representative of the types of location where pollution from road traffic is most likely to give rise to air quality issues, including in the vicinity of the M25 and in West Street, Dorking, where there is a pattern of stationery traffic on a narrow highway enclosed between relatively tall buildings.

189. There is currently no particulate matter monitoring undertaken by MVDC, however the Council keeps regional data under review and is working with other Surrey Authorities through the Surrey Air Alliance to introduce measures aimed at reducing emissions.

190. Air Quality Management Areas (AQMAs) are declared when there is an exceedance of likely exceedance of an air quality objective. MVDC currently does not have any AQMAs and the 2019 ASR confirmed that there have been no significant changes in the district since the previous round of review and assessment.

191. At a national level, the Clean Air Strategy includes a range of proposals to reduce exposure to all forms of air pollution by 2030. This includes progressive reductions in exposure to particulate matter, moving towards what are described as “challenging” WHO guidelines. The Environment Bill introduced earlier in 2019 was also intended to introduce a target regime for particulate matter, however this legislation was aborted as a result of the December 2019 General Election and its future direction is uncertain.

192. Much of the focus of national policy is on reducing sources of air pollution and helping people manage their own exposure through changes in behaviour. The Local Plan will contribute to these goals through a range of policies including requirements for Electric Vehicular Charging points and cycle parking on new development, infrastructure improvements and travel plans to promote sustainable transport options linked to larger developments and safeguarding and enhancement of green infrastructure to support healthy lifestyles.

193. Based on monitoring data, air quality issues do not currently rule out any specific locations for development. National Planning Policy Guidance provides the framework for the issue to be kept under review and if it becomes apparent that site-specific mitigation measures are required in any particular location, this can be addressed through application of appropriate development management policies at planning application stage and/or through the five yearly review of the Local Plan.

194. As mentioned in section 1: Nature Conservation, MVDC has also undertaken a joint study of potential impact of air pollution on the Special Area of Conservation. This was completed in June 2018 and concluded that growth to 2033 would not have a significant in- combination effect on the SAC. However, some targeted measures were recommended to monitor air quality in a specific section of the highway network at Reigate Hill/Pebble Hill Road and this is incorporated in the Monitoring Framework in the Regulation 18 consultation draft Local Plan.

Summary: Air Quality

There are no Air Quality Management Areas within Mole Valley. Based on monitoring data, air quality issues do not rule out any strategic options for development. However, the emerging Local Plan includes a range of policies which will contribute to the management of air quality during the plan period and support national strategic plans for reducing air pollution.

Should it become apparent that site-specific mitigation measures are required in any specific location, this can be addressed through application of appropriate development management policies at planning application stage. This includes locations identified through the Mole Gap to Reigate Escarpment SAC Air Quality Impact Assessment 2018 and/or Habitats Regulation Assessment of the emerging Local Plan.

Section 9: Transport 195. Transport infrastructure is not one of the constraints identified in Paragraph 11 of the NPPF. However, the NPPF requires that transport issues are considered from the earliest stages of plan-making so that

a) the potential impacts of development on transport networks can be addressed;

b) opportunities from existing or proposed transport infrastructure, and changing transport technology and usage, are realised – for example in relation to the scale, location or density of development that can be accommodated;

c) opportunities to promote walking, cycling and public transport use are identified and pursued;

d) the environmental impacts of traffic and transport infrastructure can be identified, assessed and taken into account – including appropriate opportunities for avoiding and mitigating any adverse effects, and for net environmental gains; and

e) patterns of movement, streets, parking and other transport considerations are integral to the design of schemes, and contribute to making high quality places.

196. National Planning Policy Guidance also highlights the importance of establishing a robust transport evidence base in order to support the preparation of a Local Plan. The evidence base should identify opportunities for encouraging a shift to more sustainable transport usage, where reasonable to do so and highlight infrastructure requirements which will need to be progressed during implementation of the Local Plan.

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

198. As a first step in establishing the evidence base for transport considerations, MVDC commissioned Surrey County Council to analyse current transport patterns and issues in the District. Their report3 provided an insight into existing transport trends and constraints, covering all modes of transport.

199. The following issues were identified which would have a bearing on the development of strategic development options for the Local Plan:

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

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

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

3 Mole Valley District Council Local Plan: Existing Transport Trends & Constraints, March 2017, available at www.futuremolevalley.org

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

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

 There are existing congestion issues on the approaches into both Leatherhead and Dorking centres, notably in the areas around the Knoll Roundabout/A24/Leatherhead bypass and Waterway Road, Leatherhead and the A24 in the area of the North Holmwood roundabout/Chart Lane/Deepdene Avenue in Dorking. To a lesser extent, congestion is also identified as an issue on the A25 approaches to the east and west of Dorking, the Randalls Road approach into Leatherhead, parts of the A243 Kingston Road and roads linking to the A24 south of Leatherhead.

