Section seven

Historic and natural environment

Our historic and natural environment makes us proud of where we live; it inspires and engages us, improving the quality of life for our communities. It makes our area unique and special, as well as providing for economic success for the district and beyond.

Our historic environment is outstanding and our heritage is all around us, including a World Heritage Site (Canterbury Cathedral, St Martin’s Church and St Augustine’s Abbey), 1,880 listed buildings and 97 conservation areas.

With a variety of landscapes, species and habitats, many of which are protected, our district’s natural environment is exceptionally rich and diverse. Access to nature and also our world-class historic environment can improve everyone’s physical and mental health, wellbeing and happiness.

Through the issues consultation and engagement so far, we know that people value both the natural and historic environments and we’ve prepared options for how we should approach these issues through the new Local Plan.

In this section we are asking about things like improving biodiversity, protecting our valued landscapes, improving open spaces and retrofitting historic buildings with energy efficiency and renewable energy technologies.

Heritage and the historic environment

Protecting and enhancing our heritage assets

The Canterbury district has a rich heritage that makes a valuable contribution to the distinctive character of the area, a sense of place, cultural identity and quality of life. The historic environment is an irreplaceable and valuable asset which makes a significant contribution to economic development and tourism, education, regeneration, recreation and leisure, sustainability, and community and cultural development.

Different types of heritage assets are protected, enhanced and managed in different ways, and through different legislation:

  • The Planning (Listed Buildings and Conservation Areas) Act 1990
  • The Ancient Monuments & Archaeological Areas Act 1979
  • The Protection of Wrecks Act 1973

National planning policies recognise the historic environment as a key element of sustainable development, and set out that heritage assets are an irreplaceable resource, and should be conserved in a manner appropriate to their significance so that they can be enjoyed by existing and future generations.

The high quality of Canterbury’s historic environment means that heritage is very important in the district’s strategies including transport, economic development, and culture and tourism. Our Heritage Strategy combines these strategies into one vision for heritage as a way to deliver long-term economic, social and environmental benefits to the district. The Heritage Action Plan outlines a set of objectives looking at safeguarding, promoting and capitalising on our unique historic environment.

From earlier consultation, there is a clear agreement that the historic environment is of significant value that should be both protected and enhanced.

Where buildings are empty or not used enough, they should be brought back into use and new development should combine the distinctiveness of the historic environment into new design.

Our heritage also promotes tourism, defines character, boosts our local economy and supports growth. So it’s important that our historic environment is preserved and enhanced to continue to contribute to the district’s economic, social and environmental success.

Issue NE1. How can we protect and enhance our heritage assets?

Option NE1A (preferred option) – continue with the current Local Plan approach

The current Local Plan sets out detailed policies for:

  • the World Heritage Site
  • buffer zone and views
  • heritage assets like listed buildings, conservation areas, shopfronts, archaeology and historic landscapes and parks and gardens

We’ve reviewed these policies and think they are still effective and up to date.

Option NE1B – make changes to the current Local Plan policies

Although we don’t think the current policies need updating, you can suggest changes to improve their effectiveness.

Supporting the adaptation of the historic environment to achieve improvements in carbon emissions and energy efficiency

Planning decisions can contribute to national and corporate objectives for addressing climate change by shaping new and existing development in ways that reduce carbon emissions and build resilience.

The historic environment in our district has a significant role to play in meeting current and future climate change targets. Opportunities to mitigate or adapt to climate change, and secure sustainable development through the reuse or adaption of heritage assets to minimise the consumption of building materials and energy is beneficial.

There are two key aspects to addressing the relationship between the historic environment and climate change:

  • reducing greenhouse gas emissions towards net zero goals
  • making buildings resilient to a changing climate

The energy and carbon performance of most historic buildings can be improved, but striking the right balance between benefit and harm is not always easy.

The difference in traditional designs and construction methods means it is important that a ‘one size fits all’ approach is not pursued, and that energy improvement proposals show a whole building approach, based on an understanding of the construction and history of the building. For example, to find a solution that keeps heritage significance, saves energy, and maintains a healthy indoor environment.

Houses of traditional construction don’t perform in the same way as modern ones. Most modern buildings depend on impermeable barriers to control the movement of moisture and air through the building fabric. In contrast, traditional forms of building construction take up moisture from their surroundings and release it according to ambient conditions. They also tend to heat up and cool down more slowly.

Assessing development proposals that want to improve energy efficiencies or building resilience would need consideration of the suitability of the measures for a particular property against the risk of harming the significance of the heritage asset.

Installing solar panels is currently a national permitted development right in much of the district, but this right does not exist in conservation areas where planning permission is required.

People made it clear that the historic environment is of significant value that should be both protected and enhanced.

It’s also recognised that there is capacity for the historic built environment to incorporate climate change adaptation solutions while keeping significance and character. For example, many people supported a more relaxed approach to solar panels in the district.

Issue NE2. How can we support the adaptation of the historic environment to achieve improvements in carbon emissions and energy efficiency?

Option NE2A – continue with the current approach which gives general design policies

This approach gives general design policies, but doesn’t offer design guidance specifically on encouraging the adaptation and retrofitting of buildings in conservation areas and historic buildings.

Option NE2B (preferred option) – support the adaptation and retrofitting of buildings in conservation areas and historic buildings through new guidance

This approach will give better guidance for adapting buildings in conservation areas and historic buildings, to improve energy efficiency and carbon emissions.

