Sustainability Appraisal (SA) of the and Malling Local Plan

SA Report Addendum

April 2019

Tonbridge and Malling Local Plan SA SA Report Addendum

Quality information

Prepared by Checked by Approved by

Chris McNulty Mark Fessey Steve Smith Senior Consultant Associate Director Technical Director

Prepared for:

Tonbridge and Malling Borough Council

Prepared by:

AECOM Infrastructure & Environment UK Limited Aldgate Tower 2 Leman Street London E1 8FA aecom.com

© 2019 AECOM Infrastructure & Environment UK Limited. All Rights Reserved.

This document has been prepared by AECOM Infrastructure & Environment UK Limited (“AECOM”) for sole use of our client (the “Client”) in accordance with generally accepted consultancy principles, the budget for fees and the terms of reference agreed between AECOM and the Client. Any information provided by third parties and referred to herein has not been checked or verified by AECOM, unless otherwise expressly stated in the document. No third party may rely upon this document without the prior and express written agreement of AECOM.

AECOM

Tonbridge and Malling Local Plan SA SA Report Addendum

Table of Contents

Non-technical summary ...... 1 1. Introduction ...... 3 2. Development strategy alternatives ...... 5 3. Green Belt extension alternatives ...... 15 4. Conclusions ...... 17 Appendix A Sifting Green SLAA sites ...... 18 Appendix B - Detailed appraisal of the 2019 development strategy options...... 32 Appendix C - Detailed appraisal of the Green Belt alternatives ...... 47

AECOM

Tonbridge and Malling Local Plan SA SA Report Addendum

Non-technical summary

This SA Report Addendum presents the outcome of targeted supplementary Sustainability Appraisal (SA) work completed in March and April 2019. Specifically, this report presents the outcome of work to explore reasonable alternatives, thereby supplementing the discussion of reasonable alternatives presented in Chapter 5 of the submission SA Report (2019). More specifically, this report presents the outcome of supplementary work to explore reasonable alternatives in respect of: the development strategy; and Green Belt extension. The development strategy

Chapter 2 explores reasonable alternatives in respect of the development strategy. It is structured under two sub- headings: Reasons for selecting the alternatives; and Alternatives appraisal findings.

Reasons for selecting the alternatives

A step-wise process was completed in order to arrive at a series of development strategy alternatives, i.e. alternative packages of site allocations. The starting point was the list of site options subjected to appraisal within Appendix 6 of the SA Report (pg.103), whilst the key step in the process involved ‘sifting’ sites in order to arrive at a shortlist of sites to feed into the alternatives.

The alternatives ultimately arrived at are presented in summary form here:

Description of sites selected for Total yield of housing Total yield of allocation allocations* employment allocations

Option 1 Sites at Tonbridge or the Medway Gap 5,595 homes 37.2 ha

Option 2 Sites adjacent to a settlement 9,634 homes 39.5 ha

Option 3 Sites close to a transport hub 6,595 homes 5.5 ha

Option 4 Sites outside of the Green Belt & AONB 3,927 homes 22 ha

Option 5 The submission strategy 6,834 homes 32.8 ha

* in addition to allocations there is set to be supply of 8,058 homes from other sources under all alternatives.

Alternatives appraisal findings

Focusing on Option 5, which is the submission strategy, the appraisal predicts significant positive effects in respect of ‘homes’, ‘health and care’ and ‘accessibility’. Significant negative effects are predicted in respect of ‘land use’, and uncertain negative effects in respect of ‘economy’; however, in both cases only one of the four alternatives performs better (Option 4 in respect of land use; Option 2 in respect of the economy). In respect of four further objectives, namely ‘flood risk’, ‘air quality’, ‘climate change’ and ‘water’, the appraisal finds that the submission strategy is not the best performing of the alternatives, but does not highlight any significant concern. Green Belt extension

Chapter 3 explores reasonable alternatives in respect of Green Belt extension. It is structured under two sub- headings: Reasons for establishing the alternatives; and Alternatives appraisal findings.

Reasons for establishing the alternatives

Drawing upon work reported in detail in the Council’s Green Belt Exceptional Circumstances Topic Paper (see Chapter 3), the following alternatives were established (each of which involves an increased scale of Green Belt extension in turn):

 Option 1 - no Green Belt extension (i.e. no new restriction on growth).  Option 2 - extend eastwards to the A228 Ashton Way (i.e. new restriction on growth to the east of ; the 2016 approach)

 Option 3 - extend further eastwards to Road) (i.e. new restriction on growth east of West Malling, north of and west of East Malling; the submission approach)

AECOM 1

Tonbridge and Malling Local Plan SA SA Report Addendum

 Option 4 - extend further eastwards to Kiln Barn Road (i.e. new restriction on growth east of West Malling, north of Kings Hill and either side of East Malling)

Alternatives appraisal findings

The appraisal broadly serves to highlight that extension of the Green Belt is supported in respect of environmental objectives, but leads to tensions in respect of socioeconomic objectives; however, the picture is not entirely clear- cut, with extension not supported in respect of climate change objectives, as the area in question has good rail connectivity. The submission strategy involves a greater area of new Green Belt than one of the alternative options appraised, but less than another, with a view to striking a balance between competing objectives.

AECOM 2

Tonbridge and Malling Local Plan SA SA Report Addendum

1. Introduction

Background

1.1 The Tonbridge and Malling Local Plan has been prepared by Tonbridge and Malling Borough Council. Once in place, the Local Plan will establish a spatial strategy for growth and change in the Borough over the period up to 2031, allocate sites and establish the policies against which planning applications will be determined. The Local Plan is at an advanced stage of preparation, with the Proposed Submission Plan having been published in September 2018, under Regulation 19 of the Local Planning Regulations, and then submitted to Government for independent examination in January 2019, under Regulation 22.

1.2 The Local Plan has been developed alongside a process of Sustainability Appraisal (SA) - a legally required process that aims to ensure that the significant effects of an emerging draft plan, and alternatives, are systematically considered and communicated. The SA Environmental Report (henceforth ‘the SA Report’) was published and then submitted alongside the Local Plan in 2018/19, subsequent to which the Council commissioned AECOM to undertake some targeted supplementary SA work. The outcome of that work is reported in this SA Report Addendum, with a view to informing the Local Plan examination.

This SA Report Addendum

1.3 This SA Report Addendum presents the outcome of targeted supplementary SA work completed in March and April 2019. Specifically, this report presents the outcome of work to explore reasonable alternatives, thereby supplementing the discussion of reasonable alternatives presented in Chapter 5 of the submission SA Report (2019).

1.4 More specifically, this report presents the outcome of supplementary work to explore reasonable alternatives in respect of two matters, namely:  the development strategy - see Chapter 2 of this report; and  Green Belt extension - see Chapter 3 of this Report.

N.B. this is an ‘SA Report Addendum’ on the basis that it focuses on a specific matter – namely further appraisal of reasonable alternatives – as opposed to the Local Plan as a whole, which is the remit of the SA Report. This report supplements and does not seek to replace the submission SA Report (2018).

Scope of the SA

1.5 The scope of SA work, with respect to the Tonbridge and Malling Local Plan, is introduced within the SA Report (2018; see Section 4.1). Essentially, the scope is reflected in a list of sustainability objectives (established through a process of ‘scoping’, which included consultation in 2016). The sustainability objectives provide a methodological ‘framework’ for appraisal – see Table 1.1.

AECOM 3

Tonbridge and Malling Local Plan SA SA Report Addendum

Table 1.1: The SA framework

SA objective1 Supplementary appraisal questions

1 Homes  Will it deliver affordable housing? To ensure that everyone has the  Will it deliver sufficient supply to meet the identified housing opportunity to live in an need? affordable home  Will it provide housing for the aging population?  Will it provide for the accommodation needs of Gypsies and Travellers and Travelling Showpeople? 2 Flood risk  Will it reduce the number of people and properties at risk of To reduce and manage the risk flooding? of flooding  Will it manage water efficiently and sustainably?

3 Health and care  Will it promote healthy lifestyles? To improve the health and care  Will it improve access to healthcare? of the population  Will it increase and quantity and quality of publically accessible open space? 4 Crime  n/a To reduce crime and the fear of crime

5 Accessibility  Will it provide increased travel choice? To improve accessibility for  Will it support the continued viability of urban and rural centres? everyone to services and facilities

6 Land use  Will it use land that has been previously developed? To improve efficiency of land  Will it avoid the sterilisation of economic mineral reserves? use  Does it result in the loss of best and most versatile agricultural land? 7 Air quality  Will it avoid locating development in areas of existing poor air To protect and improve air quality? quality  Will it help avoid the creation of additional AQMAs?

8 Climate change  Will it support the use of renewable resources? To ensure that the Borough  Will it promote energy efficiency? responds positively, and adapts to, the impacts of climate change

9 Natural and heritage assets  Will it minimise habitat fragmentation? To protect and enhance natural  Will it provide increased access to and understanding of the and heritage assets historic environment?  Will it conserve and enhance designated landscapes? 10 Waste management  Will it reduce waste generation? To reduce waste and achieve  Will encourage the re-use of materials? sustainable waste management

11 Water  Will it avoid a deterioration of the quality of waterways and To maintain and improve water groundwater? quality and to use water more  Will it facilitate water re-use and recycling? efficiently

12 Economy  Will it encourage the rural economy and diversification? To achieve and maintain a  Will it contribute to providing a range of employment vibrant economy. opportunities in accessible locations?  Will it support town centre vitality?

1 These topics align with the issues listed in the Regulations as potentially necessitating consideration through SA (see Schedule II(f)). The SA Report (see para 1.3.1) explains the links between the framework and the list of issues in the Regs.

AECOM 4

Tonbridge and Malling Local Plan SA SA Report Addendum

2. Development strategy alternatives Introduction

2.1 The aim of this section is to introduce and appraise up-to-date development strategy alternatives, i.e. alternative approaches to the allocation of land for housing and employment.

2.2 In essence, the aim is to supplement: Section 5.1 of the SA Report, which presents the appraisal of ‘Strategic Development Strategy Options’ from the 2016 Regulation 18 stage; and Section 5.2 of the SA Report, which presents the appraisal of individual site options completed in 2018. Establishing the alternatives

2.3 The aim of this section is to present “an outline of the reasons for selecting the alternatives dealt with”, in accordance with the regulations (Schedule 2(8).

2.4 The starting point was the list of site options subjected to appraisal within Appendix 6 of the SA Report (pg.103). This list comprises refined versions2 of all sites rated as ‘suitable and deliverable’ (green) by the Council’s Strategic Land Availability Assessment (SLAA), as well as four sites rated as ‘suitable but undeliverable’ (amber) by the SLAA.

2.5 The total housing yield of this shortlist of sites is far in excess of needs. As such, the next step was to implement a ‘sifting’ process in order to identify a refined shortlist. Appendix A reports this process.

2.6 The final step was then to identify combinations of site options (from the refined shortlist, i.e. those that emerge from the sifting process presented in Appendix A). There are many such site combinations; however, on the other hand, there is a need to limit the number of development strategy options. Ultimately, following discussions between the Council and AECOM, it was reasonable to model 2019 development strategy alternatives on the 2016 Strategic Development Strategy Options.

2.7 Accordingly, the following reasonable development strategy alternatives were identified:

 Option 1 - sites at Tonbridge or the Medway Gap

 Option 2 - sites adjacent to a settlement (all sites)  Option 3 - sites close to a transport hub  Option 4 - sites outside of the Green Belt and AONB  Option 5 - the submission strategy (not to be confused with Option 5 from Section 5.1 of the SA Report, i.e. the preferred option from the 2016 Issues and Options stage). N.B. to be clear, the package of sites proposed for allocation at the Regulation 18 Issues and Options stage is no longer reasonable. This is on the basis that this strategy included several sites at their ‘unrefined’ extent, i.e. at an extent subsequently found to be unsuitable and/or undeliverable (see discussion above at para 2.3, and the discussion within footnote 2, below).

2.8 The five reasonable development strategy options (2019) are presented below within Table 2.1.

2 The Council went through a process of refining the extent of SLAA sites in 2016, and then a process of further refinement in 2018, with the aim of removing parts of each site that are unsuitable and/or undeliverable. The final refinements were made in light of representations received during the consultation on the Regulation 18 Plan and taking account of evidence published between the Regulation 18 and Regulation 19 stages of plan-making, including the Housing Delivery Study (September 2017), A20 VISUM Study (March 2018) and the Transport Assessment (June 2018) and Addendum (August 2018). The process of refining sites, and in turn the preferred development strategy, was discussed at paragraph 5.2.5 of the submission SA Report.

AECOM 5

Tonbridge and Malling Local Plan SA SA Report Addendum

2.9 Notes on the table are as follows:

 For each settlement:

─ Firstly, the table groups sites for which allocation was taken as something of a given, for the purposes of exploring development strategy alternatives. Specifically, 16 sites fall within this category, comprising: eleven ‘building block’ sites,3 which are strongly supported on the basis of within a settlement (brownfield or at low risk of flood) or comprising existing safeguarded land (including the Bushey Wood area of opportunity, on the east bank of the Medway in the north of the Borough); and five sites that are allocations within the existing Development Plan that can safely be rolled-forward into the new Local Plan.4

─ Secondly, the table lists the other sites (housing and then employment) for which allocation is a constant across the alternatives on account of being located: at Tonbridge or the Medway Gap; close to a transport hub; and outside of the Green Belt and AONB.

─ Thirdly, the table lists sites (housing and then employment) for which allocation is a variable across the alternatives. Sites are listed in size order.

 With regards to the blue shaded rows at the bottom of the table:

─ the first provides the total yield of the housing allocations listed in the preceding rows; ─ the second contrasts this figure to the target yield of housing allocations, which is 5,862 homes. This target figure is the difference between the requirement figure of 13,920 and 8,058, which is the number of homes set to be delivered through other sources of supply over the plan period, namely homes at sites that have already been built (‘completions’) or gained planning permission (‘commitments’) since the start of the plan period, and the assumed number of homes that, it is assumed, will be delivered at small windfall sites, i.e. non-allocated sites. N.B. it can be seen that the proposal is to examine options involving providing for significantly above and below the requirement, as well as options that would involve providing for more or less the requirement. Implications are explored further within the appraisal.

─ the third provides the total yield of employment allocations listed in the preceding rows; and ─ the fourth contrasts this figure to the target yield of employment allocations, which is 46.8ha. N.B. it can be seen that none of the options provide for the employment target figure, and several options would involve a large shortfall. There is not considered to be any reasonable higher growth option, given the sites that are available. Furthermore, the view of the Council is that there is the potential to close the gap between supply and the target figure through intensifying employment activity on existing employment sites. This is an approach supported through policies LP34 and LP35 of the Local Plan).

 Finally, on detailed points:

─ Site 188 includes sites 381 and 392. ─ Site 192/254/355/386 was nominated multiple times and therefore received multiple site reference numbers.

─ Site 251 includes Site 266 ─ Site 327 includes sites 325 and 326. ─ Site 408 includes sites 283 and 312.

3 Sites 189, 195, 196, 197, 198, 199, 236, 242, 243, 248, 310 4 109 Hall Road, ; Nu Venture Coaches, Mill Hall Aylesford; Oil Depot, Station Road, Aylesford; Park House, 110-112 Mill Street, East Malling; and Kings Hill remainder.

