Representation by Kent Downs AONB Unit (Kent Downs AONB Unit)
- Date submitted
- 31 March 2021
- Submitted by
- Non-statutory organisations
While lying some 5.1km from the boundary of the Kent Downs AONB, the scale of the proposal is such that there is potential for the development to impact on the Kent Downs AONB. These impacts could be as a result of inter-visibility, light pollution and increased use of the highways network in the AONB. We welcome the inclusion of an LVIA within the Environment Statement and we are generally in agreement with the proposed methodology set out within this and welcome the inclusion of viewpoints from within the Kent Downs AONB that have been included following engagement with the AONB Unit. We also welcome the inclusion of photomontages within the assessment. The AONB Unit has concerns that the assessed level of impact on views from two of the viewpoints (Nos 41 and 74) may be underassessed, due to an underestimation of the magnitude of change, taking into account the nature and scale of the development. In order to assist with fully understanding the impacts, we would welcome more realistic images be provided in the photomontages, including proposed materials and colours and more accurate representation of the proposed structures as these could all influence the impacts. The AONB Unit also welcomes consideration of night-time effects on the Kent Downs within the ES. However, we have concerns that this has not been adequately assessed. It is advised that it is anticipated that there will be little change to the baseline scenario as a result of the development due to distance and the abundance of lighting in the vicinity of the Project Site. We raise concerns that insufficient detail is available to be able to make this assessment. While we accept that general street lighting would probably not significantly vary the baseline situation to an unacceptable impact, the nature of the proposal and visuals provided within the London Resort website would indicate that there may be more ornamental lighting including lighting of structures, coloured lighting and lighting that would project skywards. This does not appear to be assessed in the Night- time effects study and could introduce elements that would result in more significant impacts that are predicted in the night-time assessment. Inclusion of night-time effects photomontages within the LVIA would assist in understanding potential impacts. The proposal has the potential to increase use of vehicular traffic using the highway network in the AONB, as a result of visitors accessing the site from the south, such as on the A225 Shoreham Road. A significant increase in traffic would impact on tranquillity, which is one of the identified special characteristics of the Kent Downs. Increased use of lower grade roads could also impact on their character, for example as a result of degradation of sunken lanes. We therefore consider that the ES should include an assessment of potential impacts on the highways network within the AONB.