Plans that want to improve energy efficiency or building resilience can be assessed against their suitability for the particular property and against the risk of harming the significance of the heritage asset.

This would make sure the process is carefully managed so that the historic environment and its heritage assets are kept for present and future generations, while also helping tackle and respond to climate change.

Protecting and enhancing biodiversity and green and blue infrastructure (parks, rivers and other spaces)

We know that wildlife species and habitats are declining globally, and that climate change is one of the factors driving this.

Our district has many sites recognised internationally, nationally and locally for their protected plants, animals and habitats, and 229 of England’s most threatened species have been recorded in the district.

These designated sites are protected through existing legislation and national planning policies, and will continue to be protected in the same way through the new Local Plan:

  • Ramsar sites (wetlands), special protection areas (SPAs) for birds and their habitats, and special areas of conservation for specific habitats and species of importance are internationally important. They are given the highest level of protection, and we have five in our district
  • sites of special scientific interest – with important wildlife or geological value are nationally important and there are 15 in our district
  • marine conservation zones – nationally rare or threatened habitats and species in our seas – are nationally important and there are two in our coastal waters
  • national nature reserve sites – the finest wildlife and geological sites – are nationally important and there are two in our district
  • Royal Society for the Protection of Birds (RSPB) reserves are nationally important and there are two in our district
  • local nature reserves (LNRs) are locally important. There are 11 LNRs in our district, which promote nature conservation and increase public enjoyment and understanding of nature
  • local wildlife sites (LWS) are locally important. There are 49 LWS representing the local character and distinctiveness and supporting biodiversity
  • roadside nature reserves (RNR) are locally important wildlife corridors with scarce or threatened habitats or species. There are nine in our district
  • regionally important geological or geomorphological sites (RIGS) are locally important as educational, research, historical or recreational resources. There are five in our district

As we develop the new Local Plan we will complete a Habitats Regulations Assessment (HRA) which will look at whether the plan might affect the protected features of a designated habitat site.

The HRA in the current Local Plan identified that more new development could potentially impact wintering birds because of a potential increase in recreational disturbance. The Thanet Coast and Sandwich Bay SPA and Thames, Medway and Swale SPA strategic access management and monitoring strategies were written to help stop this.

Along with potential impacts to wintering birds, we are aware that there are water quality concerns at the Stodmarsh protected site, and that more development could cause air quality impacts in the Blean complex (woods) conservation area.

The HRA will look at these potential impacts and identify any others, which will then be part of future Local Plan work. HRA options are not proposed at this stage.

The government has recognised the decline and break up of species and habitats and the Environment Bill is part of their response. The bill is currently making its way through Parliament and is expected to introduce a mandatory requirement for developments to show a 10% improvement in biodiversity – known as biodiversity net gain – for the majority of developments, as well as other measures.

Green and blue infrastructure can create and enhance wildlife species and habitats. It also has other benefits like helping address climate change, improving health and wellbeing, providing sustainable transport routes, and improving water resources and flood management.

Blue infrastructure is water elements like rivers, canals, ponds, wetlands and floodplains.

Green infrastructure includes:

  • parks, gardens and country parks
  • natural and semi-natural urban and rural green spaces like Duncan Downs
  • green (wildlife) corridors, like river banks, cycleways, and rights of way
  • outdoor sports facilities like playing fields
  • amenity green space, like informal recreation spaces, green spaces in and around housing, domestic gardens and village greens
  • allotments, community gardens, and urban farms
  • cemeteries and churchyards;
  • accessible countryside in urban fringe areas
  • woodlands and trees
  • green roofs and walls

The Canterbury district green infrastructure strategy 2018-2031 aims to ‘deliver an integrated and multifunctional green infrastructure network covering all of Canterbury district, which supports sustainable development, health and wellbeing and economic growth, as well as providing a distinctive and high quality local environment that is managed and valued by Canterbury’s communities’.

Key actions are identified across the district like the Seasalter Marshes project which is the creation of a Wetlands RSPB nature reservation, and expansion and improvement of the Duncan Downs at Whitstable.

Work is also starting on a district tree strategy and a pollinator plan, as well as biodiversity net gain and local recovery strategies to support the Environment Bill at a local level.

National planning policies make it clear that valued landscapes, sites of biodiversity or geological value and soils should be protected and enhanced through Local Plans. They should be protected according to the importance of their designation.

Consultation on changes to national planning policies that would see blue spaces combined in the definition of green spaces has recently taken place, and the outcomes and implications of these changes will be considered.

The break up of habitats and limited greenery, particularly in high traffic areas, were concerns.

To help address this, more urban greening and wildlife corridors were suggested. There was also concern over the loss of biodiversity and destruction of ecosystems. However, there wasn’t much said on the amount of biodiversity net gain which should be found – whether that should be 10%, 20% or have no limits.

Trees were a key issue, with many people saying that more trees should be planted, and there were concerns about the loss of trees through development and inappropriate management.

Issue NE3. How should we protect and enhance biodiversity and green and blue infrastructure?

Option NE3A: continue with the current Local Plan approach of new developments providing and extending green infrastructure (including trees) where they can, and set a 10% biodiversity net gain requirement

The current approach emphasises the importance of green spaces (including trees) being provided through new developments.

Where they can, new developments will provide and establish green space networks to support wildlife and the health and wellbeing of our communities.

