� � Correspondence Address Kingsdown Conservation Group

c/o The Gate House Upper Street

Kingsdown CT14 8EU

Tel:�01304 366628 Email: philip@kingsdownconservation.org.uk Website: www.kingsdownconservation.org.uk

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Ms Sarah Platts,

Senior Planning Officer,

Dover District Council,

White Cliffs Business Park,

Dover,

Kent.

CT16 3PJ 14th

March 2013

Dear Ms Platts

Planning Application DOV / 12 / 01016 - Application to install

demountable/moveable beach huts on part of the private beach along

Undercliff Road, Kingsdown on behalf of Tingdene Holiday Parks Ltd

This document is the formal objection to the above Application by the Kingsdown

Conservation Group (KCG). It takes full account of planning laws and policies, and

rebuts the majority of the claims made by the applicant's planning agent.

The document has been written by Nick Harper and Philip Evemy on behalf of the

residents of Kingsdown and those from further afield who share their love of this

seaside village and their deep concern at the threats posed by the Application.

Some 265 residents of Kingsdown and further afield have objected to the

Application on Dover District Council's planning portal, and more than 650 people

from around the world have signed a petition objecting to the proposals.

Copies of objection statements by some of the statutory consultees and photographs

are appended to this document. Other objections can be seen by visiting the

planning portal on DDC's website.

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Summary of KCG Objections to the Application

• It fails to fulfill Sustainable Development, as defined in Central

Government's National Planning Policy Framework 2012, and 'embedded'

in Dover District Council's (DDC) Local Development Framework Core

Strategy 2010.

• It does not meet the stringent requirements of: BIODIVERSITY – Duty of

Regard NERC 2006 -Section 40.

• It fails to satisfy other planning policies adopted by DDC's Local

Development Framework Core Strategy 2010

• It has no social, environmental, or economic merit and it threatens tourism.

• Claims made in the Application to adhere to The National Planning Policy

Framework and Dover District Council's Core Strategy 2010 have been

rejected unequivocally by The National Trust, by Kingsdown Conservation

Group (in this document) and by many other objectors.

• Under the provisions of Article 10 of the Town and Country Planning

(General Development Procedure) Order 1995 and Section 28 of the Wildlife

and Countryside Act 1981 (as amended), and using its statutory power to

ensure that the natural environment is conserved, enhanced and managed for

the benefit of present and future generations, Natural England has objected

to the development on the grounds that is likely to damage or destroy the

interest features of the SSSI on which the proposed 'huts' would be placed.

• The Kent Downs AONB Unit has opposed the Application because it

would ignore policies set out in The Kent Downs AONB Management Plan

which DDC has adopted, and refers to, in its Core Strategy - paragraph 1.57.

It also ignores policies covered by the KD Landscape Design Handbook.

• To justify its validity, the applicant's planning agent has used an Ecological

Appraisal report produced four years ago when the area and defensive

integrity of the shingle bank was entirely different from that which exists

today.

• The Application documents display lack of due diligence. They are

endlessly repetitive and also contradictory.

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The National Planning Policy Framework and DDC

Core Strategy

Tingdene's proposal is to place 12 'huts' on the Kingsdown Beach SSSI, which is

immediately overlooked by an AONB and Kingsdown Conservation area.

The Beach is the natural habitat of rare flora and fauna which are protected by

various pan-European organizations and laws which, if broken, are punishable by

fines and imprisonment.

The National Planning Policy Framework (NPPF) directs:

To achieve sustainable development - economic, social and environmental

gains should be sought jointly and simultaneously through the planning

system. There is no requirement that economic, social and environmental

gains should be balanced, though net gains should be sought across all

three, and significant adverse impacts on ANY of these dimensions should

be avoided.

There will be significant adverse impact socially if the Application is granted.

Kingsdown Parish Council, the local community and tourists from as far afield as

Canada, Pakistan and Australia have together registered in excess of 650 objections

with DDC Planning.

The claimed economic gain does not stand up to scrutiny. Twelve existing owners

of holiday chalets, or their guests, will have exclusive use of the proposed 'huts' and

are thus already accounted for in the local tourist economy. Shopkeepers in

Kingsdown village say they will derive no economic benefit from the development.

There is no evidence of what the part-time employee referred to will do - apart,

possibly, from clearing rubbish off the beach and warning occupants of the 'huts'

about sleeping overnight.

By contrast, there will be a reduction in the number of tourists visiting

Kingsdown Beach because its natural and 'wild' characteristics will be radically

changed.

In this context, the creation of one part-time job is irrelevant.

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Whilst there is a presumption in favour of Sustainable Development, the NPPF

makes it explicitly clear:

The presumption in favour of sustainable development cannot override

designations and policies that otherwise restrict development.

Examples of these restrictions are: ‘sites protected under the Birds and Habitats

Directives, SSSIs, Green Belt, Local Green Space, AONBs, Heritage Coast,

National Parks, the Broads Authority, designated heritage assets, and locations at

risk of flooding or coastal erosion’.

Kingsdown Beach comes under not one, but five of these protected sites. Therefore

the Application does not conform to any of the strategic objectives contained in the

NPPF's definition of ‘sustainable development’ nor does it embrace the

‘sustainability’ embedded in DDC's LDF Core Strategy.

The Application Letter - 21/12/2012

Addressed directly to Mike Ebbs, Planning Development Manager at DDC, its

heading includes: Town and Country Planning Act 1990.

The inference here is that the Application conforms to this Act when – as

subsequent examination will show – it clearly does not.

The letter presents detailed but misleading ‘facts’ to support the proposal to place

‘huts’ onto the SSSI, quoting numerous reference numbers and objectives set out in

DDC’s Core Strategy, as follows:

i) Kingsdown Beach may well ‘require considerable investment in terms of

maintenance and conservation’

In fact, any conservation work is funded by DDC, or local residents in the form of

beach cleaning, not by the applicant.

No such expenditure (apart from the rates) appears in Tingdene’s accounts. Neither

is it ‘funded by service charge contributions made by chalet owners at the holiday

park’ and this has been confirmed in writing by chalet owners.

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ii) If the applicant genuinely ‘takes its environmental protection responsibilities

seriously and respects the beautiful setting of Kingsdown Beach’ it would not have

made this Application in the first place. At the very least it would have sought a

licence from Natural England – which it is obliged to do by law – before

submitting it.

iii) The ‘Ecological appraisal report from a reputable specialist Bramley

Associates’ does not share Tingdene’s ‘confidence that the ‘huts' can be

accommodated… having due regard to environmental issues’.

