Sunday, 1 September 2013

CANTERBURY DRAFT LOCAL PLAN - OUR RESPONSE.

The consultation on the Draft Local Plan (2011-2031) ended last week. Follow the link to view the consultation document itself as the paragraph and policy numbers in our submission refer to it in detail.


INTRODUCTION
Canterbury & District Green Party fully supports the City Council's efforts to put sustainability and communities at the heart of the Local Plan.
We also understand and acknowledge that the City Council is under huge pressure from central government both to cut public spending and to build more houses, for which it is financially rewarded through the New Homes Bonus to the tune of around £400,000 per year for house-building schemes.
We do not agree with the level of housing development proposed in the Local Plan and would be happy to work alongside the City Council to challenge the government’s policy on house-building targets based on the perceived need for economic growth.
With these points in mind, we intend to provide as constructive an appraisal of the Local Plan as possible. We have covered each chapter in turn and hope that our comments and suggestions will be useful in informing the final document.
In the writing of this submission we make frequent reference to Dr Lynn Sloman’s “A Sustainable Transport Blueprint for Canterbury”, Transport for Quality of Life, January 2013, and to her own submission, “Comments on the draft Local Plan for Canterbury”, Transport for Quality of Life, July 2013, both of which we consider as providing excellently researched and formulated solutions for many of Canterbury’s serious problems, especially in the areas of traffic congestion and air quality since there is as yet no published Transport Strategy for Canterbury.
CHAPTER 1: STRATEGY
Sustainability is about treating the Earth as if we intend to stay. It is about living within our environmental limits now and meeting the needs of existing and future generations. The issues of climate change, extreme weather patterns, dwindling resources, pollution, the destruction of natural environments, conflict and social injustice are becoming more and more urgent.
By living sustainably we are clearly saying that we want to leave the best possible inheritance to our children, i.e. a planet which is safe and peaceful. Sustainability is about how we can balance economic, social and environmental factors to create a better world for everyone in it. We need to move away from the concept of economic growth at all costs and think more about sustainable development and living within our means.
To these ends, Canterbury and District Green Party believes that the concept of ‘Economic Growth’ should be replaced with the concept of ‘Steady State Economy’ throughout the Local Plan. ‘Steady State Economy’ means that physical capital is only consumed at the rate of the regenerative capacity of the Earth’s ecological systems[1]. This requires people in industrialised areas to adjust their patterns of consumption so that everyone may share in a good standard of living with less ‘stuff’, and have equal access to health & social care and support in times of need. Furthermore, the pursuit of sustainable development should take the ‘Wild Law’ perspective that infers equal rights to all life forms and the eco-cycles/systems on which they all depend.[2]
‘Wild Law’ calls for the:
·      conservation and restoration of damaged or destroyed eco-cycles/systems
·      preservation of biodiversity to halt or reverse the accelerating extinction rates for many species, including mammals, amphibians, reptiles and birds; 
·      careful husbandry of all marine and land sources of food so as to avoid over-fishing, soil and water erosion and pollution, excessive mono-cropping and natural habitat loss.[3]  
We also believe that natural and social capital should be considered equally in all discussions about development.
Sustainability has three key strands:
  • social − ensuring a strong, healthy and just society for existing and future communities;
  • economic − where environmental and social costs fall on those who cause them, and resources are distributed fairly and efficiently;
  • environmental − respecting and protecting the limits of the planet's environment, resources and biodiversity.
We all need to work together to identify creative ways in which people can live and work in harmony with their natural environment and with each other. We must ‘think global and act local’. We believe that we all have a responsibility to make the decision to live in a way which is greener, happier, more equitable and more just.
General Information on the development of local plans:
Transition Network Energy Descent Plans:



CHAPTER 2: HOUSING DEVELOPMENT  
Fundamentally, we believe that many people enjoy living in neighbourhoods and communities where the streets are free of cars, and are thus much safer environments. They may also want to move to or stay in the Canterbury district and raise families here because they can walk to shops and schools and travel to work without the need for a car. Obviously this has implications for the way that transport and housing are planned.
2.13 and 2.73: We fully support the fact that the Council is encouraging the main universities to make a greater provision for their student accommodation, but we believe that any additional housing built for this purpose should be counted as part of Canterbury District’s housing provision (or allocation) over the next 20 years because the act of building these student dwellings releases additional housing for the general public.
2.23: We are deeply concerned that all of the strategic allocation of new houses is being made on Greenfield land. Paragraph 111 of the National Planning Policy Framework document continues to advocate the use of brownfield land as a priority. The Council must make every effort to do this, especially given the brownfield sites that are available in the District.
We are further concerned that the allocation of houses in Canterbury are all concentrated into one segment of the city. Like other parts of the city, this area already suffers from considerable traffic congestion. Imposing 4,000 additional homes here can only serve to considerably exacerbate this situation, and we see little likelihood of sufficient traffic remediation measures being deployed to reduce consequent congestion and air pollution. The land on which this 4,000 housing allocation is being made has an AHLV landscape quality designation and is of Grade 1 agricultural value. Both of these designations should be vigorously respected. In our view it would better to distribute housing into dispersed smaller clusters based on existing transport arteries or nodes and that these should be factored into the overall number required, reducing the need for the scale of development proposed for certain sites. These clusters would include the following sites:
·       Howe Barracks: 600 units
·       Prison
·       700 empty homes (EDMOs)
·       Thanington
·       Wincheap
·       Chartham
·      Development/ densification of the older residential units on the UKC campus to free up     property in the city
·       Densification of underused retail developments in East and West Canterbury
·       Development of public and private car parks in and around the City Centre
2.24: We do not support development on Kingsmead Field as this runs counter to the Council’s own statements on open space contained in Policy OS8, Policy OS11 and Policy CC5.
Policy HD2:  
The City Council will require all types of residential development to make provision for affordable housing. A requirement of 30% is to be provided on-site, for schemes of 7 or more units.”
We do not understand fully why the previous (higher) recommendations from SMHA have been rejected. We agree that all issues of viability and affordability must be kept under review.
2.37: Different tenures and creative quality design are therefore necessary, in particular in areas of higher density such as town centres and around good public transport interchanges in the urban areas, to provide for the range of accommodation”   and