This option would support the minimum 10% biodiversity net gain on the majority of new developments, as mentioned in the Environment Bill.

Option NE3B – require new developments to enhance existing, or provide new, green infrastructure to conserve, and where possible enhance blue infrastructure, plus a 10% biodiversity net gain

This approach would build upon the green spaces and biodiversity net gain options in Option NE1A by also looking to conserve, and where possible, enhance blue spaces.

This option would support the minimum 10% biodiversity net gain on the majority of new developments, as mentioned in the Environment Bill.

Option NE3C (preferred option) – require new developments to enhance existing, or provide new, green infrastructure to conserve, and where possible enhance blue infrastructure, plus a 20% biodiversity net gain

This option builds on Option NE3B, emphasising the importance of both green and blue spaces.

It would increase the requirement for biodiversity net gain from 10% to 20%. This would support one of the principles in the Kent Downs AONB Management Plan 2020-2025 as well as work at a regional level.

Protecting and enhancing the character of our valued landscapes

Making sure that the local landscape designations (areas of high landscape value) continue to protect our valued landscape

Our district has an exceptionally rich and diverse natural environment, with a variety of important landscapes. This makes the landscape character an important asset which should be reinforced, restored, conserved or improved as appropriate.

The high value of our landscapes has led to several existing local designations to add increased protections in some areas.

One of these designations is areas of high landscape value (AHLVs), also known as local landscape designations (LLDs). AHLVs or LLDs are normally designated for their essential physical, environmental, visual, cultural and historical value in the landscape, which might be unique, exceptional or distinctive to the area.

We have five of designations in the current Local Plan:

  • North Kent marshes AHLV
  • Wantsum Channel AHLV
  • North Downs AHLV
  • Blean Woods AHLV
  • Canterbury AHLV (the Valley of the River Stour around Canterbury)

In these designated areas, any development must be thought about in relation to the landscape character (for example, it must have no significant impact upon the historic setting, archaeological or nature conservation interests) and should enhance the landscape for the future.

The Canterbury AHLV is slightly different to the other four areas, as it protects the historic landscape setting of the city and the World Heritage Site. The Planning Inspector who assessed the current Local Plan said that the Canterbury AHLV didn’t relate to landscape quality, but helped prevent visual damage to the setting of the city.

The Landscape Character Assessment and Biodiversity Appraisal (2020) updates our evidence on various character areas in the district and how these can be improved over the period of the new Local Plan.

The AHLV and LLD evidence has also been updated and the Canterbury District Local Landscape Designations: Review and Recommendations report (2021) says that the North Downs LLD, Blean Woods LLD, North Kent Marshes LLD and Wantsum Channel LLD all meet the designation criteria, based on up to date guidance.

The report makes recommendations about updating some existing boundaries and renaming some designations with more locally specific names. There is also a recommendation to create a new Stour Valley Floodplain (east) LLD, to protect the valued landscape associated with the Great Stour and Little Stour rivers.

The Canterbury City AHLV: Review for Local Landscape Designation report (2021) says that the area didn’t meet the same criteria as the other LLDs, and that it might be difficult to keep the Canterbury city AHLV designation based on current evidence and guidance.

The report sets out two alternative recommendations: (1) to use a strong criteria-based policy to set out key considerations for development proposals, or (2) to keep it, with some boundary modifications, as a new type of designation called ‘landscape context of Canterbury’.

Concerns were raised about damage to the natural environment through developments, over development and permitted development, and the loss of green space, open space and open countryside.

Issue NE4. How should we make sure that the local landscape designations (areas of high landscape value) continue to protect our valued landscapes?

North Kent Marshes LLD

Option NE4A – keep the North Kent Marshes LLD as identified in the existing Local Plan

This option would keep the current North Kent Marshes LLD boundary. View the boundary on a map.

Option NE4B (preferred option) – keep the North Kent Marshes LLD current boundaries and rename as Seasalter Marshes LLD

This option would keep the current boundary but would rename it to Seasalter LLD, as the existing name came from a county-wide assessment that extends the designation outside of our district boundary. View the boundary on a map.

Wantsum Channel LLD

Option NE4C – keep the Wantsum Channel LLD as identified in the existing Local Plan

This option would keep the current Wantsum Channel LLD boundary. View the boundary on a map.

Option NE4D (preferred option) – keep the Wantsum Channel LLD with the boundary changes suggested

This option would change the boundary of the Wantsum Channel LLD based on the report’s recommendations to exclude development and align with the district boundary. View the boundary on a map.

North Downs LLD

Option NE4E – keep the North Downs LLD as identified in the existing Local Plan

This option would keep the current North Downs LLD boundary. View the boundary on a map.

Option NE4F (preferred option) – keep the North Downs LLD with the boundary changes suggested

This option would change the boundary of the North Downs LLD based on the report’s recommendations. This would mean minor boundary changes because of landscape and developments, and removing the area covered by the Kent Downs Area of Outstanding Natural Beauty (AONB), because the AONB designation is of national importance and provides protection significantly above that of a LLD. View the boundary on a map.

Blean Woods LLD

Option NE4G – keep the Blean Woods LLD as identified within the existing Local Plan

This option would keep the current Blean Woods LLD boundary. View the boundary on a map

Option NE4H – keep the Blean Woods LLD with boundary changes 1 – 4 and 5i

This option would change the boundary of the Blean Woods LLD to align it with the landscape (valley floor) (1), remove a solar farm (2), and include three woods: Buckwell Wood (3), Kemberland Wood and Little Hall Wood (4).