On the contrary, Bramley Associates’ecological appraisal lists numerous caveats

regarding necessary safeguards to minimize damage to the fabric of the beach –

none of which can be practically enforced. As Natural England have confirmed, all

of the SSSI is one eco-system. The ‘bare’ shingle and the ‘vegetated shingle’ are

interdependent and necessary to support the protected flora and fauna. They cannot

be separated.

As for the ‘management programme’ envisaged by Bramley Associates, when they

wrote their report four years ago they were clearly unaware of the Kingsdown and

Walmer Beach Management Plan being drawn up by The White Cliffs Countryside

Partnership. This plan was commissioned and funded by Dover District Council.

On page 25, it warns "Adding any more beach huts to the existing ones would

not be recommended as this would increase the risk of trampling and remove

valuable habitat."

Because the Bramley Associates report was written some four years ago, the

Application takes no account of the fact that the shingle beach along the SSSI at

Kingsdown has changed considerably since then. On page 19 of the Kingsdown

and Walmer Beach Management Plan there is a clear reference to this change. It

states" It is currently estimated that the beach at Kingsdown loses approximately

18,000 cubic metres of shingle annually (This information is taken from the Deal to

Kingsdown Coastal Defences Coastal Strategy 2000 - 2005, Strategy Report,

submitted by WS Atkins Consultants Ltd)."

On March 12 2013 - just this week - the sea defences at Kingsdown beach have

been very seriously breached. Huge concrete walls have been pushed over,

steel girders buckled and vast quantities of shingle have been washed away

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By using the Bramley report, the applicant has clearly neglected to check the

current state not only of the area of shingle but also its ability to resist potential

flooding. This fact alone should illustrate how seriously the applicant has

failed to present accurate and safe information.

The resulting threat to the applicant's ability to quickly remove the huts from

danger are obvious. However, the shingle area which has been lost since the

Bramley report was written also makes it impossible for the ‘huts' to be placed in a

location which will be big enough to accommodate them.

iv)‘The huts will be moved back from the tideline in the winter months so the beach

can be rested outside the holiday season, thereby ensuring its sustainability and

protecting its ecology and biodiversity.’

This clearly illustrates a profound ignorance of the ecology and biodiversity of this

beach.

v) The ‘bespoke design’ of the 'hut' confirms that it is no more or less than a hybrid

chalet / mobile home and nothing like a traditional beach hut.

vi) To enhance credibility, the paragraph on Tourism quotes PPS4: Planning for

Sustainable Growth:

‘Local planning authorities should support sustainable rural tourism that benefits

rural businesses, communities and visitors, which utilizes and enriches rather than

harms the character of the countryside and should support extensions to existing

tourist accommodation… to ensure the future viability of such businesses.’

Twelve 'huts’ on Kingsdown Beach will NOT provide increased accommodation

for tourism, There will be LESS, as existing tourists and visitors, seeing that the

'wild' character of Kingsdown Beach has been replaced by the development of a

'mobile home' environment, will go elsewhere. Nor will the ‘huts’ provide wider

economic development in the Dover District area. The only beneficiaries will be

Tingdene and 12 existing chalet owners or their guests. There will be no net gain

for other local businesses.

To suggest that the’ huts’ will ‘utilize and enrich the character of the countryside’

(so as to conform to PPS4) is palpably untrue. Clearly and indisputably they will

actively harm it.

vii) The claim that ‘this application does not contravene any local, county or

regional planning policies and is well founded in planning law and the LDF’ is

inaccurate and misleading.

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Various planning policies are listed to support the Application – all of which, on

closer examination, are contradicted:

CS Policy DM1 & CS Policy DM3

The ‘huts’ represent development on land that is outside the urban boundaries and

rural settlement confines. As such it would not normally be permitted. However,

‘functionality’ and ‘ancilliary to existing use’ (chalets at the holiday camp) are

misleading. The 'huts' on the beach represent an entirely new development.

Furthermore, it is a contrivance to suggest that an application for 12 'huts' on a

protected SSSI beach is supported by, or meets the objectives of, Development

Management Policy DM3 for Commercial Buildings in the Rural Area.

CS Policy DM13

It would be encouraging if chalet owners walked to the beach. There is already

insufficient parking space on any sunny day, irrespective of the season. In the

summer, cars line Undercliffe Road and the parking area in front of the The

Zetland Arms. They also attempt to overpark on North and South Road. The lay-

by referred to usually has one or two camper vans parked on it for days, leaving

space for perhaps three other cars.

Parking is anything but design-led and does not meet the criteria set out by DDC in

DM13.

CS Policy DM15

The necessary constraints imposed by DM15 to ensure protection of the

countryside (in this instance an SSSI immediately overlooked by an AONB and

Conservation Area) are dismissed as follows: ‘Beach huts are a traditional feature

of the English seaside’.

These are not by any stretch of the imagination traditional beach huts.

’And we do not believe this proposal will not (sic) adversely affect the character of

the countryside in any way at all.’

The Kent Downs AONB, the National Trust and Natural England categorically

state that the proposal can only have an adverse affect. Nor are any of the five

special conditions set out in DM15 permitting ‘loss of or adversely affecting the

character or appearance of the countryside’ cited to support the application.

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SEP Policy TSR5

Tingdene designate Kingsdown Beach, an SSSI, as ‘an un-serviced tourist facility’

without working toilets. They say this can be rectified by their ‘taking over disused

public toilets on Undercliffe Road’.

These facilities are already owned by DDC, managed by the Parish Council and

paid for via the precept. They are open throughout the summer months.

There is NO ‘existing un-serviced accommodation on Kingsdown Beach for DDC’s

planning department to facilitate the upgrading and enhancement of’.

The application for 'huts' on the beach therefore has nothing whatsoever to do with

SEP Policy TSR5.

SEP Policy CC1 & SEP Policy CC6

The Application does not fulfil even one of the three elements integral to

Sustainability.

To assert that putting 'huts' onto Kingsdown beach will ‘maximise the use of

existing facilities and resources whilst protecting and respecting the environment’

is clearly untrue. It will put them at risk.

Nor, by any stretch of the imagination, will these 'huts' ‘actively promote the

creation of a sustainable and distinctive community’.

PPS1

The exact opposite of the applicant's assertions under PPS1 is true:

‘The proposal is intrinsically UNSUSTAINABLE development which does NOT

balance the needs between economic, social and environmental consideration’.

