Sustainable development cannot be achieved unless finite energy and mineral resources are conserved, renewable sources developed and used instead of non-renewables, waste products reduced, and pollution prevented or, if this is not possible, minimised. For the first time, government guidance (especially PPG12) requires a local plan to consider environmental resource issues in relation to global warming, the consumption of non-renewable resources and the emission of greenhouse gases.


Finite resources include all mineral deposits and fossil fuels, such as coal, oil and gas. Stocks are limited and, once used, cannot be replenished. On the other hand, renewable sources of energy, such as biomass, wind and tidal power, and solar energy, are potentially unlimited in amount and have environmental benefits over fossil fuels. Wastes are the unwanted by-products of any activity, which must be accommodated in the environment. Pollutants are harmful to people, other species or even entire ecosystems and, unlike waste products, are not potentially reusable.

Existing Situation


The District contains substantial mineral reserves, including limestone and colliery spoil. Most of the District's energy requirements are currently served by national distribution networks which, in turn, are mainly supplied by fossil fuel plants. Two gas-fired combined heat and power plants exist in the District at Pfizer, Sandwich and Buckland Mill, Dover. However, the District has the capacity to produce energy from renewable resources (see paragraphs 7.09-27). Large volumes of solid and liquid wastes, which are produced by consumers, are also a source of energy and, in any case, require management and final disposal. There are few major sources of pollution in the District, apart from the despoiled colliery sites. However, some parts of the District are vulnerable to locally generated air, water, noise and light pollution, and to the environmental consequences of air pollutants produced outside the District.


In 1992, at Rio de Janeiro, the Government signed Agenda 21. In doing so, the Government agreed to implement an action plan for sustainable development. A key means of implementing this is through local action. The Council is committed to increasing environmental awareness and promoting good environmental practice.

Applying the Plan's Aims and Objectives


Aim 1 provides the framework for this Chapter. The need to conserve resources, avoid waste and minimise pollution is echoed in Objectives 5, 7 and 4, respectively. The most effective way in which the Plan can conserve resources, particularly energy, and minimise pollution is to influence the location of development in order to reduce the need to travel. This is reflected in Objectives 10 - 15. The means to reduce travelling are dealt with in Chapter 4 and all the Plan's location policies. Energy conservation in building design and water resources are considered in Chapters 8 and 6, respectively.

Environmental Resources Strategy


Based on Aim 1, the Plan's environmental resource strategy seeks to:-

  1. encourage the generation of energy from renewable resources;
  2. encourage the more efficient use of non-renewable resources;
  3. provide for development in accordance with the ability of energy distribution networks to keep pace;
  4. minimise the effects of pollution by, or on, new development;
  5. improve, reclaim and reuse derelict and contaminated land, as appropriate;
  6. reduce the amount of waste produced; and
  7. conserve mineral resources.

The strategy will be implemented by the Council through the policies of the Plan and, in part, through the pollution control functions of its Environmental Health Division. However, the Council is only one of a number of agencies charged with implementing government policy in this area, the others being:-

  1. the Department of Trade and Industry (DTI) - energy planning;
  2. the Department of the Environment, Food and Rural Affairs (DEFRA) - energy efficiency and pollution control;
  3. the Environment Agency (encompassing the former Her Majesty's Inspectorate of Pollution (HMIP), the National Rivers Authority (NRA) and the Waste Management Authority) - pollution control and waste management; and
  4. Kent County Council - minerals, and waste planning and management (including disposal).

In the main, the Plan's influence is limited to specifying what is required of new development. Even then, it is not directly responsible for waste and minerals planning. This indirect role complements the more direct forms of control given to other agencies. It is, therefore, essential that there is a close working relationship between these agencies and the Council.



The environment can also be protected and fossil fuel reserves conserved through the more efficient use of non-renewable fuel sources. It is possible that new fossil fuel burning plants may be proposed in the District. Should this be the case, such plants should make use of wasted energy either through district heating or combined heat and power schemes. Should Richborough Power Station re-open, the Council would press for the incorporation of these and be opposed to the re-introduction of Orimulsion.