The purpose of the landscape designation is to recognise the high landscape value of the woodland, which is also designated as a SAC and a SSSI.

The boundary to the south between the University of Kent and Clowes Wood would extend the designation to incorporate the Sarre Penn Valley, the Crab and Winkle Way and the distinctive church of St Cosmos and St Damian in the Blean, on the ancient salt road to the coast (5i).

This would be a change from the purpose of the Blean Woods LLD as it would include predominantly farmland and horticultural or orchard land uses. View the boundary on a map.

Option NE4I – keep the Blean Woods LLD with boundary modifications 1 – 4 and 5ii

This option would make the same changes to 1-4 as above.

The boundary to the south between the University of Kent and Clowes Wood would extend the designation to the valley that marks the rise to the Stour Valley slopes and university, which is roughly inline with the Sarre Penn Valley (footpath).

Although this would be a smaller extension compared to option NE4H it would still be a change from the existing purpose of the Blean Woods LLD as it would include predominantly farmland. View the boundary on a map.

Option NE4J – keep the Blean Woods LLD with boundary changes 1 – 4, and 5iii (Tyler Hill Road)

This option would make the same changes to 1-4 as above.

The boundary to the south between the University of Kent and Clowes Wood would extend along Tyler Hill Road. This would be a smaller extension compared to option NE4H and NE4I, but would still be a change from the existing purpose of the Blean Woods LLD. View the boundary on a map.

Option NE4K (preferred option) – keep the Blean Woods LLD with boundary changes 1-4, and changes between the University of Kent and Clowes Wood

This option would make the same changes to 1-4 a above.

The boundary to the south between the University of Kent and Clowes Wood would be kept as it currently is.

A landscape criteria for this area outside the Blean Woods LLD boundary could make sure that any development proposals in this area take into account the special characteristics and sensitivities of the area. View the boundary on a map.

Stour Valley landscape

Option NE4L – think about a new Stour Valley Floodplain (east) LLD

The LLD report suggested an extra area at Stour Valley Floodplain (east). This option would involve setting out an additional LLD designation, or potentially a descriptive policy, in the new Local Plan to apply to proposals for development in this area. View the boundary on a map

Option NE4M (preferred option) – continue with the current approach to the Stour Valley landscape

The area of land identified by the report for a Stour Valley Floodplain (east) LLD is already heavily protected because of its ecological importance; including the Stodmarsh SPA, SAC and SSSI.

A high proportion of land is in Flood Risk Zone 2 or 3 (areas most at risk from flooding) which are also protected through national planning policies.

This option would not need an additional local landscape designation in this area, given the national and international protections already there.

Landscape currently protected under Canterbury AHLV

Option NE4N – keep the area with some boundary changes as a new designation – ‘landscape context of the historic city of Canterbury’

This option would keep the Canterbury AHLV area broadly as it is, with some boundary changes based on up to date evidence, as a new and different type of local designation.

Although it’s not a landscape or a heritage designation, this would mean that the area is valued for the role that the landscape plays in views and the setting of the city.

The designation would include areas of different landscape types (valley, wood hills, and so on) which each play different roles as landscape setting, identified with a boundary. View the boundary on a map.

Option NE4O (preferred option) – delete the boundary and replace with a criteria based approach setting out considerations like views, landscape character, and historic setting for development which might impact on the landscape surrounding Canterbury city

The area covered by this designation is important to the character of the historic city, but the landscape is not high quality enough to justify a landscape designation, so other requirements are in place to protect the historic nature of the city.

This option would provide a strong criteria-based approach, linked to the information in the Landscape Character Assessment and Biodiversity Appraisal (2020), to set out what is important in the surrounding landscape and a list of considerations for development proposals show that any impacts will be addressed.

The defined spatial area would be removed, meaning that the application of the policy would extend further out from the city, but proposals on areas of low quality landscape with no significant impacts on the setting or views would not be impacted greatly.

Making sure our approach to green gaps is still effective

Green gaps are another local designation which aim to keep the separate identities of certain villages and towns within the district by preventing built up areas from merging together.

National planning policies allow us to identify land where development is inappropriate. Gradual merging can not only harm the character of the open countryside but also negatively impact the setting and special character of villages and coastal towns.

There are eight green gaps in the existing Local Plan:

  • between the urban areas Herne Bay and Whitstable
  • between Canterbury and Sturry
  • between Sturry and Westbere
  • between Sturry and Hersden
  • between Sturry and Broad Oak
  • between Blean and Rough Common
  • between Canterbury and Tyler Hill
  • between Canterbury and Bridge

In green gaps most types of development are not allowed, apart from sports and recreational uses. The green gap between Herne Bay and Whistable also promotes education, outdoor leisure uses and allotments.

In the same way as green gaps, areas of land currently designated as protected open spaces (Policy OS9 in the adopted Local Plan) aim to prevent town cramming and some act as buffers.

These areas of land are different to sites identified in our open spaces strategy; which instead focused on publicly accessible spaces like parks, natural areas and recreation spaces.

These areas of land are currently being reviewed for the next stage of the Local Plan.

The Green Gaps and Local Green Spaces Review (2021) reviewed all existing green gaps and local green spaces.