Good Practice Guide on Planning for Tourism 2006

The Application claims to: ‘maximise the use of existing facilities and resources in

a sensitive and appropriate manner.’

KCG asserts that, on the contrary, it is socially insensitive, environmentally

inappropriate and economically insignificant.

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Tingdene Application Form to DDC

Tingdene’s Application for Planning Permission Town and Country Planning Act

1990 paperwork dated 21st December 2012 contains the following inaccuracies:

Biodiversity and Geological Conservation

a) Protected and priority species

b) Designated sites, important habitats or other biodiversity features.

c) Features of geological conservation importance

It is not a simple oversight to tick the boxes which indicate: Yes, on land adjacent

to or near the proposed development. It is deliberate misrepresentation to suggest

that an SSSI can be divided into ‘go’ and ‘no-go’ areas to suit the commercial

aspirations of the applicant.

Flora and fauna are an integral part of all the land on which the 'huts' are to be sited

and the entire area is a protected SSSI. The correct box should have been ticked to

reflect this.

Assessment of Flood Risk

It is encouraging to note that DDC Planning insisted on a Flood Risk Assessment

being carried out by Tingdene under this section. In spite of the applicant ticking

No against all the boxes, the sea is only a few metres away from the proposed

development, and it is common knowledge that adverse combinations of wind and

tide can increase the high tide line by several metres.

Vehicle Parking

There is not space for 12 cars in the lay-by on Undercliffe Road. During the

summer months in particular there are often camper vans that park up for days –

but even if there weren’t there is still no space for more than 7 cars (allowing for

their occupants to open the doors and get out).

Design and Access Statement

The statement opens:

‘We welcome the opportunity this Design and Access Statement presents to

demonstrate our commitment to achieve good design and to ensure accessibility.

We confirm all the work we undertake will meet the various obligations placed on

the applicants by legislation and policy’.

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Proposal

This entire section of the statement has been cut and pasted into the Letter of

Application – which has already been examined and robustly rebutted above.

Design Issues

(i) The beach CANNOT be ‘rested outside of (sic) the holiday season

thereby ensuring its sustainability and protecting its ecology and bio-

diversity’. It is unreasonable to suggest it can, and no informed

naturalist or ecologist would support this assertion, as is evidenced by

statements from Natural England and Kent Downs AONB.

(ii) How can a 4 1/2 ft gap between twelve 15 ft long 'huts' ‘maintain

UNRESTRICTED views to the sea at any point along the beach?’ It is

impossible. As soon as anything above the eye-line is placed on a beach

it causes an obstruction. Nor can the 'huts' be moved easily. They are

mounted on two small wheels which will inevitably sink into the

shingle. The only way they can be moved is with a heavy-duty tractor.

(iii) Traditional beach-huts sit flat, often on railway sleeper platforms for

stability, and are made of wood with felt roofs. Not tile-effect steel.

The design of the Tingdene 'hut' is more akin to a static mobile home,

or chalet. They will be inappropriate on Kingsdown Beach and bear no

relation to any definition of a beach hut. Furthermore, the Tingdene

'hut' is equipped with a battery pack. This will cause light pollution and

may require a noisy generator in an entirely inappropriate area.

(iv) The beach is indeed ‘a beautiful setting with an attractive backdrop of

trees, with sheer chalk cliffs behind, mostly covered in trees and

shrubbery’. However, it is not 'topped by the distinctive A-framed dark

timber chalets of Kingsdown Holiday Park.’ The chalets are completely

obscured by trees which, fortunately, are the subject of a Tree

Preservation Order imposed by DDC Planning.

(v) ‘Every care and consideration will be given to nature conservancy;

protection of biodiversity and habitat.’

Such assurances are easily given but, in real terms, are impossible to

deliver - as Bramley Associates make only too clear with their list of

caveats. Notably, the fragile shingle will be disrupted whenever the

'huts' are installed (on their timber stabilising platforms) and moved.

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(vi) 'We do not envisage any problems with rights of light, boundaries or

pollution. Similarly there are no issues relating to privacy… as far as

we are aware'.

Although Tingdene describe Kingsdown Beach as a private beach and

infer that they own it all, they are well aware that this is not the case.

Both sides of their land are bordered by private land that does NOT

belong to Tingdene.

To the north, by South Road Kingsdown Management Company Ltd

(SRKMCL) and to the south, by the MOD. It is highly likely that issues

regarding boundaries being crossed and land being adversely affected

by families 'spreading' from the 'huts' would give rise to compensation

claims for pollution and damage to 'their' sections of the SSSI.

(vii) 'We do not believe any additional crime prevention measures are

required as the beach huts will be managed and maintained by staff at

Kingsdown Holiday Village.'

The 'huts' are not close to houses nor should they be inhabited at night.

As such they are open to abuse by 'leaseholders' who may sleep in them,

and the huts are perfect targets for vandalism. Additional crime

prevention measures will definitely be required. The applicant's

presumption that these can be met by one man working part-time is

unrealistic.

Conclusion

'We believe our proposals are well designed - the beach huts are of a modest scale,

easily transportable/removable and have an attractive appearance. This proposal

respects the sensitive nature of the SSSI while delivering significant wider benefits,

including an enhanced offer for tourism and sustainable economic development in

the Dover District area.'

The first group of assertions are entirely subjective. KCG disagrees with all three:

the proposals have no design integrity whatsoever, the 'huts' are far too large to be

called beach huts (they are mobile homes), they require a heavy tractor to move

them, and their appearance is entirely inappropriate for the beach.

To then claim that placing 12 of them on Kingsdown Beach 'respects the sensitive

nature of the SSSI' and 'delivers significant wider benefits - including an enhanced

offer for tourism and sustainable economic development..' is not credible and

demonstrates ignorance of how an SSSI ecosystem works, There is no enhanced

offer for tourism or sustainable economic development.

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Bramley Associates Ecological Appraisal

The report by Bramley Associates was commissioned by Tingdene in 2009 and the

survey actually carried out on the 9th and 20th June. That's almost FOUR years

ago.

It is a carefully considered report, with many caveats to ensure that the SSSI would

have the best chance of surviving a small development, just behind the summer

high tide line, of traditional beach huts.

These included:

'Access to any huts on the site across the vegetated shingle and through the

bordering woodland will need to be strictly controlled….. It is recommended that

access to any beach huts is carried out from the public car park area, at the end of

South Road/Wellington Parade only'.

The Application ignores completely this crucial recommendation and instead says

access will be from a small lay-by next to where the vegetated shingle starts on

UnderCliffe Road.