AECOM 6

Tonbridge and Malling Local Plan SA SA Report Addendum

Table 2.1: The reasonable development strategy options (2019)

Option 1 Option 2 Option 3 Option 4 Option 5 Location SLAA ref. Primary use Tonbridge or the Medway Gap Adjacent to a settlement Transport hub Outside of the GB and AONB Submission strategy Building blocks + existing allocations Housing 220 220 220 220 220 259 Employment 1.7ha 1.7ha 1.7ha 1.7ha 1.7ha 275 Housing 1,211 1,211 346 Housing 418 418 417 Housing 319 319 319 319 393 Housing 219 219 219 219 Tonbridge 423 Housing 146 146 266 Housing 136 136 136 136 334 Housing 61 61 61 61 422 Housing 54 54 54 54 280 Employment 10.8ha 10.8ha 10.8ha 385 Employment 1.1ha 1.1ha Building blocks + existing allocations Housing 83 83 83 83 83 188 (includes yield from 329 and 381) Housing 1000 1000 1000 1000 1000 304 (Parkside) Housing 205 205 205 205 205 304c Employment 2.3ha 2.3ha 2.3ha 2.3ha 2.3ha 419 Employment 1.5ha 1.5ha 1.5ha 1.5ha 1.5ha 304 (Ditton) Housing 216 216 216 216 Medway Gap 268 Housing 125 125 125 125 212 Housing 118 118 118 389 Employment 7.3ha 7.3ha 7.3ha 7.3ha 218 Employment 5.6ha 5.6ha 304d Employment 5.5ha 5.5ha 5.5ha 5.5ha 239 Employment 1.4ha 1.4ha 1.4ha 1.4ha Building blocks + existing allocations Housing 65 65 65 65 65 Kings Hill 358 Housing 825 825 825 825 200 Housing 26 26 26 26 26 314 Employment 1.3ha 1.3ha 1.3ha Building blocks + existing allocations Housing 7 7 7 7 7 408 Housing 1,720 1,720 1,720 316 Housing 225 225 300 Housing 95 95 311 Housing 16 16 16 233 Housing 35 35 427 Housing 23 23 267 Employment 1.0ha 1.0ha 1.0ha Building blocks + existing allocations Housing 25 25 25 25 25 302 Housing 167 192/254/355/386 Housing 156 156 251 Housing 66 66 237 Housing 105 105 105 105 327 Housing 413 West Malling 396 Housing 110 110 110 299 Housing 12 12 Other settlements Building blocks + existing allocations Housing 954 954 954 954 954 and rural area 270 Housing 58 58 58

Housing supply from allocations 5,595 9,634 6,595 3,927 6,834 % above or below target -1.9% +27.1% +5.3% -13.9% +7% Employment land supply from allocations 37.2 ha 39.5 ha 5.5 ha 22 ha 32.8 ha % above or below target -20.5% -15.6% -88.2% -53.0% -29.9%

AECOM 7

Tonbridge and Malling Local Plan SA SA Report Addendum

Figure 2.1: Option 1 - Sites at Tonbridge or the Medway Gap

AECOM 8

Tonbridge and Malling Local Plan SA SA Report Addendum

Figure 2.2: Option 2 - All sites adjacent to a settlement

AECOM 9

Tonbridge and Malling Local Plan SA SA Report Addendum

Figure 2.3: Option 3 - Sites close to a transport hub

AECOM 10

Tonbridge and Malling Local Plan SA SA Report Addendum

Figure 2.4: Option 4 - Sites outside of the Green Belt and AONB

AECOM 11

Tonbridge and Malling Local Plan SA SA Report Addendum

Figure 2.5: Option 5 - The submission strategy

AECOM 12

Tonbridge and Malling Local Plan SA SA Report Addendum

Alternatives appraisal findings

2.10 Summary appraisal findings are presented in Table 2.2, with detailed appraisal findings presented in Appendix B. The methodological approach to appraisal is explained in in Appendix B, but in summary:

Each row of the table deals with one of the SA objectives that comprise the SA framework (see Table 1.1). Within each row each option is categorised in terms of ‘significant effects (using red / green / amber) and also ranked in order of preference. Also, ‘ = ’ is used to denote the alternatives performing on a par.

Table 2.2 Summary of appraisal of the 2019 development strategy alternatives Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Outside of the Submission the M’way Gap settlement GB and AONB strategy

Homes 3 3 4 2

Flood risk 2 2 2 2

Health and care 3 2 3

Crime =

Accessibility 3 2 4

Land use 2 3 2 2

Air quality 3 2 2 2

Climate change 2 3 2 2

Natural and heritage = assets Waste management =

Water 2 3 2 2

Economy 3 5 4 2

Discussion Focusing firstly on Option 5 (the submission strategy), the appraisal predicts significant positive effects in respect of ‘homes’, ‘health and care’ and ‘accessibility’. Significant negative effects are predicted in respect of ‘land use’, and uncertain negative effects in respect of ‘economy’; however, in both cases only one of the four alternatives performs better. In respect of four further objectives, namely ‘flood risk’, ‘air quality’, ‘climate change’ and ‘water’, the appraisal finds that Option 5 is not the best performing option, but does not highlight any significant concern. Option 1 also warrants stand-alone consideration, on the basis that it notably does not perform best in respect of any objective, and is the only option to register a significant negative effect in relation to three SA objectives. Whilst this does not automatically mean that Option 1 performs poorly overall (as options are not assigned any weighting), it is a strong indication. Having made these initial points, the following bullet points consider the performance of the alternatives in respect of each of the sustainability objectives for which it is possible to differentiate the alternatives:  Housing - Option 2 performs most strongly as it delivers the highest overall growth at the greatest number, variety and distribution of sites. Correspondingly, Option 4 performs most weakly as it delivers both the lowest overall growth and the least dispersed distribution of growth. With regards to effect significance, the primary consideration relates to the question of whether the requirement figure will be met, or not.  Flood risk - it is a challenge to confidently differentiate between the alternatives in terms of flood risk. In the context of a plan area with areas of significant flood risk constraint, all of the options are reasonably successful

AECOM 13

Tonbridge and Malling Local Plan SA SA Report Addendum

in directing growth to areas of low or manageable flood risk. The most notable exception to this appears to the fact that by focussing growth in the Borough’s north east, Option 4 avoids allocation of Sites 196 and 422 which are each affected by extensive surface water flood risk.  Health and care - Options 3 and 5 perform most strongly, as they would deliver the greatest proportion of growth at locations which are both of the scale to secure significant new health and care infrastructure, and at locations which are well placed to link with existing services and facilities, thereby positioning walking and cycling as a viable and attractive alternative to driving for local journeys. Option 2 also performs strongly, but includes sites with more limited potential to support walking and cycling, particularly those at Tonbridge and more rural settlements such as Hadlow and East Peckham.  Accessibility - Options 2 and 5 perform most strongly as both options direct growth towards key transport hubs which will help increase travel choices for new and existing residents. In addition, both options distribute growth to each of the key urban centres, potentially supporting a boost in vitality, whilst also providing a boost for the rural service centres of Borough Green, East Peckham and Hadlow, helping support their continued viability. On balance, it is considered appropriate to suggest the potential significant positive effects. Option 1 is considered to perform less well on the basis that the key settlement and transport hub of Borough Green is avoided, whilst Option 4 performs most weakly on the basis that for much of the Borough it neither increases access to services / facilities nor supports the vitality of urban and rural centres.  Land use - all options other than Option 4, as the lowest growth option, will result in significant loss of Green Belt and best and most versatile agricultural land, and potentially lead to sterilisation of minerals resources within known Minerals Safeguarding Areas, with Option 2 performing worst as the highest growth option.  Air quality - there are a number of designated air quality management areas in this area, hence there is an argument for following a lower growth strategy (Option 4) on air quality grounds, with growth under this option also directed predominantly to locations with good potential to link with ‘sustainable transport’ networks. The proposed relief road at Borough Green would likely relieve the traffic congestion for which the Borough Green AQMA was declared, though it would only be delivered under development strategy options which also direct growth to other AQMAs. With regards to effect significance, it is appropriate to ‘flag’ uncertain negative effects. There would be a need to interrogate detailed traffic modelling to understand impacts on AQMAs with certainty.  Climate change - there is little to distinguish between the different development strategy alternatives; however, with an overt focus on concentrating growth at transport hubs, Option 3 is considered to perform most strongly. By directing development to all locations, regardless of their likely propensity for car dependency, it is considered that Option 2 performs most weakly.  Natural and heritage assets - comprise an expansive range of designated and non-designated features in the Borough, hence reaching a clear overall appraisal conclusion is a challenge. It is not possible to simply conclude that higher growth options perform worse than lower growth option. In this context the appraisal finds that broadly equivalent significant negative effects are likely from all development strategy alternatives.  Water - Option 4 performs well, as it directs development to the north east of the Borough, thereby avoiding the Tonbridge groundwater Source Protection Zone (SPZ) and the Borough Green and SPZ.  Economy - the alternatives are ranked according to the amount of employment land allocated, and all alternatives other than Option 2 are predicted to result in significant negative effects on the basis that the target figure established by the Employment Land Review is not met (albeit with considerable uncertainty in respect of Option 5).

AECOM 14

Tonbridge and Malling Local Plan SA SA Report Addendum

3. Green Belt extension alternatives Introduction

3.1 The aim of this section is to introduce and appraise options for altering the outer extent of the Green Belt. The submission Local Plan proposes an eastwards extension to the Green Belt to take in land east of West Malling, north of Kings Hill and west of East Malling; the aim of this section is to present a formal consideration of alternatives.

N.B. the discussion below aims to supplement that presented within the Council’s Green Belt Exceptional Circumstances Topic Paper (see Chapter 3). Establishing the alternatives

3.2 Paragraph 80 of the NPPF (2012) sets out the established purposes of the Green Belt, the following four of which are relevant to Tonbridge and Malling: check the unrestricted sprawl of large built-up areas; prevent neighbouring towns merging into one another; assist in safeguarding the countryside from encroachment; and preserve the setting and special character of historic towns.

3.3 Furthermore, the NPPF expects (para.85) that local authorities should, when defining boundaries: ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development; not include land which it is unnecessary to keep permanently open; satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period; and define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.

3.4 With these purposes and policies in mind, the Council reviewed the outer boundary of the Green Belt at the beginning of the plan-making process. This review was undertaken in the knowledge that there are exceptional circumstances to justify the removal of land from the Green Belt.

3.5 One of the initial outcomes was the 2016 proposal, as reported in the Council’s Issues and Options consultation document, to realign the outer boundary of the Green Belt to the A228 Ashton Way, to the east of West Malling, mindful that the A228 was built subsequent to the establishment of the current outer boundary at West Malling, and is a clear and permanent physical feature in the landscape.

3.6 This proposal received significant support, as highlighted in the Regulation 22 Consultation Statement (January 2019, see section 2.5). However, the majority of the representations were of the view that the alteration should extend further east, i.e. either:

 extend further eastwards to Wateringbury Road (East Malling); or  extend even further eastwards to Kiln Barn Road (east of East Malling).

3.7 In light of the above, the following alternatives were established (each of which involves an increased scale of Green Belt extension in turn):

 Option 1 - no Green Belt extension (i.e. no new restriction on growth).  Option 2 - extend eastwards to the A228 Ashton Way (i.e. new restriction on growth to the east of West Malling; the 2016 approach)

 Option 3 - extend further eastwards to Wateringbury Road) (i.e. new restriction on growth east of West Malling, north of Kings Hill and west of East Malling; the submission approach)

 Option 4 - extend further eastwards to Kiln Barn Road (i.e. new restriction on growth east of West Malling, north of Kings Hill and either side of East Malling) N.B. Option 1 is the baseline situation, but it appropriate to give it formal consideration as an option nonetheless, albeit by its nature it cannot result in significant effects (on the baseline).

AECOM 15

Tonbridge and Malling Local Plan SA SA Report Addendum

Alternatives appraisal findings

3.8 Summary appraisal findings are presented in Table 2.3, with detailed appraisal findings presented in Appendix C. The methodological approach to appraisal is explained in in Appendix C, but in summary:

Each row of the table deals with one of the SA objectives that comprise the SA framework (see Table 1.1). Within each row each option is categorised in terms of ‘significant effects (using red / green / amber) and also ranked in order of preference. Also, ‘ = ’ is used to denote the alternatives performing on a par.

N.B. to reiterate the point made above - Option 1 is the baseline situation, and hence cannot result in significant effects (on the baseline).

Table 2.3 Summary of appraisal of the Green Belt alternatives

Option 1 Option 2 Option 3 Option 4 No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Homes 2 3 4

Flood risk = Health and care = Crime = Accessibility =

Land use 4 3 2

Air quality =

Climate change 2 3 4

Natural & 4 3 2 heritage assets

Waste = Water =

Economy 2 3 4

The appraisal broadly serves to highlight that extension of the Green Belt (GB) is supported in respect of environmental objectives, but leads to tensions in respect of socioeconomic objectives; however, the picture is not entirely clear-cut, with extension not supported in respect of climate change objectives, as the area in question has good rail connectivity. Having made these initial points, the following bullet points consider the performance of the alternatives in respect of each of the key sustainability objectives:  Housing - extension of the GB naturally leads to tensions, although significant concerns are not raised, given good potential to compensate through increased housing delivery within other parts of the Borough.  Land use - extension of the GB is supported given extensive ‘best and most versatile’ agricultural land, including land that is ‘grade 1’, i.e. highest quality nationally. It is Discussion appropriate to ‘flag’ the possibility of significant positive effects; however, in practice there is no certainty that the baseline situation (Option 1) would lead to significant development and in turn significant loss of best and most versatile agricultural land.  Climate change - extension of the GB is not supported, on the basis that this area is appropriate for housing growth in the sense that there is good rail connectivity.  Natural and heritage assets - extension of the GB is supported, given the presence of five conservation areas in and around this area. Option 4 would secure protection for two or three additional CAs, relative to Option 3, and also Oaken Wood to the south.  Economy - extension of the GB is not supported, on the basis that this area is appropriate for housing growth in the sense that there is good road and rail connectivity. Option 4 is potentially most problematic, given the presence of East Malling Research Station.

AECOM 16

Tonbridge and Malling Local Plan SA SA Report Addendum

4. Conclusions

4.1 This SA Report Addendum presents an appraisal of reasonable alternatives in respect of the development strategy (see Chapter 2) and Green Belt extension (Chapter 3).

4.2 Headline appraisal conclusions are as follows:

 Development strategy - the submission strategy is predicted to result in significant positive effects in respect of ‘homes’, ‘health and care’ and ‘accessibility’. Significant negative effects are predicted in respect of ‘land use’, and uncertain negative effects in respect of ‘economy’; however, in both cases only one of the four alternatives performs better. In respect of four further objectives, namely ‘flood risk’, ‘air quality’, ‘climate change’ and ‘water’, the appraisal finds that the submission strategy is not the best performing of the alternatives appraised, but does not highlight any significant concern.

 Green Belt extension - the appraisal broadly serves to highlight that extension of the Green Belt is supported in respect of environmental objectives, but leads to tensions in respect of socioeconomic objectives; however, the picture is not entirely clear-cut, with extension not supported in respect of climate change objectives, as the area in question has good rail connectivity. The submission strategy involves a greater area of new Green Belt than one of the alternative options appraised, but less than another, with a view to striking a balance between competing objectives.

AECOM 17

Tonbridge and Malling Local Plan SA SA Report Addendum

Appendix A Sifting green SLAA sites Introduction

As discussed in Section 2, a key step in the process of arriving at development strategy alternatives (i.e. alternative packages of site allocations) in 2019 involved identifying a shortlist of better performing ‘green’ SLAA sites from the full list of green SLAA sites that are subjected to appraisal within Appendix 6 of the Council’s SA Report (2018). The aim of this appendix is to report the sifting process that led to that shortlist.

The sifting of green SLAA sites is reported on a settlement-by-settlement basis, thereby enabling the potential to compare and contrast the relative merits of sites, in addition to giving consideration to the absolute merits of sites when considered in isolation. The primary source of evidence was the analysis of sites reported in Appendix 6 of the SA Report (2018), and other analysis reported within the Council’s Site Selection Topic Paper. A workshop was also held between the Council and AECOM to inform the sifting / shortlisting process.

