This final chapter assesses the environmental effects of the Plan, and describes how its progress and effectiveness will be monitored.



The Plan-led system requires the Plan to be appraised for its environmental effects. This is set down in PPG12. The value of appraising the Plan in this way is that it:-

  1. clarifies the environmental objectives of the Plan;
  2. helps to understand the implications of policies on the environment;
  3. allows wide ranging and potentially conflicting aspects of the environment to be weighed up;
  4. ensures that the environment is taken into account in all policy decisions and at all stages in the plan process; and
  5. demonstrates how the policies have had regard to the environment.

The Appraisal has provided a rigorous framework for considering the Plan and, as such, is a positive tool. It has, among other things, highlighted how much there is still to do. This is not surprising given that the Plan is taking the first step in a long progress towards more sustainable development in the District. It is also not beginning with a blank canvas. In particular, the Plan is carrying forward many difficult decisions made by the Council in response to the severe economic impact of the Channel Tunnel and the Single European Market on the District. The environmental consequences of these past decisions come through in the Appraisal.


In considering new development, as opposed to carrying forward sites, the Appraisal indicates that the Plan is generally consistent with the Environmentally Sustainable Objectives. In some cases where this is not so, it is because not all Objectives are compatible with each other. Policies also need to take account of national guidance and the Appraisal highlights areas where such advice may conflict with, and be contrary to, sustainable development. For example, protecting the countryside and not requiring operators to seek permission for some telecommunication masts. In addition, the Plan is not allowed to encroach on aspects of sustainability if these are seen to be the remit of other bodies. These conflicts are also brought out by the Appraisal.



Each policy has been appraised against all the Objectives in Chapter Two, but only the Environmentally Sustainable Objectives have been used as a measure for the Environmental Appraisal. Judging the policies against the other Objectives has been undertaken to give an indication as to how each policy contributes toward the overall Objectives.


In assessing the environmental effects, it has been assumed that the Environmentally Sustainable Objectives are reasonable environmental criteria, in that they have been drawn from a range of ideas put forward by others seeking higher environmental standards. This of course does not take account of local issues and circumstances. In carrying out the Appraisal, it has been assumed that all other policies of the Plan are operating.


The Appraisal is based on the predicted outcome of a direct relationship between the Policy and Objective. For example:-

  1. restricting shopping uses within the Dover Primary Frontage (Policy SP1) has no direct relationship with identifying and protecting open spaces (Objective 3);
  2. dualling the A2 (Policy TR4) directly works against protecting the countryside (Objective 1); and
  3. developing Tilmanstone Spoil Tip (North) for Industrial Uses (Policy LE10) makes use of redundant resources rather than exploiting new ones (Objective 7).

For each assessment it should be noted that the effect of the Policy is being compared against what would happen should there be no policy. The following codes have been used in the Appraisal matrix (which can be found in Figure 16.4 at the end of this chapter):-

if the policy contributes to meeting the Objective
if the policy is likely to contribute, but the effects are unpredictable
 if the policy works against meeting the Objective
 if the policy is likely to work against the Objective, but the effects are unpredictable
 if it is not possible to predict at this stage what the effects on the Objective will be
 if the policy has no direct relationship or the effects are insignificant
 If there has been an improvement in any aspect of a policy following consultation the box appears shaded
 If there has been a worsening in any aspect of a policy following consultation the box appears shaded as black



The analysis broadly considers whether the Objectives are supported or undermined by policies, where policies rate poorly against the Objectives, and whether Objectives and policies have weak relationships with each other. The general conclusions are summarised below. A brief summary of findings for each policy is given within each chapter.

Objectives Strongly Supported by Policies


Many policies provide strong support for the Objectives. This is especially the case with general policies, which set out criteria against which new development will be judged. These score well in terms of protecting the countryside (Objective 1), reducing pollution (Objective 4), re-using redundant land and buildings (Objective 7), protecting the historic environment (Objective 8), concentrating investment in urban areas (Objective 10) and locating new development where it can minimise the need to travel (Objective 13). The Plan has a strong environmentally sustainable theme as it applies to new development. Particularly worth highlighting are the chapters on countryside and shopping, which generally score well. In addition, various policies seek to return up to 112.7 Ha. (310.5 acres) of previously developed land to countryside (see Figure 16.1). Although the strength varies through the Plan, the Appraisal does show a spread of support for sustainability across the Objectives.

