CANTERBURY DISTRICT LOCAL PLAN
EXAMINATION
MATTERS, ISSUES AND QUESTIONS
(21 May 2015)
References to policies in brackets indicate against which main matter (or
matters) they will be considered. In some cases policies are relevant to
more than one hearing session. Any issues relating to the Local Plan
supporting text, evidence base or other documents will be considered as
appropriate under the relevant main matter.
STAGE ONE
Legal Compliance
Has the Council complied with the Duty to Co-operate:
a) Has the Council engaged constructively, actively and on an ongoing
basis on strategic matters with neighbouring authorities and other
prescribed bodies in the preparation of the Local Plan?
b) Has the Council made every effort to secure the necessary cooperation on strategic cross boundary matters before the Local Plan
was submitted for examination?
c) Is the Council justified in not meeting a request from Swale Borough
Council to accommodate some of its housing needs that are not being
met in its emerging local plan?
d) Has there been appropriate engagement with Dover District Council
concerning provision for new retail development?
e) Has there been appropriate engagement with the Mayor or the Greater
London Authority concerning possible unmet housing needs for
London?
Has the Local Plan complied with other legal requirements:
f) Has the Local Plan been prepared in accordance with the Local
Development Scheme?
g) Has the Local Plan had regard to the Sustainable Community Strategy?
h) Is the Local Plan in general accordance with the Statement of
Community Involvement and public consultation requirements?
i) Has the Local Plan been subjected to Sustainability Appraisal?
j) Has the Local Plan had regard to national policy?
k) Has a Habitat Regulations Assessment been prepared?
l) Does the Local Plan comply with the 2004 Regulations (as amended),
particularly in terms of consultation arrangements?
Matter 1: Spatial Strategy (Policies SP1, SP4)
Main issue - Whether the spatial strategy has been positively prepared
and is soundly based and justified, presenting a clear spatial vision for the
District in accordance with national policy.
(Questions e) and f) will include consideration of the Sustainability
Appraisal in so far as it provides part of the evidence base for these
aspects)
a) Are the conclusions of the Canterbury Futures Study (2006, with 2011
update) an appropriate context for the Local Plan?
b) Does the Local Plan contain an appropriate spatial vision and
objectives?
c) Do the policies in the Local Plan reflect the identified spatial vision and
objectives?
d) Does the Local Plan adequately reflect the presumption in favour of
sustainable development in national policy? Has the detailed wording
of Policy SP1 been justified in that context? Is the wording of some
policies unduly restrictive (eg ‘development will only be permitted
if…’)?
e) Have reasonable alternatives to the overall spatial strategy in terms of
the scale and distribution of development been considered? Has it
been demonstrated that the plan is the most appropriate strategy?
f) Is there a clear audit trail showing how and why the preferred overall
spatial strategy was arrived at?
g) Is the overall strategy sufficiently flexible to respond to an unexpected
change in circumstances?
h) Is the strategic approach to the location of development in Policy SP4
justified by the evidence base?
i) Are the categories in the Local Plan settlement hierarchy appropriate
and justified?
j) Does the evidence base support the position of individual settlements
within the settlement hierarchy?
k) Should the settlement hierarchy be incorporated into a plan policy?
Matter 2: Housing Strategy (Policies SP2, SP4, HD1)
Main issue – Whether the housing strategy has been positively prepared
and whether the overall level of housing provision and its distribution are
justified and appropriate.