Limited development has happened within the green gaps but some boundary changes were suggested based on the The Landscape Character Assessment and Biodiversity Appraisal (2020), which also gave guidance on the function of existing green gaps.

Concerns were raised about damage to the natural environment through developments, as well as urban sprawl, the merging of settlements and a desire to keep the separate identities of settlements.

People also mentioned the loss of green space, open space and open countryside.

Issue NE5. How should we make sure our approach to green gaps is still effective?

Approach to development allowed in green gaps

Option NE5A – keep the current approach to development acceptable in green gaps

This option would continue to support recreation and sports within the green gaps.

The larger green gap between Herne Bay and Whistable would continue with its slightly different function and support education, which could benefit both coastal towns.

A criteria would be set across all green gaps to make sure there are no negative impacts on the environment and character of the area from development.

Option NE5B (preferred option) – broaden the types of development that might be acceptable in these areas to encourage community facilities, including open space and recreation

This option would allow other specific types of infrastructure (like community infrastructure and health infrastructure) which are needed and can’t be put elsewhere, to be delivered within these areas.

Residential development would continue to not be acceptable. These would be subject to strict criteria, like design and layout, to make sure there are no negative impacts on the environment and character of the area from development.

Green gap between Sturry and Westbere

Option NE5C – keep the existing green gap identified in the current Local Plan

This option would keep the existing green gap without any changes to the boundaries. View the boundary on a map

Option NE5D (preferred option) – keep the green gap with suggested boundary changes to exclude a building to the east

This option would mean changes to the existing boundary to the east of the green gap to remove the existing building. View the boundary on a map.

Green gap between Sturry and Hersden

Option NE5E – keep the existing green gap identified in the current Local Plan

This option would keep the existing green gap without any changes to the boundaries. View the boundary on a map.

Option NE5F (preferred option) – keep the green gap with suggested boundary changes around the garage

This option would mean changes to the existing boundary to exclude the garage site. View the boundary on a map.

Green gap between Herne Bay and Whistable

Option NE5G – change the boundary of the existing green gap

Although the Green Gaps and Local Green Spaces review didn’t identify or recommend changes to the boundary, it did highlight that there are some areas at the edge of the designation which are not open countryside.

This option could change the boundary to remove some or all of these areas.

Option NE5H (preferred option) – keep the existing green gap identified in the current Local Plan

This option would keep the existing green gap without any changes to the boundaries. View the boundary on a map.

Green gap between Sturry and Broad Oak

Option NE5I – change the boundary of the existing green gap

The Green Gaps and Local Green Spaces review didn’t identify or recommend changes to the boundary, but it did highlight that there are some areas at the edge of the designation proposed for development as part of the strategic site at Broad Oak.

This option could change the boundary to remove some or all of these areas.

Option NE5J (preferred option) – keep the existing green gap identified in the current Local Plan

This option would keep the existing green gap without any changes to the boundaries. View the boundary on a map.

Green gap between Canterbury and Tyler Hill

Option NE5K – change the boundary of the existing green gap

The Green Gaps and Local Green Spaces Review didn’t identify or recommend changes to the boundary, but it did highlight that there are some areas surrounding the green gap which could prevent the two settlements merging. This option could change the boundary to include some or all of these areas.

Option NE5L (preferred option) – keep the existing green gap identified in the current Local Plan

This option would keep the existing green gap without any changes to the boundaries. View the boundary on a map.

Green gap between Canterbury and Bridge

Option NE5M – change the boundary of the existing green gap

The Green Gaps and Local Green Spaces review didn’t identify or recommend changes to the boundary, but it did highlight that there are some areas at the edge of the designation which are not open countryside.

This option could change the boundary to remove some or all of these areas.

Option NE5N (preferred option) – keep the green gap and think about opportunities to change the boundaries

This option would keep the existing green gap without any changes to the boundaries. View the boundary on a map.

Green gap between Canterbury and Sturry

Option NE5O – change the boundary of the existing green gap

The Green Gaps and Local Green Spaces review didn’t identify or recommend changes to the boundary, but it did highlight that there are some areas at the edge of the designation which are not open countryside.

This option could change the boundary to remove some or all of these areas.

Option NE5P (preferred option) – keep the existing green gap identified in the current Local Plan

This option would keep the existing green gap without any changes to the boundaries. View the boundary on a map.

Green gap between Blean and Rough Common

Option NE5Q – change the boundary of the existing green gap

The Green Gaps and Local Green Spaces review didn’t identify or recommend changes to the boundary, but it did highlight that there are some areas at the edge of the designation which are not open countryside.

This option could change the boundary to remove some or all of these areas.

Option NE5R (preferred option) – keep the existing green gap identified in the current Local Plan

This option would keep the existing green gap without any changes to the boundaries. View the boundary on a map.

New green gaps

Option NE5S – think about opportunities to identify new green gaps

The Green Gaps and Local Green Spaces review didn’t recommend any new green gaps, but there might be new areas which should be protected to prevent settlements merging and causing negative impacts on their setting and special character.

Option NE5T – (preferred option) don’t designate new green gaps

Based on the evidence there aren’t any areas that need to be designated as a green gap.

Managing outdoor lighting to support tranquility

The Kent Downs Area of Outstanding Natural Beauty (AONB), which is a nationally important landscape designation, covers around 27% of our district, and the destination protects the distinctive character and natural beauty of the exceptional landscape.