Settlements are considered below in order of their position on the settlement hierarchy (see Figure A1 below).

Figure A1: Tonbridge and Malling Borough settlement hierarchy

N.B. as the focus of this sifting exercise is to filter out sites which are less suitable for allocation, the below narratives have no need to discuss the ‘building block’ sites on the basis that these sites are already established as the most suitable for allocation and form the foundation of all development strategy options.5

5 189 Southways, Staleys Road, Borough Green; 195 North of Lower Haysden Lane, Tonbridge; 196 North of Dryhill Park Road, Tonbridge; 197 Carpenters Lane, Hadlow; 198 Land at Howlands Allotments; 199 Bushey Wood; 236 Land off Cobdown Close, Ditton; 242 North of London Road, Ditton; 243 Station Road, Ditton; 248 Drayton Road Industrial Estate, Tonbridge; 310 Barfield House, Teston Rd, Offham.

AECOM 18

Tonbridge and Malling Local Plan SA SA Report Addendum

Tonbridge Excluding building blocks and existing allocated sites, there are nine green residential SLAA sites and three green employment SLAA at Tonbridge, which is an Urban Area (Tier 1) and is the largest individual settlement within Tonbridge and Malling. It has good road and rail connections and the broadest range of services and facilities of the Borough’s settlements and it is therefore a natural location to consider allocating development through the plan. However, Tonbridge, as with a number of other settlements in the Plan area, is tightly bounded by Green Belt and is additionally constrained by its proximity to the High Weald AONB which is adjacent to the south. The River Medway runs through the centre of the town and there is a significant area of Flood Zone 3 affecting the town as result. This has kept much of the area adjacent to the town centre open and undeveloped, leading to an hourglass- shaped settlement. This constraint will continue to influence the future development of the town, and naturally divides the town into clear northern and southern halves. Hilden Park extends westwards from central Tonbridge along the B245.

Beginning with the southern site options, a cluster of substantial sites is evident at the town’s south west, where Sites 266, 385 and 393 would extend the town westwards. However, Site 385 is directly opposite the AONB and there could theoretically be potential for intensified development at the employment site to have a negative effect on the setting of the AONB. However, the site is screened by an elevated section of the A21 and is already in use as an employment site. Therefore, on the assumption that future development does not have a greater impact on the AONB the site is considered suitable to test through the development strategy alternatives.

Sites 266 and Site 393 are largely flat, and though they are partly adjacent to Flood Zone 3 the majority of this group of site options lies outside the areas of risk. However, whilst the flat topography of the wider area means the site options would not be technically challenging to develop, it also suggests development could be highly visible within the landscape, particularly at Site 266 and Site 393 which have less screening than Site 385. The existing openness contributes to the character and setting of the town’s rural/urban fringe and is potentially within the setting of the AONB. The sites are all within the Green Belt. However, there is likely to be scope to limit impact on landscape sensitivity through design and layout, and in the context of the level of flood risk at the centre of Tonbridge this southern group of site options offer good development potential relatively free of flood risk.

Moving east, there is a small site option to the south east of the existing built area around the vicinity of the A26/Pembury Road roundabout, namely Site 334 which is a small, well screened extension to existing development at Vauxhall Gardens. The site is within the Green Belt though has no other significant constraints.

The high level of fluvial flood risk at the town’s centre limits the number of site options here, though a number of employment sites are proposed as this is potentially a suitable use within Flood Zone 3. No residential sites are proposed in the central area of the town. Site 259 is a brownfield opportunity within the Deacon Trading Estate whilst Site 280 would extend the built area of the town eastwards onto currently undeveloped fields in Flood Zone 3. However, both sites are proposed for exclusively employment use and this is not necessarily unsuitable in principle. These sites are principally constrained by lack of access as there is no suitable road serving them at present. However, it is likely that access enhancements could be delivered through the development process. Site 280 is additionally constrained by its location within the Green Belt.

North east of the town centre, Site 247 is a small site option on the A26 close to bus stops and local services and facilities. However, the site is within the Green Belt and there are unlikely to be exceptional circumstances to support the release of a small individual parcel which does not relate to any strategic opportunity.

Moving to the north of Tonbridge, there are notable site options along the town’s current northern boundary with indicative capacity of over 1,700 new homes. Sites 275, 346 and 423 are directly adjacent to the built area of the town, though as elsewhere on the Tonbridge periphery, all northern sites are within the Green Belt. There are a number of constraints associated with this group of sites. Significantly, the 2018 Transport Assessment forecasts that junctions at northern Tonbridge will operate at near capacity even without development at the sites. Additional traffic from development at the sites individually or cumulatively would therefore place additional loading on these junctions, potentially taking them over capacity, and would likely have potential to negatively effect air quality at the Tonbridge Air Quality Management Area (AQMA) through the addition of extra traffic. Sites 275 and 346 in particular would likely have dependence on the existing local estate road network and/or the limited capacity Higham Lane for access. Site 423 is additionally constrained by the fact it has local designation in the adopted Local Plan as protected open space and is covered in a significant part by TPOs and ancient woodland. Accommodating the TPO and ancient woodland would direct development to the part of the site most remote from settlement confines. However, all of the northern cluster of sites are largely free of widespread fluvial flood risk (or are affected in isolated pockets only), are not within the AONB or its setting and are not notably constrained by

AECOM 19

Tonbridge and Malling Local Plan SA SA Report Addendum

heritage sensitivity. Additionally, whilst the considerable constraints are recognised, as significant site options adjacent to the urban area of the Borough’s largest individual settlement the northern sites are considered suitable to test through the development strategy alternatives.

Two green site options in the Green Belt are evident at the north eastern settlement boundary of Tonbridge, comprising Sites 417 and 422.There are a number of factors to consider in relation to these sites, particularly the potential for cumulative effects of allocation with sites at Hildenborough to the east as there could be potential for settlement coalescence or narrowing of the settlement gap. Site 422 is notable for covering a series of key community assets including the town’s football club, cricket club, sports fields, bowling club and play area. Whilst re-provision of facilities is possible, the loss of or re-location of established community facilities could be disruptive and disproportionate. However, development could be delivered around existing uses on site, retaining the existing functions. There is a degree of fluvial flood risk on site, though this could potentially be mitigated through design and layout. Neither site is subject to any high level landscape or heritage constraints and both are considered worth testing further through the development strategy alternatives.

Moving west, at Hilden Park in the east there are two green site options, Sites 207 and 447. Site 207 is significantly constrained by lack of access as access would likely only be achieved through the demolition of an existing property of which availability is unclear. The site is further constrained by Flood Zone 3a and surface water flood risk and is not considered suitable for testing further through the development strategy alternatives. Site 447 is on the northern side of Hilden Park and therefore closer to the built area of Tonbridge and its associated site nominations though the design, layout and amount of development could potentially be controlled to limit the perception of sprawl or narrowing of the settlement gap. However, there are identified highways concerns in relation to the impact of potential development on both Hill View Road and Hilden Avenue. In light of the potential for significant negative effects on the local road network it is considered the site is not suitable to test further.

In summary, a total of 11 site options at Tonbridge warrant further consideration through the appraisal of reasonable development strategy alternatives (see Table A3).

Table A3: Tonbridge site options considered for progression to the reasonable development strategy alternatives

Progress to the Potential number of development Site Name new homes strategy alternatives?

247 Land at Tile Barn Corner, Tonbridge 20

259 Munday Works, Tonbridge Employment Y

Fishponds Farm, Lower Haysden Lane, 266 136 Y Tonbridge

275 Grange Farm, Tonbridge 1,211 Y

280 Little Postern, Postern Lane, Tonbridge Employment Y

334 South of Vauxhall Gardens. Tonbridge 61 Y

346 North of Barchester Way 418 Y

385 Depot, Upper Haysden Lane, Tonbridge Employment Y

393 Manor Farm, Upper Haysden Lane 219 Y

417 Coblands Nursery, Trench Road, Tonbridge 319 Y

422 Tonbridge and Little Trench Farm 54 Y

423 Frogbridge Wood, Tonbridge 146 Y

AECOM 20

Tonbridge and Malling Local Plan SA SA Report Addendum

Medway Gap Excluding building blocks and existing allocated sites, there are 10 green SLAA residential sites, six green SLAA employment sites and one amber SLAA residential site which warrants further consideration at the Medway Gap urban area (Tier 1). The Medway Gap is the collective name for a series of contiguous settlements in the north of the Borough, principally Aylesford, Ditton, Larkfield and . The Medway Gap urban area lies just to the north west of Maidstone, to which it is directly connected by the A20. All the key Medway Gap settlements broadly follow the alignment of the M20/A20 corridor giving the area excellent connections to the SRN via J4 and J5 of the M20 and the M20/M2 interchange north of Maidstone. There are also four railway stations on two lines within the Medway Gap area, including those at East Malling and Barming. Its built character is predominantly suburban, though there are isolated individual heritage buildings along the A20 corridor, and clusters of historic assets at the original Aylesford village and at East Malling. The urban area is well served by services, facilities, employment and transport. The current Green Belt extent ends to the west of Leybourne meaning much of the built area is outside the Green Belt, though the submission Local Plan proposes extending Green Belt designation to much of the area between the Medway Gap settlements and Kings Hill to the south. Despite the urbanised character of much of the Medway Gap, a key feature is the open countryside to the south of Ditton and the north of Aylesford which contributes to the setting and character of the area as a whole. The area is notably affected by Minerals Safeguarding Areas (MSAs) including in relation to significant deposits of silica sand and sandstone to the north of the M20 and Limestone Hythe formation to the south of the M20.

In this context the Medway Gap settlements have seen a large number of site options come forward, including strategic site options. The M20 divides the Medway Gap broadly into northern and southern halves. Beginning in the north west at Leybourne, Site 218 is proposed for employment use only and is located in close proximity to J4 of the M20. Although it is remote from settlement confines it benefits from direct access to the M20 which could be a significant advantage for certain forms of employment. The site is within the Green Belt but has clear durable boundary features and makes little contribution to several Green Belt purposes, giving rise to potential for future consideration for Green Belt release. It is considered suitable to test further through the development strategy alternatives.

South of the M20, a cluster of site options is nominated south of J5 (plus Site 389 which is an extension to one existing employment site immediately north of the junction). Sites 188, 381, 392 and 410 are all east of Hermitage Lane and collectively offer potential to maximise the potential of Barming Station as a hub for growth. The sites have limited sensitivity within the wider landscape and are not notably affected by environmental, heritage or biodiversity constraints. Sites 188 and 381 are considered suitable for further testing through the development strategy alternatives. However, Sites 381 and 410 are on the boundary between Tonbridge and Malling and Maidstone Borough and development on the Maidstone side already abuts the boundary. In this context, corresponding development on the Tonbridge and Malling side of the boundary would very likely risk coalescence between the Medway Gap urban area and Maidstone. It is therefore considered that in order to maintain the settlement gap between Maidstone and the Medway Gap urban area Site 410 should not be considered for allocation and only a small portion of Site 381 in less sensitive north of the site will likely be suitable. There are MSAs in place for both limestone and sandstone and a detailed minerals survey could be necessary prior to any future development.

Moving westwards from here, it is noted that Sites 194, 262 and 435, together with part of Site 304, present an Area of Opportunity, identified by policy LP33 in the Local Plan. The sites could extend existing development along Hermitage Lane, though they will not be released for development until upgrades to the road network are complete at the A20/Mills Road/Hall Road junction, a link between Hermitage Lane and the A20 and improvements to J5 of the M20. Whilst there are no notable environmental, heritage, landscape or biodiversity concerns here, the sites are all sandwiched between the existing residential development and an extensive area of industrial and employment land to the west which could potentially be an intrusive feature on the townscape and residential amenity of future development at the sites. Policy LP33 says that these sites will only be released in the post plan period. Consequently, they do not form part of the development strategy alternatives.

The most notable site option in the southern part of the Medway Gap urban area is the strategic South Aylesford Site 304 at East Malling Research Station, south of Ditton. Site 304 is outside the current and proposed Green Belt boundaries and is unaffected by AONB or AONB setting. The site is very large and would not appropriate to develop in full as this would be a transformative and disproportionate expansion of the existing urban area. VISUM transport modelling indicates that development in full would lead to critical pressure on the surrounding road network. However, developable sub-areas can be identified within the site which direct development away from the most sensitive locations. Two of these are residential, one of which presents as infill along New Road at East Malling, whilst the other is an extension to the existing built area of Ditton to the north. The other two sub-areas are

AECOM 21

Tonbridge and Malling Local Plan SA SA Report Addendum

employment sites, located along Chapel Street, which serves as the existing access road for the employment site at the East Malling Research Station.

To the south of the urban area is Site 212 which is scored amber by the SLAA on the basis that it straddles the border between Maidstone and Tonbridge and Malling and would therefore need to be delivered in conjunction with the corresponding site in Maidstone Borough. However, it is otherwise largely unconstrained as it lies outside the Green Belt, has no significant on site environmental designations or landscape, heritage or biodiversity constraints and performs well in transport modelling. It is therefore considered suitable for further testing through the development strategy alternatives.

The area south of Ditton is entirely within a MSA for Limestone Hythe Formation. Localised heritage constraints include two Grade I-listed buildings and the conservation area at Bradbourne House in the north of the site option, a further cluster of listed buildings, including at Grade I and Grade II*, to the south west of the site and a scheduled monument. The western residential sub-area of Site 304 offers potential access to East Malling station, which would also likely serve the employment sub-areas at the Research Station. Additionally, the sub-areas are largely free of surface water and fluvial flood risk, save for isolated pockets, and are free of local, national and international biodiversity designations. Nevertheless, despite there being no landscape designation at the sub-areas, all are currently almost entirely open and undeveloped, save for isolated pockets of development, and this openness contributes both the character and setting of Ditton and to the separate identities of East Malling and Ditton. Additionally, whilst the national agricultural land quality dataset is of poor resolution, it indicates that parts of the area could be ‘best and most versatile’ agricultural land, though the fact that Site 304 has been so heavily refined to identify the less constrained sub-areas may suggest ‘best and most versatile’ land has been avoided. On the basis that minerals and agricultural surveys could be required before development, there is scope to test the sub- areas further through the development strategy alternatives.

Two further sites at East Malling can be ruled out of the development strategy alternatives. First, Site 281/369 which is located between the railway line and The Rocks Road, is well contained by durable features and would likely present as a natural extension of the settlement form. However, access constraints have been identified as a result of the site entrance being on a tight bend in the road, with poor visibility likely to make the privately maintained site entrance unsuitable for loading with high traffic flows. Second, Site 238 at the eastern extent of East Malling can be ruled out on the basis that it has very constrained access down the narrow Stickens Lane and is also within the proposed Green Belt extension.

At Winterfield Lane, south east of Leybourne and south of the A20 is the Site 268 which is adjacent to the existing urban area and has only limited landscape and biodiversity constraints and offers potential for good access to the road network and to nearby services and facilities. However, the site is within the proposed Green Belt extension. Also at Winterfield Lane, Site 390 is likely to yield below the minimum SLAA site capacity of 5 dwellings and is therefore not considered suitable for allocation.

Therefore, a total of 13 site options at the Medway Gap urban area warrant further consideration through the appraisal of reasonable development strategy alternatives, including the refined sub areas of the South Aylesford strategic site (see Table A4).

Table A4: Medway Gap site options considered for progression to the reasonable development strategy alternatives

Progress to the Potential number of development Site Name new homes strategy alternatives?