2.44: Integral to encouraging balanced and sustainable communities are measures to provide access to public transport . . .”
These measures should be a requirement not an expectation. In keeping with principles outlined in the chapters on Transport and Design and the Built Environment it is crucial that excellent public transport provision is a primary consideration on new development sites. Only once this vital condition has been met can the underlying policy of development occurring within an established network of transport provision be implemented properly[4].
We are sure that this requires detailed discussion between the relevant stakeholders to design a viable Public Transport Plan. Arising from this, clear binding commitments must be made to ensure that such a plan can realistically be implemented before any house building gets underway. We fully support actions that the City Council is taking to bring this about. We recommend that such a Plan be incorporated into and central to the Local Plan document once this first consultation is complete.
We recommend that the first phase of development on each of the larger new sites should include an area dedicated to parking-free and car-free living along the lines of Freiburg Vauban in Germany [5], [6]
2.54We fully support such shared equity schemes and agree with the importance attached to the proviso that occupiers should be prevented from buying the property outright. However, we recommend that the scheme is managed by the City Council itself and also that a Community Land Trust be established where land is provided for such housing schemes to preserve it as a community-owned asset.
Self-build schemes should be encouraged. When unemployed people work on such schemes they should not be subject to withdrawal of social security benefit.

Policy HD 9:

We fully endorse this policy. It can be applied to issues of homelessness. The City Council should maintain and update annually its register of empty property in the area and publish strategies for its use. People without homes should be proactively consulted on policies for housing provision. Thereafter, advice and help should be given to such groups to make proposals about the use of empty property, and to put those proposals into effect.


CHAPTER 3: ECONOMIC DEVELOPMENT AND EMPLOYMENT
Canterbury & District Green Party welcomes the focus of much of this chapter on sustainability, encouraging small business and home-working, supporting start-ups and re-use of buildings. However, we feel that there needs to be a greater focus on the green economy and natural capital. The New Economics Foundation (Nef) states that “the natural environment is the basis of our socio-economic system. It provides us with basic goods and services and increases our resilience to climate change and resource scarcity shocks. There is no economic stability without ecological stability.”[7]
We advocate a ‘steady state economy’ where physical capital is only consumed at the rate of the regenerative capacity of the Earth’s ecological cycles and systems[8].
3.5We feel that “sustainable economic growth” should be replaced with 'sustainable development' and that the plan should refer to 'steady state economy' rather than “economic growth” which is, by definition, socially, economically and environmentally unsustainable.
We believe that it is paramount that the City Council outlines specifically how it will encourage − and promote investment in − the green economy, including low/zero carbon enterprises.
3.6As above. The Green Party is encouraged by reference in the plan to sustainable new development and re-use of buildings and the support of sustainable rural tourism.
3.17With reference to Herne Bay, our understanding is that there has been shrinkage of the independent SME and retail sectors here. Proposals to develop any new out-of-town supermarkets are not locally supported and would work against the reinvigoration of the town centre. Such developments would also lead to increased car traffic and would not encourage people to use more sustainable modes of transport. We would not wish to see a ‘Westwood Cross’ effect in Herne Bay.
3.20We are unsure why there is only reference here to the 'Knowledge Economy'. We feel strongly that the City Council must promote investment in the 'Green Economy' as a matter of urgency. The 'Green Economy' should provide the baseline for all development, be it in housing, education, transport, leisure or any other sector. A focus on green jobs and sustainable development can ensure high levels of employment whilst at the same time reducing our ecological footprint, including reducing our greenhouse emissions.
3.26We are unsure as to why we need to increase the labour supply and create 6,500 new jobs in the district when we have one of the lowest rates of unemployment in the county, significantly lower than the national average. It seems to be a circular argument: i.e. we need more houses because we need to create more jobs although the latter appears not to be the case. Why encourage in-migration to an already crowded district? We already have to import labour to complete development contracts as we do not have sufficient local skills. That is also unsustainable. We believe that we should be supporting more job creation and development in surrounding districts where unemployment is much higher and where regeneration is a priority. Please recall that under NPPF guidance there is a “duty to cooperate” with neighbouring Districts.
3.37Any flexibility around sites for disparate needs should be based very clearly on proven community need for those businesses or developments.
3.39 and 3.40We support the Canterbury Start Up Programme (Start My Biz) and its development across the whole District.
We support the re-use of upper floors above retail and other commercial premises for start-ups. A light-touch approach to these businesses should depend on proven environmental and financial sustainability.
There should be more incentives and support for green/environmentally sustainable/low carbon businesses, including those proposing the use of renewable energy.
The City Council should be encouraging (possibly through financial incentives) developers who own business parks and large industrial/retail buildings to install solar PV arrays on the roofs of their units. This could reduce the need for prime agricultural land being taken up with renewable energy schemes. Canterbury City Partnership and Canterbury 4 Business could provide more information to developers and current site owners about the economic return on investment into renewables.
3.50We support the City Council's aim to encourage and support more home working and home-based businesses. This needs to be matched with more investment into means of sustainable transport and disincentives for developers to build any more out of town retail or business parks.
We would like to see a larger number of business units incorporated into housing developments, I.e. to reduce commuting/traffic congestion and to ensure vibrant working communities.
EMP7 and 8:
We support the need for a transport impact assessment and a review of the universities' travel plans to accompany any significant development proposal. This should relate to new developments on any site, existing or new. It would be useful to have a clearer delineation of the term ‘significant’.
We would expect all universities to mitigate any potential increase in car traffic and to positively encourage a modal shift towards sustainable transport, including measures that dis-incentivise or, preferably prevent, students from owning or using cars.
3.63We understand that this is now not the case and that Simon Langton Girls’ School will be staying on the current site.

