23 June, 2021

The Dover Society Response to the DDC First Draft Local Plan

Background
Dover District Council published the first draft of its new Local Plan on 20 January 2021 setting out the vision and framework for development in the district to 2040.

Local residents, businesses, community groups, and statutory consultees were invited to review and comment on the draft Local Plan during the first round of public consultation which expired on 17 March 2021. DDC will consider all comments before issuing a second draft for public comment.

The full draft Local Plan document can be viewed on the dedicated website www.doverdistrictlocalplan.co.uk.

The Society’s response
The Society’s response is some 20 pages long, comprising an overview plus detailed comments on particular policies and a summary. Below are the overview and summary, but for the sake of brevity the 18 pages of detailed comments are omitted.

Planning Department
Dover District Council
White Cliffs Business Park
Dover CT16 3PG                                                                                   5 March 2021

Dear Sir/Madam
Re: Regulation 18 Consultation DDC Local Plan

Overview
The Dover Society is delighted that the latest Local Plan is at consultation level following considerable delay.

In general, the Society is supportive of the draft Local Plan; however, areas where we make particular comments are contained within this response.

The Local Plan seeks ambitions but, in many areas, we feel, fails to totally address a delivery of these ambitions.

It is appreciated that the Local Plan is in relation to planning policy, but Planning Policy is only part of the necessity to have a delivery plan. Since the 2010 Core Strategy many of the “aspirations” have failed to materialise. Perhaps for Dover DTC Area) the most worrying is the decline in deprivation as at the time of the 2010 document Dover had two of the six wards in the top 20% of deprived wards in England, now ALL Dover Wards fall into this category with three now actually in the top 10% of deprived wards in England. At the time, the Core Strategy aspiration was “Have no areas falling within the 20% of those most deprived in England”. What happened to this aspiration as DDC planning permitted COU and flat conversions that failed both their own 2006 Conversion to Flats Guidelines (Not adopted by DDC) or indeed the March 2015 nationally described space standards.

The former Castle Ward was considered the most prestigious ward in Dover with estate agents highlighting this area located immediately below the Grade 1 Dover Castle The ward has many large Victorian houses that whist now being considered too large for “family” use have had ill-conceived COU’s and small substandard flats, no attempt to provide larger quality apartments but only to cram as many units as possible. Also, the failure to control HMO properties, in this context we are pleased to see Policy DM 37 and make appropriate comment as it moves in the correct direction but requires more weighted policy if quality is to return to Dover. One example in Castle ward being two large Victorian adjacent properties licensed for a total of 60 residents is now why the Socio-economic profile of Dover is now so low that becomes a restriction to attract inward investment and what little inward investment is secured is of a low quality that does little to reverse the current trend.

There are many properties in a poor state of repair, including many Listed buildings within Conservation Areas. The Dover Society spearheaded a working group to identify such properties and take action using Section 215 of the Town and Country Planning Act 1990 If used correctly the use of such enforcement is a valuable tool in particular to improvements in areas requiring regeneration.  Initial success with 108 properties being listed and 52% carrying out work. However, suddenly DDC took no further action and when asked why said ‘Councillors not happy with the amount of work for Dover that is affecting other areas of the District” Exactly how many residents feel that Dover is the backwash for proactive planning/development initiatives.

A further example was when a Grade II listed building within a Conservation Area removed a period style shop front and replaced it with a plate glass window. This property is immediately opposite the Grade 1 Listed Maison Dieu. Dover Society reported this to DDC, and a retrospective planning application was made. This went to full Planning Committee and planning was refused. The applicant appealed to the Planning Inspectorate with the appeal being rejected (APP/X2220/C/18/3198191) and in March 2019 the applicant was informed by the Inspectorate to restore the removed shop front as given planning consent in 1997 (DOV/97/00939). Now two years later nothing has been done. If in Sandwich it is certain DDC would have taken appropriate action to comply with the Inspectorate decision to support the planning decision made by DDC.

The Local Plan makes no reference to enforcement to ensure the various planning policies are delivered. It is this lack of activity that frustrates many Dover people who have seen the demise of the town.

The Plan should include a section to deal with its delivery and how changing circumstances will be addressed with appropriate modification. The section should include a review carried out every two years by DDC addressing the effectiveness of delivery and any proposed changes required, the review being subject to public comment.

Summary
Overall, The Dover Society is pleased to see a generally, forward thinking Local Plan.

There is no doubt the DDC aspiration objectives, although sincere, will fail to materialise even with dedication and enthusiasm if a delivery plan is not adopted. Ideally this should clearly show short, medium and long term business development policy and objectives with projected delivery dates and with whom (as partners) these dates will be achieved and most importantly who at DDC is responsible for the delivery.

Currently, it is perceived that DDC wait for interested development partners to come to them rather than being proactive and seeking the partners to develop and deliver projects. There are too many sites that have been given planning consent and no development takes place, in particular, some of the larger properties in Dover (e.g. former Magistrates’ Court and St. Mary’s Care Home). It is not acceptable that so-called developers secure consent and either attempt to “sell on with planning consent” or just “Land Bank”.

At the time of circulating the Local Plan Consultation one of our members responded that two words used within the document act as “wriggle room” for DDC. These are the regular use of “significant” and “substantial”. Another felt too many “soft words” such as “considering, identifying opportunities, facilitating, focusing, supporting, should” and too few “definite, will, must”. We leave these thoughts with you!

Yours faithfully,

Derek Leach
Chairman

Alan Lee

I am a member of the Dover Society Committee and the Editor of the Dover Society Newsletter

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