DOVER DISTRICT LDF CORE STRATEGY
EXAMINATION IN PUBLIC
DOVER DISTRICT COUNCIL STATEMENT
IN RESPONSE TO HEARING QUESTIONS
RAISED BY THE INSPECTOR
HEARING 2
15 OCTOBER 2009
CONTEXT, OVERALL STRATEGY, SETTLEMENT HIERARCHY
AND POLICY CP1
Question 1
Does the “current picture of the district” (2.2 – 2.68) give an accurate summary of the district?
Is there adequate reference to biodiversity?
Is flood risk overstated as a constraint to development in Sandwich?
Council Response
1.1 The “Current Picture of the District” section provides a rounded and accurate picture of the District. It is
structured to give the reader an appreciation of the features which make the District unique and diverse
and is balanced in that it recognises positive attributes as well as those that cause social, economic or
environmental issues.
1.2 It firstly describes the location of the District and its principal external influences before considering its
range of natural and historic assets. Social aspects are then assessed, followed by economic
performance and transport. Social, economic and environmental conditions vary considerably
throughout the District. The Current Picture reflects this and differences are summarised in paragraphs
2.56 to 2.68 which look separately at the towns of Dover, Deal and Sandwich and the rural area.
1.3 The Council has drawn on the evidence base in order to establish the District‟s Current Picture and
avoids reliance on assertions. Sources of information are generally set out in the Core Strategy and
include national and regional data as well as information from District-wide studies undertaken
specifically to help formulate the Core Strategy, including public opinion surveys. Tables, graphs and
diagrams have been used to help put across the information in a more accessible way.
1.4 Biodiversity – this is considered in the Natural Assets part of the Current Picture, paragraphs 2.9 to
2.15 (especially 2.14) and European designated sites are illustrated on Figure 2.2. More detailed
information on the nature and extent of the District‟s biodiversity can be found in the Kent Habitat
Survey and the Habitat Regulations Assessment (Doc 8/69), as cross-referenced in the Core Strategy.
1.5 Flood risk at Sandwich – paragraph 2.63 and Figure 2.2 set out the position based upon the finding of
the Strategic Flood Risk Assessment (Doc. 18/00). Figure 2.2 shows that, apart from a quadrant to the
south west and a small area to the east, the town is within the flood risk area. Flood Zones With
Climate Change Sheet 3 in the SFRA shows that this area is categorised as flood zone 3a with a small
area of 3b at Sandwich Quay. Zone 3 is the highest category of flood risk and Table 3.2 sets out the
Government‟s current policy approach to development in such areas, which is to generally steer
vulnerable development away from them unless there is a demonstrably exceptional case. In addition,
Rapid Inundation Zone sheet 2 in the SFRA shows the extent of this flood zone that is within the
Maximum Breach and Overtopping Flood Outline associated with a breach of the sea defences
between Sandwich and Deal. The final part of paragraph 4.2.2 in the SFRA sets out the significant
risks in this area. Bearing all this in mind it is not considered that flood risk has been overstated as a
constraint at Sandwich.
1
Question 2
Is the “diagnosis” a thorough and robust summary of the imbalances facing the district?
Is there adequate reference to environmental issues, such as air quality?
Should it include reference to transport?
Is the “fine tuning” approach to Deal and Sandwich justified?
Council Response
2.1 The Diagnosis is structured to ensure that it addresses social, economic and environmental issues and
thereby relates to the main themes of sustainability appraisal. The Government Office has commented
that it considered this to be helpful (LD 8/24). The summary box accompanying paragraph 2.67
summarises the findings in the Current Picture section and also cross-references with the sustainability
issues identified in Table 5 of the Sustainability Appraisal Main Report. In order to make the summary
box succinct it has been necessary to summarise some issues into more generic references but fuller
information and more detailed references can be found in the evidence base and the SA report. The
cross-referencing with the evidence base and the SA should ensure that the summary is thorough and
robust.
2.2 Local environmental stresses are referred to in the penultimate bullet in the Environmental section of
the summary box. Although this is not specified, it does relate to air quality but also to noise,
congestion and severance (as set out in paragraph 2.50) and is an example of generic reference
referred to in the paragraph above. Existing air quality conditions are also described in paragraph 2.23.