1,000 (includes yield for 188 Whitepost Field, Aylesford Y Site 381 and Site 392) 212 Land off Oakapple Lane, Barming 118 Y 218 Land at Birling Road, Leybourne Employment Y 238 Westbrook Farm, East Malling 137 Land south of Hermitage Court, Hermitage 239 Employment Y Lane 268 Hermitage Farm, Winterfield Lane, East Malling 125 Y 281/369 Paris Farm, Rocks Road, East Malling 127

AECOM 22

Tonbridge and Malling Local Plan SA SA Report Addendum

304 (Parkside) Parkside (East Malling Research Station) 205 Y 304 (Ditton) Ditton Edge (East Malling Research Station) 216 Y East Malling Research Station (East Malling 304c Employment Y ward) 304d East Malling Research Station (Ditton ward) Employment Y Yield included in that of 381 Bunyards Farm, Allington Y Site 188 389 North of M20 Junction 5, Coldharbour Lane Employment Y 390 Winterfield House, Larkfield 6 Yield included in that of 392 Barming Depot, Hermitage Lane Y Site 188 410 East of Hermitage Lane 465 419 North of RBLI Warehouse, Aylesford Employment Y Kings Hill Excluding building blocks and existing allocated sites, there are three green SLAA sites at Kings Hill, one of which is the strategic Site 358 (Land north of Kings Hill). Kings Hill is a new settlement, developed on and around land formerly in use as the RAF West Malling airfield. The settlement is located on the A228 between Tonbridge and the Medway Gap settlements, with good onward connectivity to Maidstone, the M20 and M26. Kings Hill is not directly on the rail network, but is in relatively close proximity to West Malling station, from where services to London are fast and frequent. By virtue of its recent development, the settlement largely has a modern suburban character, with a substantial office campus-style employment area being a notable feature at the north of the town. Only three site options have come forward at Kings Hill, though one of these is the North of Kings Hill strategic site which has indicative capacity for up to 825 dwellings over the plan period, plus substantial supporting infrastructure.

The settlement is outside the Green Belt (though it is adjacent to the settlement’s southern boundary) and is not notably constrained by national biodiversity designations, though there are a network of local wildlife sites in and around the built area. There is no notable fluvial flood risk at Kings Hill, though multiple corridors of surface water flood risk are present, including within the strategic site. The settlement as a whole is contemporary, and there is consequently no notable heritage constraint within or around much of it, though the Castle and Wateringbury conservation areas are notable features to the south of the settlement and the New Barns and Broadwater Farm conservation area is close by to the north.

Starting at the west of Kings Hill, Sites 317 in the south west and 403 in the north west each have good regard for the existing settlement form and are bound by clear defensible boundary features in the form of local and strategic roads. Site 317 occupies an undeveloped area bound by the A228 to the west, Street to the south and the existing built area of Kings Hill to the north and east. The site is entirely within the Green Belt, however, and is served by constrained roads with limited capacity, including the very narrow Kent Street to the south and local estate roads to the east. Whilst its western boundary is formed by the A228 there are highways concerns about the limited scope for establishing safe access directly to the site and it is therefore considered that access constraints make the site unsuitable for further testing. Site 403 is also adjacent to the built area of Kings Hill and bound by the local roads King Hill and Windmill Lane West to the north, and the A228 to the south. However, the A228 is a severing feature between the site and the main settlement and it would be important to demonstrate that the site would not present as dislocated development, should it be developed. Significantly, Site 403 is within the proposed Green Belt extension and in light of this it is considered unsuitable in principle for allocation.

The developable area of Site 358 (the strategic North of Kings Hill site) is outside of the current and proposed extent of the Green Belt though non-developable parts of the site will be washed over by the proposed Green Belt extension. The site is not notably constrained by biodiversity designations. A number of individual listed buildings are within the site as well as the New Barns and Broadwater Farm conservation areas. However, the scale of the site means there could be opportunities to mitigate harm through design and layout of any proposed scheme. Similarly, corridors of surface water flood risk do not represent absolute constraints in themselves on a site of this scale as there can be opportunities mitigate through scheme design and layout. There is considerable potential for the gap between Kings Hill and existing development at Broadwater Farm, New Barns and Well Street to be eroded should the entire site be developed, though it could be possible to mitigate this, again through design and layout. The site is predominantly flat and not overlooked by high ground, limiting its sensitivity within the wider landscape, though development of a site of such scale would inevitably have a transformative effect on the localised landscape

AECOM 23

Tonbridge and Malling Local Plan SA SA Report Addendum

context through the urbanisation of the existing rural setting of north Kings Hill. In summary, one site at Kings Hill warrants further consideration through the appraisal of reasonable development strategy alternatives (see Table A5).

Table A5: Kings Hill site options considered for progression to the reasonable development strategy alternatives

Progress to the Potential number of development Site Name new homes strategy alternatives?

317 Bells Wood Yard, Kings Hill 106

358 North of Kings Hill 825 Y

403 Sportsman's Farm, Teston Road, West Malling 205

Snodland

There are no green SLAA sites at . Walderslade

The settlement of Walderslade is functionally a suburb of the town of Chatham in the neighbouring authority of Medway. The majority of Walderslade is itself within Medway, though a small corner of the settlement’s south west falls within Tonbridge and Malling. The area is the only part of the Borough which is east of the M2 and there are just two site options to come forward here. The area has excellent connections to the SRN, being located adjacent to J2 of the M2 and with good north-south connectivity via the A229 between Maidstone and Rochester.

Excluding building blocks and existing allocated sites, there is just one green residential SLAA site and one green employment SLAA site at Walderslade. Site 200 is located behind existing dwellings in a spur of development situated between the M2 and the A2045. Though the area has pedestrian connectivity with the rest of Walderslade to the east via a bridge over the A2045, the only vehicular access is via the community of to the west. The site is not constrained by flood risk, heritage, or landscape and townscape sensitivities, though there could be potential air quality and noise concerns associated with the presence of two major roads either side of the site. There are also TPOs and an area of ancient woodland on site, though limited development of sensitive design and layout could potentially mitigate risk to these features. Nevertheless, the site is within walking distance of a number of key services at Walderslade and has excellent connections to the road network and it is reasonable to consider within the development strategy alternatives.

Site 314 is an employment site at Rochester Road which has recently been granted planning permission and will be an allocation in the Plan.

In this context, two sites warrant further consideration through the appraisal of reasonable development strategy alternatives, as per Table A6.

Table A6: Walderslade site options considered for progression to the reasonable development strategy alternatives

Progress to the Potential number of development Site Name new homes strategy alternatives?

200 Rear of Robin Hood Lane, Blue Bell Hill 26 Y

314 Rochester Road, Borstal Employment Y

Borough Green Excluding building blocks and existing allocated sites, there are seven green SLAA sites at Borough Green plus one amber SLAA site which warrants further consideration. Borough Green is a Rural Service Centre (Tier 2)

AECOM 24

Tonbridge and Malling Local Plan SA SA Report Addendum

settlement on the A25 to the west of the Borough with strong links to the adjacent smaller villages of , Platt and Wrotham. The settlement has good connectivity with Sevenoaks to the west and the Medway Gap settlements to the east via the A25/A227, and is also well placed to access the M26 via J2a. Further connectivity is provided by Borough Green and Wrotham station on the Maidstone Line, from which services to London are frequent. Much of Borough Green itself has a relatively low density, suburban character and a range of retail, education, healthcare and leisure services and facilities. The settlement has developed along the east-west alignment of the A25 and the north-south alignment of the A227 as it runs to Wrotham to the north and on to Gravesend to the north and Tonbridge to the south. The north eastern extent of the village of Ightham lies immediately west of Borough Green and has a separate identity despite its proximity.

This strategic location has resulted in a number of site nominations coming forward around the settlement cluster, including some major sites with capacity for significant growth.

To the west of Borough Green Site 256 is adjacent to the settlement boundary. Development at the site would extend Borough Green westwards towards Ightham, occupying a large triangle of open undeveloped land formed by the existing built area to the east, the A25 to the north and Dark Hill Road to the south. The site is sensitive within the landscape and is within the AONB. It is considered that the scale of the site could lead to major development in the AONB. However, even limited development could have potential for negative effects on landscape as the sites occupy a prominent position at the approach to Borough Green. There are also Minerals Safeguarding Area (MSA) constraints across the wider area west of Borough Green which are likely to affect Site 256. Whilst MSA constraints are not necessarily absolute (i.e. further survey work may indicate no winnable deposits at the site) the landscape sensitivity of the sites is considered to make them unsuitable to progress to the reasonable alternatives.

Moving further east, Sites 300 and 316 are also both either partially or entirely within an MSA, though lie outside the AONB. There could be potential access capacity issues for both sites as access would likely be via existing estate roads or a partially sunken lane. An adjacent Local Wildlife Site offers both constraints and potential opportunities to deliver biodiversity net gain. Both are considered suitable for testing through the development strategy alternatives.

To the north of the A25, six site nominations lie immediately adjacent to the settlement boundary. Scope for further growth along the alignment of the A227 is provided by Sites 311 and 312, which lie to the rear of existing development, and by Site 283 which is immediately east of the A227, although all three sites are within the Green Belt. There are active minerals extraction sites in the area, specifically in relation to Silica Sand, though again there could be opportunities to conduct further survey work to identify whether any winnable deposits would actually be affected by development at the sites. Sites 283 and 312 are included within the strategic Site 408 (Borough Green Gardens) and there is a need to more broadly consider the strategic opportunity presented by Site 408 which stretches in a linear form across the entire north of Borough Green as far east as J2a of the M26, filling the gap between the settlement and the motorway. Whilst parts of the site are notably constrained by active minerals operations and additional minerals safeguarding, there is likely to be scope to explore smaller areas of development potential within the site. Although the settlement of Borough Green itself is outside the Green Belt, much of Site 408 falls within the Green Belt, with a small portion of the site’s west also falling within the AONB. The aforementioned sub-parcels formed by Sites 283 and 312 and the adjacent Site 311 are also all within the Green Belt, though 311, 312 and much of 283 are outside the AONB. Much of Site 408 is within walking or cycling distance of the range of services and facilities at Borough Green, including the station, and in this context it is appropriate to consider the site through the reasonable development strategy alternatives, mindful of the fact that the final developable area of the site will reflect the on-site constraints. It is noted that although the SLAA assessed the site to be amber on the basis of uncertain availability, more recent information has indicated the whole site is available for development, though the eastern most portion would not be delivered during the plan period.

The relatively contemporary growth of Borough Green means it is not notably affected by heritage constraints, though individual Grade II listed buildings are evident on the High Street. Unlike the adjacent villages of Wrotham, Ightham and Platt there is no conservation area and no notable clusters of listed buildings. However, both Wrotham and Ightham have denser historic cores with clear concentrations of historic assets. Both villages have conservation areas. However, there are no green SLAA sites with notable heritage constraints.

In summary, a total of six green site options at Borough Green warrant further consideration through the appraisal of reasonable spatial development alternatives, though two of these (Site 283 and Site 312) are form part of the larger strategic Site 408 (see Table A7).

AECOM 25

Tonbridge and Malling Local Plan SA SA Report Addendum

Table A7: Borough Green site options considered for progression to the reasonable development strategy alternatives

Progress to the Potential number of development Site Name new homes strategy alternatives?

256 Dark Hill Farm, Borough Green 351

283 North of Tolsey Mead, Borough Green (part of 408) Y (as part of 408)

300 Crouch Lane, Borough Green 95 Y

311 North of Fairfield Rd, Borough Green 16 Y

312 West of Wrotham Road, Borough Green (part of 408) Y (as part of 408)

316 off Drylands Road, Borough Green 225 Y

408 (inc 283 Borough Green Gardens 1,720 Y and 312)

East Peckham Excluding building blocks and existing allocated sites, there are two green SLAA residential sites and one green employment site at East Peckham, reflecting in part the level of constraint around the settlement, particularly in relation to fluvial flooding. The settlement is very near to the River Medway and is consequently heavily affected by Flood Zone 3, the highest level of fluvial flood risk. East Peckham is a Rural Service Centre (Tier 2) at the south east of the Borough. The settlement is immediately west of the A228 which offers good connectivity to the Strategic Road Network (SRN), and is indirectly served by Beltring station on the Medway Valle Line, from which there are hourly services to Tonbridge and to Strood. A large area of employment land lies at the south of the village either side of the link road to the A228. All sites at East Peckham are within the Green Belt.

The two residential site options in East Peckham lie to the north of the settlement in what is currently the gap between East Peckham and Hale Street. Site 233 and Site 427 front onto Church Lane and are adjacent to each other. Their location in the gap between Hale Street and East Peckham could give rise to some concerns about narrowing the gap between the two distinct settlements, though in practice it is considered unlikely that the settlements would be at risk of actual coalescence in light of a remaining area of open space to the south of the sites which, owing to high fluvial flood risk, is likely to remain undeveloped. Site 233 offers potential for development outside of Flood Zone 2 or 3. Whilst the adjacent Site 427 is more affected by Flood Zone 2, it could be possible to mitigate this through design and layout and potentially through integration of SuDS into future development. Both sites are therefore considered suitable to test further through the development strategy alternatives.

A final site, Site 267, is nominated as an employment site only. This would form a natural extension to the existing employment area to the south of the settlement and although constrained by Flood Zone 3 is not necessarily unsuitable for non-residential development. Site 267 also represents an opportunity to redevelop a significant brownfield opportunity.

In summary, two residential site options and one employment site option at East Peckham warrant further consideration through the appraisal of reasonable development strategy alternatives (see Table A8).

Table A8: East Peckham site options considered for progression to the reasonable development strategy alternatives

Progress to the Potential number of development Site Name new homes strategy alternatives?

233 South of Church Lane, East Peckham 35 Y

AECOM 26

Tonbridge and Malling Local Plan SA SA Report Addendum

267 Wharf, East Peckham Employment Y

427 Church Lane, East Peckham 23 Y

Hadlow Excluding building blocks and existing allocated sites, there are four green SLAA sites located at the settlement of Hadlow, though Site 192/254/355/386 includes duplicate nominations which cover the same area. Hadlow is a Rural Service Centre (Tier 2), a short distance north east of Tonbridge on the A26. The settlement does not have a train station but it is well connected to the SRN with the A26 providing onward connectivity to the M20 and M26 to the north and the A21 to the south. Much of Hadlow has a modern, mid-20th century character though there are also two conservation areas, one of which includes a significant cluster of listed buildings around Hadlow Tower at the south of the settlement, including Grade I and Grade II* buildings. This gives rise to notable heritage constraints in this southern area of Hadlow, and additional constraint in the form of Flood Zone 3 is evident along the alignment of the River Bourne at the west of the settlement. Significantly, Hadlow is tightly bounded by Green Belt although the existing built area is outside Green Belt designation. The settlement is not notably constrained by designated sites of biodiversity importance at local, national or international scale.

Of the green sites, the most notable are Site 192 and Site 366 which offer potential opportunities for significant growth of over 150 dwellings each to the north of the existing built area. Whilst these sites are within the Green Belt, they are not notably affected by landscape, environmental, biodiversity or heritage concerns. However, the developable area at Site 366 would be constrained by TPOs on site which would likely direct development to the part of the site furthest from the services and facilities of Hadlow and would result in a development remote from the existing settlement confines.

Looking to the south and east of Hadlow, a further three site options - Site 251, 264 and 302 – have limited landscape, biodiversity and environmental sensitivity, though by virtue of their location adjacent to the Hadlow Tower conservation area they all have a degree of sensitivity in heritage terms. All sites are within the Green Belt. The setting of the heritage assets at Hadlow Tower is limited to a degree by the presence of existing development at The Forstal which occupies much of the space between Sites 251 and 264 and the conservation area. Site 302, the largest of these three sites, would likely require access enhancements to unlock development. Site 264 is entirely contained within the larger Site 251 and so it is not considered necessary to take both forward to the development strategy alternatives. Highways concerns have been raised through the Regulation 18 consultation regarding the cumulative impact of the three south east Hadlow sites on the basis of limited capacity at the junction of the A26 and Court Lane. If these south eastern sites were to come forward in combination and developed in full it could lead to a change in character of the eastern approach to Hadlow along Court Lane, though there could be potential to limit this through sensitive consideration of design, layout and amount of development. On the basis that Site 302’s aforementioned access constraints it is considered that just Site 251/264 should be tested through the development strategy options, as this would also help mitigate the concerns about the effect of over development on junction capacity and settlement character.