Objectively assessed housing needs
a) Has an appropriate approach been taken to defining the housing
market area?
b) What are the full, objectively assessed needs for market and affordable
housing in the housing market area? Is the Council’s methodology
appropriate and justified? Does Scenario E in the Development
Requirements Study (2012) represent full, objectively assessed need?
c) Is it necessary for the Local Plan to make specific provision for any
unmet housing needs from London?
d) How does the objectively assessed need for affordable housing relate
to the overall scale of housing provision? Would an increase in the
total housing figures help deliver the required number of affordable
homes and, if so, has this consideration been given appropriate weight
in determining the overall level of housing provision in the plan area?
e) How should the 2012-based sub national population projections be
taken into account in the assessment of objectively assessed housing
needs?
f) Has the Local Plan dealt appropriately with the relationship between
employment and population growth (and therefore between jobs and
new housing)?
g) Has appropriate account been taken of market signals in the housing
needs assessment?
h) Has the housing needs assessment appropriately addressed the needs
for all types of housing and of different groups, including the private
rented sector, self-build, family housing, housing for older people,
households with specific needs and student accommodation?
Land supply
i) Does the Local Plan assist in boosting significantly the supply of
housing?
j) Does the Local Plan assist in providing a continuous supply of specific
deliverable sites sufficient to provide 5 years worth of housing against
the housing requirement with an additional buffer of 5% or 20%? Are
the sites identified by the Council viable, are they available now, do
they offer a suitable location for development now and are they
achievable with a realistic prospect that housing will be delivered
within 5 years?
k) Is there evidence of persistent under delivery of housing that would
justify the buffer being 20%, or is 5% appropriate?
l) Should any past shortfall in new housing be addressed in the supply of
land for the first five years or be spread over the plan period as a
whole?
m) Have appropriate assumptions been made about the contribution of
small unallocated sites to the housing land supply?
n) Should allowance be made for some current planning permissions to
lapse when calculating the land supply?
o) Is the Local Plan likely to result in an appropriate supply of specific
deliverable sites or broad locations for growth in the plan period
beyond 5 years? Are the sites in a suitable location with a reasonable
prospect that they are available and could be viably developed at the
point envisaged?
p) Does the housing trajectory provide an appropriate illustration of the
expected rate of housing delivery for the plan period?
q) Is there a clear housing implementation strategy for the full range of
housing, describing how the Council will maintain delivery of a 5-year
supply of housing land to meet the housing target?
Distribution
r) Is the distribution of new housing between different settlements and
parts of the plan area in accordance with the overall spatial strategy?
s) Have reasonable alternatives to the distribution of housing
development been considered?
t) Does the plan provide appropriate guidance for new housing
development on previously developed land?
Phasing
u) Has the approach to the phasing of housing land in the Local Plan been
justified? Is it clear by what mechanism the release of land would be
phased?
Other aspects
v) Is the housing strategy sufficiently flexible to adapt to rapid change or
to respond to new circumstances?
w) Does the Local Plan provide sufficient guidance on the mix, size, type,
tenure and range of housing that is required?
x) Does the Local Plan give sufficient encouragement to people who want
to build their own homes?
Matter 3: Affordable Housing (Policies HD2, HD3)
Main issue - Whether the Local Plan makes appropriate provision for
affordable housing.
a) Have the requirements in terms of the thresholds and percentages for
affordable housing in Policy HD2 been justified by the evidence base?
Are there any implications for the Local Plan arising from the Written
Ministerial Statement and changes to national Planning Practice
Guidance (November 2014) in respect of size thresholds for affordable
housing contributions?
b) Do the other requirements of Policy HD2 accord with national policy?
c) Has the split between different affordable housing tenure types been
justified by the evidence base?
d) Has the effect of affordable housing provision on the overall viability of
development been appropriately considered?
e) Does Policy HD3 on rural exception sites accord with national policy?
Matter 4: Economic and Commercial Development Strategy
(Policies SP2, EMP1, TCL1)
Main issue – Whether the Local Plan would proactively drive and support
sustainable economic development.
a) Does the Local Plan set out a clear economic vision and strategy for
the area which proactively encourages sustainable economic growth?
b) Have the objectively assessed needs for economic development in
terms of land or floorspace been appropriately identified and justified?
c) Does the Local Plan assist in providing a supply of land for economic
development that is sufficient and suitable to meet the identified
needs?
d) Does the plan make appropriate provision for the role of the city of
Canterbury in the economy of the District?
e) Are the Local Plan employment policies sufficiently flexible that they
could accommodate needs not anticipated in the plan?
f) Is the strategy for retail and town centre uses based on an appropriate
objective assessment of needs? Is the strategy consistent with its
conclusions?