2.3 There are two main transport issues; the restraining effect that a historically slow train service has had
on the District and the wider East Kent area, and how to manage growth of strategic traffic using the
International Gateway. These are referred to in paragraphs 2.49 and 2.50 respectively and their effects
are reflected in the first two bullets in the Economic section of the summary box and the penultimate
bullet of the Environmental section.
2.4 There is no evidence to suggest that the issues at Deal and Sandwich are of the same order as at
Dover – or indeed anywhere near that level. The evidence is best summarised in Section 2 of the Core
Strategy itself. In addition, the first survey of public opinion (Doc 10/00 paragraphs 1.74 and 1.75 and
sections 3, 4 and 5) indicated much higher resident satisfaction rates with Deal and Sandwich town
centres compared with Dover. None of this should be taken to suggest that Deal and Sandwich have
no substantial issues but it does indicate that their issues are of a significantly lower order. The Core
Strategy has referred to the resultant policy approach as “fine tuning” to differentiate it from the
transformational approach taken towards Dover. This is also reflected in the outcomes of the Council‟s
issues and options work (LD 8/04 Action on Identified Priorities section).
2
Question 3
The Strategy
Is the selection of Option 4, High Growth, justified?
Does it take full account of environmental considerations?
What is the justification for going beyond the level of growth required for Growth Point status?
Does the strategy include sufficient flexibility to enable a high level of growth to be delivered in
the light of changing economic circumstances?
Should the strategy’s Key features include reference to biodiversity?
Is the focus on Dover justified?
Is the proposed urban expansion capable of delivering the desired regeneration?
Has the effect of the focus on Dover on the rest of the district area been assessed?
Should the district objectives place more emphasis on the aims (vision) for Sandwich as a
historic centre and location for employment, golf and a local service centre?
Council Response
3.1 The Council is firmly of the view that Option 4 is the most appropriate growth option. Throughout the
production of the Strategy, the Council has tested four alternative growth Options. The Sustainability
Appraisal (Doc. 8/59A) concluded that Options 1 and 2 were unlikely to tackle the District‟s issues and
that the choice therefore feel between Options 3 and 4. Overall the SA found that Option 4 was most
appropriate although it may well carry beyond 2026 for full implementation. The Business
Development Strategy (Doc. 20/00) considered the relationship between housing growth, employment
projections and labour supply and found that Options 1, 2 and 3 were not adequate to support the local
economy (Section 9 and in particular graphs 9.3 and 9.4 and paragraph 9.4).
3.2 The SA comes to conclusions on this in section 6.2, which also refers to the SA‟s identification that the
higher level of growth is associated with greater negative impacts on some sustainability objectives.
The SA does, however, also note that the Council has embedded strong mitigation measures into the
Strategy (paragraphs 6.2.7 and 6.2.8) in order to counter these impacts. The Final Comments in the
SA (paragraphs 6.2.18 and 6.2.19) reinforce these points and conclude that the Strategy shows many
aspects of good planning.
3.3 Apart from the issues identified in the evidence base and the findings of the SA, the justification for
developing a Strategy that goes beyond the level of growth required for Growth Point is summarised in
the box in paragraph 3.5 in the Core strategy. The reference in the first bullet point relates to
paragraphs 4.14 and 4.15 in PPS12 and the Government Office in its letter on the Core Strategy (see
Doc 8/24 page 2) appeared content with the flexibility that this introduces. In addition, the Policy H2ii of
the South East Plan (Doc. 11/00) requires LPAs to consider “ability to accelerate the rate of housing
delivery in Growth Areas and New Growth Points”. Explanatory paragraph 7.7 elaborates, “Local
authorities can test higher (housing) numbers through their development plan documents provided that
they are consistent with the principles of sustainable development set out in PPS1 and tested through
sustainability appraisal and Habitats Regulations Assessment.” The Council has tested high growth
throughout the process and the Core Strategy is consistent with both PPS12 and the South East Plan.
This approach provides flexibility to deliver more than 10,100 homes by 2026 should circumstances
permit, as set out in the last bullet in the box in paragraph 3.5. While economic conditions are currently
in downturn/recession the Strategy is a 20 year plus plan and needs to build-in the ability to respond
quickly to take maximum advantage of recovery and any other future cyclical variations.
