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Dover Heritage Strategy Response

Elementary Admin
By Elementary Admin &
16th August 2012

CPRE Protect Kent has sent detailed comments on Dover District’s draft Heritage Strategy and how it intends to include it in the forthcoming land allocations development plan document. The branch has welcomed the initiative taken by Dover, but we think that the balance in the strategy is skewed too much in favour of using heritage assets to further the Council’s regeneration objectives rather than recognising that assets need to be protected for future generation. Although there are many good examples of where heritage assets have played a central part in regeneration projects, it will not always be the case that the protection and future use of heritage assets will be secured through regeneration proposals.  We have called on the Council to amend the strategy to acknowledge and emphasise that regeneration will only be appropriate where it enhances and not threatens heritage assets. Without this there is the real risk of heritage being seen as an obstacle to be overcome rather than an asset to be embraced.  Our responses in full can be viewed here:

https://archive.cprekent.org.uk/index.php/consultation-responses

  • A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
  • There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
  • There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.

The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:

  • There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
  • A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
  • Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
  • Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.

Concerns about the rush to submit the plan

The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.

As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.

Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.

Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.

The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.

Further information