Matter 5: Infrastructure (including Transport) and Implementation
(Policies SP6, T1 to T17, CC13)
Main issue – Whether the infrastructure requirements for the Local Plan
are soundly based and deliverable and whether there are clear
mechanisms for implementation and monitoring?
General
a) Which of the items of infrastructure identified in the Local Plan and the
Draft Infrastructure Delivery Plan are critical to the delivery of the
Local Plan?
b) Have the items of critical infrastructure been justified by the evidence
base?
c) What would be the consequences for the strategy if any of the critical
infrastructure was not delivered? Is there sufficient clarity about the
funding sources for this infrastructure? Is there sufficient commitment
at this stage from the relevant organisations responsible for delivery?
d) Is it clear what infrastructure is required for the first 5 years of the
plan and who is going to fund and provide it?
Transport
e) Does the Canterbury District Transport Strategy 2014-31 provide an
appropriate basis for the Local Plan?
f) Have the overall transport implications of the Local Plan been
adequately assessed, including any traffic congestion effects? Will the
identified infrastructure requirements be effective in addressing those
impacts? Is it clear how the infrastructure will be delivered?
g) Does the Local Plan facilitate the use of sustainable modes of
transport?
h) Are the new cycle and pedestrian routes proposed in the Local Plan
justified and deliverable?
i) Would the Local Plan be unsound if any of the proposals for cycle and
pedestrian routes that were promoted in representations were not
included? If so are these sites soundly based and deliverable?
j) Are proposals for the extension or relocation of park and ride facilities
at Canterbury justified and deliverable?
k) Does Policy T8 provide appropriate guidance for park and ride facilities
at Whitstable?
l) Are proposals for improvements to the highway network justified and
deliverable:
 Whincheap Traffic Management Scheme (including A2 off-slip
road)
 A2 Bridge Interchange
 Herne Relief Road
 Sturry Relief Road
 A28/A257 Barracks Link Road
m) Is there a clear and compelling justification for the imposition of local
parking standards in Polices T9 and T10 (and Policy DBE3)?
Other infrastructure and services
n) Has the Local Plan taken appropriate account of water resources? To
what extent is water supply a constraint on development?
o) Have the implications of the Local Plan for waste water infrastructure
been appropriately identified and justified?
p) Are the education infrastructure implications of the Local Pan justified
and deliverable? Are there effective mechanisms for implementation?
q) Are the other elements of community and social infrastructure (adult
social services, libraries, youth services, health facilities etc) justified
and deliverable?
Implementation
r) Has the overall viability of development been appropriately assessed?
s) Have appropriate allowances been made for infrastructure
requirements in terms of s106 contributions, the CIL or other
mechanisms and the climate change mitigation requirements of the
Local Plan in assessing the overall viability of development?
t) Does the approach to infrastructure requirements comply with CIL
Regulation 122 where they would be sought by means of planning
obligations?
u) Do the limitations on the pooling of s106 contributions from April 2015
have any implications for the delivery of critical infrastructure,
particularly prior to the adoption of a CIL?
v) Are there any implications for the Local Plan arising from the Written
Ministerial Statement and changes to national Planning Practice
Guidance (November 2014) in respect of pooling financial contributions
from planning obligations on small housing sites?
w) Where policies include reference to Supplementary Planning
Documents, development briefs or other reports as a mechanism for
implementation, such as in Policies SP3, SP7, EMP11, TCL7, TCL10, T9
and LB1, do they reflect legal and national policy requirements?
x) Does the Local Plan include clear arrangements for managing and
monitoring its implementation?