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

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

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

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

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

200. SCC’s Local Transport Strategy for Mole Valley includes a forward programme of future schemes which aim to address known issues and mitigate the impact of future growth on the transport network. This provides an evidence base for future funding bids and has also informed the draft Infrastructure Delivery Plan.

201. MVDC continues to work with SCC and Highways England to ensure that strategic development options and individual potential sites take account of known transport issues and incorporate appropriate mitigation of the additional impact on the transport network.

This has included a Strategic Highway Assessment4 to model the impact of growth on traffic levels both within Mole Valley and across administrative boundaries.

202. The SCC Strategic Highway Assessment is informed by SCC’s strategic transport model. It tests five alternative scenarios to model forecast transport impacts on highways up to 2033. The Scenarios compare a “do nothing” option (A) with four alternative growth scenarios (B to E). Scenario B includes the highest level of development, with Scenarios C to E testing the impact of greater or lesser amounts of development in areas with existing known congestion issues.

203. The report identifies a series of network hotspots where junctions and sections of road are operating above capacity. These are listed in the table below. The majority of these are existing, with those in italics being new hotpots which would occur as a result of housing growth under Scenarios B to E.

Area Location Links Leatherhead M25 Junction 9 - 10 Hookwood A23 Brighton Road Junctions Ashtead A24 Leatherhead Road signalised junction with Grange Road and Ermyn Way Farm Lane with Downs Road and Headley Road Leatherhead A244 Oxshott Road roundabout with Oaklawn Road A245 Randalls Road signalised junction with Cleeve Road A245 Randalls Road signalised junction with Station Approach A245 Station Road / Station Approach signalised junction with B2122 Waterway Road B2430 Kingston Road roundabout with Cleeve Road and Dilston Road B2450 Leret Way signalised junction with B2122 Epsom Road B2450 The Crescent signalised junction with Church Street Beaverbrook Roundabout (A24 with B2033) Givons Grove Roundabout (A24 with A246 and B2450) Knoll Roundabout (A24 with A243 and B2122) M25 Junction 9a Roundabout (A243 with A245 and M25) M25 Junction 9b Roundabout (A244 with A243 and M25) Bookham A246 Leatherhead Road signalised junction with Eastwick Road and Crabtree Lane. Dorking A24 London Road roundabout with B2038 Pixham Lane A24 London Road signalised junction with A2003 Ashcombe Road A24 Deepdene Avenue roundabout with A25 Reigate Road / High Street A24 Deepdene Avenue / Horsham Road roundabout with A2003 Flint Hill A25 High Street signalised junction with London Road A25 High Street with signalised junction of West Street A25 High Street with signalised junction of Junction Road A25 Westcott Road with signalised junction of Vincent Lane B2038 Pixham Lane signalised shuttle working Wotton A25 Guildford Road priority junction with Hollow Lane A25 Guildford Road priority junction with Raikes Lane and White Down Lane Betchworth A25 Reigate Road roundabout with B2032 Station Road B2032 Station Road level crossing

4 Mole Valley District Council Local Plan: Strategic Highway Assessment 2019

Area Location Beare Beare Green Roundabout (A24 with A29) Green Capel Clarks Green Roundabout (A24 with Horsham Road and Rusper Road) Ockley A29 Stane Street priority junction with B2126 Lake Road Horsham Road with Frogetts Lane Horsham Road with Okewood Hill Okewood Hill priority junction with Ruckmans Lane Hookwood A23 Brighton Road roundabout with A217 Reigate Road and Povey Cross A217 Reigate Road roundabout (access for Tesco)

204. The report concludes that none of the impacts predicted from Local Plan growth are sufficiently severe to eliminate a scenario solely on highway impacts. However, further analysis relating to development sites and their potential mitigation measures should be focused on areas where the highway network is already under pressure as it is in these locations which highway conditions are exacerbated the most by development.

205. The above findings will form the basis for further work with SCC, Highways England and developers on a programme of mitigation measures. Site-specific transport evidence has been obtained from developers, where required, to inform the selection of sites and begin to identify potential mitigation measures in more congested areas. Specific locations which require mitigation are highlighted in the Regulation 18 version of the Infrastructure Delivery Plan and ongoing work on mitigation measures will be incorporated into an updated Infrastructure Delivery Plan to support the Regulation 19 draft Plan.