3.4 With regard to biodiversity, the Strategy‟s Key Features (third to last bullet) include reference to green
infrastructure, which itself includes biodiversity as more fully set out in point 9 of the preceding District
Objectives. The use of the term “green infrastructure” was not intended to diminish the importance of
biodiversity but was employed simply for brevity.
3.5 The main focus of the Core Strategy is on the town of Dover. Dover is the District‟s dynamo but is also
at the centre of the issues that need to be addressed. This is entirely consistent with, and justified by,
the South East Plan, East Kent and Ashford Sub-Regional Strategy. Policy EKA4vii refers to Deal as a
3
smaller town which should develop its local service functions and part v of the Policy refers only to
business growth at Sandwich, rather than growth of the town as a whole. In contrast, Dover is
recognised as a Growth Point and Secondary Regional Centre in the Table accompanying paragraph
4.11. The Table identifies Dover as an “area for economic growth and regeneration, and housing
development.” The Key Diagram also identifies Dover as a Regional Hub to which Policy SP2 applies
– see in particular parts iii, iv and v. Dover is also featured in Policies EKA1ii (and related paragraph
18.9), EKA4ii and iv, EKA6. The national and regional policy context, combined with the local
evidence base, justify the Core Strategy‟s focus on Dover. Indeed, if the Core Strategy did not take
this focus it would not be consistent with national and regional policy.
3.6 The urban expansion at Whitfield is intended to make a major contribution to increasing and
broadening Dover‟s housing offer with a particular focus on providing a range of housing that would
attract people, especially families and those of a working age, to move into the District (see Core
Strategy paragraphs 4.2 and 4.58). In doing this it also has an important role in enabling the town‟s
population to increase in order to help support a better range of town centre services (see South East
Plan paragraph 18.9) and maintain an adequate labour supply for the major areas of employment
growth, which are at Dover. This would also help to reduce commuting. The scale of development
proposed and level of interest from the development industry indicate that the proposal is quite capable
of meeting these regeneration objectives. The Strategy recognises that the proposal has risks (see
second bullet point to paragraph 4.55) but the Council believes that these are quite capable of being
managed through both the context set by the proposed next stage of masterplanning and the terms of
any subsequent planning permission, and through the proposed process of programme management
set out in the Strategy‟s Delivery Framework chapter.
3.7 The effect of the Strategy‟s focus on Dover for the rest of the District has been assessed in the
Sustainability Appraisal. Firstly, though it should be borne in mind that the Strategy has been
developed as a proportionate response to the issues identified in the evidence base for each major part
of the District, also taking account of environmental constraints. Alternatives to a focus on Dover were
considered in the Settlement Review and Hierarchy (Doc. 8/48 paragraphs 3.1 to 3.27). The District
Objectives reflect the Strategy‟s focus on Dover and the approach towards other parts of the District.
These were tested against the Sustainability Appraisal objectives in sections 5.1 and 5.2 of the SA
Main Report. The SA did not find any significant weaknesses in this approach and, indeed, found that
it scored positively in many respects (Table 12 items 1, 2 and 4 in particular).
3.8 With regard to how Sandwich is reflected in the District Objectives, the Council has proposed a change
to Objective 4 to refer to employment (Doc. 8/72). While it would be possible to expand this to refer to
the historic centre, location for golf and as a local service centre the Council would be concerned that
such emphasis on Sandwich would unbalance the references to Deal that are in the same Objective. If
there are benefits in expanding the Objective it is suggested that references to the promotion of golf
and of local service centre functions could apply to both Deal and Sandwich. Any such references
should also be cognizant of the constraints (access, flood risk, biodiversity, hydrological) that apply to
the area to the Local Centres.
4
Question 4
CP1 and the Settlement Hierarchy (SH)
Has the need for distinguishing between Rural Service Centre and Local Centre been justified?
Is the SH definition of the settlements of Worth and Coldred justified and supported by robust
evidence in Library Documents 8/48 and 8/49?
Does paragraph 3.12 as revised (Library Document 8/72) provide a clear indication of how the
settlement hierarchy will be operated? Should this explanation be included in the policy?
Council Response
4.1 The wider role of Sandwich in the rural area was recognised in the now defunct Structure Plan, in
which it was the District‟s only rural settlement to be designated as a Rural Service Centre (see Doc.