Our district is also one of the most wooded districts in south east England, with around 14% covered by ancient woodland. We also have 21.6 km of coastline which provides natural beauty from the various coastal landscapes.

One important aspect of landscape character and tranquility is dark skies – areas with low to no light pollution. In the district; particularly in the Kent Downs AONB to the south and at Blean Woods to the north, there are areas with very low levels of light pollution where dark skies can be experienced.

Minimising the impact of light pollution is important as external lighting can harm residential homes and biodiversity. However, there is also demand for artificial lighting for safety (for example, road schemes), crime prevention like security lighting and leisure activities that use flood lights, for example.

This makes light control a key design consideration in development proposals, particularly for developments in areas of darker skies. Obtrusive light is normally because of poorly designed or insensitive lighting schemes.The main problems are:

  • sky glow – the orange glow around some urban areas
  • glare – the uncomfortable brightness of a light source against a darker background
  • light trespass – light spilling beyond the boundary of the property where it is not wanted or needed

The Landscape Character Assessment and Biodiversity Appraisal (2020) also reviewed dark skies and tranquility across the entire district, identifying areas in the AONB, Blean Woods, Seasalter marshes (north west of the district), and areas to the east of the district, as having the darkest skies and highest level of tranquility within the district.

The Kent Downs AONB management plan gives principles and guidance for any activities or developments within the AONB.

Concerns about light and noise pollution and their negative impacts on wellbeing and the natural environment were raised.

Protecting areas of tranquility and dark skies was suggested as a solution.

Issue NE6. How should we manage outdoor lighting to support tranquility?

Option NE6A – continue with the current Local Plan approach of using a design criteria when assessing outdoor lighting proposals

The current Local Plan provides a list of criteria which proposals for new outdoor lighting have to show they meet through their planning application.

Option NE6B (preferred option) – include clear requirements for development proposals to conserve or enhance the tranquility provided by dark skies

This option would take a more proactive approach to make sure that new development does not impact dark skies, which are an important part of landscape character and tranquility, and contribute to the quality of life in these areas.

Where possible, development proposals should support the restoration and improvement of areas to enhance and or extend dark skies.

Provision of open space, recreation and leisure facilities

Protect existing open space in the Local Plan

Open spaces enhance the quality of life of our communities, providing spaces to relax, socialise and exercise. Many of these spaces play an important role in supporting biodiversity and connecting our communities with nature, and support health and wellbeing.

Open spaces are publicly accessible areas of land which fall into the following categories or ‘typologies’:

  • parks and gardens – including urban parks, country parks, formal gardens and historic parks and gardens
  • semi-natural and natural open space – including woodlands, urban forestry, scrub, grasslands, wetlands, open and running water, wastelands, derelict open land, and rock areas (cliffs, quarries and pits)
  • beach – we understand the importance of the beach and the valuable contribution it makes to leisure, recreation and the environment, so we view it as a category of open space in its own right
  • green corridors – including riverside areas, footpaths, cycleways, bridleways and other rights of way
  • outdoor sports facilities – including public or private playing fields, tennis courts, bowling greens, sports pitches, golf courses, athletics tracks
  • amenity greenspace – including informal recreation spaces and greenspaces normally found in a residential area and around housing
  • provision for children and young people – this is split into different subcategories depending on the type of equipment and targeted age ranges, but in general includes equipped play areas and skateboard areas
  • allotments – a piece of land which can be rented out for growing fruit and vegetables
  • cemeteries, disused churchyards and other burial grounds – areas which are valuable for informal recreation, wildlife conservation and biodiversity
  • civil space – civic and market squares and other hard surfaced areas designed for pedestrians, which have a range of recreation functions, like Gorrell Tank car park in Whitstable and the High Street in Canterbury which hold markets

Open spaces have many positive benefits, providing meeting places for people of all ages, and supporting social inclusion.

They often provide areas for physical exercise, sports and recreation, supporting the health and wellbeing of our communities. Many provide off-road walking and cycling routes, support community and economic development and contribute to the identity and sense of place and community.

They also support wildlife and biodiversity connecting habitats and wildlife, provide surface water drainage and can improve air quality.

We identify, assess and decide the shortfall and future need for the different types of open space as part of an open space strategy which supports the Local Plan.

We also have two areas designated as local green spaces within the existing Local Plan:

  • Prospect Field in Joy Lane, Whitstable
  • Columbia Avenue recreation ground in Whitstable

Local green space designations provide special protection for green areas of particular importance to local communities.

We have the opportunity to review local green space sites through the new Local Plan, but most green areas or open spaces in the district will not meet the strict criteria set in national planning policies. A green space must be:

  1. reasonably close to the community it serves
  2. special to a local community and hold particular local significance, for example because of its beauty, historic significance, recreational value, tranquillity or wildlife
  3. local in character and not an extensive area of land

The Open Space Strategy (2014- 2020) is being updated and this will review existing open space in the district and identify any shortfalls, as well as update the open space standards for new developments.

There are allocations within the current Local Plan for playing fields and allotments which will need to be reviewed through the new strategy for the next stage of the Local Plan.

Part of the strategy work includes reviewing the ‘protected open space’ designated sites, and there might be opportunities to make sure they are being protected appropriately, as well as publicly accessible open space and other designations like green gaps.

The Canterbury Playing Pitch Strategy and Action Plan (October 2020) updates our evidence on outdoor sports provision in the district.