EMP12:
We would also like to see the Council favour specific designations of land for smaller scale cooperative farming use, for example for community allotments and cooperative small-holdings, particularly those using organic, stock-free farming and permaculture methods.
EMP15:
We would like to see stronger restrictions on horse ownership. Horses occupy large areas of prime agricultural land that would be better used for improving our food security. The keeping of horses generates a lot of greenhouse gases. Many horses are kept in fields that are too small and their health and well-being is compromised. This problem is exacerbated during a recession when many people struggle financially with the care of their horses.
Additions to the Local Plan:
·  We strongly advocate that the Council makes every effort to encourage more development/regeneration of the Wincheap Industrial Estate for employment. It is ideal in the sense that it is well served by public transport. It would be preferable that development here should be small-scale, high-tech businesses.

·        We would also advocate using the old Serco site (corner of Kingsmead and Sturry Roads) for economic regeneration. This site would be particularly suited for a mix of leisure facilities. There are already some in this area, but these could be greatly and positively enhanced.

·        At present each house in the Canterbury District has on average 1.16 workers. At this rate the planned 15,600 additional houses in the District by 2031 will require about 17,000 more jobs. Although the present demographic trends probably serve to exaggerate this number of jobs, it is still clear that the District will be nowhere near creating this number of jobs, so Canterbury will quite rapidly have to become a dormitory town for (mainly) London commuters. We consider that mass commuting is an unsustainable way of providing for livelihoods.
·        We feel that the City Council could do more to support and encourage small independent businesses in the district. Such measures could include developing policies that prevent corporate businesses and brands developing in certain areas, particularly town centres, as well as policies that encourage and/or facilitate independent SMEs into those areas.
·       With this in mind, we believe that Canterbury District would benefit from its own local currency (as has worked well in Totnes, Brixton, Bristol and other towns and cities in the country)[9]. This currency could be shared across the District. These currencies could work alongside local spending reward card schemes, where these already exist. Both would have a local multiplier effect.[10] Keeping money circulating locally is widely agreed to be a key way to ensure a vibrant and thriving local economy.
·        Having said that, 'wealth' should not be measured purely in monetary terms; it is also important to consider social and natural capital as well as any reduction in dependence on social and health services, such as occurs when there is a thriving informal economy and social networks based on mutuality, reciprocity, coproduction and cooperation[11]


CHAPTER 4: TOWN CENTRES AND LEISURE
We strongly agree with the statement in 4.12 that “town centres are essential to sustainable and thriving communities and supporting their viability and vitality is crucial”.
4.13:
We would add to this paragraph: Such experiences can be enhanced by a leafier, greener town centre environment. The Council will support measures such as tree planting, green roofs and living walls to bring this about.
4.24We strongly agree with the intentions expressed here to improve “the pedestrian experience and increasing pedestrian footfall at St Peter’s Street and St Dunstan’s Street”.
Specifically, we would like to see the following measures taken in the St Dunstan’s area:
a)     Westgate Towers closed to traffic and open to pedestrians
b)     Retention of the wide pavements on lower St Dunstan’s Street
c)     20mph speed limits throughout the area
d)     No exit from Pound Lane at Westgate Towers
Policy TCL5:
We agree with the Local Centres policy. However, we would add the following additional condition for planning provision:
Where there are multiple applications for premises, preference will be given to locally owned shops and/or those that use local produce and labour.
4.36: It is well understood that part of the reason for the decline of the High Street is that planning decisions have allowed the creation of out-of-town shopping centres and outlets, designed to be accessed principally by people in their cars. We therefore strongly agree with this paragraph.
Policy TCL6:
We are concerned that, as it stands, the actions outlined here may have the effect of undermining the viability and vitality of the Town Centre.
We therefore think that the wording of this policy should be altered from:
“. . . including good local public transport services and proposals to enhance accessibility, including that for pedestrians and cyclists” to . . . including good local public transport services and good accessibility for pedestrians and cyclists. Where these do not exist, developer contributions will be required for their construction and installation.
4.44/5/6We are concerned that the choice of Wincheap Industrial Estate to act as a “satellite retail centre . . . complementary to the City centre, catering more for bulky goods and large format/mass market retailers and leisure operators”’ may have the effect of increasing vehicular traffic in an already congested area.
We are additionally concerned that a new off-slip from the A2 and a relief route for Wincheap itself will encourage drivers into the area, further increasing congestion and pollution.
Instead, we think that Wincheap, with its good public transport connections, would be better suited as the site for the high skill ‘knowledge economy’ development currently proposed for Little Barton Farm and perhaps for some residential development (see Submission to Chapter 5 below), and that the range of sustainable transport solutions proposed for Wincheap in our Chapter 5 submission would be better suited to promoting the ‘village’ character for the area mentioned in 4.28.
Additions to the Local Plan:
In addition to measures already in the plan to deliver support for sustainable communities, we would add the following:
1) The introduction of a local currency
Evidence from different studies shows that a higher percentage of a pound spent in a local economy (rather than a chain) stays in that local economy and can be up to twice as efficient at keeping a local economy alive. It also helps preserve local character in a town and helps prevent town centres becoming what the New Economics Foundation describe as ‘clone towns’[12], in which the High Street looks like every other High Street in every other town in the country.
 A local currency would encourage people to buy locally, keep more money circulating locally and give a chance for local stores and businesses to compete against ‘chains’[13].
2) A healthy, functioning sustainable transport system which prioritises walking, cycling and public transport above car use and seeks developer contributions for measures to promote these instead of those that would encourage travel by car (See submission to Chapter 5 below).
Research commissioned by London Councils in November 2012 into the impact of parking and parking charges on town centres and whether there is a link between free or cheap parking and the amount of commercial activity found that “. . . the number of people arriving at a town centre by car is frequently overestimated. Although car drivers spend more on a single trip to a town centre, walkers, cyclists and people using public transport visit more frequently and spend more money there over a week or a month than motorists do”[14] (our italics).
This evidence has been supported by research from the USA[15] and elsewhere: “The indications . . . are that a strategy of reducing dependence on cars and making it easy, attractive and affordable for people to travel by sustainable modes has been a key factor in the prosperity and vibrant city life of British cities such as York and Cambridge, as well as continental cities such as Utrecht, Copenhagen, Delft, Freiburg, Strasbourg, Winterthur and others”[16].