Matter 6: Natural Environment Strategy (Policies SP7, CC12)
Main issue - Whether the Local Plan makes appropriate provision for the
protection and enhancement of the natural environment?
a) Has it been demonstrated that the Local Plan would have no likely
significant effects upon internationally important nature conservation
sites?
b) Can appropriate and effective mechanisms be put in place to mitigate
any likely significant effects?
c) Does the Local Plan include appropriate provision for mitigation? Can
robust arrangements be put in place for funding the mitigation
measures? Is it appropriate for the measures to be funded in
perpetuity?
d) Can the proposed scale and distribution of development be achieved
without compromising Water Framework Directive objectives?
Matter 7: Strategic Site Allocations (Policy SP3)
Main issue – Whether the Strategic Site Allocations are justified and
deliverable
General
a) What is the basis for the selection and rejection of strategic sites? Is
this process justified by robust evidence?
b) Is there sufficient detail on the requirements for each site for the Local
Plan to be effective?
c) Is it appropriate for detailed requirements to be addressed in
development briefs and for Policy SP3 to require accordance with
them?
d) Is it clear what the “garden city” principles referred to in Policy SP3
mean when determining site requirements? Have these been factored
into the viability assessments?
e) Is the inclusion in the Local Plan of indicative layouts for Strategic Site
Allocations justified and appropriate?
f) Are the proposed Urban Area Boundary changes to reflect the
Strategic Site Allocations at Canterbury, Herne Bay and Whitstable
justified and appropriate?
Individual sites (the following questions g) to m) apply as appropriate to
each of the Strategic Site Allocations listed below)
Canterbury sites:
Site 1 – South Canterbury
Site 10 – Land at the Kent & Canterbury Hospital, Ridlands Farm and
Langton Field
Site 9 – Land at Howe Barracks, Canterbury
Herne Bay sites:
Site
Site
Site
Site
3
4
5
6
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Land at Hillborough, Herne Bay
Herne Bay Golf Course
Strode Farm, Herne Bay
Land at Greenhill, Herne Bay
Whitstable site:
Site 7 – Thanet Way site, Whitstable
Rural sites:
Site 2 – Land at Sturry/Broad Oak
Site 8 – Land North of Hersden (including potential site for Canterbury
Football Club)
g) Has the overall amount and mix of development proposed at the site
been justified by the evidence base?
h) Has appropriate account been taken of national policy for the best and
most versatile agricultural land?
i) Have all the infrastructure implications of the development of the site
been identified in sufficient detail and supported by the evidence base?
j) Is it sufficiently clear who is going to deliver the required infrastructure
and by when? Which infrastructure is critical to the delivery or rate of
development of the site?
k) Are the transport implications of the development and the measures to
address them sufficiently clear and deliverable?
l) Are the education implications of the development and the measures
to address them sufficiently clear and deliverable?
m) Is there sufficient viability evidence at this stage to have reasonable
certainty that the scale and mix of development proposed will be
deliverable within the plan period in the context of affordable housing
provision, necessary infrastructure and other Local Plan requirements?
‘Omission’ sites
n) Would the Local Plan be unsound if any of the additional or alternative
‘omission’ sites promoted in representations as strategic sites were
not included? If so, are these sites soundly based and deliverable in
the plan period and have they been subject to sustainability appraisal?
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‘New Thanington’ (land at Cockering Farm – SHLAA/210 –
includes SHLAA/70, 84, 106, 137)
Land at Cockering Farm and land east of Milton Manor,
Thannington (SHLAA/84, SHLAA/210)
Land at Cockering Farm, Thannington (SHLAA/106, SHLAA/137)
Land at Stuppington Lane, Canterbury (SHLAA/231)
Former, Colliery Land, South of A28, Hersden (SHLAA/041)
Land at 42 Golden Hill, Whitstable (SHLAA/135)
Land South of John Wilson Business Park, South Tankerton
(SHLAA/130)
Land at Bodkin Farm, Thanet Way, Chestfield (SHLAA/178)
Any other strategic sites
STAGE TWO
Matter 8: Housing Allocations and related Development
Management Policies (HD1, HD6 to HD10)
Whether the allocated housing sites are justified and deliverable and
whether the development management policies provide an appropriate
basis for assessing proposals for residential accommodation
a) Should the housing allocations referred to in supporting text be
identified in a plan policy?