Occupiers of beach huts installed on the non-vegetated shingle will need to be

informed about the ecological significance of adjoining habitats and behaviours

such as BBQ's, disposal of waste and dog exercising(all of which provide nutrient

enrichment), should only be carried out in the clear understanding of their

potential impact on protected habitats and species. The legal issues of taking or

picking wild flowers… will need to be clearly outlined.'

The only people empowered to patrol and enforce these safeguards are the Police -

not one part-time employee from Tingdene's holiday camp. KCG contends that the

Police are unlikely to have the desire or the resources to be involved.

The explanation for an (albeit highly qualified) positive recommendation from

Bramley Associates is that the Survey was carried out nearly FOUR years ago. And

since that time the beach has changed considerably.

It is common knowledge that extensive shingle attrition along the length of

Kingsdown Beach is entirely normal. Historically, DDC's Engineering Department

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regularly monitors the high tide line and maps movement of shingle. Hundreds of

thousands of £s are spent on shingle replenishment.

However there have been exceptional budgetary constraints over the last four years

so replenishment has not taken place with its usual frequency. During that time the

shingle has been allowed to decrease substantially - so much so that the concrete

defences in front of The Zetland Arms were undermined a year ago, when the

shingle level dropped to such a degree that the sea was able to destroy four sections

of the concrete promenade. The most recent damage and shingle attrition have

been referred to earlier in this document.

The result of this lack of shingle replenishment is that not only have the sea

defences at Oldstairs Bay been compromised (the boulders around the groin are

completely exposed now as the sea bed level drops further and further) but the high

tide line along Kingsdown Beach has been steadily moving back westwards toward

Undercliffe Road.

This change between then and now is clearly illustrated by examining Figure 1 and

Figure 5 from Bramley's Report, and comparing them with today's evidence. It is a

measurable fact (with the Council's Marine Engineering Department) that as the

level of shingle along the beach has sunk so the high tide line has moved ever

closer to the vegetated shingle. A conservative estimate would be by as much as

35 metres in the last four years.

This explains why, at the time, Bramley's Report suggested that there was enough

shingle between the high tide line and the vegetated shingle to consider a small

number of beach huts. Traditional beach huts, not 15 ft long mobile homes.

The applicant's consultants were adamant that access should only be from the

public car parking area at The Zetland Arms end of the beach. And they wanted to

carefully measure any changes in the area of the development plot (they would

have been aware of the shingle depletion and replenishment cycle which was

controlled by DDC).

It is a serious failure of due diligence on the part of Tingdene's planning agent not

to have re-commissioned an up-to-date report from Bramley Associates before

submitting this Application. Instead they have relied on a report where the all-

important issue of shingle area, height from sea level and distance from the

vegetated parts of the beach bear little relation to how they are today

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Finally, and of great concern, is the reference by Bramley Associates to a future

review of the planning permission. This implies that possible expansion of the 'hut'

scheme was already being discussed four years ago.

Flood Risk

Summary

Almost all of the report’s Summary has been cut and pasted from the Letter of

Application – which has already been examined and robustly contradicted above.

Apart from:

'The development proposal for 'removable beach huts' on Kingsdown Beach is

supported by this flood risk assessment which demonstrates:

- the proposed development is unlikely to be affected by current or future surface

water flooding from any source.

- the design (of this development) will reduce flood risk to the development and

elsewhere, by incorporating sustainable drainage systems and flood resilience

measures; and

- the development will create opportunities to enhance bio-diversity and amenity,

and protect the historic environment'.

All three of these statements do not apply to putting 12 ' huts' onto a shingle beach

set back from the high tide line.

Proposal Sustainability

In this section the applicant has cut and pasted no less than 14 of DDC's

Sustainability Objectives. No link or explanation is made between these objectives

and Tingdene's proposal to put 'huts' onto Kingsdown beach. This is just as well

because the proposal does not fulfill any of them. These particular objectives relate

to large-scale building developments and have no bearing on this Application

Similarly, another section is lifted from the Core Strategy in its entirety under the

heading Achieving Sustainable Development.

The crucial sentence 'The presumption in favour of sustainable development cannot

override designations and policies that otherwise restrict development' has been

carefully edited out of the cut and paste.

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But, inexplicably, the paragraph that follows, which lists examples of these

restrictions (Kingsdown Beach comes under not one, but five of them) is included:

‘Sites protected under the Birds and Habitats Directives, SSSIs, Green Belt, Local

Green Space, AONBs, Heritage Coast, National Parks, the Broads Authority,

designated heritage assets, and locations at risk of flooding or coastal erosion’.

Presumably the reference to flooding and coastal erosion was seen as being

relevant to a Flood Risk Assessment, while actually its inclusion and context

underlines the paucity of any supporting argument for Tingdene's proposal which

cannot override designations and policies that otherwise restrict development.

'Kingsdown Beach is currently enjoyed by walkers and is open to the public even

though it is funded by service charge contributions made by the chalet owners at

Kingsdown Holiday Park.'

INCORRECT.

'The new beach huts will be an extremely welcome attraction for Kingsdown Beach

and we believe this proposal is intrinsically sustainable because: - is accessible to

all services, facilities, recreational opportunities and employment.

INCORRECT.

- protects and enhances the SSSI beach and local heritage.

INCORRECT.

- beach hut users will have no need to travel. as they will already be staying at the

nearby holiday park village which is five minutes from the beach, and therefore the

proposal encourages alternatives to the car and makes the best use of existing

transport Infrastructure'.

This directly contradicts the assertion that the 'lay-by for twelve cars' is a designed

parking solution. How does walking make the best use of Kingsdown's transport

infrastructure?

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Conclusions to Flood Risk Assessment

PPS 25 (and the new NPPF) state that for all stages of the planning process, the

minimum requirements for flood risk assessment are that they should:

(iv) Be undertaken by competent people as early as possible in the particular

planning process, to avoid misplaced effort and raising landowner expectations

where land is unsuitable for development.

'We liaised with officers from DDC and the EA upfront, and the professional

qualifications of the author are given below.'

This is simply not credible. DDC's Policy document includes the following explicit

Instruction:

'Any proposals for development in Flood Zone 3 will require developers to

under-take a detailed Flood Risk Assessment.

Developers should seek advice from the Environment Agency as to the

specific requirements for assessment'.

There is no reference in the Application to the names of the officers from DDC and

the Environment Agency. Nor are there references to dates, plans and projections,

shingle measurements from a qualified marine engineer, ‘hut’ locations, tide

timetables etc.

