demountable/moveable beach huts on part of the private beach …€¦ · 14-03-2013 · the beach...
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� � Correspondence Address Kingsdown Conservation Group
c/o The Gate House Upper Street
Kingsdown CT14 8EU
Tel:�01304 366628 Email: [email protected] Website: www.kingsdownconservation.org.uk
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Ms Sarah Platts,
Senior Planning Officer,
Dover District Council,
White Cliffs Business Park,
Dover,
Kent.
CT16 3PJ 14th
March 2013
Dear Ms Platts
Planning Application DOV / 12 / 01016 - Application to install
demountable/moveable beach huts on part of the private beach along
Undercliff Road, Kingsdown on behalf of Tingdene Holiday Parks Ltd
This document is the formal objection to the above Application by the Kingsdown
Conservation Group (KCG). It takes full account of planning laws and policies, and
rebuts the majority of the claims made by the applicant's planning agent.
The document has been written by Nick Harper and Philip Evemy on behalf of the
residents of Kingsdown and those from further afield who share their love of this
seaside village and their deep concern at the threats posed by the Application.
Some 265 residents of Kingsdown and further afield have objected to the
Application on Dover District Council's planning portal, and more than 650 people
from around the world have signed a petition objecting to the proposals.
Copies of objection statements by some of the statutory consultees and photographs
are appended to this document. Other objections can be seen by visiting the
planning portal on DDC's website.
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Summary of KCG Objections to the Application
• It fails to fulfill Sustainable Development, as defined in Central
Government's National Planning Policy Framework 2012, and 'embedded'
in Dover District Council's (DDC) Local Development Framework Core
Strategy 2010.
• It does not meet the stringent requirements of: BIODIVERSITY – Duty of
Regard NERC 2006 -Section 40.
• It fails to satisfy other planning policies adopted by DDC's Local
Development Framework Core Strategy 2010
• It has no social, environmental, or economic merit and it threatens tourism.
• Claims made in the Application to adhere to The National Planning Policy
Framework and Dover District Council's Core Strategy 2010 have been
rejected unequivocally by The National Trust, by Kingsdown Conservation
Group (in this document) and by many other objectors.
• Under the provisions of Article 10 of the Town and Country Planning
(General Development Procedure) Order 1995 and Section 28 of the Wildlife
and Countryside Act 1981 (as amended), and using its statutory power to
ensure that the natural environment is conserved, enhanced and managed for
the benefit of present and future generations, Natural England has objected
to the development on the grounds that is likely to damage or destroy the
interest features of the SSSI on which the proposed 'huts' would be placed.
• The Kent Downs AONB Unit has opposed the Application because it
would ignore policies set out in The Kent Downs AONB Management Plan
which DDC has adopted, and refers to, in its Core Strategy - paragraph 1.57.
It also ignores policies covered by the KD Landscape Design Handbook.
• To justify its validity, the applicant's planning agent has used an Ecological
Appraisal report produced four years ago when the area and defensive
integrity of the shingle bank was entirely different from that which exists
today.
• The Application documents display lack of due diligence. They are
endlessly repetitive and also contradictory.
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The National Planning Policy Framework and DDC
Core Strategy
Tingdene's proposal is to place 12 'huts' on the Kingsdown Beach SSSI, which is
immediately overlooked by an AONB and Kingsdown Conservation area.
The Beach is the natural habitat of rare flora and fauna which are protected by
various pan-European organizations and laws which, if broken, are punishable by
fines and imprisonment.
The National Planning Policy Framework (NPPF) directs:
To achieve sustainable development - economic, social and environmental
gains should be sought jointly and simultaneously through the planning
system. There is no requirement that economic, social and environmental
gains should be balanced, though net gains should be sought across all
three, and significant adverse impacts on ANY of these dimensions should
be avoided.
There will be significant adverse impact socially if the Application is granted.
Kingsdown Parish Council, the local community and tourists from as far afield as
Canada, Pakistan and Australia have together registered in excess of 650 objections
with DDC Planning.
The claimed economic gain does not stand up to scrutiny. Twelve existing owners
of holiday chalets, or their guests, will have exclusive use of the proposed 'huts' and
are thus already accounted for in the local tourist economy. Shopkeepers in
Kingsdown village say they will derive no economic benefit from the development.
There is no evidence of what the part-time employee referred to will do - apart,
possibly, from clearing rubbish off the beach and warning occupants of the 'huts'
about sleeping overnight.
By contrast, there will be a reduction in the number of tourists visiting
Kingsdown Beach because its natural and 'wild' characteristics will be radically
changed.
In this context, the creation of one part-time job is irrelevant.
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Whilst there is a presumption in favour of Sustainable Development, the NPPF
makes it explicitly clear:
The presumption in favour of sustainable development cannot override
designations and policies that otherwise restrict development.
Examples of these restrictions are: ‘sites protected under the Birds and Habitats
Directives, SSSIs, Green Belt, Local Green Space, AONBs, Heritage Coast,
National Parks, the Broads Authority, designated heritage assets, and locations at
risk of flooding or coastal erosion’.
Kingsdown Beach comes under not one, but five of these protected sites. Therefore
the Application does not conform to any of the strategic objectives contained in the
NPPF's definition of ‘sustainable development’ nor does it embrace the
‘sustainability’ embedded in DDC's LDF Core Strategy.
The Application Letter - 21/12/2012
Addressed directly to Mike Ebbs, Planning Development Manager at DDC, its
heading includes: Town and Country Planning Act 1990.
The inference here is that the Application conforms to this Act when – as
subsequent examination will show – it clearly does not.
The letter presents detailed but misleading ‘facts’ to support the proposal to place
‘huts’ onto the SSSI, quoting numerous reference numbers and objectives set out in
DDC’s Core Strategy, as follows:
i) Kingsdown Beach may well ‘require considerable investment in terms of
maintenance and conservation’
In fact, any conservation work is funded by DDC, or local residents in the form of
beach cleaning, not by the applicant.
No such expenditure (apart from the rates) appears in Tingdene’s accounts. Neither
is it ‘funded by service charge contributions made by chalet owners at the holiday
park’ and this has been confirmed in writing by chalet owners.
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ii) If the applicant genuinely ‘takes its environmental protection responsibilities
seriously and respects the beautiful setting of Kingsdown Beach’ it would not have
made this Application in the first place. At the very least it would have sought a
licence from Natural England – which it is obliged to do by law – before
submitting it.
iii) The ‘Ecological appraisal report from a reputable specialist Bramley
Associates’ does not share Tingdene’s ‘confidence that the ‘huts' can be
accommodated… having due regard to environmental issues’.