3) ‘Greening’ of the City centre
We believe that, through ‘greening up’ town centres with, for example, living walls, green roofs, and tree-planting programmes, the environment of the City will be improved and visitor experience can be enhanced and visitor numbers increased.
Such green areas absorb carbon and other harmful toxins, add oxygen to the atmosphere and can provide free food. They can play a role in bringing people together in creative and positive ways, thus breaking down barriers and promoting community cohesion. These initiatives also make pedestrian routes more attractive, encouraging more walking and cycling. 



CHAPTER 5: TRANSPORT INFRASTRUCTURE

Canterbury & District Green Party agrees with many of the stated aims and objectives in this chapter, especially with the emphasis on sustainability, reducing greenhouse gas emissions and on creating more road space by prioritising measures to promote walking, cycling, public transport use and car clubs. We are also in agreement with many of the measures proposed to deliver these aims.
However, we are concerned that certain other statements, and specific proposals for infrastructure at developments, would have the opposite outcome to those suggested above and result instead in more traffic congestion, poorer air quality and higher emissions.
We also have concerns about the degree to which the summary of the Jacobs (2012) Canterbury VISUM Model: Draft Option Testing Report accurately reflects some of the data contained in it. This has serious implications for the evidence base for the Preferred Option.

 5.11: “By 2016 more people will choose to travel sustainably…”
We would prefer specific targets to be set for the numbers walking, cycling, using public transport and car-sharing and lift-sharing by car.
We are concerned that, although sustainable transport measures are very evident on the proposed new developments, sustainable transport access to and from the city from these developments will negatively affect traffic flow, air quality and greenhouse gas emissions. In our view, such provision lags well behind that afforded to cars. As a result, any modal shift from cars to sustainable transport will be limited.
 “. . . congestion will remain at 2011 levels and air quality will not have worsened.”
We feel that this target lacks ambition. Even if air quality does not get worse it will still mean that for a large part of the city for the next 3 years, air quality levels will remain in breach of EU and DEFRA guidelines.

5.15: “(The NPPF) sets out three tests that development plans and decisions should take account of:
·        the opportunities for sustainable transport modes have been taken up depending on the nature and location of the site, to reduce the need for major transport infrastructure.”
We strongly agree with this statement.

The Strategy Approach

5.20: We strongly agree with the whole of this paragraph. However, in addition, we would add the following:
For this approach to be most effective, sustainable transport measures should be introduced instead of, rather than alongside, new infrastructure to facilitate car travel. Also, sustainable transport measures should be ‘built into’ any proposed new developments. All development should be designed to be public transport centred and be easiest to access by sustainable means of transport rather than being easiest to access by car. Sustainable transport measures provide better pound for pound value than road schemes[17] and developer’s contributions should be sought for such schemes only.

5.22: In addition we would add (in bold) the following to the first point:
  • looking to locate development near existing transport hubs and on major public transport corridors
We would then add the following points to this paragraph:
  • ensuring a relationship exists between higher housing density and lower car use and that development should therefore have as high a housing density as possible
  • providing residents of new developments with free bus travel for a year
  • making parking on new developments only at the edge of such developments for an annual fee, which is then put into a fund for sustainable transport measures
  • ensuring car clubs are established to reduce the need for car ownership be on each new development and throughout the existing central and inner city
  • providing robust support for car-sharing measures and promoting “kentjourneyshare” at each new development.
  • ensuring the number of car parking spaces per unit is limited to less than one per household
·         ensuring each new major development has a Travel Centre on-site.
POLICY T1:

f)        “Seeking the construction of new roads and/or junction improvements which will improve environmental conditions and/or contribute towards the economic well-being of the District”

It is our view that the construction of new roads and/or junction improvements rarely, if ever, improves environmental conditions.
We would maintain that the kind of sustainable transport measures mentioned in 5.20 and implied in the hierarchy of transport modes and elsewhere in our submission would be much more likely to yield improvement in environmental conditions. We strongly advocate using these instead.

5.24: We strongly agree with this transport hierarchy. However, we are of the view that the proposals for new development and levels of funding for different transport modes appear to us not to reflect this hierarchy.