Furthermore, the supporting material that is supplied is cut and pasted from

existing publications which set out general principles, but they are not related

specifically to Kingsdown Beach which is in a Flood Zone 3 and has a high

probability of inundation from the sea.

(v) Consider both the potential adverse and beneficial effects of flood risk

management…

'The huts are set back from existing sea defences maintained by Dover DC but

in the event of an alert they can be relocated easily.'

To ensure (as Tingdene's proposal sets out) that the ‘huts’ would not encroach

on vegetated shingle they would need to be positioned perilously close to the

high tide line because the width of shingle between that line and vegetated

shingle on 10th March 2013 varies from between 8m at the northern

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perimeter of its land and 17m at the southern perimeter Consequently, there

would be a high risk of flooding.

Not only are the ’huts’ difficult to move because they are heavy and have small

wheels which ‘dig’ into the shingle, but to remove 12 buildings like mobile homes

safely away from the high tide line in a matter of hours without encroaching on and

damaging the vegetated shingle would be impossible.

More Reasons for Objecting to this Application

Planning Policy Statement 4

Objectives:

Quote: ‘The government's overarching objective is sustainable growth, that is:

Growth that can be sustained and is within environmental limits, but also enhances

environmental and social welfare’

The Tingdene 'huts' on Kingsdown beach are a socially divisive & environmentally

destructive proposition.

Quote: To raise the quality of life and the environment in rural areas by promoting

thriving, inclusive and locally distinctive rural communities whilst continuing to

protect the open countryside for the benefit of all.’

The Tingdene 'huts' on Kingsdown beach will reduce the quality of life and the

environment in Kingsdown, it will be socially exclusive for the benefit of 12

families at the expense of the local community – who are universally opposed to

this development – and will certainly not protect the beach

EC2 Planning for Sustainable Growth

Of the 11 (a-k) directives to Local Planning Authorities from central government,

not one includes or supports the kind of development proposed by

the Tingdene 'huts' on Kingsdown beach

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EC6 Planning for Economic Development in Rural Areas

6.i Quote: Local planning authorities should ensure that the countryside is

protected for the sake of its intrinsic character and beauty, the diversity of its

landscapes, heritage and wildlife, the wealth of its natural resources and to ensure

that it may be enjoyed by all.

6.ii Quote: Strictly control economic development in open countryside away from

existing settlements or outside areas …

EC7 Planning for Tourism in Rural Areas

7.1 Quote: Help deliver the Government’s tourism strategy, support sustainable

rural tourism and leisure development that benefits rural businesses, communities

and visitors and which utilise and enrich rather than harm the character of the

countryside.

The Tingdene 'huts' on Kingsdown beach will not benefit any of the target groups

and will impoverish and harm the wild, unspoilt nature of Kingsdown beach.

7.i.a Quote: Carefully weighing the objectives of providing adequate facilities or

enhancing visitors’ enjoyment .. with the need to protect landscapes and

environmentally sensitive sites.

7.i.c Quote: Support extensions to existing tourist accommodation where the scale

of the extension is appropriate to its location and where the extension may help to

ensure the future viability of such business.

The Tingdene 'huts' on Kingsdown beach are not appropriate in scale, and

Tingdene’s holiday park at Kingsdown has provided no audited evidence that it

needs the help of 12 'huts' on a beach to ensure its future viability.

7.i.d Quote : Ensure that new or expanded holiday and touring caravan sites and

chalet developments are not prominent in any landscape and that any visual

intrusion is minimized by effective, high quality screening and examine the scope

for relocating any existing visually or environmentally-intrusive site away from

sensitive areas (SSSI) or from sites prone to flooding or coastal erosion.

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The Tingdene 'huts' on Kingsdown beach would be a prominent development on an

ecologically sensitive site protected by Natural England, the AONB & Kingsdown

Conservation Area.

7.i.e Quote: Recognise that in areas statutorily recognised for their national or

cultural heritage qualities there will be scope for tourist and leisure related

developments subject to appropriate control over their number form and location

to ensure that the particular qualities or features that justified the designation are

conserved.

Kingsdown Beach is an SSSI which is protected by Natural England and the Kent

Downs AONB. DDC’s Planning Department has been advised of this, by statutory

consultative organizations.

Planning Policy Statement 7

Instructions to local Planning Departments

Objectives:

i: Raise the quality of life and the environment in rural areas through the

promotion of:

Continued protection of the open countryside for the benefit of all, with the highest

level of protection for our most valued landscapes and environmental resources.

ii: Promote more sustainable patterns of development:

Key Principles

The following key principles should be applied in combination with all the policies

set out in PP7:

Decisions on development proposals should be based on sustainable development

principles, ensuring an integrated approach to the consideration of:

- social inclusion, recognising the needs of everyone.

- effective protection and enhancement of the environment

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- prudent use of natural resources

- maintaining high and stable levels of economic growth and employment.

The Tingdene 'huts' on Kingsdown beach meets the needs of 12 families to the

detriment of thousands of residents, visitors and tourists. It undermines and spoils

the environment, and provides negligible growth and employment.

All developments in rural areas should be well designed and inclusive, in

keeping and scale with its location and sensitive to the character of the

countryside and local distinctiveness.

The Tingdene 'huts' on Kingsdown beach are nothing like a traditional British

seaside beach-hut. 15ft wide, with a tile effect roof and mounted on wheels it looks

more like a mobile home or chalet. Its design is utterly insensitive to the character

of the beach location or wider countryside environment.

Countryside Protection and Development

Planning Policies should have particular regard to any areas that have been

statutorily designated for their landscape, wildlife or historic qualities where

greater priority should be given to restraint of potentially damaging development.

When preparing policies for LDD’s and determining planning applications for

development in the countryside, local planning authorities should:

- take account of the need to protect natural resources

- conserve specific features and sites of landscape and wildlife..in accordance

with statutory designations.

Kingsdown beach is an SSSI which is protected by Natural England and the Kent

Downs AONB. DDC’s Planning Department has been advised of this, by both

statutory consultative organizations.

Nationally Designated Areas

Nationally designated areas comprising… Areas of Outstanding Natural Beauty

have been confirmed by the Government as having the highest status of

protection in relation to landscape and scenic beauty. The conservation of

wildlife and the cultural heritage are important considerations in these areas.

