In the third part of her article on the Dover District Local Plan Sarah Waite-Gleave examines how developers care, or fail to care for the natural environment
This the last of a series of three pieces on Dover district Local Plan and the Dover and Deal Green Party work in 2021, 2022, and in December 2023 at the public hearings in the DDC council chamber. Part One was on how planning processes function; part two was on the push to get really affordable homes in the right place, within Dover town. In this last piece, the focus is on the need for independent, honest auditing of developers’ promises to protect the natural environment; and protections for local road users. The story of the improvements we asked for doesn’t imply that our suggestions will be heeded!
Robust protection of nature
We told the planning inspectors of the KCC report ‘Natural Solutions to Climate Change in Kent’ of March 2021, paid for from the public purse, on the need for Kent and our district’s chalk grasslands, wetlands, and woodlands to be retained and enhanced. We said the report should be adopted as a planning guideline. Because these places are our flood sponges, and our carbon-capturing, habitat-providing natural capital.
Strengthen the policy on tree preservation
Vague promises ‘to facilitate tree planting and protection where possible’ are a very inadequate response, because replacing existing trees with trees that will only start their carbon capture career in 2040 will not allow the UK or Kent to meet its climate change targets. Deal residents have seen, on a large Persimmon building site prior to 2022, the death of hundreds of young trees, because the developer failed to plant professionally or to care for the trees after planting. What reactions will greet the news that Persimmon are in talks to become one of four big developers, taking on contracts to build-out the Whitfield urban expansion.
On tree protections, we said DDC policy wording should be strengthened, that an additional policy should be included:
Existing trees which are capturing carbon in this decade 2020–2030 and the next 2030–2040, must be protected, as pockets of retained amenity woodland within building sites. DDC will accelerate the rate of making Tree Preservation Orders and Woodland Preservation Orders and provide appropriate staffing and resources to sustainably and effectively deliver this policy. Honest, independent evidence from an arboriculturalist will be required if felling is requested on grounds of tree disease.
Experience has caused trust in the planning process to expire in the minds of many of the public. Without independent, robust auditing, extracting promises from developers all too often results merely in employment for public relations professionals, greenwash’ paid by developers.
So, an addition is needed for the Plan to become sound:
Where permission is given subject to conditions regarding tree retention, tree planting and / or biodiversity enhancement, applicants will need to agree to abide by ‘robust auditing’ (as Wildlife Trusts insisted that the Environmental Bill legislate for). This means that honest, objective, before-and-after evaluations / baseline measurements must be used.
DDC councillors on the planning committee have in recent years pointed out how very inadequate and misleading the sketchy, google-map-based ecology reports paid for by developer applicants are. . A case of, ‘he who pays the piper calls the tune’. We suggested therefore, DDC needed a DM policy requiring ‘Environmental Impact Assessments on all planning applications for developments of over 15 dwellings on greenfield or rewilded brownfield sites.’
More details of the improvements suggested by Dover district local Green Party are in this link: https://doveranddeal.greenparty.org.uk/better-cheaper-homes-in-dover-town-and-a-better-ddc-local-plan-please/
Limitations of Kent Highway assessment for DDC Plan.
The selection of a Kingsdown site, we suggested was dangerous. The Deal / Walmer conurbation of 30,000 depends on the A258 between Dover and Walmer / Deal. When it is blocked, the narrow (single lane in places) Ringwould road, carries diverted traffic every time A258 is blocked by an accident or by road works. The Highways assessment in the Local Plan evidence base showed no awareness of the strategic importance of the Ringwould Road as part of the transport infrastructure of the whole district. Diverted traffic is a nightmare for the village.
Again, the Highways assessment showed no awareness of another narrow road to the north of Kingsdown on the diversion route, along Glen Rd/ Liverpool road in Walmer, with another building site planned, which, if developed, would again mean diverted traffic could not get in / out of Deal / Walmer urban area of 30,000 inhabitants.
Local residents working for emergency services said they opposed both developments for this reason. And the enormous difficulties within Dover district of making local roads safe for the 40% of the district population who live in villages, in a district with poor national road infrastructure, on routes of the highest national importance, were difficulties referred to in the local hearings time and time again by public-minded people of different parishes.
Residents and local parish councils should tussle with the planning language, and scrutinise the work of their planning departments, in the pubolic interest. . The Dover and Deal Green Party (with its ten town councillors) was the only local political party to do so in the Dover district. A number of parish councils spoke up clearly, including Nonington PC who commissioned a professional report of their own.
We, the public, should check the accuracy of highways assessments, habitat assessments, viability assessments, because mistakes can be found. We can ask for corrections and make constructive recommendations. Local planning authorities can look at National Planning Policy Framework (NPPF) and require higher standards. We, the public, should ask for this. In the interests of our national food security, I pointed out that the NPPF requirement to protect ‘best and most versatile farmland’ is very limiting and our Plan should protect Dover’s ‘good and versatile farmland’, especially all of our horticultural land and orchards. And the same is true elsewhere in Kent.
Help is available for us busy, non-planning professionals. For example, help is available, if we look at the work of CPRE (Campaign for Protection of Rural England) Kent. Also the report ‘Permission accomplished’, from Transparency International UK on our planning processes. Examples of other recommendations made by Dover and Deal Green Party on the DDC Local Plan can be found in the attached PDF.
If unhappy with the planning system we can work to change it. There are opportunities for level 1 parish councils to work together, e.g. with KALC (Kent Association of Local Councils). There’s the Community Planning Alliance, and Channel 4’s programme on the Great Climate Fight with Kevin McCloud Dec 2023. For the longer term, we, the greens, work with other parties to get a proportional voting system which will help us change national government and get these priority planning policies implemented throughout the country.