Structure Plan Policy S9 requires planning authorities not to permit development unless the infrastructure required to service the development can be made available at the appropriate time. The relationship between development and energy infrastructure provision is considered below.



There are no anticipated problems with electricity supply during the Plan Period, apart from Aylesham and the Dover area, where supplies will require major reinforcement. New infrastructure associated with the proposed expansion of Aylesham is considered in Chapter 14.


Electricity cabling is authorised by the DTI after consultation with, amongst others, the Council. The Council and the Countryside Agency are generally concerned about the impact of power lines on the landscape. The Council will press for the undergrounding of all new low voltage (132kV and under) cabling in an Area of Outstanding Natural Beauty, Heritage Coast or Special Landscape Area unless nature conservation, archaeological or recreation interests would be harmed. When undergrounding is not possible, and in instances of high voltage lines, the Council will press for cables to be sensitively located and designed to minimise landscape harm.


Dover may need a 132/33kV sub-station, which would require a site of approximately 0.3 Ha (0.7 acre). The supply would be distributed by existing underground 33kV cables. A site has been safeguarded on land fronting the Roman Road, to the north of the Dover-Deal railway line, and is shown on the Proposals Map. The site is well placed to serve the main distribution network and development here would minimise impact on local amenity and agricultural interests. Although there is no firm indication of the route, it is possible that the sub-station would be served by a connection from the existing overhead line at Shepherdswell. In addition, should part of the route cross the Long Hill area and the White Cliffs Business Park, which are both prominent in the landscape, the Council will seek the undergrounding of cables.

Policy ER2 –

Land adjoining the Roman Road at Danes Court, shown on Sheet 6 of the Proposals Map, is safeguarded for a 132/33kV sub-station.

Environmental Appraisal

The policy only has limited relationships with the Objectives. The site is beyond the urban boundary and therefore contrary to the Objectives protecting the countryside and recycling of redundant resources. However, the site is acceptable due to its proximity to the distribution network. Other locations would also be more visually damaging.


The Council considers that, in the interests of visual amenity and on the grounds of noise, new residential development, including garden land and associated open space, should be sited well away from overhead power lines and pylons/lattice towers. In judging schemes affected by such structures, the distance at which development is acceptable will depend on the overall size of the pylons/lattice towers and the physical characteristics of the site. Policies ER5 and DD1 will apply.



Some pollutants are adversely affecting the world's atmosphere, with health and other consequences. This District is not immune from the effects of global warming, ozone depletion, acid rain and smog conditions. More locally, there may be problems associated with lead, carbon monoxide accumulation and ground-level ozone. Recent figures suggest that ground-level ozone in the District is among the worst in the UK1, often equalling levels in Los Angeles 2. To some extent, road traffic and industry in the District are contributing to these pollution problems. Road transport is an activity largely influenced by locational patterns of development (see especially Chapter 4), though the District's strategic position as a road corridor to the rest of Europe is also important.


Industrial sources of air pollution include power stations and general industrial processes. While air pollution in existing industry is a matter for the Environment Agency and the Council's Environmental Health Division, the Plan is required by Government guidance to consider the relationship between polluting development and sensitive land uses, such as housing. PPG12 requires development plans to include policies designed to control pollution. PPG23 makes the potential generation of pollution a material consideration to be taken account of in applications for new development.


The ways in which the Plan can be used to control pollution are set out in PPG23. Essentially, development plans should act to separate incompatible uses and develop criteria by which applications for polluting development will be determined, while taking into account the extent to which they are subject to pollution control. Structure Plan Policy ENV20 requires pollution impacts to be reduced to an acceptable level, as a prerequisite to planning permission. In doing so, the Structure Plan puts the emphasis on design of plant rather than location. This recognises that the effects of air pollution are often felt some distance from their source and that an isolationist approach in such a densely developed County is not possible.