On the contrary, Bramley Associates’ecological appraisal lists numerous caveats
regarding necessary safeguards to minimize damage to the fabric of the beach –
none of which can be practically enforced. As Natural England have confirmed, all
of the SSSI is one eco-system. The ‘bare’ shingle and the ‘vegetated shingle’ are
interdependent and necessary to support the protected flora and fauna. They cannot
be separated.
As for the ‘management programme’ envisaged by Bramley Associates, when they
wrote their report four years ago they were clearly unaware of the Kingsdown and
Walmer Beach Management Plan being drawn up by The White Cliffs Countryside
Partnership. This plan was commissioned and funded by Dover District Council.
On page 25, it warns "Adding any more beach huts to the existing ones would
not be recommended as this would increase the risk of trampling and remove
valuable habitat."
Because the Bramley Associates report was written some four years ago, the
Application takes no account of the fact that the shingle beach along the SSSI at
Kingsdown has changed considerably since then. On page 19 of the Kingsdown
and Walmer Beach Management Plan there is a clear reference to this change. It
states" It is currently estimated that the beach at Kingsdown loses approximately
18,000 cubic metres of shingle annually (This information is taken from the Deal to
Kingsdown Coastal Defences Coastal Strategy 2000 - 2005, Strategy Report,
submitted by WS Atkins Consultants Ltd)."
On March 12 2013 - just this week - the sea defences at Kingsdown beach have
been very seriously breached. Huge concrete walls have been pushed over,
steel girders buckled and vast quantities of shingle have been washed away
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By using the Bramley report, the applicant has clearly neglected to check the
current state not only of the area of shingle but also its ability to resist potential
flooding. This fact alone should illustrate how seriously the applicant has
failed to present accurate and safe information.
The resulting threat to the applicant's ability to quickly remove the huts from
danger are obvious. However, the shingle area which has been lost since the
Bramley report was written also makes it impossible for the ‘huts' to be placed in a
location which will be big enough to accommodate them.
iv)‘The huts will be moved back from the tideline in the winter months so the beach
can be rested outside the holiday season, thereby ensuring its sustainability and
protecting its ecology and biodiversity.’
This clearly illustrates a profound ignorance of the ecology and biodiversity of this
beach.
v) The ‘bespoke design’ of the 'hut' confirms that it is no more or less than a hybrid
chalet / mobile home and nothing like a traditional beach hut.
vi) To enhance credibility, the paragraph on Tourism quotes PPS4: Planning for
Sustainable Growth:
‘Local planning authorities should support sustainable rural tourism that benefits
rural businesses, communities and visitors, which utilizes and enriches rather than
harms the character of the countryside and should support extensions to existing
tourist accommodation… to ensure the future viability of such businesses.’
Twelve 'huts’ on Kingsdown Beach will NOT provide increased accommodation
for tourism, There will be LESS, as existing tourists and visitors, seeing that the
'wild' character of Kingsdown Beach has been replaced by the development of a
'mobile home' environment, will go elsewhere. Nor will the ‘huts’ provide wider
economic development in the Dover District area. The only beneficiaries will be
Tingdene and 12 existing chalet owners or their guests. There will be no net gain
for other local businesses.
To suggest that the’ huts’ will ‘utilize and enrich the character of the countryside’
(so as to conform to PPS4) is palpably untrue. Clearly and indisputably they will
actively harm it.
vii) The claim that ‘this application does not contravene any local, county or
regional planning policies and is well founded in planning law and the LDF’ is
inaccurate and misleading.
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Various planning policies are listed to support the Application – all of which, on
closer examination, are contradicted:
CS Policy DM1 & CS Policy DM3
The ‘huts’ represent development on land that is outside the urban boundaries and
rural settlement confines. As such it would not normally be permitted. However,
‘functionality’ and ‘ancilliary to existing use’ (chalets at the holiday camp) are
misleading. The 'huts' on the beach represent an entirely new development.
Furthermore, it is a contrivance to suggest that an application for 12 'huts' on a
protected SSSI beach is supported by, or meets the objectives of, Development
Management Policy DM3 for Commercial Buildings in the Rural Area.
CS Policy DM13
It would be encouraging if chalet owners walked to the beach. There is already
insufficient parking space on any sunny day, irrespective of the season. In the
summer, cars line Undercliffe Road and the parking area in front of the The
Zetland Arms. They also attempt to overpark on North and South Road. The lay-
by referred to usually has one or two camper vans parked on it for days, leaving
space for perhaps three other cars.
Parking is anything but design-led and does not meet the criteria set out by DDC in
DM13.
CS Policy DM15
The necessary constraints imposed by DM15 to ensure protection of the
countryside (in this instance an SSSI immediately overlooked by an AONB and
Conservation Area) are dismissed as follows: ‘Beach huts are a traditional feature
of the English seaside’.
These are not by any stretch of the imagination traditional beach huts.
’And we do not believe this proposal will not (sic) adversely affect the character of
the countryside in any way at all.’
The Kent Downs AONB, the National Trust and Natural England categorically
state that the proposal can only have an adverse affect. Nor are any of the five
special conditions set out in DM15 permitting ‘loss of or adversely affecting the
character or appearance of the countryside’ cited to support the application.
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SEP Policy TSR5
Tingdene designate Kingsdown Beach, an SSSI, as ‘an un-serviced tourist facility’
without working toilets. They say this can be rectified by their ‘taking over disused
public toilets on Undercliffe Road’.
These facilities are already owned by DDC, managed by the Parish Council and
paid for via the precept. They are open throughout the summer months.
There is NO ‘existing un-serviced accommodation on Kingsdown Beach for DDC’s
planning department to facilitate the upgrading and enhancement of’.
The application for 'huts' on the beach therefore has nothing whatsoever to do with
SEP Policy TSR5.
SEP Policy CC1 & SEP Policy CC6
The Application does not fulfil even one of the three elements integral to
Sustainability.
To assert that putting 'huts' onto Kingsdown beach will ‘maximise the use of
existing facilities and resources whilst protecting and respecting the environment’
is clearly untrue. It will put them at risk.
Nor, by any stretch of the imagination, will these 'huts' ‘actively promote the
creation of a sustainable and distinctive community’.
PPS1
The exact opposite of the applicant's assertions under PPS1 is true:
‘The proposal is intrinsically UNSUSTAINABLE development which does NOT
balance the needs between economic, social and environmental consideration’.