Individual housing sites (the following questions b) to g) apply as
appropriate to each of the new housing allocations listed below)
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St Martin’s Hospital, Canterbury
Kingsmead Field, Canterbury
Land at Bullockstone Road, Herne Bay
Land at Spires, Bredlands Lane, Hersden
Barham Court Farm, Church Lane, Barham
Land at Baker’s Lane, Chartham
b) Has the overall amount and mix of development proposed at the site
been justified by the evidence base?
c) Have all the infrastructure implications of the development of the site
been identified in sufficient detail and supported by the evidence
base?
d) Is it sufficiently clear who is going to deliver the required infrastructure
and by when? Which infrastructure is critical to the delivery or rate of
development of the site?
e) Are the transport implications of the development and the measures to
address them sufficiently clear and deliverable?
f) Are the education implications of the development and the measures
to address them sufficiently clear and deliverable?
g) Is there sufficient viability evidence at this stage to have reasonable
certainty that the amount of development proposed will be deliverable
within the plan period in the context of affordable housing provision,
necessary infrastructure and other Local Plan requirements?
h) Is the retention of housing and employment allocations close to
Canterbury West Station justified and soundly based, particularly in
the light of the loss of car parking that would result?
i) Is there justification for revisions to housing site boundaries at
Parham Road, Canterbury and Beresford Road, Whitstable
j) Is the identification of Chaucer Road, Canterbury as an opportunity
site for housing justified and is it developable?
k) Would the Local Plan be unsound if any of the additional or alternative
‘omission’ housing sites that were promoted in representations were
not included? If so, are these sites soundly based and deliverable in
the plan period and have they been subject to sustainability appraisal?
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l)
m)
n)
o)
p)
The Old Coal Yard, Belmont Road, Whitstable (SHLAA/145)
Land at Taringa, Church Lane, Seasalter (SHLAA/189)
Land at Thornden Wood Road, Greenhill (SHLAA/071)
Land at Richmond Drive/Puffin Road, Beltinge, Herne Bay
(SHLAA/131)
Land at Rattington Street, Chartham (SHLAA/140)
Land to East of Chartham Mill, Chartham (SHLAA/216)
Land at Shrubhill Road, Chestfield (SHLAA/181)
Great Bossingham Farm, Bossingham (SHLAA/218)
Land to the north east of The Hill, Littlebourne (SHLAA/091)
Land at Bekesbourne Lane, Littlebourne (SHLAA/044)
Land at Westbere Lane, Westbere (SHLAA/072)
Land off Island Road, Westbere (SHLAA/200)
Durite Plant, Westbere Lakes, Fordwich Road, Sturry (SHLAA/081,
SHLAA 214)
Former Highways Depot, Staines Hill, Sturry (SHLAA/50)
Land at Goose Farm, Shalloak Road, Broad Oak (SHLAA/174)
Land to rear of Royal Oak, Blean (SHLAA/217)
Lucketts Farm, Blean (SHLAA/215)
Land at Rough Common Road, Rough Common (SHLAA/078)
Land at Patrixbourne Road, Bridge (SHLAA/201, SHLAA/ 221)
Land at Brewery Lane, Bridge (SHLAA/139)
Land at Cockering Road, Thannington (9 units) (SHLAA/004)
Barton Business Park, Canterbury (SHLAA/065)
Land adjacent to Parham Road, Canterbury (SHLAA/056)
Buildings 1-7 the Tannery, Stour Street, Canterbury
Any other housing sites
Is the approach to Houses in Multiple Occupation in Policy HD6
justified and would it be effective?
Does Policy HD7 make appropriate provision for purpose built student
accommodation?
Do policies HD8 and HD9 make appropriate provision for the retention
of housing accommodation and bringing empty property into
residential use?