Walking and Cycling

5.29: “. . . new developments will need to take into account the requirements of pedestrians in terms of design, layout and permeability . . .”
We would add:
This entails walking and cycling greenways, pedestrian-friendly street design, and ‘filtered permeability’ as ‘built-in’ features of each new development.  and
Special consideration should be given to the safe separation of pedestrians and cyclists in all new shared use proposals.
And we would amend “Pedestrian priority measures in residential streets will be sought and vehicle speeds must be kept low.” to read:
Pedestrian priority measures in residential streets will be sought, pedestrians be given priority for crossing all roads with the minimum of delay, and vehicle speeds in residential streets, throughout the city and near all schools and children’s play areas will be limited to 20mph.

5.30: “Canterbury already has a good cycle network and more routes may be identified in the emerging Transport Strategy, these are necessary to make cycling a sustainable alternative to the car.”
We would amend this to read:
Canterbury has the potential for a really good cycle network and, in addition to those new routes outlined in the Local Plan, the following routes/measures will be identified in the emerging Transport Strategy as essential factors in making cycling a sustainable alternative to the car:
a)     a segregated cycle route on New Dover Road running from the roundabout at the existing Park and Ride directly into the city.  New Dover Road is comfortably wide enough to accommodate such a measure.
b)     a cycle route from the proposed new development in Sturry to link to the existing ‘riverside’ route to provide a direct, off-road cycle route directly into the centre of Canterbury
c)     cycle lanes to link the proposed new development in Hersden to the cycle lanes proposed above for Sturry.
d)     a cycle lane on the A28 (at times a shared bus/cycle lane) all the way from the Sturry direction to the Military/Tourtel Road roundabout.
e)     a cycle lane along the Whitstable Road entrance to the city.
f)       direct, easy cycle and pedestrian access from Thanington Without to the Great Stour Way cycle route.
g)     cycle priority measures to enable cyclists from the south part of Wincheap to easily and safely cross the A28 and then be able to access the Horses and Goats underpass route into the city centre.
h)     investigation of the use of Broad Oak Road for cycle/bus lanes after completion of the ‘riverside’ route detailed  above.
i)        All cycle paths/lanes/tracks proposed in the Walking and Cycling Strategy not included above to be completed.
“All new development will look to provide traffic free segregated cycle routes with residential streets that are safe for cycling through low vehicle speeds.”
We would amend this to read:
All new development will provide traffic-free segregated cycle routes and ‘home zones’ with residential streets that are safe for cycling through low vehicle speeds of a maximum of 20mph.

5.31: “A sufficient number of secure and covered cycle parking spaces must be provided as part of new residential developments . . .”
We would amend this to:
There should be cycle parking/storage for all households on new developments.
Bus
5.35: “The main improvements currently needed are bus priority measures along the main routes into the City . . .”
We agree, and would add:
. . . including the removal of some on-street parking where such parking prevents the construction of bus lanes. In such cases, residents should be given ample notice and alternative parking arrangements provided if unavailable − paid for, if necessary, from developer contributions.
And in addition we would add two more points to this paragraph:
·         real-time bus information displayed at every bus stop
·         free bus travel for a year for residents of new developments
Park and Ride
5.41: We are concerned that a Park and Ride site at Faulkner’s Lane in Harbledown would have the following effects:
a)     a modal shift from sustainable transport to car travel from Faversham, Whitstable and surrounding areas, undermining − and possibly causing the loss of − some public transport services that many rely on;
b)     an increase in greenhouse gas emissions;
c)      an increase in vehicular traffic and bad air quality in Harbledown;
d)     The loss of high quality orchard land in the immediate vicinity of the city.

Since the Wincheap Park & Ride is likely to be retained and/or extended, there is no point in having two P & R facilities serving the A2 within a mile of each other.
We therefore disagree with this policy.
Managing the Network
Wincheap Traffic Management Scheme
5.49: As mentioned in Chapter 4 above, we are doubtful that Wincheap is  “. . .the most suitable location for meeting retail capacity for the City over the plan period.” We feel that existing plans that it cater for “. . . more bulky goods and large format/mass market retailers and leisure operators” is a waste of its position close to major public transport hubs, as few customers for its proposed use are likely to travel there by rail or bus. We feel that its situation would be better served by it being developed as the high skill ‘knowledge economy’ development currently proposed for Little Barton Farm and/or for some residential development.
We feel that a new off-slip from the A2 and a relief/mini gyratory system for Wincheap will encourage car use to and from the site, reduce patronage of public transport to access the site and/or to commute, increase traffic congestion and worsen air quality.
We believe that resources would be better spent on sustainable transport measures, in addition to those already proposed and those stated elsewhere in this submission, such as:
i)                    ‘fast’ bus links (at least every 15 minutes) that serve Chartham into the city and Thanington Without;
ii)                   bus priority measures and bus lanes through Wincheap and through the industrial estate;
iii)                creation of off-street parking through multi-level parking on the industrial estate to enable the removal of on-street parking on Wincheap;
iv)               the vigorous promotion of car-sharing and car clubs in Thanington Without/Chartham and for commuters from Ashford.

A2 Bridge Interchange
5.51: “This is for a mixed use development including housing . . .”
We would amend to: . . . including high density housing . . .
5.53: “. . . the following transport measures are considered essential:
·         a new grade separated interchange on the A2”
We strongly agree with Dr Sloman’s statement that the Local Plan “. . . should not assume that a grade-separated interchange on the A2 is required in order to develop the site here. Such an interchange will increase the proportion of trips that residents make by car, and will also encourage longer distance out-commuting to jobs elsewhere in the county.” [18]
Dr Sloman estimates that, based on analysis elsewhere, the effect might be in the order of a 20% increase in trips by car, therefore greatly and perhaps fatally undermining any aspiration to make this development site sustainable. We therefore oppose this interchange.
In addition to the sustainable transport measures already specified we would add:
a)     The removal of on-street parking that inhibits the provision of a fast service into the city (See above);
b)     The creation of a segregated cycle route on New Dover Road from the roundabout at the existing park and ride directly into the city (See above).