Good Practice Guide on Planning for Tourism 2006
The Application claims to: ‘maximise the use of existing facilities and resources in
a sensitive and appropriate manner.’
KCG asserts that, on the contrary, it is socially insensitive, environmentally
inappropriate and economically insignificant.
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Tingdene Application Form to DDC
Tingdene’s Application for Planning Permission Town and Country Planning Act
1990 paperwork dated 21st December 2012 contains the following inaccuracies:
Biodiversity and Geological Conservation
a) Protected and priority species
b) Designated sites, important habitats or other biodiversity features.
c) Features of geological conservation importance
It is not a simple oversight to tick the boxes which indicate: Yes, on land adjacent
to or near the proposed development. It is deliberate misrepresentation to suggest
that an SSSI can be divided into ‘go’ and ‘no-go’ areas to suit the commercial
aspirations of the applicant.
Flora and fauna are an integral part of all the land on which the 'huts' are to be sited
and the entire area is a protected SSSI. The correct box should have been ticked to
reflect this.
Assessment of Flood Risk
It is encouraging to note that DDC Planning insisted on a Flood Risk Assessment
being carried out by Tingdene under this section. In spite of the applicant ticking
No against all the boxes, the sea is only a few metres away from the proposed
development, and it is common knowledge that adverse combinations of wind and
tide can increase the high tide line by several metres.
Vehicle Parking
There is not space for 12 cars in the lay-by on Undercliffe Road. During the
summer months in particular there are often camper vans that park up for days –
but even if there weren’t there is still no space for more than 7 cars (allowing for
their occupants to open the doors and get out).
Design and Access Statement
The statement opens:
‘We welcome the opportunity this Design and Access Statement presents to
demonstrate our commitment to achieve good design and to ensure accessibility.
We confirm all the work we undertake will meet the various obligations placed on
the applicants by legislation and policy’.
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Proposal
This entire section of the statement has been cut and pasted into the Letter of
Application – which has already been examined and robustly rebutted above.
Design Issues
(i) The beach CANNOT be ‘rested outside of (sic) the holiday season
thereby ensuring its sustainability and protecting its ecology and bio-
diversity’. It is unreasonable to suggest it can, and no informed
naturalist or ecologist would support this assertion, as is evidenced by
statements from Natural England and Kent Downs AONB.
(ii) How can a 4 1/2 ft gap between twelve 15 ft long 'huts' ‘maintain
UNRESTRICTED views to the sea at any point along the beach?’ It is
impossible. As soon as anything above the eye-line is placed on a beach
it causes an obstruction. Nor can the 'huts' be moved easily. They are
mounted on two small wheels which will inevitably sink into the
shingle. The only way they can be moved is with a heavy-duty tractor.
(iii) Traditional beach-huts sit flat, often on railway sleeper platforms for
stability, and are made of wood with felt roofs. Not tile-effect steel.
The design of the Tingdene 'hut' is more akin to a static mobile home,
or chalet. They will be inappropriate on Kingsdown Beach and bear no
relation to any definition of a beach hut. Furthermore, the Tingdene
'hut' is equipped with a battery pack. This will cause light pollution and
may require a noisy generator in an entirely inappropriate area.
(iv) The beach is indeed ‘a beautiful setting with an attractive backdrop of
trees, with sheer chalk cliffs behind, mostly covered in trees and
shrubbery’. However, it is not 'topped by the distinctive A-framed dark
timber chalets of Kingsdown Holiday Park.’ The chalets are completely
obscured by trees which, fortunately, are the subject of a Tree
Preservation Order imposed by DDC Planning.
(v) ‘Every care and consideration will be given to nature conservancy;
protection of biodiversity and habitat.’
Such assurances are easily given but, in real terms, are impossible to
deliver - as Bramley Associates make only too clear with their list of
caveats. Notably, the fragile shingle will be disrupted whenever the
'huts' are installed (on their timber stabilising platforms) and moved.
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(vi) 'We do not envisage any problems with rights of light, boundaries or
pollution. Similarly there are no issues relating to privacy… as far as
we are aware'.
Although Tingdene describe Kingsdown Beach as a private beach and
infer that they own it all, they are well aware that this is not the case.
Both sides of their land are bordered by private land that does NOT
belong to Tingdene.
To the north, by South Road Kingsdown Management Company Ltd
(SRKMCL) and to the south, by the MOD. It is highly likely that issues
regarding boundaries being crossed and land being adversely affected
by families 'spreading' from the 'huts' would give rise to compensation
claims for pollution and damage to 'their' sections of the SSSI.
(vii) 'We do not believe any additional crime prevention measures are
required as the beach huts will be managed and maintained by staff at
Kingsdown Holiday Village.'
The 'huts' are not close to houses nor should they be inhabited at night.
As such they are open to abuse by 'leaseholders' who may sleep in them,
and the huts are perfect targets for vandalism. Additional crime
prevention measures will definitely be required. The applicant's
presumption that these can be met by one man working part-time is
unrealistic.
Conclusion
'We believe our proposals are well designed - the beach huts are of a modest scale,
easily transportable/removable and have an attractive appearance. This proposal
respects the sensitive nature of the SSSI while delivering significant wider benefits,
including an enhanced offer for tourism and sustainable economic development in
the Dover District area.'
The first group of assertions are entirely subjective. KCG disagrees with all three:
the proposals have no design integrity whatsoever, the 'huts' are far too large to be
called beach huts (they are mobile homes), they require a heavy tractor to move
them, and their appearance is entirely inappropriate for the beach.
To then claim that placing 12 of them on Kingsdown Beach 'respects the sensitive
nature of the SSSI' and 'delivers significant wider benefits - including an enhanced
offer for tourism and sustainable economic development..' is not credible and
demonstrates ignorance of how an SSSI ecosystem works, There is no enhanced
offer for tourism or sustainable economic development.
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Bramley Associates Ecological Appraisal
The report by Bramley Associates was commissioned by Tingdene in 2009 and the
survey actually carried out on the 9th and 20th June. That's almost FOUR years
ago.
It is a carefully considered report, with many caveats to ensure that the SSSI would
have the best chance of surviving a small development, just behind the summer
high tide line, of traditional beach huts.
These included:
'Access to any huts on the site across the vegetated shingle and through the
bordering woodland will need to be strictly controlled….. It is recommended that
access to any beach huts is carried out from the public car park area, at the end of
South Road/Wellington Parade only'.