In summary, a total of three green site options at Hadlow warrant further consideration through the appraisal of reasonable spatial development alternatives (see Table A9).

Table A9: Hadlow site options considered for progression to the reasonable development strategy alternatives

Progress to the Potential number of development Site Name new homes strategy alternatives?

192 (254, 355 North of The Paddock, Hadlow 156 Y and 386) 251 (incorporating Land off Court Lane, Hadlow 66 Y 264)

302 Goblands Farm, Court Lane, Hadlow 167 Y

366 North of Hadlow Park 153

AECOM 27

Tonbridge and Malling Local Plan SA SA Report Addendum

Hildenborough Excluding building blocks and existing allocated sites, there are two green SLAA sites at Hildenborough, which is a Rural Service Centre (Tier 2) located to the west of Tonbridge at the south of the Borough. The two settlements have separate identities but are very nearly connected at the suburb of Hilden Park and it will be important to consider whether the cumulative effect of allocations at Hildenborough and Tonbridge could result in unacceptable risk of settlement coalescence. All sites at Hildenborough are within the Green Belt.

Moving to the west of Hilden Park, Site 237/402 lies within a triangle of land formed by the railway line to the south, Stocks Green Road to the north and the existing built area to the east. There are no notable heritage, landscape or biodiversity constraints at the site. It is bounded on three side by existing development and is perceptually closely aligned with the settlement. The site would be well placed to access existing services and facilities at the settlement.

In Hildenborough itself, one further green site option has come forward. Site 227 lies to the south of the settlement and has relatively good regard for the existing form of development, though it is strictly speaking outside the current settlement boundary. However, there is historical sensitivity at the site as it is fully within the Foxbush Historic Park and Garden and partly within the Hildenborough Conservation Area, to which the site contributes through its open and undeveloped character. Additionally, a Grade II listed drinking fountain is at the site entrance and the site is within the setting of the Grade II listed Pembroke Lodge. The site is also bounded on two sides by a blanket TPO and has area TPOs within the site, giving it a degree of biodiversity sensitivity also.

In light of the above, only one site option at Hildenborough warrants further consideration through the appraisal of reasonable development strategy alternatives (see Table A10).

Table A10: Hildenborough site options considered for progression to the reasonable development strategy alternatives

Progress to the Potential number of development Site Name new homes strategy alternatives?

227 Chequers Farm, Hildenborough 20

237 Land at Stocks Green Road, Hildenborough 105 Y

West Malling

Excluding building blocks and existing allocated sites, there are five green SLAA sites at West Malling, plus one amber SLAA site which warrants further consideration. The settlement is in close proximity to, but remains distinct from, the Medway Gap urban area which lies just to the north and east, separated by the A228. West Malling has excellent road and rail connectivity as it is minutes from J4 of the M20 and immediately adjacent to the A228 and A20 as well as benefitting from a station with frequent services to and from London. The entire historic core of the settlement is designated as a conservation area. There is particular historic sensitivity in relation to the High Street, which is lined by listed buildings for its full extent, and in relation to St Marys Abbey which has a cluster of five Grade I-listed buildings of exceptional historic interest. This naturally focusses the search for potential growth options towards the less historically sensitive west and north of the settlement, though the western extent of West Malling is very tightly bounded by Green Belt. Additionally, the entire settlement is surrounded by minerals safeguarding areas (MSAs) meaning sites to the west, north and south all fall within an MSA for Limestone Hythe Formation. This is not necessarily an absolute constraint though it will mean that the sites will likely require a more detailed minerals assessment to establish if there are winnable deposits that may be sterilised by development.

Three green site options are nominated to the west of West Malling. These are all greenfield sites on land currently in productive agricultural use within the Green Belt - Site 282, Site 327 (which incorporates Sites 325 and 326) and Site 378. The national agricultural land quality dataset is of poor resolution, but it indicates that the land west of West Malling has potential to be Grade 1 agricultural land. This is considered ‘best and most versatile’ (BMV) agricultural land and the NPPF is clear that its unnecessary loss should be avoided. Additionally, the area is open and rural in character and this is considered to make an important contribution to the rural setting and character of the settlement. However, this western area of the settlement is free of flood risk constraint and has no local, national or internationally designated biodiversity sites, and it is consequently considered that Site 327 should be tested further through the development strategy alternatives.

AECOM 28

Tonbridge and Malling Local Plan SA SA Report Addendum

South of the settlement is Site 299. The site is open and undeveloped, though is within the broader footprint of the settlement by virtue of surrounding development. The site is bounded to the east and south by the West Malling conservation area, though has no heritage sensitivities to the north and west. The site’s openness contributes to the localised character of the area though it is well screened from the wider landscape and has no broader landscape sensitivity. There could be potential to retain some form of open space through the development process. The site is free of flood risk and designated biodiversity constraints, though is significantly constrained by highways concerns as the local road network is of limited capacity.

Looking to the north of the settlement there is one green site, Site 372, situated in the A20/London Road corridor. Site 372 extends the settlement eastwards towards Leyboune. The site is not notably affected by landscape or biodiversity constraints, though it is within the West Malling conservation area and it also closes the gap between West Malling and Leybourne meaning there are likely to be coalescence concerns if it were developed in full. Additionally, the site is within the proposed Green Belt extension and is considered unsuitable in principle for allocation. The amber SLAA site, Site 396, is also in the London Road corridor though is outside the most historically sensitive areas of the settlement but inappropriate development could still have potential to harm the wider setting and character of the historic core. The site is well placed to access town centre services and facilities, and has good regard for the existing settlement form, with low landscape sensitivity. The site is in the Green Belt. The SLAA scored the site amber on the basis of uncertain availability, though it has subsequently been clarified as fully available and warrants further testing. It is noted that the site has recently been granted permission on appeal for specialist elderly accommodation.

In summary, three site options at West Malling warrant further consideration through the appraisal of reasonable development strategy alternatives (see Table A11).

Table A11: West Malling site options considered for progression to the reasonable development strategy alternatives

Progress to the Potential number of development Site Name new homes strategy alternatives?

282 North of Norman Road, West Malling 63

299 East of Offham Road, West Malling 12 Y

327 West of West Malling 413 Y

372 Banky Meadow, West Malling 92

378 Appledene Farm, Norman Road, West Malling (part of 282)

396 Rear of London Road, West Malling 110 Y

AECOM 29

Tonbridge and Malling Local Plan SA SA Report Addendum

Other rural settlements

Other settlements to support a green SLAA site are Aylesford Village, , Eccles, Ightham Common, Mereworth, Offham, Platt, , Fairseat, , Wateringbury, Wrotham and . Excluding building blocks, these settlements feature 11 residential and two employment site options. All of these settlements are either Tier 3 (Other rural settlements) or Tier 4 (Rural areas) on the settlement hierarchy.

The most notable of these is Site 278 which is directly north of Aylesford village and is of a significant scale. Smaller sites are nearby, namely Site 391 at Aylesford Priory and Site 206 which would extend the existing strategic employment site at Pratling Street northwards. These sites are not within the current or proposed Green Belt boundaries but cumulative development of all the sites would be unsuitable on the basis of the loss of settlement identity of Eccles and Aylesford village. There is a degree of surface water flood risk within the overall area though this is likely to be mitigatable through design and layout, and there is no notable widespread fluvial flood risk. Aylesford village provides notable localised heritage sensitivity, with additional sensitivity provided by a scheduled monument on a Roman villa site west of Eccles. The key constraints affecting the broader combined site area are likely to be biodiversity designations. Site 278 would impact the entire Aylesford Pit SSSI and would be in close proximity to areas of the Wouldham to Detling Escarpment SSSI to the north. These are substantial constraints in isolation and there is an additional need to carefully consider the cumulative impacts of significant development in the area, including being mindful of the cumulative effects of the strategic building block site at Site 199 at Eccles6. It is considered that the ongoing minerals extraction workings at Site 278 demonstrate that there are winnable deposits beneath the site which could be at risk of sterilisation through development. In light of the biodiversity and minerals constraints at Site 278, particularly in combination with the strategic building block Site 199, it is not considered suitable to take forward to the development strategy alternatives. Site 206 is considered to encroach upon land which is within the AONB setting and sensitive within the landscape whilst also lying beyond the rational boundary of the existing Pratling Street employment area. Site 391 is considered to be constrained in terms of heritage and distance from services. Site 269 is within the rural settlement of Eccles and presents an opportunity to deliver development which supports the vitality of the village, though is captured through the strategic building block Site 199 and is consequently not considered separately here.

Looking elsewhere, Site 223 near Fairseat is ruled out as it has poor access and is remote from settlement confines and unlikely to be a sustainable location for growth. Similarly, Site 384 at Ightham Common does not progress as it is outside of a settlement with defined confines and is considered remote from services and facilities.

Site 231 at Platt, Site 273 at Wouldham and Site 353 at Wateringbury all have constrained access likely to make delivering development technically challenging or likely to exacerbate traffic concerns. At Site 353 there are additional concerns over air quality as poor quality air is already an issue and introducing additional traffic would have potential to make this worse. The site is additionally constrained by its location at Grade 1 ‘best and most versatile’ agricultural land.

Site 235 at Platt is an identified receptor site for Great Crested Newts and is not taken forward, whilst Site 303 at Wateringbury is within an area of Grade 1 ‘best and most versatile’ agricultural land and is not tested further. At Site 333 at Plaxtol is not suitable to take forward as it is within the AONB and development would result in the loss of the village allotments, a valued community facility.

Site 230/296 forms a triangular site to the east of Ightham, extending the village eastwards towards Borough Green. The site is within the AONB, though whilst its landscape sensitivity is somewhat limited by the presence of existing development to the south and west and the A25 to the north, the site’s lack of development contributes to the setting and character of Ightham. There are also Minerals Safeguarding Area (MSA) constraints likely to affect the site and the site is not considered suitable for testing through the development strategy alternatives.

This leaves Site 270 at Burham as the one site suitable for consideration through the development strategy alternatives on the basis that there are not significant identified on site constraints at each and both could have potential to deliver growth at more rural settlements, helping to sustain the vitality of each (see Table A12).

6 Although Site 199 is a ‘building block’ site and is therefore not the focus of this, it is considered within this discussion on the basis of potential significant cumulative effects with sites in this appraisal resulting from its size and scale.

AECOM 30

Tonbridge and Malling Local Plan SA SA Report Addendum

Table A12: Site options considered for progression to the reasonable development strategy alternatives

Progress to the Number of new development Site Name homes strategy alternatives?

206 North of Pratling Street, Aylesford Employment

223 Land off Crabtree Close, Fairseat Employment

230/296 Dark Hill Farm/Gracelands Park, Ightham 243

231 Rear of Platt Mill Close, Platt 17

235 North of Maidstone Rd, Platt 37

270 Bell Lane, Burham 58 Y

273 Wouldham Allotments 134

278 Aylesford Quarry, Aylesford 1,877

303 Land off Fields Lane, Wateringbury 138

333 Plaxtol Allotments 50

353 West of The Orpines, Wateringbury 36

384 The Paddock, Common Road, Ightham Common 34

391 East of Aylesford Priory 21

AECOM 31

Tonbridge and Malling Local Plan SA SA Report Addendum

Appendix B - Detailed appraisal of the 2019 development strategy options Introduction

Section 2 presents a summary appraisal of the 2019 development strategy options, whilst the aim of this appendix is to present detailed appraisal findings.

Appraisal findings are presented as a discussion under each of the sustainability topic headings that comprise the SA Framework. A final heading also presents a concise conclusion.

By way of methodology -

For each of the alternatives, the assessment identifies / evaluates ‘likely significant effects’ on the baseline, drawing on the sustainability topics/objectives identified through scoping (see Table 1.1) as a methodological framework.

Green is used to indicate significant positive effects, whilst red is used to indicate significant negative effects. Every effort is made to predict effects accurately; however, this is inherently challenging given the high level nature of the policy approaches under consideration. The ability to predict effects accurately is also limited by understanding of the baseline (now and in the future under a ‘no plan’ scenario). In light of this, there is a need to make considerable assumptions regarding how scenarios will be implemented ‘on the ground’ and what the effect on particular receptors will be. Where there is a need to rely on assumptions in order to reach a conclusion on a likely effect, this is made explicit in the appraisal text.

Where it is not possible to predict likely significant effects on the basis of reasonable assumptions, efforts are made to comment on the relative merits of the alternatives in more general terms and to indicate a rank of preference. This is helpful, as it enables a distinction to be made between the alternatives even where it is not possible to distinguish between them in terms of ‘significant effects’.

Finally, it is important to note that effects are predicted taking into account the criteria presented within Regulations (Schedules 1 and 2). For example, account is taken of the duration, frequency and reversibility of effects. Cumulative effects are also considered (i.e. the effects of the plan in combination with other planned or on-going activity).

AECOM 32

Tonbridge and Malling Local Plan SA SA Report Addendum

Homes Ensure that everyone has the opportunity to live in an affordable home

Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Avoid Green Belt Submission Medway Gap settlement / AONB strategy

Rank 3 3 4 2

Significant Yes Yes Yes Yes effects?

The Local Plan must seek to deliver the Borough’s housing need which stands at 13,920 dwellings over the plan period. After completions and permissions are accounted for the residual need is 5,862 dwellings over the plan period. Therefore, a key consideration in terms of the performance of the reasonable development strategy options is the quantum of housing they will deliver, and the extent to which this will meet the Borough’s identified housing need. Additionally, there is also a need to consider the extent to which development will meet the specialist needs of different groups within the community, particularly in terms of affordable housing, specialist elderly accommodation and gypsy and traveller accommodation. Finally, there is a need to consider how this growth is distributed across the plan area and how the likely effects of growth are shared between key settlements. Options 2, 3 and 5 would deliver more than the minimum housing requirement. Option 2 performs most strongly, providing for as much as 3,500 above the requirement. Options 1 and 4 deliver less than the minimum housing requirement, with Option 4 falling significantly short. Option 4 is by far the weakest option in terms of the quantum of delivery, delivering a shortfall as potentially significant as 2,000 dwellings. In respect of affordable and specialist housing delivery, Options 2 and 5 perform well, on the Discussion basis that they would involve highest delivery at large, strategic sites that might be most suited to delivering the required quota of affordable housing, and also specialist housing.

Spatially, the Borough is divided in a broadly even split between the Sevenoaks and Tunbridge Wells HMA to the west and the Maidstone HMA (including one ward in the Medway HMA) to the east. The Strategic Housing Market Assessment (SHMA) explores this split, finding that households in the Borough are distributed around 49/51 between the two HMAs. It may therefore be important to deliver growth which reflects this broad distribution to reflect this near equal distribution of need between the HMAs. Options 2 and 3 perform most strongly in this regard, delivering a 45% / 55% split between the Sevenoaks and Tunbridge Wells HMA and the Maidstone HMA. Option 4, which skews development towards the less constrained Maidstone HMA and away from the more constrained Sevenoaks/Tunbridge Wells HMA, performs poorly, with just 23% being delivered in the Sevenoaks/Tunbridge Wells HMA. On balance it is considered that Option 2 performs most strongly against SA Objective 1 as it delivers the highest overall growth at the greatest number, variety and distribution of sites. Correspondingly, Option 4 performs most weakly as it delivers both the lowest overall growth and the least dispersed distribution of growth.