Has the Local Plan adequately addressed the accommodation needs of
travellers?
Are the criteria for consideration of proposals for traveller sites in
Policy HD10 appropriate and consistent with national policy?
Matter 9: Employment Allocations, Tourism and related
Development Management Policies (EMP1 to EMP11, TV1 to TV5)
Whether the allocated employment sites are justified and deliverable and
whether the development management policies provide an appropriate
basis for assessing proposals for employment and tourism development
Individual employment sites (the following questions a) to e) apply as
appropriate to each of the new employment allocations listed below)
Land at Sturry Road, Canterbury – including changes to the existing Green
Gap designation
Extension to Joseph Wilson Industrial Estate, Whitstable
Hillborough Business Park Herne Bay (unimplemented planning
permission)
Altira, Margate Road, Herne Bay (unimplemented planning permission)
Chaucer Business Park, Whitstable
a) Has the overall amount of development proposed at the site been
justified by the evidence base?
b) Have all the infrastructure implications of the development of the site
been identified in sufficient detail and supported by the evidence
base?
c) Is it sufficiently clear who is going to deliver the required
infrastructure and by when? Which infrastructure is critical to the
delivery or rate of development of the site?
d) Are the transport implications of the development and the measures
to address them sufficiently clear and deliverable?
e) Is there sufficient viability evidence at this stage to have reasonable
certainty that the amount of development proposed will be deliverable
within the plan period?
f)
Would the Local Plan be unsound if any of the additional or alternative
‘omission’ employment sites that were promoted in representations
were not included? If so, are these sites soundly based and
deliverable in the plan period and have they been subject to
sustainability appraisal?
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Hall Place, Harbledown, Canterbury
Land east of Lakesview Business Park, Hersden
Hoplands Farm, Island Road, Hersden
The Paddock, Thanet Way, Whitstable
Former FDS Site, Hawthorne Corner, Hillborough
Any other employment sites
g) Is the approach to the protection or release for redevelopment/change
of use of existing employment sites or premises in Policies EMP1,
EMP2 and EMP4 consistent with national policy?
h) Are Policies EMP3 and EMP5 concerning office use of retail and
commercial premises and home-working justified and consistent with
national policy?
i) Does the Local Plan make appropriate provision for the University of
Kent, Canterbury Christ Church University and colleges and schools in
the plan area?
j) Have the boundaries to the University sites been appropriately
defined?
k) Does the Local Plan make appropriate provision for development at
Whitstable Harbour?
l) Is the approach to marina proposals in Policy TV5 justified by the
evidence base, including possible provision at Whitstable Harbour?
m) Do Policies TV1 and TV2 provide a justifiable and effective strategy for
the promotion of tourism and culture, having regard to environmental
considerations?
n) Are Policies TV3 and TV4 relating to visitor accommodation and
caravan tourist sites supported by the evidence base and consistent
with national policy?
Matter 10: Town Centres and Leisure (Policies TCL2 to TCL12)
Main issue – Whether the Local Plan provides a sound basis for retail and
leisure development and the management and growth of town and local
centres
a) Does the Local Plan define a hierarchy of centre that is resilient to
anticipated future economic changes? Should the hierarchy and the
identified centres be included in a plan policy?
b) Has the Canterbury Primary Shopping Area been justified by the
evidence base?
c) Are the Primary Shopping Frontages in Canterbury, Herne Bay and
Whitstable justified by the evidence base?
d) Are the Mixed Shopping Frontages at Canterbury, Herne Bay and
Whitstable consistent with national policy and justified by the evidence
base?
e) Is the Cultural Enhancement Area at Canterbury consistent with
national policy and justified by the evidence base?
f) Does Policy TCL5 provide a justifiable and effective approach to
development in Local Centres?
g) Is the approach to main town centre uses in Policy TCL6 justified and
consistent with national policy?
h) Has the Wincheap Retail Area been justified by the evidence base and
is it deliverable? Has the potential impact on Canterbury City Centre
and other centres been appropriately assessed? Will the requirements
of Policy TCL7 be effective in ensuring that the intended outcome is
achieved?
i) Are the sites allocated for mixed use development within and around
town centres in Policy TCL10 justified and deliverable? Is the
particular mix of development justified?
j) Are Policies TCL8, TCL9, TC11 and TCL12 justified and likely to be
effective in supporting the viability and vitality of town centres?