The Application ignores completely this crucial recommendation and instead says
access will be from a small lay-by next to where the vegetated shingle starts on
UnderCliffe Road.
Occupiers of beach huts installed on the non-vegetated shingle will need to be
informed about the ecological significance of adjoining habitats and behaviours
such as BBQ's, disposal of waste and dog exercising(all of which provide nutrient
enrichment), should only be carried out in the clear understanding of their
potential impact on protected habitats and species. The legal issues of taking or
picking wild flowers… will need to be clearly outlined.'
The only people empowered to patrol and enforce these safeguards are the Police -
not one part-time employee from Tingdene's holiday camp. KCG contends that the
Police are unlikely to have the desire or the resources to be involved.
The explanation for an (albeit highly qualified) positive recommendation from
Bramley Associates is that the Survey was carried out nearly FOUR years ago. And
since that time the beach has changed considerably.
It is common knowledge that extensive shingle attrition along the length of
Kingsdown Beach is entirely normal. Historically, DDC's Engineering Department
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regularly monitors the high tide line and maps movement of shingle. Hundreds of
thousands of £s are spent on shingle replenishment.
However there have been exceptional budgetary constraints over the last four years
so replenishment has not taken place with its usual frequency. During that time the
shingle has been allowed to decrease substantially - so much so that the concrete
defences in front of The Zetland Arms were undermined a year ago, when the
shingle level dropped to such a degree that the sea was able to destroy four sections
of the concrete promenade. The most recent damage and shingle attrition have
been referred to earlier in this document.
The result of this lack of shingle replenishment is that not only have the sea
defences at Oldstairs Bay been compromised (the boulders around the groin are
completely exposed now as the sea bed level drops further and further) but the high
tide line along Kingsdown Beach has been steadily moving back westwards toward
Undercliffe Road.
This change between then and now is clearly illustrated by examining Figure 1 and
Figure 5 from Bramley's Report, and comparing them with today's evidence. It is a
measurable fact (with the Council's Marine Engineering Department) that as the
level of shingle along the beach has sunk so the high tide line has moved ever
closer to the vegetated shingle. A conservative estimate would be by as much as
35 metres in the last four years.
This explains why, at the time, Bramley's Report suggested that there was enough
shingle between the high tide line and the vegetated shingle to consider a small
number of beach huts. Traditional beach huts, not 15 ft long mobile homes.
The applicant's consultants were adamant that access should only be from the
public car parking area at The Zetland Arms end of the beach. And they wanted to
carefully measure any changes in the area of the development plot (they would
have been aware of the shingle depletion and replenishment cycle which was
controlled by DDC).
It is a serious failure of due diligence on the part of Tingdene's planning agent not
to have re-commissioned an up-to-date report from Bramley Associates before
submitting this Application. Instead they have relied on a report where the all-
important issue of shingle area, height from sea level and distance from the
vegetated parts of the beach bear little relation to how they are today
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Finally, and of great concern, is the reference by Bramley Associates to a future
review of the planning permission. This implies that possible expansion of the 'hut'
scheme was already being discussed four years ago.
Flood Risk
Summary
Almost all of the report’s Summary has been cut and pasted from the Letter of
Application – which has already been examined and robustly contradicted above.
Apart from:
'The development proposal for 'removable beach huts' on Kingsdown Beach is
supported by this flood risk assessment which demonstrates:
- the proposed development is unlikely to be affected by current or future surface
water flooding from any source.
- the design (of this development) will reduce flood risk to the development and
elsewhere, by incorporating sustainable drainage systems and flood resilience
measures; and
- the development will create opportunities to enhance bio-diversity and amenity,
and protect the historic environment'.
All three of these statements do not apply to putting 12 ' huts' onto a shingle beach
set back from the high tide line.
Proposal Sustainability
In this section the applicant has cut and pasted no less than 14 of DDC's
Sustainability Objectives. No link or explanation is made between these objectives
and Tingdene's proposal to put 'huts' onto Kingsdown beach. This is just as well
because the proposal does not fulfill any of them. These particular objectives relate
to large-scale building developments and have no bearing on this Application
Similarly, another section is lifted from the Core Strategy in its entirety under the
heading Achieving Sustainable Development.
The crucial sentence 'The presumption in favour of sustainable development cannot
override designations and policies that otherwise restrict development' has been
carefully edited out of the cut and paste.
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But, inexplicably, the paragraph that follows, which lists examples of these
restrictions (Kingsdown Beach comes under not one, but five of them) is included:
‘Sites protected under the Birds and Habitats Directives, SSSIs, Green Belt, Local
Green Space, AONBs, Heritage Coast, National Parks, the Broads Authority,
designated heritage assets, and locations at risk of flooding or coastal erosion’.
Presumably the reference to flooding and coastal erosion was seen as being
relevant to a Flood Risk Assessment, while actually its inclusion and context
underlines the paucity of any supporting argument for Tingdene's proposal which
cannot override designations and policies that otherwise restrict development.
'Kingsdown Beach is currently enjoyed by walkers and is open to the public even
though it is funded by service charge contributions made by the chalet owners at
Kingsdown Holiday Park.'
INCORRECT.
'The new beach huts will be an extremely welcome attraction for Kingsdown Beach
and we believe this proposal is intrinsically sustainable because: - is accessible to
all services, facilities, recreational opportunities and employment.
INCORRECT.
- protects and enhances the SSSI beach and local heritage.
INCORRECT.
- beach hut users will have no need to travel. as they will already be staying at the
nearby holiday park village which is five minutes from the beach, and therefore the
proposal encourages alternatives to the car and makes the best use of existing
transport Infrastructure'.
This directly contradicts the assertion that the 'lay-by for twelve cars' is a designed
parking solution. How does walking make the best use of Kingsdown's transport
infrastructure?
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Conclusions to Flood Risk Assessment
PPS 25 (and the new NPPF) state that for all stages of the planning process, the
minimum requirements for flood risk assessment are that they should:
(iv) Be undertaken by competent people as early as possible in the particular
planning process, to avoid misplaced effort and raising landowner expectations
where land is unsuitable for development.
'We liaised with officers from DDC and the EA upfront, and the professional
qualifications of the author are given below.'
This is simply not credible. DDC's Policy document includes the following explicit
Instruction:
'Any proposals for development in Flood Zone 3 will require developers to
under-take a detailed Flood Risk Assessment.
Developers should seek advice from the Environment Agency as to the
specific requirements for assessment'.
