The archaeology department of Kent County Council has submitted a comment to the planning application that says that the harm to the historic environment provides sufficiently strong grounds for the application to be refused.
They say that it is not enough to consider the impact of the development on certain fixed views as the applicant has done. Instead the assets setting needs to be considered “in the round” looking at a range of views, environmental factors and mental links that are understood together.
They believe that the harm that the scheme would cause is higher than the applicant’s assessment of “limited to moderate harm.”
They acknowledge that the provision of a new leisure centre is an important public benefit which could be balanced against the harm to the setting to the canal but point out that the leisure centre could be built elsewhere. They say that the proposed improvements to the canal itself are not sufficient to balance the harm to the canal caused by the development and in any case do not pass the test of being directly related to the development as they could be delivered independently of the development.
The say that the contribution the development would make to Shepway’s housing need is small.
And they conclude by pointing out the great weight that the NPPF places on the conservation of the Royal Military Canal as a designated asset of the highest significance.
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