Matter 11: Development in the Countryside (Policies HD4, HD5,
EMP12 to EMP15, TV6 to TV8, OS8)
Main issue - Whether the Local Plan is consistent with national policy
relating to the countryside.
a) Does the Local Plan take a positive approach to sustainable new
development in rural areas?
b) Is Policy HD4 relating to housing in the countryside consistent with
national policy?
c) Is Policy HD5 on the conversion of rural buildings consistent with
national policy?
d) Is Policy EMP12 on agricultural land consistent with national policy?
e) Does the Local Plan promote the development and diversification of
agriculture and land-based businesses? Are Policies EMP1, EMP14 and
EMP15 consistent with this approach?
f) Does the Local Plan support sustainable rural tourism and leisure
developments?
g) Is Policy OS8 on sports and recreation in the countryside consistent
with national policy?
Matter 12: Climate Change, Flooding and Coastal Change (Policies
CC1 to CC11, CC13, DBE1, DBE2)
Main issue - Whether the Local Plan makes appropriate provision to
address climate change, flood risk and coastal change management
a) Does the Local Plan contain a proactive strategy to mitigate and adapt
to climate change?
b) Do Policies CC1, CC2 and DBE2 reflect a positive strategy to promote
energy from renewable and low carbon sources? Do they contain an
appropriate balance between maximising renewable and low carbon
energy development while ensuring that adverse impacts are
addressed satisfactorily?
c) Are Policies DBE1, CC2 and CC13 consistent with national policy
following the Housing Standards Review and the Written Ministerial
Statement of 25 March 2015?
d) Has it been demonstrated that the Local Plan requirements for climate
change mitigation measures would not threaten the viability of
development?
e) Is the requirement in Policy CC3 for developments over 200 units to
provide Combined Heat and Power or to connect with an existing
network other than where not viable or feasible justified by the
evidence base?
f) Does the approach to flood risk in Policies CC4, CC5, CC6 accord with
national policy and would it be effective?
g) Are policies for the coast consistent with the Shoreline Management
Plan Review and with national policy?
h) Is Policy CC11 concerning Sustainable Drainage Systems consistent
with national policy?
Matter 13: Built and Historic Environment (DBE3 to DBE13, HE1 to
HE13)
Whether the Local Plan provides an appropriate strategy for the
conservation and enhancement of the historic environment and the
achievement of good design
a) Does the Local Plan include robust and comprehensive policies that set
out the quality of development that will be expected for the area?
b) Do the design policies provide an appropriate degree of detail in
seeking to achieve high quality design?
c) Do the requirements for the submission of Design and Access
Statements in Policy DBE5 accord with The Town and Country
Planning (Development Management Procedure) (England) Order 2015
and, if not, what is the justification for departing from the statutory
approach?
d) Is it clear in what circumstances a Sustainability Statement would be
required in accordance with Policy DBE6 and has this been justified?
e) Does the setting of residential space standards in Policy DBE7,
including reference to Lifetime Homes, accord with national policy
following the Written Ministerial Statement of 25 March 2015?
f) Is Policy DBE9 on residential intensification justified and effective?
g) Does the approach to heritage assets in Policy HE1 accord with
national policy?
h) Is there a sound approach to the protection and enhancement of the
Canterbury Word Heritage Site? Is the Buffer Zone appropriately
defined and justified?
i) Are the separate policies relating to proposed development that might
affect listed buildings, conservation areas, archaeological sites and
historic landscapes consistent with the statutory requirements or
national policy, as appropriate? Will they be effective in achieving
their aims?