It identifies existing shortfalls of youth football pitches (11v11 and 9v9), rugby union pitches, and access to additional outdoor netball courts for summer youth netball. There would also be a potential shortfall in adult football pitches, cricket pitches and a 3G pitch (probably in Herne Bay) for team training.

The strategy, developed with local stakeholders and Sports England, will be used in the relevant parts of the open space strategy and later stages of the Local Plan.

The Indoor Sports Facilities Strategy (October 2020) identifies the need to support existing clubs and make sure they continue to have access to appropriate facilities. In particular, gymnastics, roller hockey, indoor bowls and table tennis might need support with improving or moving existing facilities. We will use this information in the next stage of the Local Plan.

The Green Gaps and Local Green Spaces Review (2021) reviewed all existing green gaps and local green spaces. It confirmed that there had been no development in local green spaces, or any substantial changes.

There were many comments including:

  • the loss of open spaces due to development
  • inappropriate management of open spaces
  • inappropriate use of open spaces
  • lack of open space in the district
  • poor access to open space
  • a lack of well-equipped childrens play areas and publicly available tennis courts or other exercise spaces

Lots of suggestions were put forward including creating a large park which could have several functions like a lake or public tennis courts, more local green spaces, more allotments, community gardens and urban farms, and well equipped children’s play areas and outdoor gym equipment.

Suggestions for a Heritage Country Park at Fordwich and a Stour Valley Regional Park were mentioned. Designations of this type involve a detailed application process in line with strict criteria set by government and Natural England.

Although this hasn’t happened yet, they will be considered if needed in later stages of the new Local Plan.

We recognise that improving the quality and quantity of open spaces will be a key feature of the new Local Plan, so background work on this is being developed in our new open spaces strategy and this work will be reflected in a later stage of the new Local Plan.

At this stage it is helpful to look at some key issues around the protection of existing open space.

Issue NE7. How should we protect existing open space in the Local Plan?

Open spaces like parks, natural areas and allotments play an important role in community life, and contribute significantly to the quality of life of residents. Although those areas of land identified through Policy OS9 are protected, many of these important community assets don’t currently have any protection within the Local Plan.

These options focus on open spaces which are usable and publicly accessible – areas which fall into the categories or typologies used for the open space strategy.

Option NE7A – continue with the existing approach

Sites like play areas and semi-natural spaces are normally not identified in the Local Plan for specific protection, as it instead focuses on protecting playing fields, allotments and open space provided through new developments.

Option NE7B (preferred option) – identify and protect open spaces within the Local Plan, providing clear criteria to be met if open space is proposed to be lost

This option would take a more proactive approach to protecting our open spaces.

Through the open spaces strategy work, open spaces will be identified, assessed and mapped. This will then allow them to be identified on maps and protected through the new Local Plan.

If a development proposal could lead to the loss of open space, any application would need to meet strict criteria, for example, that the space was no longer needed, and that the loss would be compensated for.

Issue NE8. How can we support the provision of accessible outdoor sports and recreation across the district?

Option NE8A – keep the current approach

This option would keep the current approach of looking for a balanced contribution of open space in line with the open space standards, with proportionate amounts of each type of open space.

Option NE8B (preferred option) – consider prioritising sport facilities where there is an identified lack of them

Where there is a particular need for a specific sports facility, this option would allow us to rebalance open space provision from developments.

For example, there are identified shortfalls of youth 11v11 football pitches in the north rural analysis area and youth 9v9 pitches in the Canterbury City, Herne Bay, North Rural and Whitstable analysis areas.

So open space provision as part of new developments in this area would be focused on addressing that, while still making sure that the overall requirement for open space provision from a development is reasonable and proportionate.

Issue QNE9. How should we make sure our approach to local green spaces is still effective?

Option NE9A – consider removing the existing local green space

This option would remove the designations at Prospect Field and Columbia Avenue in Whitstable, if there is evidence to show that the sites no longer meet the strict criteria set out in national planning policies.

However, the Green Gaps and Local Green Spaces Review (2021) doesn’t suggest any changes here.

Option NE9B (preferred option) – keep the local green spaces identified in the current Local Plan

This option would keep the existing local green spaces in Whitstable.

Through the development of the new Local Plan there might also be opportunities to assess the potential for more green spaces in the district, where areas have the potential to meet the strict criteria set out in national planning policies.

Water environment and how it connects with our communities

Development where there are coastal protection and overtopping hazard zones

The water environment is incredibly important in our district; supporting wildlife and biodiversity, as well as the health and wellbeing of our communities.

For example, the River Stour is the second longest river in Kent ,and as a chalk river, it is one of only 200 examples of this rare habitat in the world.

Along our 21.6 kilometres of coastline there are some areas at Seasalter, Swalecliffe, Bishopstone and Reculver which have great scientific interest and recreational value. These attractive areas of undeveloped coast are currently protected through the Local Plan as undeveloped coast’ and will continue to be.

Other areas of the coast are protected through zonal protections:

  • overtopping hazard zone (waves coming over sea defences) – development is not allowed in an area at Faversham Road in Seasalter as it is at risk of overtopping from the sea, meaning that buildings can be damaged by waves
  • coastal protection zone – at Studd Hill and Eastcliff in Herne Bay there are areas where the cliffs and coastal slopes are not stable because of erosion. Developments in certain areas could make the situation worse and affect future works, so for public safety, development is normally not allowed

Some areas of our district are at risk of flooding and surfaces like roads, footpaths, paved gardens, driveways and roof slopes can contribute to this by not allowing water through.