8/48 paragraphs 3.28 and 3.33). Aylesham is the next largest rural settlement in the District with a
considerable range of facilities and transport connections (Doc 8/48 Appendix 2). Furthermore,
Aylesham was identified as a Strategic Development Location in the Structure Plan which was carried
through into what are now saved District Local Plan policies for a major expansion allied to an
improvement to its services and facilities. Both Sandwich and Aylesham (as proposed) have a higher
order range of services, and therefore function, than the District‟s other large rural settlements. These
distinctions are described in paragraphs 3.94 to 3.96 of Doc. 8/48 and justify a different policy
approach.
4.2 The definition of a „village‟ in the Core Strategy states:
„Tertiary focus for development in the rural area; suitable for a scale of development that would
reinforce its role as a provider of services to essentially its home community. It should provide primary
education facilities, community recreation area, at least one shop and be accessible by a bus or train
service’.
4.3 At the time the background survey work was completed (June/July 2007), Worth met these criteria.
Since that time the shop has unfortunately closed and now the settlement falls one criterion short of
the definition.
4.4 This, however, raises a grey area when considering what role settlements play in the hierarchy. Some
settlements play a wider role than others and it is not simply a matter of adding up the number of
facilities. This issue is discussed further in the Council‟s response to Hearing 4, Question 12 (see
paragraph 12.4).
4.5 Settlements that are considered suitable for a „village‟ designation but do not fully meet the prescribed
four criteria are; Ringwould; Alkham; West Hougham; Staple, Ripple and East Langdon. It is because
of this issue that the Council, when writing the Policy, use the word „should‟ rather than words such as
„must‟ or „will‟.
4.6 Those settlements that were designated as „Hamlets‟, fell short of this provision and, at most, only met
one or two of the criteria. For example, Tilmanstone, the largest of the „Hamlets‟ (120 dwellings), met
one criterion, as it is served by an hourly bus route but it does not have a shop or school, and so would
be unsuitable for further development. Another example is that of Northbourne, which meets most of
the criteria but is of a very small size (68 dwellings) and it is located in a rural area away from the
primary road network and so would not be suitable for further development.
4.7 Worth is a larger settlement (250 dwellings, including residential areas attached to the settlement) with
a school, a recreation ground and a good bus service. Whilst the settlement has lost the shop, this
should not mean it would not automatically fall into the lower designation of a Hamlet. As
demonstrated above, there are specific reasons why certain settlements are designated as Hamlets
and these would not apply to Worth. The Council‟s approach is thus robust but pragmatic and flexible
and has regard to particular circumstances.
5
4.8 Coldred does not feature in Doc. 4/48 because it falls below the cut-off point of the survey.
Notwithstanding this, the Addresspoint system indicates that there are approximately 50 homes at the
settlement and a visual inspection in September 2009 revealed that it was only served by a public
house, a church and an infrequent bus service (the 88a service, which runs four times a day to Dover,
Sandwich and Ramsgate). In view of the small size and level of services the Council believes that it
was correct in identifying Coldred as a hamlet and that it did not need to feature in Appendix 2 to Doc
4/48.
4.9 It is considered that the proposed change to paragraph 3.12 does improve clarity of how the Policy
CP1 Settlement Hierarchy will be operated in that it makes it clearer that the policy informs plan
making, as well as development management and infrastructure investment decisions. If this proposed
change is found to be acceptable it would be consistent to reflect it in the Policy itself.
6
Question 5
Key Diagram
Does the key diagram provide a clear illustration of the strategy with regard to:
1) settlement hierarchy
2) spatial issues for Dover/ Deal/ Sandwich
3) movement flows
4) geographical setting/ cross boundary issues?
Council Response
5.1 The Council appreciates that the A4 format of the Key Diagram does make it difficult to distinguish
some of its features and is considering whether an A3 size diagram would overcome these difficulties.
It may also assist if it were made clear that Figures 3.3, 3.4 and 3.5 are intended to be insets to the Key
Diagram. The movement flows and geographic setting/cross boundary issues illustrated on Figures 2.2
and 3.1 were intended as scene setting information, rather than forming the basis of proposals that
should be illustrated on the Key Diagram.
7