Matter 14: Landscape and Biodiversity (LB1 to LB13)
a) Are the requirements of Policy LB1 relating to the Kent Downs Area of
Outstanding Natural Beauty consistent with national policy?
b) Is it consistent, and therefore effective, to seek to address the
landscape impacts of development through Areas of High Landscape
Value (AHLVs) in Policy LB2 and an approach based on Landscape
Character Areas in Policy LB4?
c) Are the AHLVs appropriately defined?
d) Is the protection afforded to the different levels of designated nature
conservation sites in the hierarchy in Policies LB5, LB6, LB7 and LB8
commensurate with their status in accordance with national policy?
e) Has the designation of Regionally Important Geological/
Geomorphological sites been justified by the evidence base?
f) Is the approach in Policy LB9 towards the impact of development
proposals on nature conservation interests consistent with national
policy?
g) Are other biodiversity policies (LB10 to LB13) justified and effective?
Matter 15: Open Space (SP5, OS1 to OS7, OS9 to OS15)
Whether the Local Plan provide an appropriate strategy for the protection,
enhancement or designation of open space
a) Are the Local Plan proposals for new Local Green Spaces and the
policy requirements that would apply within them justified and
consistent with national policy:
 Prospect Field, Whitstable?
 Columbia Avenue Recreation Ground, Whitstable?
 West Beach, Whitstable?
b) Would the Local Plan be unsound if any of the other proposals for
Local Green Space that were promoted in representations were not
included? If so are these designations soundly based and consistent
with national policy?
c) Are policies for the protection and provision of playing fields (OS2 to
OS5) soundly based?
d) Have proposals for new Green Gaps ( and those retained from the
existing Local Plan) and the policy requirements that would apply
within them been justified by the evidence base:
 between Canterbury and Bridge?
 between the University of Kent and Canterbury?
 other Green Gaps
e) Are the criteria in Policy OS7 for development within the Herne Bay
and Whitstable Green Gap justified by the evidence base?
f) Would the Local Plan be unsound if any of the other proposals for
Green Gaps that were promoted in representations were not included?
If so are these designations soundly based?
g) Is the approach to protecting open spaces in Policies OS9 and OS10
justified and consistent with national policy?
h) Have proposals for new Open Space allocations been justified by the
evidence base:
 adjacent to St Augustine’s Business Park, Swalecliffe
 Stuppington Lane, Canterbury
i) Have proposals for the protection of existing Open Space in the
context of Policy OS9 been justified by the evidence base, including
the following new areas:
 Hollow Lane, Canterbury
 Kingsmead Field, Canterbury
 Duncan Down and Benacre Wood, Whitstable
 Church Lane, Whitstable
 Mariners View, Whitstable
 Land adjacent to Herne Bay Golf Club
 Extension to existing open space from Bishopstone Manor to
Reculver
j) Should local open space standards be incorporated in a policy?
k) Is the approach towards a Green Infrastructure Strategy in Policy SP5,
which cross refers to the production of another document, effective,
justified and consistent with national policy?
l) Does Policy OS12 provide an effective basis for considering the Green
Infrastructure implications of development?
m) Does Policy OS13 provide an effective basis for protecting the river
corridors?
n) Do Policies OS14 and OS15 provide soundly based guidance for the
provision and protection of allotments?
o) For clarity and effectiveness should all individual protected open
spaces in each category be listed in a policy in the Local Plan?
Matter 16: Community Facilities and Health (QL1 to QL13)
Whether the Local Plan plans positively for the provision and use of
community facilities and other local services, including health services
a) Does the Local Plan include appropriate policies for the provision and
protection of valued community facilities and services in accordance
with national policy?
b) Does the Local Plan include appropriate and soundly-based policies for
the provision of health care facilities?
c) Dose the Local Plan include effective policies to address the effects of
development on air quality in particular and pollution in general?
d) Is it appropriate for the Local Plan to include a policy (QL13) on waste
management and recycling which are matters for the Kent Minerals
and Waste Local Plan?