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As well as reflecting these policies in LDD’s and where appropriate RSS, should

also support suitably designed and located development necessary to facilitate the

economic and social well-being of their designated areas and their communities…

Tourism and Leisure

Local Authority RSS and LDD’s should:

- support through planning policies sustainable rural tourism and leisure

developments that benefit rural businesses, communities and visitors and

which utilize and enrich but do not harm the character of the countryside…

its villages and other features.

- Recognize that in areas statutorily designated for their landscape, nature

conservation there will be scope for tourist and leisure related

developments, subject to appropriate control over their number, form and

location to ensure the particular qualities or features that justify the

designation are conserved.

- Plan for and support the provision of general tourist and visitor facilities in

appropriate locations where identified needs are not met by existing

facilities in rural service centres.

Tourist Accommodation

Local authorities should carefully weigh the objective of providing adequate

facilities and sites with the need to protect landscapes and environmentally

sensitive sites, and examine the scope for re-locating any existing visually or

environmentally-intrusive sites away from sensitive areas, or for re-location

away from sites prone to coastal erosion.

Where appropriate (e.g. popular holiday areas) set out policies in LDD’s on the

provision of new holiday and touring caravan sites and chalet developments,

and on the expansion and improvement of existing sites and development –

while ensuring:

New or expanded sites are not prominent in the landscape and that any visual

intrusion is minimized..

The Tingdene 'huts' on Kingsdown beach are to be sited on an extremely sensitive

environmental site which contains protected species of flora and fauna and is prone

to coastal erosion. The 'huts' would be prominent in the landscape and there is

already ample chalet- style accommodation available within the existing holiday

park owned by Tingdene in Kingsdown.

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Conclusion�

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All these documents, all these government bodies and initiatives, all these laws

to protect our national heritage, our landscape, our enjoyment and

appreciation of Nature. And yet this scheme has been proposed by an

applicant claiming to respect the environment.

Kingsdown Conservation Group, on behalf of all who live in this unique

seaside village and those from further afield who share their deep concern, ask

Dover District Council to give reasonable and proper consideration to the

material contained in the document and in its appendices in determining this

application.

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Philip Evemy Nick Harper

Chairman Consultant

Kingsdown Conservation Group Kingsdown Conservation Group

Appendices

Statements of objection to the Application by Natural England, The National Trust,

Ringwould with Kingsdown Parish Council, The Kent Downs AONB Unit, email

dated March 13 2013 from Jennifer Bate, Kent Downs Planning Officer to Philip

Young, and pictures of beach showing shingle depletion and increase in flood risk.

Cc

Patrick MacWilliam Chairman, Ringwould with Kingsdown Parish Council

Charlie Elphicke- Member of Parliament for Dover & Deal

Cllr Sue le Chevalier - District Cllr for Ringwould & Parish Clllr for Walmer

Cllr Steve Manion - Kent County Councillor

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Appendices

E-Mail clarifying Adoption of ANOB Management Plan by Dover

District Council in their CORE STRATEGY

To: Philip Young

Cc: Gill Bell ; Nick Johannsen ; Peter Wallace ; Alice Fey ; Nick Delaney

Sent: Wednesday, March 13, 2013 12:35 PM

Subject: RE: Borders of the AONB - The setting�

Dear Philip

As you may know we have objected to the application at Kingsdown. I enclose a copy of our

comments to Dover.

The application is within the 'setting' of the AONB which is part of the reasons for designation of

the Kent Downs - the quality of the views out and towards the AONB being a factor in their

designation.

The conservation and enhancement of the setting of protected landscapes (AONBs and

National Parks) is not covered by the new National Planning Policy Guidance (NPPF); The

'setting' of AONBs was previously covered by policy C3 of the South East Regional Strategy.

However this strategy will be revoked on 25th March 2013.

The Dover Core Strategy and Development Management policies and saved Local Plan policies

have general landscape and countryside policies that do not specifically mention the AONB or

its setting. It therefore appears that as from 25th March there could be a policy gap in relation to

the setting of the AONB. However, Dover has adopted the Kent Downs AONB Management

Plan and refers to the AONB in the Core Strategy para 1.57. It is a material consideration in

determining any planning application. The Management Plan's objectives cover the need to

conserve and enhance the AONB, and its setting and there are specific policies addressing

this: page 61, LLC8; and page 128, SDT5

You can access the KD Management Plan on our web site.

The reason why the setting is included in the Management Plan is because development within

the setting can challenge the purposes of designation of the AONB.

The legal context of AONBs is set out in the CROW Act 2000:

Section 82 – sets out the primary purpose of designations of an AONB to conserve and enhance

natural beauty

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Section 84 – states the powers that LAs have to take action to achieve conservation and

enhancement

Section 85, Duty of Regard”: states that in exercising or performing any functions in relation to,

or so as to affect, land in and AONB, authorities “shall have regard” to their purposes please

refer to Natural England’s publication: ‘England’s Statutory Landscape Designations’

Section 89 - The Act requires a management plan to be produced; the first Kent Downs AONB

Management Plan was published in April 2004 and the first revision management plan (2009-

2014) was published in April 2009. This has been formally adopted by all the local authorities of

the Kent Downs and is a material consideration in all planning decisions.

If a proposal in the setting of an AONB challenges the purposes of designation of that AONB it is

clear that this should be a material consideration in the determination of the application.

So in answer to your question - Government Planning Guidance does not specifically cover the

‘setting’ of AONBs, but the legal context and the importance of the Kent Downs Management

Plan – Dover’s own plan for the management of the Kent Downs AONB in their area – means

that any development within the setting needs to be determined in relation to its impact on the

purposes of designation of the AONB. In the case of the Kent Downs ANOB one of the main

reasons for designation was the quality of the views both towards, and out of the AONB.