206. The Regulation 18 consultation draft Local Plan also includes a range of policies to support more sustainable transport, including requirements for travel plans linked to larger development, improvement of cycle infrastructure and a range of site-specific requirements.

Summary: Transport

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

The development of strategic options has taken account of existing known congestion issues, particularly affecting the approaches into Leatherhead and Dorking town centres. Strategic transport modelling has been undertaken as part of the process of selecting preferred sites, together with consideration of site-specific transport evidence and mitigation options.

The transport evidence base does not indicate that traffic impacts associated with Local Plan growth would be sufficiently severe to eliminate any of the tested scenarios on highway grounds. However, there are several locations in the District which suffer from congestion and where there will be additional traffic as a result of growth. Therefore a package of targeted mitigation measures is required, drawing on the evidence to date. Ongoing work on mitigation measures will be incorporated into an updated Infrastructure Delivery Plan to support the Regulation 19 draft Plan.

Joint working with Highways England is ongoing, to understand the implications of congestion and safety concerns on the M25, particularly at Junction 9a.

Account has also been taken of different levels of accessibility to public transport options, with strategic sites being located in the most accessible locations around urban areas and larger villages with access to a variety of transport options.

Draft policies including a range of measures to support sustainable travel should help support a shift away from use the private car for shorter journeys of 2-5km.

Conclusions 207. The boxes at the end of each of the above sections highlight the key constraints which are influencing the strategic direction of the Local Plan. In some cases, they identify natural constraints which have precluded development of a strategic scale on land within certain categories. In this context, development of a strategic scale refers to developments providing more than 100 dwellings, or an equivalent amount of development for alternative uses.

208. The areas within which strategic-scale development has been ruled out as a matter of principle are as follows:  Land within the Surrey Hills Area of Outstanding Natural Beauty (AONB)  Land within the Area of Great Landscape Value (until such time as a review of the AONB boundary has been completed)  Land which is designated as a Site of Special Scientific Interest  Land which is designated as a Special Area of Conservation  Land which is designated as a Registered Park or Garden  Land within the Functional Flood Plain (Flood Zone 3b)  Common Land  Inalienable Land within the ownership of the National Trust  Land within the 54LAeq day time and/or 48LAeq night time noise contour associated with Gatwick Airport

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

Map 14: Areas excluded in principle from strategic-scale development

In addition to the constraints shown on Map 14, there are a number of key areas where further assessment and/or mitigation will be required to take account of important constraints and in some cases mitigate the impact of development. These constraints are illustrated on Map 15 (below) and the issues can be summarised as follows:

Constraint Further assessment/mitigation

Nature Conservation: Draft Local Plan policies include mitigation measures as European Sites recommended in Regulation 18 Habitats Regulation Assessment.

Draft Local Plan monitoring framework reflects recommendations in Mole Gap to Reigate Escarpment SAC Air Quality Impact Assessment, June 2018

Further engagement with Natural England and other stakeholders in relation to Regulation 18 consultation.

Nature Conservation: Network of designated nature conservation sites, SSSIs and other irreplaceable habitat and priority habitats taken into account designated areas when assessing site suitability. Site-specific measures to mitigate impact on biodiversity incorporated in proposed site allocations, where relevant.

Nature Conservation: Draft Local Plan policies highlight the need for new Biodiversity Opportunity development to take opportunities to enhance biodiversity, in Areas Biodiversity Opportunity Areas.

Green Belt Proposed site allocations have been informed by a Green Belt Review published January 2020, which identifies areas which make a less significant contribution to the purposes of including land within the Green Belt.

Heritage Impact on heritage assets has been taken into account when assessing site suitability. Measures to safeguard heritage assets and their setting incorporated in proposed site allocations, where relevant.

Flooding Sequential approach adopted during the selection of sites, to direct development towards areas at least risk of flooding. Exception test applied in the very limited number of cases where development may be proposed in Flood Zones 2 or 3 or is at risk of flooding from other sources.

Noise Additional site-specific noise evidence obtained in relation to proposed sites close to M25. Mitigation measures to be secured through site allocation policies where relevant.

Constraint Further assessment/mitigation

Transport Strategic transport modelling undertaken to inform the selection of strategic sites. Congestion hotpots identified which will be the focus of mitigation measures to tackle increased congestion as a result of growth. Site-specific mitigation measures to be secured through site allocations, where required.

Map 15: Combined Constraints 65