Sturry Crossing
5.55: “. . . a Sturry by-pass that avoids the level crossing by providing a new road bridge including a bus lane over the railway line.”
We strongly disagree with this idea.  We understand that the degree of development here is due, in part, to the need to pay for such a by-pass[19].
We believe instead that developer contributions should be sought to provide the sustainable transport measures specified elsewhere in this submission, which would then allow the scale of development here to be reduced.
We think that the level crossing and section of A28 through the village should remain in use with 20mph speed limits through the extent of the village.
We believe that the obvious answers to promoting sustainable development in Hersden would be the development of a rail station, perhaps utilising what remains of the infrastructure at the old Chislet Halt, plus the major enhancement of bus services along the A28 between Canterbury and Thanet.
We urge that the Council rigorously explore this possibility.

A28/A257 Barracks Link
5.57: Evidence from similar by-pass schemes in other parts of the country suggests that a by-pass scheme such as that proposed for Eastern Canterbury would not provide long-term relief from traffic problems on Canterbury’s existing ring road, but would instead ultimately result in accelerated traffic growth. We therefore oppose this idea.

5.64 to 5.66: 
These paragraphs begin In order to assess the transport implications of future development, Canterbury City Council and KCC have jointly funded a strategic multi-modal VISUM model
for the District.”
The findings of the VISUM modelling study carried out by Jacobs (2012) are not only incorrectly reported in the Jacobs study but they are also totally fallacious with respect to the current Local Plan development intentions. It is important therefore to draw to the Council’s attention that, based on supporting evidence currently presented, there is no reliable transport information upon which any of the intended developments in the Local Plan can proceed. We will therefore be interested to ascertain what the City Council intends to do about this matter.



CHAPTER 6: TOURISM AND VISITOR ECONOMY
We very much welcome both the important provisions in 6.16: “. . . tourism should . . . be managed so that it does not increase problems of traffic congestion, but promotes alternative modes of travel to and from visitor destinations. It is also important to ensure that accommodation and tourism facilities make provision for people with disabilities and are accessible to everyone throughout the district.
6.20 “‘Public Art’ can encompass a wide variety of elements and includes art as part of the design of buildings and developments, the design of landscape and planting, street furniture, signing, entrance features, sculpture, water features, mosaics, murals and lighting in the public realm for general enjoyment.”
We would wish to include the city’s subways in this paragraph. The subway from Castle St to Wincheap is in a particularly shocking state. It is dirty, with paint peeling off the walls. Decoration and maintenance of all the city’s subways on the model of the section from St George’s Street to the New Dover Road should be specified in the Local Plan. It could form the basis of a competition for the best murals encompassing schools as well as residents’ associations.
Policy TV5 on marinas: f. “If any proposals relate to Whitstable Harbour, they must ensure that any development does not undermine the Harbour Strategy to maintain a working harbour.”
We consider this an important proviso.
Policy TV6 on Reculver: Any proposals would be subject to design, visual and environmental impacts, including meeting habitat regulations requirements and ensuring suitable access arrangements.”
We believe these safeguards are vital for any future development of the Reculver site.
6.50 on Whitstable: “The Council will support new visitor attractions and additional provision for tourist accommodation to attract additional visitors to stay longer in the area provided that the character of the town is maintained and enhanced.”
We consider this proviso vital for any future development of tourism in Whitstable.
6.52 on rural tourism: “Rural tourism must be developed and managed in a sustainable way ensuring that the character of the countryside and the very asset on which its popularity depends is not destroyed. Therefore, the Council will support tourism initiatives which are appropriate in scale to their surroundings and which seek to reuse existing buildings, thereby avoiding the proliferation of buildings in the countryside.”
We consider these safeguards vital for any future development of rural tourism.

CHAPTER 7: CLIMATE CHANGE, FLOODING AND COASTAL CHANGE
We suggest that the title of this chapter incorporates “. . . and Water Resources”. This is important since about a third of the chapter covers water resources and they are of major importance to local planning considerations.
Policy CC1: 
Add to this policy (which is concerned with the promotion of renewable energy) the fact that the Council will not accept planning applications for hydraulic fracturing (fracking) plants or facilities to be located within the District boundaries, nor will it allow any future coal extraction from the East Kent coalfields. Failure to stipulate this will put the Council in direct contradiction to the aims of Para.s 7.1 to 7.3. This will be brought about by the development of a technology that will significantly increase the amount of fossil fuels that are available to be burned. It is the burning of such fuels that lie at the heart of increasing CO2 levels in the atmosphere. If carbon emissions are to be met then at least 75% of known fossil fuel reserves must be kept in the ground.
7.5 to 7.18:
These paragraphs are all concerned with climate change mitigation or adaptation as will be relevant to new developments. Despite the fact that paragraph 7.3 notes that the NPPF requires planning authorities to actively support energy efficiency improvements to existing buildings the City Council has chosen to almost ignore existing buildings. As many District Councils throughout the UK have found, addressing the deficiencies in existing buildings is an excellent means of addressing CO2 targets, of reducing eco-footprints of the District, of improving the standard of comfort within dwellings and of improving the health of many local residents.
7.44:
Since most of the residents of Faversham Road who may be affected by the fact that future plans are not to defend this part of the shoreline from flooding due to sea level rise will have purchased their properties in good faith, we strongly recommend that the Council arranges some type of compensation for the residents concerned. After all, this is what would happen if the houses were to be compulsorily purchased for some other purpose.