Structure Plan Policy ENV20 is sufficiently comprehensive with regard to air pollution for the Council to apply it for the purposes of development control. Close co-operation with pollution control authorities is needed to ensure that air pollution control standards are met before granting planning permission for new industrial development or changes in existing industrial processes. The advice of pollution control authorities is absolutely essential in dealing with such applications.

Air Quality Modelling


The Government's 1997 National Air Quality Strategy identified air quality as a key issue for environmental policy. It sets out the Government's policies on the assessment and management of air quality. The planning system is seen as a key means of improving air quality. The effects of new development and local plan policies on air quality can be predicted through Air Quality Modelling. The Council is in the process of developing such a model. The model will then be used to assess the effects of Development Plan policies on air pollution and used as part of the Environmental Appraisal. The model will also be used to predict the effects of new developments on air quality and, if the results warrant it, will be used to justify refusals.


The Council will make use of existing monitoring work carried out by the Kent Air Quality Partnership, its Environmental Health Division and other agencies to compile monthly reports on air quality in the District.



Lighting is important for safety, especially where traffic and security arrangements are concerned. However, a proliferation of lighting schemes can lead to problems of skyglow at night - a form of visual pollution. The invasive nature of light can disturb the amenity of residential areas, and harm the character of villages and the countryside. Light pollution also represents wasted energy and is an inefficient use of scarce resources. In most instances, these problems are caused by wasteful, poorly designed and misdirected lighting.


Existing light pollution is not categorised as a statutory nuisance, but there is an opportunity for the Plan to influence the design of lighting schemes associated with new development. PPG23 requires local planning authorities to take harmful emissions of light into account in preparing development plans. The preamble to Structure Plan Policy ENV20 suggests that the reduction of light pollution in new development projects is one way of minimising the risk of pollution.


Policy ER6 establishes a basis for promoting the use of more sensitive lighting in new development which, in the long term, should assist in reducing energy consumption, disturbance to neighbouring properties and loss of the night sky. Lighting units should illuminate the object or place intended. This can be achieved through a combination of design, siting and output. In design terms, styles which cause light spill will be unacceptable. However, this can usually be overcome by using full cut-off lanterns which direct light downwards. In requiring full cut-off lanterns there is a need to be aware of the surface material from which the light will be reflected. In implementing Policy ER6, the Council will use the standards set out by the Institute of Lighting Engineers and will not grant permission for developments involving external lighting, such as flood lighting or street lighting, which do not use full cut-off lanterns. Conditions may be used to control the type of lighting and hours of use.

Policy ER6 –

Proposals for development which entail:

  1. advertisement illumination will not be permitted unless units are well directed and not excessive for the task;
  2. external lighting will only be permitted where full cut-off lanterns are used, unless Historic Environment interests indicate otherwise.

Environmental Appraisal

The policy works positively towards the Objectives of protecting the countryside and historic environment, reducing pollution and energy efficiency. The policy is also likely to be positive in enhancing and managing species and landscapes, although the exact effects are unpredictable. No Objectives are adversely affected.


Road lighting is a matter for the County Council and the DTLR. As part of its consultation role, the Council will encourage these agencies to adopt sensitive lighting schemes where new roads or replacement lighting projects are proposed. Footpath lighting is a responsibility of the District and Parish Councils, but carried out by the District Council. To minimise light pollution, the District Council will seek to use best practice in footpath lighting.



Wastes are produced by a variety of domestic, commercial, construction, industrial and agricultural activities. Only some types of wastes are controlled through the provisions of the Environmental Protection Act 1990. The management of these wastes is the responsibility of waste collection authorities (including the District Council) and waste regulation and disposal authorities (County Council and the Environment Agency).