There is no reference in the Application to the names of the officers from DDC and
the Environment Agency. Nor are there references to dates, plans and projections,
shingle measurements from a qualified marine engineer, ‘hut’ locations, tide
timetables etc.
Furthermore, the supporting material that is supplied is cut and pasted from
existing publications which set out general principles, but they are not related
specifically to Kingsdown Beach which is in a Flood Zone 3 and has a high
probability of inundation from the sea.
(v) Consider both the potential adverse and beneficial effects of flood risk
management…
'The huts are set back from existing sea defences maintained by Dover DC but
in the event of an alert they can be relocated easily.'
To ensure (as Tingdene's proposal sets out) that the ‘huts’ would not encroach
on vegetated shingle they would need to be positioned perilously close to the
high tide line because the width of shingle between that line and vegetated
shingle on 10th March 2013 varies from between 8m at the northern
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perimeter of its land and 17m at the southern perimeter Consequently, there
would be a high risk of flooding.
Not only are the ’huts’ difficult to move because they are heavy and have small
wheels which ‘dig’ into the shingle, but to remove 12 buildings like mobile homes
safely away from the high tide line in a matter of hours without encroaching on and
damaging the vegetated shingle would be impossible.
More Reasons for Objecting to this Application
Planning Policy Statement 4
Objectives:
Quote: ‘The government's overarching objective is sustainable growth, that is:
Growth that can be sustained and is within environmental limits, but also enhances
environmental and social welfare’
The Tingdene 'huts' on Kingsdown beach are a socially divisive & environmentally
destructive proposition.
Quote: To raise the quality of life and the environment in rural areas by promoting
thriving, inclusive and locally distinctive rural communities whilst continuing to
protect the open countryside for the benefit of all.’
The Tingdene 'huts' on Kingsdown beach will reduce the quality of life and the
environment in Kingsdown, it will be socially exclusive for the benefit of 12
families at the expense of the local community – who are universally opposed to
this development – and will certainly not protect the beach
EC2 Planning for Sustainable Growth
Of the 11 (a-k) directives to Local Planning Authorities from central government,
not one includes or supports the kind of development proposed by
the Tingdene 'huts' on Kingsdown beach
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EC6 Planning for Economic Development in Rural Areas
6.i Quote: Local planning authorities should ensure that the countryside is
protected for the sake of its intrinsic character and beauty, the diversity of its
landscapes, heritage and wildlife, the wealth of its natural resources and to ensure
that it may be enjoyed by all.
6.ii Quote: Strictly control economic development in open countryside away from
existing settlements or outside areas …
EC7 Planning for Tourism in Rural Areas
7.1 Quote: Help deliver the Government’s tourism strategy, support sustainable
rural tourism and leisure development that benefits rural businesses, communities
and visitors and which utilise and enrich rather than harm the character of the
countryside.
The Tingdene 'huts' on Kingsdown beach will not benefit any of the target groups
and will impoverish and harm the wild, unspoilt nature of Kingsdown beach.
7.i.a Quote: Carefully weighing the objectives of providing adequate facilities or
enhancing visitors’ enjoyment .. with the need to protect landscapes and
environmentally sensitive sites.
7.i.c Quote: Support extensions to existing tourist accommodation where the scale
of the extension is appropriate to its location and where the extension may help to
ensure the future viability of such business.
The Tingdene 'huts' on Kingsdown beach are not appropriate in scale, and
Tingdene’s holiday park at Kingsdown has provided no audited evidence that it
needs the help of 12 'huts' on a beach to ensure its future viability.
7.i.d Quote : Ensure that new or expanded holiday and touring caravan sites and
chalet developments are not prominent in any landscape and that any visual
intrusion is minimized by effective, high quality screening and examine the scope
for relocating any existing visually or environmentally-intrusive site away from
sensitive areas (SSSI) or from sites prone to flooding or coastal erosion.
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The Tingdene 'huts' on Kingsdown beach would be a prominent development on an
ecologically sensitive site protected by Natural England, the AONB & Kingsdown
Conservation Area.
7.i.e Quote: Recognise that in areas statutorily recognised for their national or
cultural heritage qualities there will be scope for tourist and leisure related
developments subject to appropriate control over their number form and location
to ensure that the particular qualities or features that justified the designation are
conserved.
Kingsdown Beach is an SSSI which is protected by Natural England and the Kent
Downs AONB. DDC’s Planning Department has been advised of this, by statutory
consultative organizations.
Planning Policy Statement 7
Instructions to local Planning Departments
Objectives:
i: Raise the quality of life and the environment in rural areas through the
promotion of:
Continued protection of the open countryside for the benefit of all, with the highest
level of protection for our most valued landscapes and environmental resources.
ii: Promote more sustainable patterns of development:
Key Principles
The following key principles should be applied in combination with all the policies
set out in PP7:
Decisions on development proposals should be based on sustainable development
principles, ensuring an integrated approach to the consideration of:
- social inclusion, recognising the needs of everyone.
- effective protection and enhancement of the environment
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- prudent use of natural resources
- maintaining high and stable levels of economic growth and employment.
The Tingdene 'huts' on Kingsdown beach meets the needs of 12 families to the
detriment of thousands of residents, visitors and tourists. It undermines and spoils
the environment, and provides negligible growth and employment.
All developments in rural areas should be well designed and inclusive, in
keeping and scale with its location and sensitive to the character of the
countryside and local distinctiveness.
The Tingdene 'huts' on Kingsdown beach are nothing like a traditional British
seaside beach-hut. 15ft wide, with a tile effect roof and mounted on wheels it looks
more like a mobile home or chalet. Its design is utterly insensitive to the character
of the beach location or wider countryside environment.
Countryside Protection and Development
Planning Policies should have particular regard to any areas that have been
statutorily designated for their landscape, wildlife or historic qualities where
greater priority should be given to restraint of potentially damaging development.
When preparing policies for LDD’s and determining planning applications for
development in the countryside, local planning authorities should:
- take account of the need to protect natural resources
- conserve specific features and sites of landscape and wildlife..in accordance
with statutory designations.
Kingsdown beach is an SSSI which is protected by Natural England and the Kent
Downs AONB. DDC’s Planning Department has been advised of this, by both
statutory consultative organizations.
Nationally Designated Areas
Nationally designated areas comprising… Areas of Outstanding Natural Beauty
have been confirmed by the Government as having the highest status of
protection in relation to landscape and scenic beauty. The conservation of
wildlife and the cultural heritage are important considerations in these areas.