I hope this clarifies the situation for you

Best wishes

Jenny

Jennifer Bate

Kent Downs Planning Officer

Kent Downs AONB Unit

West Barn, Penstock Hall Farm

Canterbury Road

East Brabourne

Ashford

Kent

TN25 5LL

Tel. 01303 815170

Email: jenny.bate@kentdowns.org.uk Conserving and enhancing the Kent Downs Area of Outstanding Natural Beauty

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Objection E-Mail from Natural England Date: 08 March 2013

Our ref: 79704

Your ref: DOV/12/01016

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Sarah Platts Development Control, White Cliffs Business Park, Dover, Kent, CT16 3PJ BY EMAIL ONLY

Customer Services Hornbeam House Crewe Business Park Electra Way Crewe Cheshire CW1 6GJ T 0300 060 3900

Dear S Platts, Proposal: Erection of twelve beach huts Location: Kingsdown (Private) Beach, Undercliffe Road, Kingsdown, CT14 8EU Thank you for your consultation on the above dated 26 February 2013 which was received by Natural England on the same date. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. This reply comprises our statutory consultation response under the provisions of Article 10 of the Town and Country Planning (General Development Procedure) Order 1995 and Section 28 of the Wildlife and Countryside Act 1981 (as amended). Objection This application is directly within Dover to Kingsdown Cliffs Site of Special Scientific Interest (SSSI). Natural England objects to this development on the grounds that the application, as submitted, is likely to damage or destroy the interest features for which this SSSI has been notified. Our concerns are set out below. � This part of the SSSI (unit 23) is a broad shingle plateau with a succession of plant communities influenced in their extent and composition by increasing shingle stability. Coastal vegetated shingle is a UK BAP priority habitat. The habitat is slow to form and is easily damaged by vehicles and trampling by access on foot that is associated with this development. While the applicant is proposing to place the beach huts on the unvegetated shoreline, this does not prevent damage from the associated movement of the users of the huts. Additionally, the annual placing and removal of the huts has the potential to interrupt the natural movement of shingle and thus the environmental and ecological processes.

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� The SSSI is also notified for its vascular plant and invertebrate assemblages. Of particular note in unit 23 are the early spider orchid Ophrys sphegodes which is a nationally rare plant protected under schedule 8 of the Wildlife and Countryside Act 1981 (as amended); and the bright wave moth Idaea ochrata a UK BAP species with a very restricted breeding range in Britain largely confined to localised areas along an 18km stretch of coastline in East Kent between Ramsgate and Kingsdown. Both the plant and invertebrate assemblages would be at risk from increased recreational activity that would be associated with the provision of these beach huts. We have considered this application along with the proposed mitigation and view that it is unlikely that even if the mitigation was strictly enforced that there would be no adverse impacts upon the rare and fragile vegetated shingle habitat (and associated flora and fauna). We therefore object to this proposal. If your Authority is minded to grant consent for this application contrary to the advice relating to Dover to Kingsdown Cliffs SSSI contained in this letter, we refer you to Section 28I (6) of the Wildlife and Countryside Act 1981 (as amended), specifically the duty placed upon your authority, requiring that your Authority:

� Provide notice to Natural England of the permission, and of its terms, the notice to include a statement of how (if at all) your authority has taken account of Natural England’s advice, and � Shall not grant a permission which would allow the operations to start before the end of a period of 21 days beginning with the date of that notice.

Designated Landscapes The proposal is less than 600 metres from and therefore within the setting of the Kent Downs Area of Outstanding Natural Beauty (AONB). The AONB Unit should therefore be consulted on this application for views on the impact of this proposal upon the designated landscape. The proposal site also lies less than 400 metres from the South Foreland Heritage Coast. Other advice We would expect the Local Planning Authority (LPA) to assess and consider the other possible impacts resulting from this proposal on the following when determining this application:

� local sites (biodiversity and geodiversity)

� local landscape character Natural England does not hold locally specific information relating to the above. These remain material considerations in the determination of this planning application and we recommend that you seek further information from the appropriate bodies (which may include the local records centre, your local wildlife trust or other recording society and any local landscape characterisation document), in order to ensure the LPA has sufficient information to fully understand the impact of the proposal before it determines the application. A more comprehensive list of local groups can be found at Wildlife and Countryside link. We value your feedback to help us improve the service we offer. We have attached a feedback form to this letter and welcome any comments you might have about our service. If the form is not attached, it can also be accessed on our website. For any queries relating to the specific advice in this letter only please contact Mary Tomlinson on the contact details below. For any new consultations, or to provide further information on this consultation please send your correspondences to consultations@naturalengland.org.uk..

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Yours sincerely, Mary Tomlinson Land Use Operations Tel: 0300 060 0296 Email: Mary.tomlinson@naturalengland.org.uk On behalf of Nigel Jennings, Senior Advisor, Land Use Operations

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Objection E-Mail from National Trust

To: Philip Evemy (Kingsdown Conservation Group)

Sent: Monday, March 11, 2013 15:21 PM

Subject: RE: wheeled huts on Kingsdown beach

Hello Phillip

I am attaching here the final version of the letter that was sent to DDC Planning Officer Sarah Platts – unfortunately as it is a file copy it has been sent to me with no heading (Trust stationery). I’ve asked for a more official version but thought that you might like to read the text in the meantime.

Best wishes

Virginia

Virginia Portman General Manager White Cliffs & Winchelsea portfolio National Trust Telephone 01304 200005 Mobile 07768 027034

National Trust letter reads:

The National Trust objects to this application. As you are aware the Trust owns and manages

much of the coastline within the district and in particular Kingsdown Leas which extends to the

south of the site.

The National Trusts’ recent (2012) public appeal to raise funds to purchase a section of this

coastline, at Fan Bay, is testament to the extent that people value and wish to conserve this

stretch of unspoilt and iconic Kent coastline. This was probably the most successful appeal ever

by the Trust for a coastal acquisition, raising £1.2 million in under 100 days. We feel that

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allowing the type of development proposed in the same area would be seriously detrimental to

its landscape, heritage and conservation.

Impacts on the area

We are strongly opposed to the use of the beach for any form of built development. We also

consider the proposed huts, at 5.5m x 2.7m x 3.5m in height to be large scale and bulky and that

these in no way reflect traditional seaside huts. We are concerned that they will have a totally

undesirable impact on the landscape of the beach and completely spoil the open, tranquil,

unspoilt character of the area. It is stated in the application that lighting and power will be

available which not only implies that they could quite easily be occupied as dwelling units but will

cause highly undesirable light pollution. The proposal will adversely affect the amenity of

residents of the area and users of the White Cliffs Country Trail. The site is part of the Dover to

Kingsdown Cliffs SSSI which is notified for its extreme importance geologically and

physiographically and for its varied floral and faunal communities. We do not agree with the

conclusions of the Ecological Appraisal that the proposal is acceptable subject to the measures

proposed. The Ecological Appraisal mentions the importance of the SSSI and adjacent County

Wildlife Sites and the surveys identified a very wide range of flora and fauna. However, there

was little discussion of, for example, U.K Biodiversity Action Plan species and habitats or of

mitigation for European Protected Species. In addition the measures proposed to mitigate

development on such a fragile SSSI are wholly inadequate and consists largely of mapping and

monitoring its effects. The Ecological Appraisal itself mentions a number of these potentially

damaging effects, such as increased dog numbers, waste, barbeques, introduction of non native

species, trampling and picking wildflowers. To this could be added the detrimental effects of

noise, additional lighting and the positioning of large beach huts. There are no significant

remedial measures proposed in the report.

