Policy 3 Landscape and AONB

As acknowledged in the Plan document, over 60% of the district lies within the Kent Downs AONB,
however the policy wording does not appear to be providing the highest level of protection to these
protected landscapes. The policy needs to ensure that designated landscapes are protected and
enhanced with clear criteria or other guidance on what development will or will not be acceptable.

Currently, the policy does not set out clear criteria for appropriate development within or impacting on
the AONB or its setting. Guidelines should be produced to include consideration of the
appropriateness of development in the AONB, including establishing what may constitute major
development, along with suggested enhancement options, in line with the AONB Management plan
and supporting documents. These would greatly aid decision making at the outset.

All strategic site allocations should be informed by a Landscape and Visual Impact Assessment (LVIA)
in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). LVIAs
should also be used to guide large development proposals coming forward. Cross-referencing to
Policy 15 (Design Principles) may also be beneficial to encourage the highest standards of design.

Please note that if protected landscapes could be adversely affected by any preferred option included
within the plan (including site allocations), this would be inconsistent with sustainable development
objectives laid out within this policy (and elsewhere in the local plan e.g. policies 6, 15 and Appendix
6), the AONB Management Plan and national planning policy. We refer to the ‘three tests’ included in
NPPF paragraph 172. All allocations for major development within the AONB need to be robustly
assessed against these three tests. Subject to assessment against the three tests, Natural England
objects to allocations proposing major development in the AONB. Whilst the decision on whether a
proposal constitutes major development is up to the decision maker (and we advise this is included
in local plan policy/guidelines), Natural England currently objects to allocations MX48 (Land at
Pedham Place) and HO371 – 374 & EM17 (Land north and east of Westerham).