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As well as reflecting these policies in LDD’s and where appropriate RSS, should
also support suitably designed and located development necessary to facilitate the
economic and social well-being of their designated areas and their communities…
Tourism and Leisure
Local Authority RSS and LDD’s should:
- support through planning policies sustainable rural tourism and leisure
developments that benefit rural businesses, communities and visitors and
which utilize and enrich but do not harm the character of the countryside…
its villages and other features.
- Recognize that in areas statutorily designated for their landscape, nature
conservation there will be scope for tourist and leisure related
developments, subject to appropriate control over their number, form and
location to ensure the particular qualities or features that justify the
designation are conserved.
- Plan for and support the provision of general tourist and visitor facilities in
appropriate locations where identified needs are not met by existing
facilities in rural service centres.
Tourist Accommodation
Local authorities should carefully weigh the objective of providing adequate
facilities and sites with the need to protect landscapes and environmentally
sensitive sites, and examine the scope for re-locating any existing visually or
environmentally-intrusive sites away from sensitive areas, or for re-location
away from sites prone to coastal erosion.
Where appropriate (e.g. popular holiday areas) set out policies in LDD’s on the
provision of new holiday and touring caravan sites and chalet developments,
and on the expansion and improvement of existing sites and development –
while ensuring:
New or expanded sites are not prominent in the landscape and that any visual
intrusion is minimized..
The Tingdene 'huts' on Kingsdown beach are to be sited on an extremely sensitive
environmental site which contains protected species of flora and fauna and is prone
to coastal erosion. The 'huts' would be prominent in the landscape and there is
already ample chalet- style accommodation available within the existing holiday
park owned by Tingdene in Kingsdown.
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Conclusion�
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All these documents, all these government bodies and initiatives, all these laws
to protect our national heritage, our landscape, our enjoyment and
appreciation of Nature. And yet this scheme has been proposed by an
applicant claiming to respect the environment.
Kingsdown Conservation Group, on behalf of all who live in this unique
seaside village and those from further afield who share their deep concern, ask
Dover District Council to give reasonable and proper consideration to the
material contained in the document and in its appendices in determining this
application.
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Philip Evemy Nick Harper
Chairman Consultant
Kingsdown Conservation Group Kingsdown Conservation Group
Appendices
Statements of objection to the Application by Natural England, The National Trust,
Ringwould with Kingsdown Parish Council, The Kent Downs AONB Unit, email
dated March 13 2013 from Jennifer Bate, Kent Downs Planning Officer to Philip
Young, and pictures of beach showing shingle depletion and increase in flood risk.
Cc
Patrick MacWilliam Chairman, Ringwould with Kingsdown Parish Council
Charlie Elphicke- Member of Parliament for Dover & Deal
Cllr Sue le Chevalier - District Cllr for Ringwould & Parish Clllr for Walmer
Cllr Steve Manion - Kent County Councillor
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Appendices
E-Mail clarifying Adoption of ANOB Management Plan by Dover
District Council in their CORE STRATEGY
To: Philip Young
Cc: Gill Bell ; Nick Johannsen ; Peter Wallace ; Alice Fey ; Nick Delaney
Sent: Wednesday, March 13, 2013 12:35 PM
Subject: RE: Borders of the AONB - The setting�
Dear Philip
As you may know we have objected to the application at Kingsdown. I enclose a copy of our
comments to Dover.
The application is within the 'setting' of the AONB which is part of the reasons for designation of
the Kent Downs - the quality of the views out and towards the AONB being a factor in their
designation.
The conservation and enhancement of the setting of protected landscapes (AONBs and
National Parks) is not covered by the new National Planning Policy Guidance (NPPF); The
'setting' of AONBs was previously covered by policy C3 of the South East Regional Strategy.
However this strategy will be revoked on 25th March 2013.
The Dover Core Strategy and Development Management policies and saved Local Plan policies
have general landscape and countryside policies that do not specifically mention the AONB or
its setting. It therefore appears that as from 25th March there could be a policy gap in relation to
the setting of the AONB. However, Dover has adopted the Kent Downs AONB Management
Plan and refers to the AONB in the Core Strategy para 1.57. It is a material consideration in
determining any planning application. The Management Plan's objectives cover the need to
conserve and enhance the AONB, and its setting and there are specific policies addressing
this: page 61, LLC8; and page 128, SDT5
You can access the KD Management Plan on our web site.
The reason why the setting is included in the Management Plan is because development within
the setting can challenge the purposes of designation of the AONB.
The legal context of AONBs is set out in the CROW Act 2000:
Section 82 – sets out the primary purpose of designations of an AONB to conserve and enhance
natural beauty
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Section 84 – states the powers that LAs have to take action to achieve conservation and
enhancement
Section 85, Duty of Regard”: states that in exercising or performing any functions in relation to,
or so as to affect, land in and AONB, authorities “shall have regard” to their purposes please
refer to Natural England’s publication: ‘England’s Statutory Landscape Designations’
Section 89 - The Act requires a management plan to be produced; the first Kent Downs AONB
Management Plan was published in April 2004 and the first revision management plan (2009-
2014) was published in April 2009. This has been formally adopted by all the local authorities of
the Kent Downs and is a material consideration in all planning decisions.
If a proposal in the setting of an AONB challenges the purposes of designation of that AONB it is
clear that this should be a material consideration in the determination of the application.
So in answer to your question - Government Planning Guidance does not specifically cover the
‘setting’ of AONBs, but the legal context and the importance of the Kent Downs Management
Plan – Dover’s own plan for the management of the Kent Downs AONB in their area – means
that any development within the setting needs to be determined in relation to its impact on the
purposes of designation of the AONB. In the case of the Kent Downs ANOB one of the main
reasons for designation was the quality of the views both towards, and out of the AONB.