The National Planning Policy Framework

In our opinion the proposal is contrary to the principles and policies contained in the National

Planning Policy Framework 2012. In particular paragraph 109 seeks to protect and enhance

valued landscapes, and geological conservation interests, and minimise impacts on biodiversity.

Paragraph 113 seeks to ensure that designated areas are protected in a manner commensurate

with their status and that appropriate weight is given to the importance of the area and the

contribution made to wider ecological networks.

Of particular importance is paragraph 114 which states:

‘Local Planning Authorities should:

….maintain the character of the undeveloped coast, protecting and enhancing distinctive

landscapes, particularly in areas defined as Heritage Coast, and improve public access to and

enjoyment of the coast’.

Paragraph 118 states that development on land within an SSSI which is likely to have an

adverse effect on the site should not normally be permitted. Exceptions should only be made

where the benefits outweigh the impacts on both the site itself and the broader impact over a

wider area. The proposed development has, in our opinion, no material benefits to outweigh the

potential harm of the proposal.

The proposal also conflicts with the policies of the NPPF with regard to potential pollution

including noise and light pollution – paragraphs 120 to 125.

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Dover District Core Strategy 2010

The application site falls outside the boundary of the built up area of Kingsdown and is adjacent

to the Kingsdown Conservation Area. The proposal conflicts with local planning policy on a

number of counts. Firstly the proposal is contrary to Policy CP7 of the Core Strategy which

seeks to protect and enhance the integrity of the Green Infrastructure Network of the district.

The coastline is an integral part of this network.

The proposal conflicts with Policy DM1 which only permits development outside settlement

boundaries if specifically justified by other policies of the plan, functionally requires such a

location or is ancillary to existing development. The proposal does not meet these criteria.

The proposal conflicts with Policy DM15 which seeks to prevent development which would result

in the loss of or adversely affect the character or appearance of the countryside. It is not justified

by the need to sustain the rural economy and could well be accommodated elsewhere. The

proposal is not ancillary to the existing Holiday Park but forms a major new venture. Finally the

proposal also conflicts with Policy DM16 which seeks to prevent development that would harm

the character of the landscape.

I trust you will give due consideration to our views in determining this application.

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Objection E-Mail from Kent Downs AONB Unit

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From: Jenny Bate

Sent: 05 March 2013 11:52

To: 'alicefey@dover.gov.uk'

Cc: mary.tomlinson@naturalengland.org.uk; 'sean.hanna@naturalengland.org.uk'; Gill Bell

Subject: RE: Tingdene - Kingsdown Beach DOV/12/01016 {Scanned by ADM Mail Safe}

Importance: High

Dear Alice

We have been advised of the application for beach huts at Kingsdown beach by a third party.

The site is in the setting of the Kent Downs AONB. However we would not normally expect to

be consulted by you on this application under the protocol we have with you. As it will have a

damaging impact on the views from the AONB to the south ( the Lees) we would however draw

your attention to the policies in The Kent Downs AONB Management Plan, and the KD

Landscape Design Handbook. This development would change the outlook from the AONB

northwards along this coastal stretch and be damaging to the purposes of designation. We

would therefore support you in a decision to refuse this application.

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Relevant KD Management Plan policies:

General:MPP2

The setting:

Views of the AONB- the cliffs – from the beach level south into the AONB

Views out from the AONB – from the Lees looking north

LLC2 , LLC8, GNR5

Page 58 of the Management Plan – Heritage Coast

Page 60 – para 2 Taking a landscape character approach

Biodiversity: BD2 f) the conservation and enhancement of chalk cliffs and the foreshore.

The habitat here is an inherent element of the landscape character contributing to the visual

importance of this area.

If we can be of further help please contact me.

Best wishes

Jennifer Bate

Kent Downs Planning Officer

Kent Downs AONB Unit

West Barn, Penstock Hall Farm

Canterbury Road

East Brabourne

Ashford

Kent

TN25 5LL

Tel. 01303 815170

Email: jenny.bate@kentdowns.org.uk

Conserving and enhancing the Kent Downs Area of Outstanding Natural Beauty

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Letter of objection to Dover District Council from Ringwould with

Kingsdown Parish Council

In regards to planning application DOV/12/01016. Erection of 12 beach huts on Kingsdown beach, Published on Date: Thursday 7 March, 2013

This is the most significant planning application for the community of Kingsdown for many years. The Parish Council wish to object to this development in the strongest terms. The Parish Council, given the character, landscape, environmental and amenity value of this land, does not feel that any development should be permitted on this land. This is an area of outstanding character beauty and charm. Equally, its environmental value is nationally recognized in the SSSI designation. It is part of an unspoilt, special and unique land and seascape from the cliffs, the rifle range to the South Road Conservation Area. The area is over looked by the AONB and National Trust land on the cliffs. The views enjoyed from the rifle range to the conservation area have delighted generations over the years. The proposed development will destroy these views and change the beauty of the area. The development will fundamentally alter and damage this landscape. The character and charm of this area is crucial to the identity of Kingsdown and the conservation area. The Parish Council believe this area should be protected by its designation as an SSSI and Heritage Coast. The Coastal Footpath will run through this area. Any owner of an SSSI has a duty to promote the features of ‘interest’ cited in the SSSI and this proposal does not do this. There are many natural habitats in the area and this area is an important location for bats and biodiversity in general. We believe there is no way this development cannot but damage the SSSI and the ‘vegetated shingle’ environment. This is a special and unique area, partly because it is the only area locally that is not backed by housing development; the shingle beach has a particular character backed by the cliffs and the trees. Dover District Council have re-constructed the rifle range and this now forms an attractive location for visitors and tourists. This development will change the wild and natural character of this area and will make it feel more like a resort and will detract form the visitor experience. The development relies on public facilities and is not viable as an independent entity. Any attempt to develop facilities would add further weight to the arguments against the proposal. This is a public space which has always been enjoyed by residents and tourists alike. This development will make it a privatised space. The development will not benefit the community of Kingsdown and is universally opposed by residents. The Parish Council believes that both local and District Council’s have a duty to reflect these views. It is imperative that the character and use of this area is protected and conserved for the public benefit not only for current users but for generations to come. The Parish Council request the Planning Authority to refuse permission for this application.

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Pictures of beach showing shingle depletion and increase in flood risk