Figure 16.1: Estimated Area of Developed Land Returned to Countrside
Betteshanger Colliery Spoil Tip
Snowdown Colliery Spoil Tip

Objectives Undermined by Policies


A major conclusion highlighted by the Appraisal is that some of the specific development proposals undermine certain of the Objectives. In particular, if all the proposals in the Plan were implemented by 2006, it is estimated that 140 Ha. (350 acres) of countryside would be lost to development - contrary to Objectives 1 and 2 (see Figure 16.2). This amounts to 0.6% of all land in the District.

Figure 16.2: Estimated Area of Countryside Lost to Development
New commitments
A2 widening (esimate)
Pzifer expansion
Albert Road, Deal
Existing commitments  
Aylesham expansion
White Cliffs Business Park Phase II/III1
Sub-total 82.5
1 White Cliffs Business Park appears as a loss of countryside even though it is shown on the Proposals Map as within the Urban Boundaries. This is because if it was not proposed for employment development it would have remained outside the urban area.

These sites are, by definition, outside the urban area and represent significant investment contrary to Objective 10, are poorly located in terms of minimising the need to travel (Objective 13) and consequently encourage car-borne commuting and air pollution (Objective 4). Given the significant amounts of redundant land available, the loss of fresh land is contrary to Objective 7.


However, only the expansion of Pfizer, an employment site at Albert Road, Deal, new housing sites at Ash and widening of the A2 are new sites identified by the Plan (about 40% of the total). The A2 widening, which has been brought about directly as a result of the Channel Tunnel, amounts to 21% of the land take. About 52% of the land lost is for economic development reasons which, in the main, have also been driven by the Channel Tunnel. Aylesham, which is a longstanding Structure Plan commitment, accounts for 24%

Objectives with Weak Relationships to the Policies


Some Objectives have been shown to have only weak relationships with the policies. In many instances, these can be easily explained because the policies deal with specific issues. For example, encouraging the transport of freight by water and rail (Objective 15) has no relationship with the housing policies. However, the Appraisal has highlighted some weak relationships where strong ones would have been expected. The restrictive wording of Objective 3 (open space) means it has particularly weak relationships with many policies. Objective 7 encompasses the re-use of materials as well as land and buildings. This is only reflected in policies dealing with the spoil tips.

Policies rating poorly against the Objectives


Not all policies are going to relate well to all Objectives. Indeed, some Environmentally Sustainable Objectives are not compatible with each other. An important part of the Appraisal has been to identify policies or policy areas which rate poorly to the Objectives. Those with the poorest rating have tended to work against the Objectives of restricting development in the countryside (Objective 1), re-using redundant resources (Objective 7), concentrating investment in the urban area (Objective 10), minimising the need to travel (Objective 13) and making provision for cyclists, pedestrians and public transport (Objective 14). Policies and policy areas conflicting with one or more of the Objectives listed above are:-

  1. Policies LE3, 6 and 9, which allocate sites for employment development;
  2. Policies allowing employment and tourism development in rural areas (though such policies are required by PPG7);
  3. Policies TR4 and 5 on new road construction;
  4. Policy TR13 on telecommunications masts (required by PPG8);
  5. Policies HS10, 13 and 14 allowing for housing development outside the urban areas (these are accepted as exceptions); and
  6. Aylesham (Policy AY1 and several associated policies).

Policies with Weak Relationships to the Objectives


Some policies and policy areas have weak relationships to the Objectives, but this is not surprising because they relate to specific policy areas. Others have no direct relationship with the Environmentally Sustainable Objectives, but essentially deal with accessibility. Five policies have very little or no relationship with the Objectives, but warrant further consideration. Policy DD11 (security in new developments), Policy WE8 (flood risk) and Policy CF3 (seeking developers to fund community facilities) do not relate to any of the Environmentally Sustainable Objectives. With the exception of Policy CF3 these policies essentially relate to human safety and/or amenity which is not reflected in any Objective. Policy LE8 relating to Southwall Road has limited relationships with the Environmentally Sustainable Objectives. This is because the policy is intended to deal with a site causing disturbance to local amenity.