Additions to the Local Plan:
·        Although this chapter is extremely detailed, there are ways in which climate change will affect the District that have not been considered. Thus during the life of this Plan it is likely that significant changes will have occurred in natural species distributions,  especially with optimum cropping patterns, the length of growing seasons, etc.  These factors are likely to impact considerably on agricultural land uses and on biodiversity in the District. Additionally, and potentially of great importance, there are likely to be impacts on human health. This will be most reflected in increased morbidity and mortality due to excessive summer heating, and the incidence of diseases caused by new strains of viruses or bacteria or by insect-borne diseases such as malaria. These factors need to be considered in the Plan.
·        We propose that the City Council offers free (or subsidised) energy audits for all existing householders. This would encourage local investments in energy saving measures thus generating local business and creating jobs, as well as helping the City Council to reduce CO2 emissions and to better achieve emissions targets. Alternatively, the Council needs to promote the government’s Green Energy deal which commenced in January 2013 (see gdcashback.decc.gov.uk), and which provides home owners with cash saving incentives to invest in a range of energy saving installations.
·        Policy CC2: It is very important that this policy is revisited and that the Council includes Canterbury District targets for reducing CO2 emission levels and for reducing the high eco-footprint that the city apparently has. Thus in 2007 Canterbury was ranked as the fifth worst city in the country re its eco-footprint, with its then level of consumption equal to 3.4 planets.
·        Under the heading “Water Quality, Water Efficiency and Water supply”, there needs to be a policy stating that water quality in local river catchments will achieve the Water Framework Directive targets by the year 2015

CHAPTER 8: DESIGN AND THE BUILT ENVIRONMENT

Overall there is much to admire in this chapter, as the underpinning philosophy is suitably modern and relevant. It will ensure that all new development will be “attractive, functional and sustainable”[20].

Policy DBE 1
This policy sets a Code for Sustainable Homes (CSH) benchmark of Level 4 for new buildings. There are currently housing developments where a higher standard has been achieved, notably Sinclair Meadows, South Shields[21], Green Space, Chelmsford[22] and the Lancaster Cohousing Project, which are all at Level 6. In addition the award-winning Lancaster Cohousing Project[23]  is certified by Passivhaus and Life Time Homes. It has been occupied since August 2012, is affordable and car-free.
The UK Green Building Council has recently reported that planning permission had been granted for 150 houses with Passivhaus Certification on a 20-acre site at Kingstone in rural Herefordshire[24]. Councillors on Herefordshire Council’s planning committee praised the scheme as a “visionary proposal” which “represents green sustainable development in the best possible way”. Whatever the outcome of the current Housing Standards Review we recommend that the benchmark for new development in Canterbury should be at CSH Level 6 (or equivalent) from the outset. Then we can look forward to City Councillors feeling justifiably proud in making similar statements.

Policy DBE 3
Sub-section i. is concerned with “the provision of appropriate amenity and open space”
This should include:
  • recreational amenity (dog walking, reading and sports)
  • functional/social amenity (allotments)
  • visual amenity (a still and empty green open space has a value in itself)
  • all within a 5-10 minute walking distance from home.

It is encouraging to see these amenities enshrined elsewhere in the Plan at 1.47 and 1.48 and that allotments are included in the indicative plans for the major areas of new development. At 11.85 an allotment standard has been suggested for the allocation of 15 plots per 1,000 households. The National Society of Allotment and Leisure Gardeners, which gave this figure, also define the size of a plot as 250 square metres, roughly equivalent to a doubles tennis court [25]. This important statistic should be adhered to.

Policy DBE 11
Sub-section b. notes “Integrate with existing path, circulation networks and patterns of activity and permeability”
8.58, 8.74 and 8.80 all describe an important principle for the layout of the new developments. This is to ensure that “built form and external space design (are) conceived together prior to traffic circulation”; “built development is then arranged within the openings in the framework”. 8.74 sets this out most clearly and this is excellent. It exploits the potential offered by new sites for designing in favour of community life rather than the car.
We fully support this approach and stress that existing Public Rights of Way (footpaths, bridleways and National Cycle Routes) should be retained as they are and not diverted.
The Plan recognises that neighbourhood amenities, such as local shopping areas and meeting halls, are important in allowing communities to develop. There is potential for these community buildings themselves to be at the forefront of sustainable design and living. The Singleton Centre[26] in Ashford is a superb example of this.
Canterbury District, especially the schools within it, needs such centres of excellence as our children adapt to − or perhaps even embrace − a low-carbon future. Each of the eight larger developments should have community buildings of outstanding sustainable design.


CHAPTER 9: HISTORIC ENVIRONMENT
9.4:
The historic environment underpins planning policy for the District; it encompasses the interpretation and preservation of heritage assets, preservation of outstanding buildings and sites, and enhancement of the character and appearance of the area.”
Reference should here be made to the Westgate Towers, the oldest surviving mediaeval gate in the country. The Council must ensure that they reopen to visitors, together with the popular café on the location, which draws visitors into this prime heritage site.
Moreover, the Council must undertake to close the Towers to traffic since a recent survey by Stonewest[27] found that the stonework was not only heavily scoured and damaged by vehicles striking it, but also eroded by salt-laden water splashed from vehicles passing through the archway. 
In order to “enhance the character and appearance of the area” as stated, the whole of lower St Dunstan’s Street should be pedestrianised.
9.35    Canterbury & District Green Party welcomes the provision in this paragraph for the reduction of the energy consumption of listed buildings, allowing roof insulation, draught proofing and secondary glazing to be installed.

