Kent County Council Unsupportive of Shepway’s Proposals

Kent County Council are surprisingly unsupportive of Shepway’s proposals for Princes Parade . Here are their comments from the recent local plan consultation:

Heritage: We have substantial concerns about the allocation of the site at Princes Parade for development and with the wording of Policy UA25. The policy as worded needs to express a better understanding of the contribution that the site makes to the significance of the Scheduled Monument of the Royal Military Canal and we are concerned that it would not be possible to deliver a development on the site of the type described whilst meeting the requirements of the policy.

Understanding the contribution that the site makes to the significance of the Royal Military Canal The site lies adjacent to the far eastern end of the Royal Military Canal on its seaward side. The Royal Military Canal is of national importance and is designated as a Scheduled Monument. It is a unique fortification, built as part of part a system of fortifications in the area to defend against invasion by Napoleonic France. The eastern connection of the canal to the sea was particularly well defended in association with other batteries, redoubts and Martello towers (all also Scheduled).

We feel that mixed-use development here of the type described in Policy UA25 could cause very great harm to the significance of the Scheduled Royal Military Canal by change in its setting. The openness between the canal and the coast is especially important in telling the story of the canal, its purpose and its specific design. This is because the canal was designed to protect against invasion from the sea. As such the seaward setting of the canal makes a substantial contribution to its significance.

We would note that the adjacent site, known as Hotel Imperial Golf Course land, Hythe was assessed as part of the SHLAA exercise where it was noted that the “open character of the site forms part of the setting to this scheduled monument and its loss to development would be highly detrimental” and was rejected partly on the basis that the “land is considered important for the setting of the scheduled monument”. We would suggest that the same issues similarly apply to the present site. Comments on the proposed policy wording Policy UA25 sets out five criteria whereby development will be supported. Criteria 2 and 3 are intended to address issues relating to the historic environment: Criterion 2 requires that “key features of the Royal Military Canal and its setting, which contribute to its significance as a Scheduled Monument would be preserved and enhanced”. Whilst the site has been subject to land-raising in the past, the present open and undeveloped nature of the site is, in our view, a key feature that contributes to the significance of the Scheduled Monument. We feel that this openness is intrinsic to the setting of the scheduled monument. We welcome the requirements set-out in Criteria 2 to preserve and enhance those key features of the canal and its setting that contribute to the monument’s significance. We cannot however presently foresee a way in which the level of development proposed within this policy can be accommodated at the site whilst also ensuring that the monument’s setting is preserved and enhanced.

In essence, development within the setting of the canal, even if the harmful effects of such development are minimized, cannot preserve the setting of the canal, which we feel is a key feature that makes an important contribution to the monument’s significance.

Criterion 3 requires that “any less than substantial harm is clearly and convincingly demonstrated to be outweighed by the public benefits of the proposal, which should include heritage benefits”. We would see such public benefits as being ones that fulfill one or more of the objectives of sustainable development as set out in the NPPF, provided the benefits will be for the wider community and not just for private individuals or companies. We would suggest that the specific heritage benefits should be clearly identified and should be meaningful, deliverable and be based on a proper understanding of the monument’s significance.

The NPPF however requires more than a simple balancing exercise. It requires (para 133) both that the harm is necessary to achieve the public benefits and that these outweigh the harm or loss. In other words the public benefits would be reliant on the delivery of the development and could not be achieved through other means or that the same benefits could not be delivered elsewhere. In this instance we feel that the potential for harm to the significance of the Royal Military Canal would be very great and remain unconvinced that sufficient benefits could be delivered or have yet been identified to outweigh this very great harm.

The provision of a new swimming pool and leisure facility is one suggested benefit, but accommodating such a building on the site without causing great harm to the setting of the canal would appear problematic. Another such benefit would be the contribution that the site would make to the district’s housing requirement; however we feel that there are wider opportunities and alternative sites for development which would be preferred.

PROW: Public Bridleway HB83 would be directly affected by this development. This development should deliver improvements to the Public Bridleway alongside the canal on the south side to enhance the amenity vale of this resource. In order to secure the future protection of public access in this area, it is advised that the policy specifies that that at least two links between the canal crossings and princes parade are dedicated as Public Footpaths or Bridleways.

Japanese Knotweed

The integrity of the Leader of the Council and his Cabinet will be put to the ultimate test on Tuesday when they have to decide whether to ignore evidence of the presence of Japanese Knotweed. To be fair to the current officers, they were clearly unaware that Princes Parade was infested with this highly invasive weed in 2009 . The evidence for this arises from a legally sworn Statutory Declaration by the council’s own site manager. Even treatment with Glyphosate would only knock it back to a dormant state and this could be a significant impediment to development on Princes Parade. This is just one of the many risks associated with developing Princes Parade which have not been mentioned in the agenda papers for Tuesday’s cabinet meeting.

Kent County Council Elections

As you may be aware there will be Kent County Council elections on May 4th this year. These elections won’t have a direct impact on Princes Parade as that is a Shepway District Council issue but we believe that several Shepway DC councillors and cabinet members (including David Monk) will be standing for election on May 4th. (Susan Carey who is a Shepway cabinet member is already a KCC councillor and will no doubt be standing for re election.). Save Princes Parade is not political and we aren’t going to tell you who to vote for but do we really want to give these people more power after what they are trying to do to Princes Parade? If you are not registered to vote you can register here: https://www.gov.uk/register-to-vote. We need better and more transparent decision making at all levels of local government.

Make a Lot of Noise to Save Princes Parade

We know lots of people are quietly supporting us but with the submission of planning application due for discussion at cabinet on 7 February we need you all to start making a lot more noise – letters to the local press, emails to David Monk and the other Shepway cabinet members and a lot more posters in windows etc. We know we’re not a minority but we need to convince David Monk. Contact details for the cabinet on our website here: https://saveprincesparade.co.uk/who-to-write-to/ and a poster you can print off here: https://saveprincesparade.co.uk/poster/

Cabinet Meeting 7 February

Just had notification that the decision to submit the planning application for Princes Parade will discussed at the cabinet meeting on 7 February. Please put the date in your diaries – cabinet meetings are usually at the very inconvenient time of 5pm

Historic England Comments

Historic England is of the view that this site should not be allocated for significant new development in the draft local plan, and that it should remain as largely open green space as per the last Local Plan inquiry and the decision by the Inspector. This may allow for modest development envisaged in the last Local Plan site specific policy for this site.Full details here : https://saveprincesparade.co.uk/english-heritage/

Survey on Princes Parade

Shepway have just sent out this press release – it’s not clear why they are still doing this sort of work when the public exhibitions will take place on 29th & 30th November.

Parts of Princes Parade will be cleared next week (Monday 28 November) ahead of a survey to find out how the land lies.The topographic survey, commissioned by land owners, Shepway District Council, will show where the land rises and falls and by how much, and map the position of different features like trees, vegetation and paths. The results will be used to assist the masterplanning for the site.Because the site is overgrown, Shepway District Council staff will be cutting back an area around the proposed recreation centre and creating narrow strips across site so that the surveyors can carry out their work.The survey is being carried out by local company J C White.The ground work and the survey are likely to take three weeks to complete

Demo 3 December 10.30 am

There will be a mass demo against all the unwanted developments in the district on Sat 3 December. Meet at the Civic Centre in Folkestone at 10.30 am ready to march through the town. Bring Save Princes Parade banners etc and be prepared to make a lot of noise.