Kent County Council are surprisingly unsupportive of Shepway’s proposals for Princes Parade . Here are their comments from the recent local plan consultation:
Heritage: We have substantial concerns about the allocation of the site at Princes Parade for development and with the wording of Policy UA25. The policy as worded needs to express a better understanding of the contribution that the site makes to the significance of the Scheduled Monument of the Royal Military Canal and we are concerned that it would not be possible to deliver a development on the site of the type described whilst meeting the requirements of the policy.
Understanding the contribution that the site makes to the significance of the Royal Military Canal The site lies adjacent to the far eastern end of the Royal Military Canal on its seaward side. The Royal Military Canal is of national importance and is designated as a Scheduled Monument. It is a unique fortification, built as part of part a system of fortifications in the area to defend against invasion by Napoleonic France. The eastern connection of the canal to the sea was particularly well defended in association with other batteries, redoubts and Martello towers (all also Scheduled).
We feel that mixed-use development here of the type described in Policy UA25 could cause very great harm to the significance of the Scheduled Royal Military Canal by change in its setting. The openness between the canal and the coast is especially important in telling the story of the canal, its purpose and its specific design. This is because the canal was designed to protect against invasion from the sea. As such the seaward setting of the canal makes a substantial contribution to its significance.
We would note that the adjacent site, known as Hotel Imperial Golf Course land, Hythe was assessed as part of the SHLAA exercise where it was noted that the “open character of the site forms part of the setting to this scheduled monument and its loss to development would be highly detrimental” and was rejected partly on the basis that the “land is considered important for the setting of the scheduled monument”. We would suggest that the same issues similarly apply to the present site. Comments on the proposed policy wording Policy UA25 sets out five criteria whereby development will be supported. Criteria 2 and 3 are intended to address issues relating to the historic environment: Criterion 2 requires that “key features of the Royal Military Canal and its setting, which contribute to its significance as a Scheduled Monument would be preserved and enhanced”. Whilst the site has been subject to land-raising in the past, the present open and undeveloped nature of the site is, in our view, a key feature that contributes to the significance of the Scheduled Monument. We feel that this openness is intrinsic to the setting of the scheduled monument. We welcome the requirements set-out in Criteria 2 to preserve and enhance those key features of the canal and its setting that contribute to the monument’s significance. We cannot however presently foresee a way in which the level of development proposed within this policy can be accommodated at the site whilst also ensuring that the monument’s setting is preserved and enhanced.
In essence, development within the setting of the canal, even if the harmful effects of such development are minimized, cannot preserve the setting of the canal, which we feel is a key feature that makes an important contribution to the monument’s significance.
Criterion 3 requires that “any less than substantial harm is clearly and convincingly demonstrated to be outweighed by the public benefits of the proposal, which should include heritage benefits”. We would see such public benefits as being ones that fulfill one or more of the objectives of sustainable development as set out in the NPPF, provided the benefits will be for the wider community and not just for private individuals or companies. We would suggest that the specific heritage benefits should be clearly identified and should be meaningful, deliverable and be based on a proper understanding of the monument’s significance.
The NPPF however requires more than a simple balancing exercise. It requires (para 133) both that the harm is necessary to achieve the public benefits and that these outweigh the harm or loss. In other words the public benefits would be reliant on the delivery of the development and could not be achieved through other means or that the same benefits could not be delivered elsewhere. In this instance we feel that the potential for harm to the significance of the Royal Military Canal would be very great and remain unconvinced that sufficient benefits could be delivered or have yet been identified to outweigh this very great harm.
The provision of a new swimming pool and leisure facility is one suggested benefit, but accommodating such a building on the site without causing great harm to the setting of the canal would appear problematic. Another such benefit would be the contribution that the site would make to the district’s housing requirement; however we feel that there are wider opportunities and alternative sites for development which would be preferred.
PROW: Public Bridleway HB83 would be directly affected by this development. This development should deliver improvements to the Public Bridleway alongside the canal on the south side to enhance the amenity vale of this resource. In order to secure the future protection of public access in this area, it is advised that the policy specifies that that at least two links between the canal crossings and princes parade are dedicated as Public Footpaths or Bridleways.