Sustainable drainage systems (SuDS) aim to minimise the risk of flooding by allowing water to soak into the soil underneath, or even hold the water temporarily to prevent it over filling drains or rivers.

SuDS can also enhance and support wildlife, biodiversity and habitats and support the efficient use of clean water. Examples of SuDS include:

  • bioswales or swales – a small dip in a piece of land which directs water through soil and vegetation before joining a drain
  • soakaways – a hole filled with rubble which temporarily stores water before draining away
  • permeable pavement – using a design or different material which allows water to seep through to the soil below
  • ponds, ditches, and retention or detention basins – areas which can start as wet or dry and provide space for excess water to be stored
  • wetlands – a habitat which can support large volumes of water
  • green roofs – slows down runoff and filters rainwater as it falls

We live in a water stressed area, meaning at certain times of the year our demand for clean water exceeds the amount of water available. With the impacts of climate change, the protection of groundwater is important to reduce the chance of water shortages.

Existing national legislation aims to protects water from pollution:

  • groundwater protection zones – areas where the groundwater is at risk from pollution contamination. In England, groundwater provides a third of our drinking water, but in our district this is much higher at 80%
  • drinking water safeguard zones – areas where water is used as drinking water and the use of certain substances (including fertilisers, pesticides or other chemicals) must be carefully managed to prevent pollution
  • nitrate vulnerable zones – areas at risk from agricultural nitrate pollution

The Landscape Character Assessment and Biodiversity Appraisal (2020) identifies the existing area of undeveloped coast at Seasalter, Swalecliffe, Bishopstone and Reculver as a part of the landscape which should continue to be conserved.

The Environment Agency regularly reviews and updates the flood risk zones. These amendments will be taken into account during the update of the 2019 strategic flood risk assessment and the new Local Plan.

Other plans have been, or are being produced, like the South East Marine Plan and the Isle of Grain to South Foreland Shoreline Management Plan. The implications of these will be considered in the new Local Plan.

National planning policies set clear requirements for Local Plans to take full account of flood risk and coastal change, including climate change.

Inappropriate development in areas at risk of flooding should be avoided and SuDS should be incorporated where needed. Local Plans should also contribute to and enhance the natural and local environment by preventing development from contributing to water pollution.

We are aware that there are water quality concerns about the Stodmarsh protected site. As we develop the new Local Plan we will complete a Habitats Regulations Assessment (HRA) which will determine if the plan might affect the protected features of a designated habitat site: Ramsar; special protection areas (SPAs); special areas of conservation (SACs), and European marine sites.

The HRA is ongoing and will look at any impacts, which will then be thought about in future Local Plan work. HRA options are not proposed at this stage.

Many people raised concerns over the increased risk of flooding due to climate change, hard landscaping in new developments and the creation of driveways at existing properties that have resulted in the loss of greenspace and an increase in the amount of water runoff.

They also commented that SuDS schemes are not effective and more could be done to enhance designs to increase their other benefits.

More careful management of surface water drainage, more permeable paving and keeping areas of grass or other green infrastructure to help drainage were some of the options suggested.

It was widely recognised that our district is a water stressed area and there were concerns over water supplies and potential shortages and water pollution including from nutrients, waste and rubbish.

Issue NE10. How do we approach development where there are coastal protection and overtopping hazard zones?​

Option NE10A – keep the current Local Plan approach of preventing all development within coastal protection and overtopping hazard zones (waves coming over sea walls)

This option would refuse all developments in these zones, which are identified through the most up to date evidence.

Option NE10B (preferred option) – think about allowing coastal defences for individual properties in these zones

Coastal defences for individual properties would not change the fact that these zones are at risk of erosion and falling into the sea or overtopping.

Personal coastal defences are unlikely to make any long term difference to protection, especially in the face of a changing climate.

Further investigation and discussions with partners and stakeholders would be needed to make sure safety and sustainability was met; including a requirement to show that work would not make the situation worse or affect the delivery of future strategic works.

Issue NE11. How can we maximise the benefits of sustainable drainage systems (SuDS)?

Option NE11A – keep the current approach to require enough drainage and encourage major developments to design SuDS that include other benefits

The current approach is focused on having enough drainage and only on major developments are SuDS encouraged to be designed with other benefits.

Option NE11B (preferred option) – encourage all developments to contain SuDS, and also keep the requirement to have enough drainage. Encourage SuDS to be designed to include other benefits and provide information and guidance on the design of them

This option would mean that all appropriate developments are encouraged to provide SuDS, and that they are designed to have as many benefits as possible.

Guidance could be given to help this.

Issue NE12. What should we do about groundwater protections?

Option NE12A – keep the existing approach of having groundwater protection zones

This relies on other existing legislation like the Water Directive and no specific requirements are set out in the Local Plan itself

Option NE12B (preferred option) – set clear requirements for development proposals in groundwater protection zones, nitrate vulnerable zones and drinking water safeguard zones

This option would take a more proactive approach to developments in these areas, setting out clear criteria on the types of development which might be supported and making sure that they don’t create adverse impacts.

Further information and guidance would be given to support applicants.

Give us your views on the the historic and natural environment