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Constraints Analysis

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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 2 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. 4 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. 5 Map 1: Mole Gap to Reigate Escarpment Special Area of Conservation 6 Map 2: Thames Basin Heaths Special Protection Area, 5km and 7km zones 7 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);
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