With regards to effect significance, the primary consideration relates to the question of whether the requirement figure will be met, or not.

AECOM 33

Tonbridge and Malling Local Plan SA SA Report Addendum

Flood risk Reduce and manage the risk of flooding

Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Avoid Green Belt Submission Medway Gap settlement / AONB strategy

Rank 2 2 2 2

Significant No effects?

Areas within Tonbridge and Malling are affected by fluvial flood risk, particularly in relation to the course of the River Medway which flows through the north east and the south of the Borough. Notably, these areas of risk directly affect the two largest urban areas of the Medway Gap and Tonbridge. However, all of the reasonable development strategy options are largely effective at directing housing growth away from the areas of Flood Zone 2 (i.e. an annual probability of flooding of between 1 in 100 and 1 in 1000), Flood Zone 3a (1 in 100 or greater probability of flooding) and Flood Zone 3b (functional flood plain). Options 2 and 5 would include Sites 233 and 427 at East Peckham, both of which are partially within FZ2; however, development could be directed away from the areas of risk at each site. All options include growth at Site 195 at Lower Haysden Lane in Tonbridge, of which around a third is within FZ2; however, in each instance the area of risk is furthest from the likely points of access and it is considered that mitigation through design and layout will be possible. In this context there is little to distinguish between the options in terms of fluvial flood risk. Surface water flood risk is more pervasive within the Borough and will likely have some degree of influence on sites across all of the reasonable development strategy alternatives. By directing development away from Tonbridge, Option 4 is the only option to avoid development at the heavily affected Sites 196 and 422 at Tonbridge and Little Trench Farm and North of Dry Hill Park Road, west of Tonbridge. The sites collectively have capacity for 373 dwellings, though the relatively extensive area of risk at each has potential to make this challenging to mitigate through design and layout alone. Whilst technical interventions can also offer potential mitigation, the Discussion most effective mitigation is to direct development elsewhere (Option 4). Similarly, Option 4 is the only one to direct growth away from Sites 195 and 393 to the south west of Tonbridge which are affected by a broad corridor of surface water flood risk through their centre. Of the key strategic sites, all options feature Site 199 (Bushey Wood) which is notably affected by both isolated pockets and more extensive ribbons of surface water flood risk. However, the size of the site option means it could be likely that development can be directed away from areas of highest risk.

Similarly, the strategic Site 408 north of Borough Green has numerous pockets of surface water flood risk throughout. This will likely affect the developable area though again by virtue of its scale the site could likely support substantial development which avoids areas of risk through appropriate design and layout. Options 1 and 4 direct development away from Site 408.

The strategic Site 358, north of Kings Hill, has a number of ribbons of surface water flood risk running through it, though as elsewhere it is likely that design and layout could mitigate the risk. Site 358 features in all options except Option 1. On balance, Option 4 is considered to perform most strongly in terms of surface water flood risk as it offers a strategy which all areas of risk at Tonbridge and Borough Green are avoided, though it is acknowledged that Option 4 does include the strategic Site 358. Finally, there is a need to consider groundwater flood risk though there is less opportunity for granular analysis in this regard as the areas of risk within the Borough are very broad. Much of the northern two thirds of the Borough lie within an area of major groundwater vulnerability, with a further area of minor vulnerability at the south of Borough. A band of no vulnerability divides

AECOM 34

Tonbridge and Malling Local Plan SA SA Report Addendum

the two. In this regard, development strategy options which direct growth to the lower areas of vulnerability are likely to perform more strongly, i.e. all options except Option 4.

Overall, it is a challenge to confidently differentiate between the alternatives in terms of flood risk. In the context of a plan area with areas of significant flood risk constraint, all of the options are reasonably successful in directing growth to areas of low or manageable flood risk. The most notable exception to this appears to the fact that by focussing growth in the Borough’s north east, Option 4 avoids allocation of Sites 196 and 422 which are each affected by extensive surface water flood risk. Significant negative effects are not predicted under any option, given good potential to avoid and mitigate flood risk through masterplanning and design measures.

Health and care Improve the health and care of the population

Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Avoid Green Belt Submission Medway Gap settlement / AONB strategy

Rank 3 2 3

Significant No Yes Yes No Yes effects?

Key considerations include the extent to which the development strategy alternatives promote and enable healthy lifestyles, particularly via walking and cycling, and the extent to which they will improve access to healthcare and publically accessibly open space. Major developments can offer potential opportunities to deliver significant green infrastructure both within the development itself and as a means of connecting with external services, facilities and transport hubs. This can provide good opportunities for enabling healthy lifestyles by increasing the viability and attractiveness of walking and cycling as a mode of transport. Similarly, larger developments can have greater capacity to integrate substantial areas of informal open green space as well as areas of play, formal sports facilities and other kinds of public open spaces. In this context, the options which promote large strategic sites are likely to provide the most significant opportunities for delivering substantial green infrastructure are likely to perform well, and therefore Options 2, 3 and 5 perform notably strongly (N.B. a number of the strategic sites appear across all alternatives and hence do not help differentiation). Discussion Site 358 (north of Kings Hill) offers particularly strong potential to connect with existing services and facilities at Kings Hill via comprehensive green infrastructure delivery. The flat landscape and existing green infrastructure network within Kings Hill has potential to support an extended and integrated network of walking and cycling, whilst the scale of the site offers potential for new open space delivery. There is an existing GP surgery located on Kings Hill, but the strategic site allocation will generate a need for additional facilities as set out in the Infrastructure Delivery Plan. Site 358 appears in Options 2-5.

Site 408 (Borough Green Gardens) similarly offers good potential for green infrastructure delivery, though the existing settlement is less well served by existing green infrastructure and there may be fewer opportunities to naturally integrate new green infrastructure networks with the existing built area of the town. Nevertheless, there could potentially be opportunities to deliver enhancements within the existing settlement through financial contributions, including enabling new development to connect with the train station and town centre services which could encourage more users. Options 2, 3 and 5 include Site 408. Site 408 could also potentially be of sufficient scale to enable delivery of additional healthcare facilities, particularly under Option 2 which would also deliver new development at nearby Sites 300 and 316.

AECOM 35

Tonbridge and Malling Local Plan SA SA Report Addendum

In terms of strategic-scale sites at Tonbridge, Site 275 north of Tonbridge (Options 1 and 2) offer more limited potential for promoting healthy lifestyles through green infrastructure connectivity. This is because it is more distant from Tonbridge centre, thereby offering less opportunity to position waking and cycling as a viable alternative to driving as a means of accessing town centre services. The South West of Tonbridge strategic site (comprising Sites 195, 266 and 393 under Options 1, 3, 4 and 5) are much closer to the centre of Tonbridge and would likely better placed to maximise the potential for walking and cycling. Smaller sites generally offer less potential to deliver significant green infrastructure or new healthcare facilities and are therefore not necessarily instructive as way of differentiating between the reasonable development strategy option. In light of the above, it is considered that Options 3 and 5 perform most strongly, as they would deliver the greatest proportion of growth at locations which are both of the scale to secure significant new health and care infrastructure, and at locations which are well placed to link with existing services and facilities, thereby positioning walking and cycling as a viable and attractive alternative to driving for local journeys. Option 2 also performs strongly, but includes sites with more limited potential to support walking and cycling, particularly those at Tonbridge and more rural settlements such as Hadlow and East Peckham.

Crime Reduce crime and fear of crime

Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Avoid Green Belt Submission Medway Gap settlement / AONB strategy

Rank = = = = = Significant No effects?

The planning system can assist with reducing crime, and fear of crime, through design concepts such as providing high levels of oversight of public spaces from passing pedestrian and vehicular traffic and avoiding expansive windowless walls, enclosed spaces and pedestrian bottlenecks. Additionally, by enabling derelict or abandoned buildings and spaces to be swiftly and effectively brought back into use the planning system can help deter vandalism and other forms of anti- social behaviour. However, matters of design and layout of new development are scheme- Discussion specific details not considered through the development strategy and correspondingly there is nothing to distinguish between the development strategy alternatives. In terms of recycling derelict land, rationalising previously developed sites and harnessing the opportunity presented by changes of use of former industrial sites to residential, there could theoretically be potential to differentiate between the development strategy alternatives; however, in practice, all options make similarly full use of available brownfield sites (as a necessary response to the high level of Green Belt constraint in the Borough).

AECOM 36

Tonbridge and Malling Local Plan SA SA Report Addendum

Accessibility

Improve accessibility for everyone to services and facilities

Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Avoid Green Belt Submission Medway Gap settlement / AONB strategy

Rank 3 2 4

Significant No Yes No Yes effects?

Option 3 performs well in relation to increasing travel choice in that new development will be focussed around existing transport hubs, particularly train stations. This means that the majority of new development will be within walking or cycling distance of regular public transport, which will provide choice to users who wish to access services and facilities which are more distant. In many instances, sites within Option 3 are also close to the existing urban centres as this tends to be where transport hubs are found. However, as a polycentric urban area the Medway Gap does not have a clear coherent centre, and two of its train stations (East Malling and Barming) are peripheral to the settlement and do not support access to any key nearby services. Nevertheless, development at strategic Site 188 (South Aylesford) will likely support the vitality of the Quarry Wood out of town retail park, and also support travel choices, particularly via train thanks to the proximity to Barming station. Development of Site 188, which features under all options, may help catalyse enhanced linkages between Barming station and Site 212 at Barming which is featured in Options 2, 4 and 5. Options 1 and 2 would direct significant growth to Tonbridge and this would likely help support the vitality and viability of Tonbridge town centre through the introduction of additional users and patrons of local services and facilities. However, these options would see much of the growth at Tonbridge delivered beyond reasonable walking or cycling distance of Tonbridge station, particularly at Sites 275 and 346 to the north of the existing urban area. This may not be Discussion consistent with increasing travel choices, even if some local day-to-day needs were able to be met within the development. Option 4 would see growth concentrated at the Medway Gap urban area. Whilst this would likely lead to a boost for the viability of the Medway Gap settlements, it would deprive the other key settlements of growth and could lead to imbalanced economic growth, potentially threatening the long term viability of urban centres at Borough Green, Tonbridge and Hildenborough in particular. Options 2 and 5 are the only options likely to notably affect the viability of rural centres as both direct some growth to sites at the rural settlements of Hadlow and East Peckham. This could help ensure the long term viability of the local services, and retail, at each settlement. On balance, it is considered that Options 2 and 5 perform most strongly as both options direct growth towards key transport hubs which will help increase travel choices for new and existing residents, whilst also distributing growth to each of the key urban centres, potentially supporting a boost in vitality, and also providing a boost for the rural service centres of Borough Green, East Peckham and Hadlow, helping support their continued viability. On balance, it is considered appropriate to suggest the potential significant positive effects. Option 4 performs most weakly on the basis that for much of the Borough it neither increases access to services / facilities nor supports the vitality of urban and rural centres. However, it is not possible to conclude significant negative effects.

AECOM 37

Tonbridge and Malling Local Plan SA SA Report Addendum

Land use Improve efficiency of land use

Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Avoid Green Belt Submission Medway Gap settlement / AONB strategy

Rank 2 3 2 2

Significant Yes No Yes effects?

The key issues to consider in respect of efficiency of land use include effects from development on the Green Belt, on Minerals Safeguarding Areas (MSAs), the extent to which available brownfield land is reused or recycled, and the extent to which ‘best and most versatile’ (BMV) agricultural land is affected.

All development strategy options include a significant extension of the Green Belt boundary to land between Kings Hill and the Medway Gap. Therefore, although this is a significant effect of the Local Plan, for the purposes of this appraisal the newly designated Green Belt is not relevant as it does not help to differentiate between the options. In relation to effects on existing Green Belt, Option 4 performs notably strongly. This is because growth is directed to sites at the north east of the Borough, outside the Green Belt (including the proposed extension). All other options involve substantial Green Belt release. Option 2 performs weakest in terms of its effect on the Green Belt because, as the high growth option, it leads to the greatest area of Green Belt land being released. Most notably, this includes all of the non-Medway Gap strategic sites, i.e. Site 408 (Borough Green Gardens) and Sites 266 and 393 which form part of the South West Tonbridge strategic site. Additionally, Option 2 includes Site 275 (Grange Farm) and 346 (North of Barchester Way) which collectively have indicative capacity for a further 1,600 dwellings in the Green Belt north of Tonbridge. It is also the only option to include Site 327 which is in the Green Belt west of West Malling and has indicative capacity for over 400 dwellings. Similarly, Option 2, along with Option 1, would deliver significant employment land in the Green Belt at Site 206 at Leybourne. Discussion In summary, Options 1, 3 and 5 all release different combinations of significant Green Belt sites and it is considered that they perform broadly on a par in this respect, less strongly than Option 4 but more strongly than Option 2.

In terms of effects upon MSAs, the picture is more nuanced, partly as a result of the widespread nature of MSAs for various mineral deposits within the plan area. Again, as the highest growth option, Option 2 performs most weakly because of the cumulative effect of including so many sites which are within an MSA. For example, all of the strategic sites are at least partially within an MSA so as the only option to include all the strategic sites, Option 2 affects the greatest amount of safeguarded land. Additionally, Option 2 includes sites such as Site 327 at West Malling and 300 and 316 and Borough Green, all of which are large sites within MSAs. Although there are significant MSAs in centre of the Borough, there are two bands which are free of notable minerals safeguarding constraints north of Tonbridge and north of the Medway Gap. By directing development towards these areas Option 1 performs most strongly in relation to minerals as it results in the lowest direct impact upon MSAs. In terms of brownfield land it is difficult to meaningfully differentiate between the options as all options include the same building block sites, many of which are brownfield sites in existing urban areas. In terms of the impact on BMV agricultural land, the high level national dataset (the poor resolution of which is acknowledged) indicates that much of the land around the Medway Gap urban area could be Grade 2, with localised areas of Grade 1. Further areas of Grade 2 land are indicated to the north of Aylesford and around East Peckham. Therefore Options 1 and 4, which

AECOM 38

Tonbridge and Malling Local Plan SA SA Report Addendum

concentrate some or all growth at the Medway Gap, would likely have the greatest impact on BMV land. Site 327 at West Malling has potential to be within an area of the highest quality Grade 1 land, though it is only included within Option 2. Although Option 5 does not include Site 327 it does include small sites at East Peckham which have potential to be on BMV land; however, the East Peckham sites are small and are not part of wider open countryside as they fall within a narrow settlement gap between East Peckham and Hale Street. In conclusion, appraising the efficiency of land use requires balancing the potential effects on a variety of indicators, a process made more complicated by the fact that equal weight cannot necessarily be attributed to all the different designations. For example, loss of Green Belt is theoretically clear and measurable (setting aside the notion of strongly and weakly performing Green Belt parcels), whilst loss of BMV land or land within an MSA may not necessarily result in harm on the ground subject to detailed surveys. This makes identifying a clearly preferably development strategy option challenging as weighing up the overall harm or gain upon the range of factors is highly nuanced. In this context, it is considered that, overall, Option 2 performs least well, as the highest growth option, whilst Option 4 performs best as the lowest growth option.

In respect of effect significance, all options other than Option 4 are judged to lead to significant negative effects given loss of Green Belt, loss of BMV agricultural land and potential sterilisation of minerals resources.

Air quality Protect and improve air quality

Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Avoid Green Belt Submission Medway Gap settlement / AONB strategy

Rank 3 2 2 2

Significant ? effects?