 Whilst the Appraisal has shown strong support for the Objectives in some areas, it has highlighted conflicts elsewhere. As noted in paragraphs 16.03-04, this is not surprising given that this is the first time that sustainable development has been considered in a local plan for the District and that the Plan includes the legacy of past decisions and commitments.



Monitoring is an integral part of the Plan as it is important to check:-

  1. that policies are working towards the Plan's Aims and Objectives;
  2. that the assumptions on which the Plan is based are still true;
  3. that the Plan is up to date and soundly
  4. based; that the proposals are being implemented;
  5. that the policies are being successful in guiding development; and
  6. whether additional policies are required in any Review of the Plan.

In order to monitor the Plan, the Council has identified a series of Indicators, Measures and Targets (see Figure 16.3). Targets offer a clear view of what the Plan is trying to achieve and, in the main, give a measure against which to judge the Plan's effectiveness. However, in some cases (especially those relating to pollution), the Targets extend well beyond the influence of land use planning but are, nevertheless, indicators of environmental well-being.


Monitoring will make use of information that is easily collectable and readily available. The results of monitoring will be published in the form of an Annual Monitoring Statement. It will include details of progress toward the Targets identified. Results will be fed into future Reviews of the Plan.

Figure 16.3: Indicators and Targets
Development in the Countryside Ha. of land lost to development by designation
None over Plan allocations
Number of Planning applications refused
All except where exceptions policy
Nature Conservation
Number and status of sites
No reduction in number and status
  New sites designated and existing sites upgraded through management initiatives
Biodiversity Action Plan
Contribute to Kent BDAP for local habitats and species
Northh Downs Management Plan
Prepared by new Joint Advisory Committee
Kentish Stour Countryside Project
Prepared by newly established Project
Stour Estuary Management Plan
Prepared by newly established Plan
Open Space
OS for protection
Identify by end 1996
Ha OS lost to development
None identified for protection
Local OS standards
Identify by end 1996
Ratio of existing OS to requirement
At least 1:1
Air quality
Annual increase in number of good 'air quality' days in the year
  District monitoring of Nitrous Oxides, Sulphur Dioxide and Ozon
Water quality
All beaches pass EC standard
  River water quality at least maintained 4,2
Derelict and contaminated land
Reduction in area of existing derelict and contaminated land
  Polluter pays principle in all new commercial permissions
Light pollution
New development incorporating full cut-off lanterns
Energy Saving
Number of buildings achieving a SAP rating of 90
75% of new development
Percent of housing stock with an energy rating of 10
Annually increasing percent
Renewable Energy Electricity generated from renewable sources
1 MW
Recycling Resources
Amount of domestic waste
25% recycled
Permissions to demolish buildings/changes of use ratio
Annual reduction
Percent of vacant commercial units and Council houses
Annual reduction
Historic Environment
Conservation Area Assessments
Prepare scheme for all CAs by end 2003
CAP scheme At least 1 running every year
Listed buildings at risk
No increase in number on list
Demolition of listed buildings
Urban Concentration Percent of population living in urban areas
Increase above 1991 Census figure
Percent of Social Classes 1 and 2 living in urban areas
Increase above 1991 Census figure
Number of houses permitted outside urban areas
Annual reduction
Village Services and Needs
Number of shops, social and community facilities
No less than at mid 1996
Hectares and floorspace for rural enterprise by parish
Amount of employment land in relation to resident workforce to increase
Location of Development Resident workforce to number of jobs in Dover and Deal
No net out-commuting 4,11,13,14
Permissions granted contrary to location criteria policies
Travel Patterns and Options
Travel to work by car
Percent no greater than 1991 Census
Level of bus and train services
No less than at mid 1996
Length of separated cycle route
Annual increase
Urban footpath improvement schemes
Permissions involving freight by water or rail
Increased tonnage of rail and water - freight through District
State of Local Economy
Floorspace permitted and developed 30 Ha land developed and occupied between 2001-2006
Allocations at Deal
Deal allocations developed and occupied
Floorspace lost to non B Use Classes None
Percent Unemployed
Ratio of District to Kent average closes
Jobs by Industrial Sector
District profile moves towards Kent average
Number of new social dwellings
Ratio of social to market housing does not fall
Percent of new dwellings with access for the disabled
Increases manually
Features to help disabled to town centres
Improvements completed by 2001

1To or throughout the Plan Period unless otherwise stated.