I hope this clarifies the situation for you
Best wishes
Jenny
Jennifer Bate
Kent Downs Planning Officer
Kent Downs AONB Unit
West Barn, Penstock Hall Farm
Canterbury Road
East Brabourne
Ashford
Kent
TN25 5LL
Tel. 01303 815170
Email: [email protected] Conserving and enhancing the Kent Downs Area of Outstanding Natural Beauty
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Objection E-Mail from Natural England Date: 08 March 2013
Our ref: 79704
Your ref: DOV/12/01016
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Sarah Platts Development Control, White Cliffs Business Park, Dover, Kent, CT16 3PJ BY EMAIL ONLY
Customer Services Hornbeam House Crewe Business Park Electra Way Crewe Cheshire CW1 6GJ T 0300 060 3900
Dear S Platts, Proposal: Erection of twelve beach huts Location: Kingsdown (Private) Beach, Undercliffe Road, Kingsdown, CT14 8EU Thank you for your consultation on the above dated 26 February 2013 which was received by Natural England on the same date. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. This reply comprises our statutory consultation response under the provisions of Article 10 of the Town and Country Planning (General Development Procedure) Order 1995 and Section 28 of the Wildlife and Countryside Act 1981 (as amended). Objection This application is directly within Dover to Kingsdown Cliffs Site of Special Scientific Interest (SSSI). Natural England objects to this development on the grounds that the application, as submitted, is likely to damage or destroy the interest features for which this SSSI has been notified. Our concerns are set out below. � This part of the SSSI (unit 23) is a broad shingle plateau with a succession of plant communities influenced in their extent and composition by increasing shingle stability. Coastal vegetated shingle is a UK BAP priority habitat. The habitat is slow to form and is easily damaged by vehicles and trampling by access on foot that is associated with this development. While the applicant is proposing to place the beach huts on the unvegetated shoreline, this does not prevent damage from the associated movement of the users of the huts. Additionally, the annual placing and removal of the huts has the potential to interrupt the natural movement of shingle and thus the environmental and ecological processes.
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� The SSSI is also notified for its vascular plant and invertebrate assemblages. Of particular note in unit 23 are the early spider orchid Ophrys sphegodes which is a nationally rare plant protected under schedule 8 of the Wildlife and Countryside Act 1981 (as amended); and the bright wave moth Idaea ochrata a UK BAP species with a very restricted breeding range in Britain largely confined to localised areas along an 18km stretch of coastline in East Kent between Ramsgate and Kingsdown. Both the plant and invertebrate assemblages would be at risk from increased recreational activity that would be associated with the provision of these beach huts. We have considered this application along with the proposed mitigation and view that it is unlikely that even if the mitigation was strictly enforced that there would be no adverse impacts upon the rare and fragile vegetated shingle habitat (and associated flora and fauna). We therefore object to this proposal. If your Authority is minded to grant consent for this application contrary to the advice relating to Dover to Kingsdown Cliffs SSSI contained in this letter, we refer you to Section 28I (6) of the Wildlife and Countryside Act 1981 (as amended), specifically the duty placed upon your authority, requiring that your Authority:
� Provide notice to Natural England of the permission, and of its terms, the notice to include a statement of how (if at all) your authority has taken account of Natural England’s advice, and � Shall not grant a permission which would allow the operations to start before the end of a period of 21 days beginning with the date of that notice.
Designated Landscapes The proposal is less than 600 metres from and therefore within the setting of the Kent Downs Area of Outstanding Natural Beauty (AONB). The AONB Unit should therefore be consulted on this application for views on the impact of this proposal upon the designated landscape. The proposal site also lies less than 400 metres from the South Foreland Heritage Coast. Other advice We would expect the Local Planning Authority (LPA) to assess and consider the other possible impacts resulting from this proposal on the following when determining this application:
� local sites (biodiversity and geodiversity)
� local landscape character Natural England does not hold locally specific information relating to the above. These remain material considerations in the determination of this planning application and we recommend that you seek further information from the appropriate bodies (which may include the local records centre, your local wildlife trust or other recording society and any local landscape characterisation document), in order to ensure the LPA has sufficient information to fully understand the impact of the proposal before it determines the application. A more comprehensive list of local groups can be found at Wildlife and Countryside link. We value your feedback to help us improve the service we offer. We have attached a feedback form to this letter and welcome any comments you might have about our service. If the form is not attached, it can also be accessed on our website. For any queries relating to the specific advice in this letter only please contact Mary Tomlinson on the contact details below. For any new consultations, or to provide further information on this consultation please send your correspondences to [email protected]..
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Yours sincerely, Mary Tomlinson Land Use Operations Tel: 0300 060 0296 Email: [email protected] On behalf of Nigel Jennings, Senior Advisor, Land Use Operations
___________________________________________________________________
Objection E-Mail from National Trust
To: Philip Evemy (Kingsdown Conservation Group)
Sent: Monday, March 11, 2013 15:21 PM
Subject: RE: wheeled huts on Kingsdown beach
Hello Phillip
I am attaching here the final version of the letter that was sent to DDC Planning Officer Sarah Platts – unfortunately as it is a file copy it has been sent to me with no heading (Trust stationery). I’ve asked for a more official version but thought that you might like to read the text in the meantime.
Best wishes
Virginia
Virginia Portman General Manager White Cliffs & Winchelsea portfolio National Trust Telephone 01304 200005 Mobile 07768 027034
National Trust letter reads:
The National Trust objects to this application. As you are aware the Trust owns and manages
much of the coastline within the district and in particular Kingsdown Leas which extends to the
south of the site.
The National Trusts’ recent (2012) public appeal to raise funds to purchase a section of this
coastline, at Fan Bay, is testament to the extent that people value and wish to conserve this
stretch of unspoilt and iconic Kent coastline. This was probably the most successful appeal ever
by the Trust for a coastal acquisition, raising £1.2 million in under 100 days. We feel that
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allowing the type of development proposed in the same area would be seriously detrimental to
its landscape, heritage and conservation.
Impacts on the area
We are strongly opposed to the use of the beach for any form of built development. We also
consider the proposed huts, at 5.5m x 2.7m x 3.5m in height to be large scale and bulky and that
these in no way reflect traditional seaside huts. We are concerned that they will have a totally
undesirable impact on the landscape of the beach and completely spoil the open, tranquil,
unspoilt character of the area. It is stated in the application that lighting and power will be
available which not only implies that they could quite easily be occupied as dwelling units but will
cause highly undesirable light pollution. The proposal will adversely affect the amenity of
residents of the area and users of the White Cliffs Country Trail. The site is part of the Dover to
Kingsdown Cliffs SSSI which is notified for its extreme importance geologically and
physiographically and for its varied floral and faunal communities. We do not agree with the
conclusions of the Ecological Appraisal that the proposal is acceptable subject to the measures
proposed. The Ecological Appraisal mentions the importance of the SSSI and adjacent County
Wildlife Sites and the surveys identified a very wide range of flora and fauna. However, there
was little discussion of, for example, U.K Biodiversity Action Plan species and habitats or of
mitigation for European Protected Species. In addition the measures proposed to mitigate
development on such a fragile SSSI are wholly inadequate and consists largely of mapping and
monitoring its effects. The Ecological Appraisal itself mentions a number of these potentially
damaging effects, such as increased dog numbers, waste, barbeques, introduction of non native
species, trampling and picking wildflowers. To this could be added the detrimental effects of
noise, additional lighting and the positioning of large beach huts. There are no significant
remedial measures proposed in the report.