Key considerations in terms of air quality are the need to avoid locating development in areas of existing poor air quality and the need to avoid creating new areas of poor air quality as a result of new development. Declared AQMAs are the natural focus of attention as they indicate areas where existing air quality is poorest and where there are enduring issues with volume of traffic or with stationary/idling vehicles. Of the seven declared AQMAs in the Borough, one relates to the M20 and is unlikely to be primarily influenced by activity within the Borough, and another is at Wateringbury and will therefore not be the focus of development through any of the development strategy alternatives. Of the remaining five AQMAs, one is at Tonbridge, one is at Borough Green and three are at the Medway Gap. In this context, Option 1 which focusses growth at Tonbridge and the Medway Gap has potential Discussion to perform poorly, as all development will be focussed nearest to areas with declared AQMAs, likely leading to increased traffic flows through the affected areas. Options 2 and 5 also have potential to affect both the Tonbridge AQMA and the Medway Gap AQMA. However, Options 2 and 5 also direct substantial growth to Borough Green, including the Borough Green Gardens proposal at Site 408. This is significant as the scheme would deliver a relief road as an integral part of development (see LP29 of the submitted Plan). This would be likely to substantially reduce traffic flows through the Borough Green AQMA and remove the cause of traffic congestion in the town which is the reason the AQMA was declared. This suggests the net effect of Options 2 and 5 could potentially be less harmful in air quality terms than Option 1 as although there could be negative effects on two AQMAs, there would likely be a significant positive on one AQMA.

AECOM 39

Tonbridge and Malling Local Plan SA SA Report Addendum

By directing growth entirely to the Medway Gap urban area Option 4 would likely increase traffic flows through the three Medway Gap AQMAs, though overall growth would be substantially lower than the other options and the impact on the AQMAs may be less significant. Option 3 focusses growth around transport hubs though in practice this means concentrating development at existing urban areas, including those affected by the AQMAs. However, there is clearly potential for greater take up of public transport under Option 3 which could help minimise the number of new vehicle journeys through AQMAs. Therefore, all options direct some degree of growth to areas of the Borough likely to generate traffic flows through the AQMAs, with Options 2 and 5 directing significant growth to the most affected areas of the Borough (i.e. Borough Green, Tonbridge and the Medway Gap AQMAs). However, growth also brings potential opportunities to deliver new and enhanced infrastructure and sustainable transport options and it would be simplistic to suggest that higher growth necessarily leads exclusively to greater negative effects. In this context, Options 2 and 5 are anticipated to lead to significant positives in relation to Borough Green where the traffic congestion which led to the declaration of the AQMA in the town will likely be addressed through provision of a new relief road. On balance, it is considered that Option 4 performs well on the basis that overall growth will be lowest and focussed at the highest proportion of sites with potential to link with new or existing sustainable transport networks. Option 1 is considered to perform least strongly as it will likely lead to growth which generates increased traffic flows through two AQMAs without offering any of the benefits of Options 2 and 5. With regards to effect significance, it is appropriate to ‘flag’ uncertain negative effects. There would be a need to interrogate detailed traffic modelling to understand impacts on AQMAs with certainty.

Climate change Ensure that the Borough responds positively, and adapts to, the impacts of climate change

Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Avoid Green Belt Submission Medway Gap settlement / AONB strategy

Rank 2 3 2 2

Significant No effects?

A key consideration in relation to climate change adaptation is that of avoiding and reducing the risk of flooding. However, this is covered separately by a dedicated SA objective. This discussion therefore focusses more closely on climate change mitigation, i.e. reduction in greenhouse gas emissions from the built environment and from transport. In light of this, Option 3 performs notably well in that new development will be focussed around existing transport hubs, particularly train stations. There is strong potential to make fuller use of a number of the Borough’s train stations as hubs for new development, particularly Barming Discussion Station, which is nearly adjacent to Aylesford but surrounded by open undeveloped land, and at Borough Green where large parts of the strategic Site 408 are within the 800m buffer used to define the catchment of a transport hub. Option 3 also delivers over 300 dwellings at Sites 300 and 316 at Borough Green, also within the 800m buffer. Option 2, as the high growth option, also maximises the potential of Sites 300 and 316, though Option 3 performs more strongly as it delivers a higher overall proportion of development at locations which are not necessarily car dependant, whereas Option 2 also includes sites more likely to be car dependant.

AECOM 40

Tonbridge and Malling Local Plan SA SA Report Addendum

The majority of site options at Tonbridge are well beyond the 800m buffer of both Tonbridge station itself and Hildenborough station to the west, particularly sites at the north of the town. This means that both Option 1, which concentrates growth at Tonbridge and the Medway Gap, and Option 2, which is the high growth option, perform poorly in relation to reducing the need to travel by car. All other options avoid the more peripheral Tonbridge sites. By focussing development around transport hubs, Option 3 also offers the strongest potential to provide effective green infrastructure linkages between new development and train stations, on the basis the growth will be located within 800m of transport hubs. This is likely to be within cycling distance, and potentially walking distance, for many and will help reduce the need to make journeys by car. It is acknowledged that the strategic sites will be of scale sufficient to deliver some level of service offering within the development. This is likely to mean that all strategic sites will contribute to an extent to enabling residents to meet limited needs locally, thus further limiting the need to travel by car for some journeys. However, as all options include a number of strategic sites it is considered that this does not enable the most of the options to be meaningfully differentiated, though Option 1 and Option 4 are considered to perform marginally less strongly than the others on the basis that they do not include the strategic opportunity at Site 408 which has strong potential to deliver development which supports sustainable travel. It is also acknowledged that some stations at which there would be the physical capacity to deliver new development are removed from their associated settlement and as a result are not suitably sustainable locations for growth. This is particularly true of Hildenborough station and Beltring station near East Peckham. In terms of emissions from the built environment, there is little to differentiate between the options at such a high level. Strategic sites offer potential opportunities to deliver innovative energy efficiency measures, and potentially also decentralised low carbon heat/power generation, though this is a matter of detail and not of development strategy. On balance, there is little to distinguish between the different development strategy alternatives in terms of climate change mitigation. However, with an overt focus on concentrating growth at transport hubs, Option 3 is considered to perform most strongly. By directing development to all locations, regardless of their likely propensity for car dependency, it is considered that Option 2 performs most weakly.

With regards to effect significance, significant negative effects are not predicted under any option, recognising that climate change mitigation is a global issue (i.e. local actions, whilst of great importance, can only have a limited effect).

Natural and heritage assets Protect and enhance natural and heritage assets

Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Avoid Green Belt Submission Medway Gap settlement / AONB strategy

Rank = = = = = Significant Yes effects?

Key considerations in relation to natural and heritage assets include the AONB and its setting, designated sites of biodiversity significance and heritage assets such as listed buildings, conservation areas, scheduled monuments and registered parks and gardens. Discussion All development strategy options are likely to have a degree of impact on the Kent Downs AONB which stretches across the west and north of the Borough, encompassing a number sites. Most notably, Site 408, which is the strategic Borough Green Gardens site, falls partially within the AONB and potentially entirely within its setting. The Bushey Wood strategic site (Site 199) also has potential to fall at least partially within the setting of the AONB as it sits lower in the landscape

AECOM 41

Tonbridge and Malling Local Plan SA SA Report Addendum

than the AONB and long range views are supported into the site. However, all development strategy options include Site 199. Options 1 and 4, which do not include Borough Green Gardens, are likely to have potential for a lower impact on the AONB than Options 2, 3 and 5. None of the development strategy options include sites within the High Weald AONB at the south of the Borough, though part of the South West Tonbridge strategic site (comprising Sites 195, 266 and 393) could have potential to be within its setting as the rising landform south of the sites provides a high degree of oversight. In summary, Option 4 performs most strongly in relation to AONB as it focusses the highest proportion of growth away from sites within or adjacent to either of the two AONBs or their respective settings. The north east of the Borough is most notably affected by national biodiversity designations, particularly SSSIs. The most notably affected site in biodiversity terms is Site 199 as it is adjacent to the Aylesford Pit SSSI and is also close to Holborough to Burham Marshes SSSI to the north, as well as the Wouldham to Detling Escarpment SSSI to the east, the Peter’s Pit SSSI to the north. However, as noted above, all development strategy alternatives include Site 199 and it is therefore more instructive to consider the potential for cumulative effects from sites which are nearby but do not feature in all of the options. This is because of the potential for greater recreational pressure on the designated sites from options which also include sites in close proximity to Site 199. In practice, however, Site 58 at Burham (included in Options 2, 4 and 5) is the only site in the vicinity which does not feature in all of the development strategy options and it has a relatively low yield. Options 2, 3 and 5 include the Borough Green Gardens strategic site (Site 408) which is partially within the Impact Risk Zone of the Halling to Trottiscliffe Escarpment SSSI and the Trottiscliffe Meadows SSSI, which both lie to the north of the M26. However, they are of sufficient distance the risk does not apply to residential development. Despite the relatively limited extent of national or international biodiversity designations in the Borough there is a significant quantity of local wildlife sites (LWS), many of which are extensive. Despite this, few of the site options within the development strategy alternatives are within or adjacent to an LWS. Notable exceptions are Sites 300 and 316 at Borough Green, which feature in Options 2 and 3; these sites are adjacent to the Bourne Valley Woods LWS to the south of the settlement. Additionally, Site 212, which features in Options 2, 4 and 5, is adjacent to the Oaken Wood LWS at Barming. More significantly, strategic Site 199 (Bushey Wood) includes the entire Eccles Old Pits LWS suggesting there is clear potential for sensitivity to inappropriate future development, though as discussed above this site features within all development strategy options. Although direct effects on local, national and international biodiversity designations appear to be limited, there is a need to also consider the indirect or secondary effects of new development, particularly the potential for increased recreational pressure. In this light, there could be a potentially greater risk of more recreational pressure from options which deliver a higher quantum of growth as this has potential to increase visitor numbers. However, in practice all options deliver a similar pattern of growth in the areas of greatest sensitivity, with variable sites coming into play in less sensitive areas of the Borough, such as around Tonbridge. On this basis it is considered that recreational pressure from the higher growth options, such as Options 2 and 5, will not necessarily lead to clear additional recreational pressure on the Borough’s designated sites.

It is important to also recognise the potential for delivering a net gain in biodiversity through the development process. A number of biodiversity opportunity areas are identified within the plan area and the strategic sites in particular offer the potential to seek biodiversity net gain at an ambitious scale. This is on the basis that larger sites can often offer the greatest opportunities to integrate features such as habitat corridors and green and blue infrastructure. In this context, the options which direct a higher proportion of development to the strategic sites and the large non- strategic sites, principally Option 2, but essentially all options other than Option 4, perform potentially strongly. The wide variety of heritage assets throughout the plan area mean that all options involve a degree of impact on listed buildings, conservation areas and scheduled monuments. Notable

AECOM 42

Tonbridge and Malling Local Plan SA SA Report Addendum

examples include the cluster of Grade I listed buildings at Bradbourne House, and their associated conservation area, which all fall within Site 304 in Options 2-5. Strategic Site 358, also in Options 2-5, includes the entire New Barns and Broadwater Farm conservation area and is adjacent to both the West Malling conservation area and the Mill Street Conservation area. Conversely, Strategic Site 188, which features in all options, is free of any designated heritage assets. On balance it appears as though Option 1 features less direct impact on designated historic assets, though it is noted that in some instances development can help enhance the setting, understanding-of and access-to a historic asset. In conclusion, natural and heritage assets comprise an expansive range of designated and non- designated features in the Borough, hence reaching a clear overall appraisal conclusion is a challenge. It is not possible to simply conclude that higher growth options perform worse than lower growth option. In this context the appraisal finds that broadly equivalent significant negative effects are likely from all development strategy alternatives.

Waste management Reduce waste and achieve sustainable waste management

Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Avoid Green Belt Submission Medway Gap settlement / AONB strategy

Rank = = = = = Significant No effects?

The alternatives do not lead to notable implications for the achievement of waste management Discussion objectives. There is no reason to suggest that any option would lead to problems in respect of delivering the waste management facilities necessary to ensure effective management of waste in accordance with the waste hierarchy.

Water Maintain and improve water quality and to use water more efficiently

Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Avoid Green Belt Submission Medway Gap settlement / AONB strategy

Rank 2 3 2 2

Significant No effects?

The key aspect of maintaining and improving water quality in the Borough will be minimising negative effects of new development on source protection zones (SPZs). SPZs map areas around public potable groundwater abstraction sites within which inappropriate development could potentially harm potable water quality. There are a number of SPZs within the Borough, most notably at Tonbridge in the south and at Borough Green, Wrotham, Leybourne and Ditton Discussion in the north. On this basis, Option 4 performs well, as it directs development to the north east of the Borough, thereby avoiding the Tonbridge SPZs and the Borough Green and Wrotham SPZs. SA Objective 11 is also concerned with the potential for facilitating re-use and recycling of water; however, achievement of this sub-objective will be a factor more of detailed decisions in respect of design at the development management stage.

AECOM 43

Tonbridge and Malling Local Plan SA SA Report Addendum

Economy Achieve and maintain a vibrant economy

Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Avoid Green Belt Submission Medway Gap settlement / AONB strategy

Rank 3 5 4 2

Significant Yes No Yes ? effects?

Whilst none of the development strategy options involve allocations sufficient to meet the target figure established by the Employment Land Review (ELR, 2017) of 46.8 hectares employment land, Option 2 falls short by only 15%. Other options perform notably less well; however, under Option 5 there is some confidence in the ability to close the gap between supply and the target figure through intensifying employment activity on existing employment sites. This is an approach supported through Policy LP34 of the Local Plan. For example, the largest employment site in the borough, the former Aylesford Newsprint site, could be redeveloped for light industry, general industry and/or storage and distribution leading to more intensive use of the site than the former Discussion paper mill (see Policy LP35 in the submitted Local Plan). Furthermore, there may some modest potential to deliver new employment floorspace as part of one of more of the strategic mixed use schemes under consideration. Perhaps most notably, Options 2, 3 and 5 would involve allocation of Strategic Site 408 (Borough Green Gardens), which would deliver over 1,700 new dwellings and could potentially deliver some employment floorspace, particularly in light of its strategic location next to a station and J2a of the M26. In conclusion, the alternatives are ranked according to the amount of employment land allocated, with Options 1 and 3 and 4 predicted to result in significant negative effects, and uncertain negative effects predicted in respect of Option 5.