The Council collects and transports domestic and commercial refuse to the County's Bulk Transfer Stations at Whitfield and Hawkinge. The collection process represents the best opportunity for the separation of waste for recycling. The Council has produced a range of waste management policies in line with Government strategies and County plans. The statutory recycling targets for the District are for 2003/4, 10% and 2005/6, 18%.


To help achieve this target, the Council is establishing an ever growing network of can, glass, paper and textile recycling centres, and is running composter bin trials. Most recycling centres are grouped in Council-owned or supermarket car parks, where permitted or ancillary use rights often prevail and planning permission is not required. Other types of waste are collected by private companies such as scrap merchants, vehicle breakers and demolition contractors for processing, storage and resale. These companies perform a valuable service in reducing the demands placed on virgin resources, but their activities usually require some form of control to preserve neighbouring amenity.

Processing and Disposal


The County Council is responsible for the strategic planning of waste sites and the determination of development proposals whilst the Environment Agency is responsible for site licensing and on-going monitoring of individual sites. The Structure Plan sets the context for the County's preparation of a Waste Local Plan. In line with the Structure Plan, the Kent Waste Local Plan discounts landfill as a long term disposal option. The Kent Waste Local Plan, nevertheless, acknowledges that there may be circumstances where a need can be demonstrated. The Council has a long-standing objection to the use of Tilmanstone colliery spoil tip for landfill. The Richborough landfill closed in August 1994.


The Waste Local Plan gives priority to reduction, re-use, recycling and incineration of waste. In order to achieve these aims, the Waste Local Plan identifies:-

  1. land at Richborough adjacent to the landfill as a suitable location for the preparation, for re-use, of demolition waste and spoil material (Policy W7(1));
  2. land at Richborough and the existing Bulk Transfer Stations at Whitfield and Hawkinge as suitable locations for the separation and transfer of degradable industrial waste and domestic refuse (Policy W9); and
  3. adding a combined refuse incinerator and power generator to Richborough Power Station (Policy W11).

The District Council supports, in principle, these proposals outlined in the Waste Local Plan but, as a consultee, it will seek to ensure that all environmental concerns are satisfied.



The County Council, as mineral planning authority, has adopted a Minerals Local Plan for Kent. It comprises three parts; the Brickearth and Construction Aggregates, the Chalk and Clay, and Oil and Gas sections. The Structure Plan establishes the context for the preparation of the Minerals Local Plan. It acknowledges that the need to exploit the County's mineral reserves will remain, but makes clear that, in some cases, the maintenance of a land bank will not be possible due to constraints on development in the countryside. Structure Plan Policy NR6 sets out the criteria by which applications for mineral extraction will be considered.


The Construction Aggregates section of the Plan identifies the following proposals in the District:-

  1. the expansion of existing mineral importation facilities at Dover Western Docks and Port Richborough (Policy CA4);
  2. the development of processing and dispatching facilities at Stonar Cut and on land to the north of the Richborough landfill, associated with extensive underground limestone mining beneath the Ash Levels (Policies CA4 and CA13); and
  3. the use of substitute and recycled materials such as colliery spoil or minestone (Policy CA5).

Neither the Brickearth nor Chalk and Clay sections of the Plan identify any sites for development. The Council will seek to ensure that the effects on landscape, nature conservation and local amenity are taken into account in drawing up proposals.


Although the Oil and Gas section contains no specific sites for development, an exploration licence covers most of the District. The Licence grants sole rights to search for oil and gas for a period of six years. It permits the holder to carry out seismic investigations, to drill deep exploratory boreholes and to test any discovery for a period not exceeding four days. Should oil or gas be discovered in the District, development for onshore oil or gas fields will be judged against the policies in the Oil and Gas section of the Plan and the Council will seek to ensure that any development includes stringent environmental safeguards. Proposals for refineries would be considered against the policies in the Dover District Local Plan.


1Ozone in the United Kingdom 1993, UK Photochemical Oxidants Review Group 1993
2Elements, Summer 1994, Kent County Council