The National Planning Policy Framework
In our opinion the proposal is contrary to the principles and policies contained in the National
Planning Policy Framework 2012. In particular paragraph 109 seeks to protect and enhance
valued landscapes, and geological conservation interests, and minimise impacts on biodiversity.
Paragraph 113 seeks to ensure that designated areas are protected in a manner commensurate
with their status and that appropriate weight is given to the importance of the area and the
contribution made to wider ecological networks.
Of particular importance is paragraph 114 which states:
‘Local Planning Authorities should:
….maintain the character of the undeveloped coast, protecting and enhancing distinctive
landscapes, particularly in areas defined as Heritage Coast, and improve public access to and
enjoyment of the coast’.
Paragraph 118 states that development on land within an SSSI which is likely to have an
adverse effect on the site should not normally be permitted. Exceptions should only be made
where the benefits outweigh the impacts on both the site itself and the broader impact over a
wider area. The proposed development has, in our opinion, no material benefits to outweigh the
potential harm of the proposal.
The proposal also conflicts with the policies of the NPPF with regard to potential pollution
including noise and light pollution – paragraphs 120 to 125.
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Dover District Core Strategy 2010
The application site falls outside the boundary of the built up area of Kingsdown and is adjacent
to the Kingsdown Conservation Area. The proposal conflicts with local planning policy on a
number of counts. Firstly the proposal is contrary to Policy CP7 of the Core Strategy which
seeks to protect and enhance the integrity of the Green Infrastructure Network of the district.
The coastline is an integral part of this network.
The proposal conflicts with Policy DM1 which only permits development outside settlement
boundaries if specifically justified by other policies of the plan, functionally requires such a
location or is ancillary to existing development. The proposal does not meet these criteria.
The proposal conflicts with Policy DM15 which seeks to prevent development which would result
in the loss of or adversely affect the character or appearance of the countryside. It is not justified
by the need to sustain the rural economy and could well be accommodated elsewhere. The
proposal is not ancillary to the existing Holiday Park but forms a major new venture. Finally the
proposal also conflicts with Policy DM16 which seeks to prevent development that would harm
the character of the landscape.
I trust you will give due consideration to our views in determining this application.
___________________________________________________________________
Objection E-Mail from Kent Downs AONB Unit
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From: Jenny Bate
Sent: 05 March 2013 11:52
To: '[email protected]'
Cc: [email protected]; '[email protected]'; Gill Bell
Subject: RE: Tingdene - Kingsdown Beach DOV/12/01016 {Scanned by ADM Mail Safe}
Importance: High
Dear Alice
We have been advised of the application for beach huts at Kingsdown beach by a third party.
The site is in the setting of the Kent Downs AONB. However we would not normally expect to
be consulted by you on this application under the protocol we have with you. As it will have a
damaging impact on the views from the AONB to the south ( the Lees) we would however draw
your attention to the policies in The Kent Downs AONB Management Plan, and the KD
Landscape Design Handbook. This development would change the outlook from the AONB
northwards along this coastal stretch and be damaging to the purposes of designation. We
would therefore support you in a decision to refuse this application.
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Relevant KD Management Plan policies:
General:MPP2
The setting:
Views of the AONB- the cliffs – from the beach level south into the AONB
Views out from the AONB – from the Lees looking north
LLC2 , LLC8, GNR5
Page 58 of the Management Plan – Heritage Coast
Page 60 – para 2 Taking a landscape character approach
Biodiversity: BD2 f) the conservation and enhancement of chalk cliffs and the foreshore.
The habitat here is an inherent element of the landscape character contributing to the visual
importance of this area.
If we can be of further help please contact me.
Best wishes
Jennifer Bate
Kent Downs Planning Officer
Kent Downs AONB Unit
West Barn, Penstock Hall Farm
Canterbury Road
East Brabourne
Ashford
Kent
TN25 5LL
Tel. 01303 815170
Email: [email protected]
Conserving and enhancing the Kent Downs Area of Outstanding Natural Beauty
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Letter of objection to Dover District Council from Ringwould with
Kingsdown Parish Council
In regards to planning application DOV/12/01016. Erection of 12 beach huts on Kingsdown beach, Published on Date: Thursday 7 March, 2013
This is the most significant planning application for the community of Kingsdown for many years. The Parish Council wish to object to this development in the strongest terms. The Parish Council, given the character, landscape, environmental and amenity value of this land, does not feel that any development should be permitted on this land. This is an area of outstanding character beauty and charm. Equally, its environmental value is nationally recognized in the SSSI designation. It is part of an unspoilt, special and unique land and seascape from the cliffs, the rifle range to the South Road Conservation Area. The area is over looked by the AONB and National Trust land on the cliffs. The views enjoyed from the rifle range to the conservation area have delighted generations over the years. The proposed development will destroy these views and change the beauty of the area. The development will fundamentally alter and damage this landscape. The character and charm of this area is crucial to the identity of Kingsdown and the conservation area. The Parish Council believe this area should be protected by its designation as an SSSI and Heritage Coast. The Coastal Footpath will run through this area. Any owner of an SSSI has a duty to promote the features of ‘interest’ cited in the SSSI and this proposal does not do this. There are many natural habitats in the area and this area is an important location for bats and biodiversity in general. We believe there is no way this development cannot but damage the SSSI and the ‘vegetated shingle’ environment. This is a special and unique area, partly because it is the only area locally that is not backed by housing development; the shingle beach has a particular character backed by the cliffs and the trees. Dover District Council have re-constructed the rifle range and this now forms an attractive location for visitors and tourists. This development will change the wild and natural character of this area and will make it feel more like a resort and will detract form the visitor experience. The development relies on public facilities and is not viable as an independent entity. Any attempt to develop facilities would add further weight to the arguments against the proposal. This is a public space which has always been enjoyed by residents and tourists alike. This development will make it a privatised space. The development will not benefit the community of Kingsdown and is universally opposed by residents. The Parish Council believes that both local and District Council’s have a duty to reflect these views. It is imperative that the character and use of this area is protected and conserved for the public benefit not only for current users but for generations to come. The Parish Council request the Planning Authority to refuse permission for this application.
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Pictures of beach showing shingle depletion and increase in flood risk