AECOM 44

Tonbridge and Malling Local Plan SA SA Report Addendum

Conclusion Option 1 Option 2 Option 3 Option 4 Option 5

Tonbridge or Adjacent to a Transport hub Outside of the Submission the M’way Gap settlement GB and AONB strategy

Homes 3 3 4 2

Flood risk 2 2 2 2

Health and care 3 2 3

Crime =

Accessibility 3 2 4

Land use 2 3 2 2

Air quality 3 2 2 2

Climate change 2 3 2 2

Natural and heritage = assets Waste management =

Water 2 3 2 2

Economy 3 5 4 2

Discussion Focusing firstly on Option 5 (the submission strategy), the appraisal predicts significant positive effects in respect of ‘homes’, ‘health and care’ and ‘accessibility’. Significant negative effects are predicted in respect of ‘land use’, and uncertain negative effects in respect of ‘economy’; however, in both cases only one of the four alternatives performs better. In respect of four further objectives, namely ‘flood risk’, ‘air quality’, ‘climate change’ and ‘water’, the appraisal finds that Option 5 is not the best performing option, but does not highlight any significant concern. Option 1 also warrants stand-alone consideration, on the basis that it notably does not perform best in respect of any objective, and is the only option to register a significant negative effect in relation to three SA objectives. Whilst this does not automatically mean that Option 1 performs poorly overall (as options are not assigned any weighting), it is a strong indication. Having made these initial points, the following bullet points consider the performance of the alternatives in respect of each of the sustainability objectives for which it is possible to differentiate the alternatives:  Housing - Option 2 performs most strongly as it delivers the highest overall growth at the greatest number, variety and distribution of sites. Correspondingly, Option 4 performs most weakly as it delivers both the lowest overall growth and the least dispersed distribution of growth. With regards to effect significance, the primary consideration relates to the question of whether the requirement figure will be met, or not.  Flood risk - it is a challenge to confidently differentiate between the alternatives in terms of flood risk. In the context of a plan area with areas of significant flood risk constraint, all of the options are reasonably successful in directing growth to areas of low or manageable flood risk. The most notable exception to this appears to the fact that by focussing growth in the Borough’s north east, Option 4 avoids allocation of Sites 196 and 422 which are each affected by extensive surface water flood risk.  Health and care - Options 3 and 5 perform most strongly, as they would deliver the greatest proportion of growth at locations which are both of the scale to secure significant new health and care infrastructure, and at locations which are well placed to link with existing services and facilities, thereby positioning walking and cycling as a viable and attractive alternative to driving for local journeys. Option 2 also performs strongly, but

AECOM 45

Tonbridge and Malling Local Plan SA SA Report Addendum

includes sites with more limited potential to support walking and cycling, particularly those at Tonbridge and more rural settlements such as Hadlow and East Peckham.  Accessibility - Options 2 and 5 perform most strongly as both options direct growth towards key transport hubs which will help increase travel choices for new and existing residents. In addition, both options distribute growth to each of the key urban centres, potentially supporting a boost in vitality, whilst also providing a boost for the rural service centres of Borough Green, East Peckham and Hadlow, helping support their continued viability. On balance, it is considered appropriate to suggest the potential significant positive effects. Option 1 is considered to perform less well on the basis that the key settlement and transport hub of Borough Green is avoided, whilst Option 4 performs most weakly on the basis that for much of the Borough it neither increases access to services / facilities nor supports the vitality of urban and rural centres.  Land use - all options other than Option 4, as the lowest growth option, will result in significant loss of Green Belt and best and most versatile agricultural land, and potentially lead to sterilisation of minerals resources within known Minerals Safeguarding Areas, with Option 2 performing worst as the highest growth option.  Air quality - there are a number of designated air quality management areas in this area, hence there is an argument for following a lower growth strategy (Option 4) on air quality grounds, with growth under this option also directed predominantly to locations with good potential to link with ‘sustainable transport’ networks. The proposed relief road at Borough Green would likely relieve the traffic congestion for which the Borough Green AQMA was declared, though it would only be delivered under development strategy options which also direct growth to other AQMAs. With regards to effect significance, it is appropriate to ‘flag’ uncertain negative effects. There would be a need to interrogate detailed traffic modelling to understand impacts on AQMAs with certainty.  Climate change - there is little to distinguish between the different development strategy alternatives; however, with an overt focus on concentrating growth at transport hubs, Option 3 is considered to perform most strongly. By directing development to all locations, regardless of their likely propensity for car dependency, it is considered that Option 2 performs most weakly.  Natural and heritage assets - comprise an expansive range of designated and non-designated features in the Borough, hence reaching a clear overall appraisal conclusion is a challenge. It is not possible to simply conclude that higher growth options perform worse than lower growth option. In this context the appraisal finds that broadly equivalent significant negative effects are likely from all development strategy alternatives.  Water - Option 4 performs well, as it directs development to the north east of the Borough, thereby avoiding the Tonbridge groundwater Source Protection Zone (SPZ) and the Borough Green and Wrotham SPZ.  Economy - the alternatives are ranked according to the amount of employment land allocated, and all alternatives other than Option 2 are predicted to result in significant negative effects on the basis that the target figure established by the Employment Land Review is not met (albeit with considerable uncertainty in respect of Option 5).

AECOM 46

Tonbridge and Malling Local Plan SA SA Report Addendum

Appendix C - Detailed appraisal of the Green Belt alternatives Introduction

Section 3 presents a summary appraisal of Green Belt extension alternatives, whilst the aim of this appendix is to present detailed appraisal findings.

Appraisal findings are presented as a discussion under each of the sustainability topic headings that comprise the SA Framework. A final heading also presents a concise conclusion.

By way of methodology -

For each of the alternatives, the assessment identifies / evaluates ‘likely significant effects’ on the baseline, drawing on the sustainability topics/objectives identified through scoping (see Table 1.1) as a methodological framework.

Green is used to indicate significant positive effects, whilst red is used to indicate significant negative effects. Every effort is made to predict effects accurately; however, this is inherently challenging given the high level nature of the policy approaches under consideration. The ability to predict effects accurately is also limited by understanding of the baseline (now and in the future under a ‘no plan’ scenario). In light of this, there is a need to make considerable assumptions regarding how scenarios will be implemented ‘on the ground’ and what the effect on particular receptors will be. Where there is a need to rely on assumptions in order to reach a conclusion on a likely effect, this is made explicit in the appraisal text.

Where it is not possible to predict likely significant effects on the basis of reasonable assumptions, efforts are made to comment on the relative merits of the alternatives in more general terms and to indicate a rank of preference. This is helpful, as it enables a distinction to be made between the alternatives even where it is not possible to distinguish between them in terms of ‘significant effects’.

Finally, it is important to note that effects are predicted taking into account the criteria presented within Regulations (Schedules 1 and 2). For example, account is taken of the duration, frequency and reversibility of effects. Cumulative effects are also considered (i.e. the effects of the plan in combination with other planned or on-going activity). Homes Ensure that everyone has the opportunity to live in an affordable home

Option 1 Option 2 Option 3 Option 4

No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Rank 2 3 4

Significant No effects?

The Local Plan must provide for the Borough’s housing need which stands at 13,920 dwellings over the plan period. After completions and permissions are accounted, this necessitates Local Plan allocations for 5,862 dwellings over the plan period. Furthermore, there is a need to consider the possibility of allocating additional homes as a ‘buffer’, to ensure that the need figure is Discussion provided for in practice. The options involve an increasing amount of land within the Green Belt land, and hence an increasing amount of land where housing growth would be considered acceptable only in ‘exceptional circumstances’. The ranking of the options reflects this fact.

AECOM 47

Tonbridge and Malling Local Plan SA SA Report Addendum

With regards to effect significance, it is not possible to conclude that Option 4 would lead to a significant negative effect. This is on the basis that the Council’s SLAA shows there to be sufficient ‘suitable and deliverable’ land outside of this ‘Medway Gap’ area to meet needs.

Flood risk Reduce and manage the risk of flooding

Option 1 Option 2 Option 3 Option 4

No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Rank = Significant No effects?

Flood risk from fluvial and surface water is not particularly extensive in this area, and in any case there is a presumption against vulnerable development (including housing) in the flood risk zone, hence it is difficult to suggest that an extension to the Green Belt is a ‘positive’ in respect of this Discussion objective. New land within the Green Belt might feasibly be utilised to deliver water storage or attenuation measures, in order to reduce downstream flood risk (notably in the Ditton area); however, there is little reason to suggest that such land use interventions would be more likely under Option 4, relative to Option 1. As such, the alternatives are ranked ‘on a par’ and significant effects are not predicted.

Health and care Improve the health and care of the population

Option 1 Option 2 Option 3 Option 4

No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Rank = Significant No effects?

Preserving accessible countryside (there are currently a number of footpaths through the land in question) could potentially have positive health implications for nearby communities, including urban communities in the Leybourne to Ditton conurbation; however, it is difficult to suggest Discussion positive implications with any certainty. This is on the basis that the countryside in this area is not particularly high quality or accessible, and strategic development (greatest potential under Option 1) could potentially deliver new accessible green / openspace and/or new facilities in support of health and wellbeing, e.g. new sports facilities or healthcare facilities. As such, the alternatives are ranked ‘on a par’ and significant effects are not predicted.

AECOM 48

Tonbridge and Malling Local Plan SA SA Report Addendum

Crime Reduce crime and fear of crime

Option 1 Option 2 Option 3 Option 4

No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Rank = Significant No effects?

It is difficult to suggest the likelihood of these alternatives having any implications for the achievement of ‘crime’ objectives. One of the purposes of Green Belt is to assist in urban Discussion regeneration, by encouraging the recycling of derelict and other urban land; however, in practice it is not clear that any nearby regeneration objectives would be supported under Option 4 more so than Option 1. As such, the alternatives are ranked ‘on a par’ and significant effects are not predicted.

Accessibility

Improve accessibility for everyone to services and facilities

Option 1 Option 2 Option 3 Option 4

No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Rank = Significant No effects?

Extending the Green Belt to encompass West Malling and East Malling (Option 4) would limit opportunities for strategic extensions to these settlements that deliver new facilities of benefit to the local community; however, these are relatively well-connected settlements, with limited Discussion existing problems in respect of accessibility to services/facilities. Furthermore, extension of the Green Belt could lead to increased likelihood of development, with associated delivery of new facilities, at more rural communities, and rural villages may also be in need of housing growth to support viability of the existing village centre. As such, the alternatives are ranked ‘on a par’ and significant effects are not predicted.

AECOM 49

Tonbridge and Malling Local Plan SA SA Report Addendum

Land use Improve efficiency of land use

Option 1 Option 2 Option 3 Option 4

No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Rank 4 3 2

Significant No Yes effects?

The nationally available agricultural land quality dataset (which is very low resolution) shows there to be a band of higher quality ‘grade 2’ agricultural land running through this part of the Borough. Furthermore, some land in this area has been surveyed in detail (applying the ‘post 1988 criteria’ methodology, which involves field surveys), with land found to be a mixture of grade 1, grade 2 and grade 3a quality. This includes a significant area of best quality ‘grade 1’ directly to the east of West Malling (i.e. land that would be included in the Green Belt under Options 2, 3 and 4). As such, the alternatives are ranked according to the extent of the Green Belt. Discussion With regards to effect significance, it is appropriate to ‘flag’ the possibility of significant positive effects under Options 2 to 4; however, in practice there is no certainty that the baseline situation (Option 1) would lead to significant development and in turn significant loss of best and most versatile agricultural land. N.B. the land in question also comprises a minerals safeguarding area (MSA); however, this is considered a secondary consideration, given the extensive nature of MSAs and also the potential for extraction of minerals ahead of development.

Air quality Protect and improve air quality

Option 1 Option 2 Option 3 Option 4

No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Rank = Significant No effects?

Air quality is problematic in the vicinity of the land in question, with air quality management areas (AQMAs) designated in Leybourne / Larkfield / Ditton and also within the west of Maidstone. As Discussion such, there could be an argument for restricting growth in this area through extension of the Green Belt; however, there is no certainty that problematic development would occur under the baseline scenario (Option 1). As such, the alternatives are ranked ‘on a par’ and significant effects are not predicted.

AECOM 50

Tonbridge and Malling Local Plan SA SA Report Addendum

Climate change Ensure that the Borough responds positively, and adapts to, the impacts of climate change

Option 1 Option 2 Option 3 Option 4

No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Rank 2 3 4

Significant No effects?

The land in question is relatively well connected by rail, leading to the potential for any new communities to have relatively low per capita emissions from transport. As such, the baseline situation is favoured, as opposed to options involving extension of the Green Belt and increased restrictions on new housing or employment development in this area. However, significant negative effects are not predicted, even under Option 4, given the inherent uncertainties, and Discussion also noting that climate change mitigation is a global consideration (such that local actions can have only limited effect). One of the purposes of Green Belt is to assist in urban regeneration, by encouraging the recycling of derelict and other urban land; however, in practice it is not clear that any nearby regeneration objectives would be supported under Option 4 more so than Option 1. As such, the alternatives are ranked ‘on a par’ and significant effects are not predicted.

Natural and heritage assets Protect and enhance natural and heritage assets

Option 1 Option 2 Option 3 Option 4

No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Rank 4 3 2

Significant No Yes effects?

There are notable heritage constraints associated with the land in question, with designated conservation areas at West Malling, New Barns And Broadwater Farm, Clare Park and Blacklands (west of East Malling), Mill Street (south of East Malling), East Malling village (in the vicinity of the rail station) and Bradbourne House (east of East Malling). Biodiversity constraint is more limited, although there are several small patches of priority woodland habitat, and Option Discussion 4 might provide some protection to Oaken Wood, which is a large ancient woodland (replanted). The core of this woodland is designated as a nationally important SSSI.

On the basis of the above considerations it is fair to conclude that an extension to the Green Belt could lead to benefits. It is difficult to draw conclusions in respect of significance, but on balance it is appropriate to highlight Option 4 as having the potential to lead to significant positive effects.

AECOM 51

Tonbridge and Malling Local Plan SA SA Report Addendum

Waste management Reduce waste and achieve sustainable waste management

Option 1 Option 2 Option 3 Option 4

No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Rank = Significant No effects?

The alternatives do not lead to notable implications for the achievement of waste management Discussion objectives. There is no reason to suggest that any option would lead to problems in respect of delivering the waste management facilities necessary to ensure effective management of waste in accordance with the waste hierarchy.

Water Maintain and improve water quality and to use water more efficiently

Option 1 Option 2 Option 3 Option 4

No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Rank = Significant No effects?

The alternatives do not lead to notable implications for the achievement of ‘water’ objectives. Part of the land in question falls within a groundwater source protection zone; however, this does Discussion not serve to indicate a significant constraint on development. There is no reason to suggest that any option would lead to problems in respect of delivering requisite drainage solutions wastewater treatment solutions.

Economy Achieve and maintain a vibrant economy

Option 1 Option 2 Option 3 Option 4

No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Rank 2 3 4

Significant No Yes effects?

As per the discussion above under ‘Housing’, there is little reason to suggest that the Council’s ability to provide for objectively assessed economic development needs would be hindered by Discussion an extension to the Green Belt, even under Option 4. However, this part of the Borough is relatively well connected by road and rail, and this is reflected in a relatively high concentration of existing employment land, with East Malling Research Station falling within the land area that would be added to the Green Belt under Option 4.

AECOM 52

Tonbridge and Malling Local Plan SA SA Report Addendum

On the basis of the above considerations it is fair to conclude that an extension to the Green Belt is not supported. It is difficult to draw conclusions in respect of significance, but on balance it is appropriate to highlight Option 4 as having the potential to lead to significant negative effects.

Conclusion

Option 1 Option 2 Option 3 Option 4 No Green Belt Extend eastwards to Extend further to Extend further to Kiln extension the A228 Ashton Way Wateringbury Road Barn Road (east of (East of West Malling) (East Malling) East Malling)

Homes 2 3 4

Flood risk = Health and care = Crime = Accessibility =

Land use 4 3 2

Air quality =

Climate change 2 3 4

Natural & 4 3 2 heritage assets

Waste = Water =

Economy 2 3 4

The appraisal broadly serves to highlight that extension of the Green Belt (GB) is supported in respect of environmental objectives, but leads to tensions in respect of socioeconomic objectives; however, the picture is not entirely clear-cut, with extension not supported in respect of climate change objectives, as the area in question has good rail connectivity. Having made these initial points, the following bullet points consider the performance of the alternatives in respect of each of the key sustainability objectives:  Housing - extension of the GB naturally leads to tensions, although significant concerns are not raised, given good potential to compensate through increased housing delivery within other parts of the Borough.  Land use - extension of the GB is supported given extensive ‘best and most versatile’ agricultural land, including land that is ‘grade 1’, i.e. highest quality nationally. It is Discussion appropriate to ‘flag’ the possibility of significant positive effects; however, in practice there is no certainty that the baseline situation (Option 1) would lead to significant development and in turn significant loss of best and most versatile agricultural land.  Climate change - extension of the GB is not supported, on the basis that this area is appropriate for housing growth in the sense that there is good rail connectivity.  Natural and heritage assets - extension of the GB is supported, given the presence of five conservation areas in and around this area. Option 4 would secure protection for two or three additional CAs, relative to Option 3, and also Oaken Wood to the south.  Economy - extension of the GB is not supported, on the basis that this area is appropriate for housing growth in the sense that there is good road and rail connectivity. Option 4 is potentially most problematic, given the presence of East Malling Research Station.

AECOM 53