Policy HE4 and Policy HE6
All older buildings in the city whether listed or not, should have energy audits. This is hugely important as a way of saving CO2, of warming houses, of improving health (especially for the elderly) and of providing jobs in the energy savings/insulation industries.
We propose an addition to these two policies:
It is desirable that all buildings have an energy audit and that owners act upon it to reduce energy consumption in those older buildings in the city which are particularly prone to energy waste.


CHAPTER 10: LANDSCAPE AND BIODIVERSITY
Again, the Canterbury & District Green Party welcomes the strong conservation and sustainability ethos that lies behind much of the content of this chapter.
Policy LB2:
It is impossible to conceptualise how the building of 4,000 homes in the Canterbury AHLV area “would protect the local landscape character and enhance the future appearance of the designated landscape and its nature conservation interest.”
The development is completely at odds with this policy.
10.13/14: It would seem that the Council very appropriately puts a strong emphasis on countryside and landscape protection, on conservation and on the protection and enhancement of biodiversity. However, since the Draft Local Plan seeks to locate approximately 4,000 houses on land in the SE quadrant of Canterbury, which the Local Planning inspector in 2006 agreed should be designated as an Area of High Landscape Value (AHLV), this level of designation is clearly unsatisfactory with respect to conserving this land. We would further remind the City Council
that in paragraph 3.76 of the 2006 Local Plan the then Planning Inspector (Mr Charles Hoyle) inserted the following:
"If for whatever reason the development envisaged at Little Barton Farm does not take place with(in) a reasonable period, the site will not be regarded as suitable for other forms of development, and will be returned to agricultural use."
This statement refers to 20 hectares of the land which is now being designated for housing purposes in SE Canterbury. Surely the whole point of planning decisions by inspectors is that their decisions be respected.
10.33: This paragraph recognises that recreational activities and disturbance will have an impact on coastal areas and birds, and that these impacts “need to be dealt with at a strategic level because in-combination impacts are likely and effects can occur at a significant distance from the development itself, especially recreational disturbance as a result of new housing”.
Almost exactly the same can be said of some farming practices in this part of Canterbury District. Thus repeated use of insecticides and pesticides over recent decades, in combination with changes in weather patterns, has resulted in the decimation in many rural areas of insect life including mainly bees, flies, beetles and butterflies. Government at all levels need to be addressing this problem. Although habitat restoration programmes can be set up as part of land-use planning, for such programmes to be effective it is essential for the Council to implement planning policies aimed at reducing the disturbance (mostly from spraying) that is having an extremely severe impact on insects and similar smaller but important species[28]. The National Environmental Research Council points out that the large-scale destruction of pollinators will have a severe effect on local economies[29]. We urge the City Council to intervene in this area of agricultural spraying in order that the activity can be seriously monitored.
10.57:  Following on from paragraph 10.33, it should be of major concern to Council planners and citizens of the District that the various guides to faunal protection (quoted in this paragraph) are likely not to be comprehensive. For instance, there is no guidance here for the protection of all species of UK amphibians and of bees plus a wide list of other pollinators, all of whose numbers have dramatically declined in the last few years[30]. Of equal concern must be the dramatic decline of flies, beetles, moths and butterflies throughout the South East, as recorded in Norman Maclean’s “Silent Summer” (2010). The Council must have a Policy stating that they will work in partnership with local and national nature conservation organisations to help ensure the survival and continued sustainability of the whole range of wildlife mentioned here.
Policy LB13:
Here it will be necessary to provide a more definitive indication as to the extent of any tree planting required. Failure to do so is likely to mean that only very minimal quantities of tress will be delivered to any development.
Policy LB16:
Although we welcome this policy to conserve and enhance river corridors and catchments, thus giving promotion to nature and aquatic ecosystems, this policy will almost certainly conflict with increasing public access, as suggested in Para 10.74.  We suggest that some of the rarer ecosystems are offered complete protection from public access in much the same way as applies to Bus Company island.
Additions to the Local Plan:
·        The Council quite rightly recognises the importance of nature and its conservation, and it describes numerous actions being taken to maintain and enhance a range of natural sites. It further recognises the importance of establishing “landscape scale biodiversity networks” (p.242). However, we strongly believe that commitments to landscape and biodiversity protection should be more seriously demonstrated through the designation of some of Canterbury’s rural hinterland as “Green Belt”. We realise that this designation by itself cannot make land sacrosanct from development, but it would send strong signals to developers (and others) not to even contemplate submitting development proposals in these areas. It is useful to recall here that the Council’s Core Strategy (2010) states (paragraph 9.52):
“The District’s biodiversity will continue to be safeguarded through designation and protection of sites and support for the Kent Biodiversity Action Plan. This Core Strategy, however, would like to go a step further and respond to the biodiversity opportunities identified in the Landscape character and Biodiversity Assessment by encouraging the protection of land that may contribute to habitat networks in the future and support sensitive land management practices and proactive initiatives for biodiversity improvement.”
We suggest that only the designation of Green Belt status will allow these very appropriate aims to be achieved. The areas to be designated as such could be selected by the Council working in conjunction with local statutory nature conservation and wildlife groups. These areas should contain not only the more obvious areas that contain important species or that already have existing nature designations, but should also consist of smaller fragments of land that serve to join up presently isolated valuable nature conservation land so as to form corridors of ‘species sympathetic’ areas that can better protect species sustainability by allowing freer movement for species. Above all, it must be pointed out that we will never be able to retrofit Green Belt; once it is gone the loss will be permanent. It is going to take strong, informed and dedicated governance to ensure that the natural world receives equal or more attention than the built environment.


CHAPTER 11: OPEN SPACE
Canterbury & District Green Party wholeheartedly agrees with the need for open space expressed in the Draft Local Plan and the stated objective of creating a comprehensive and attractive network of formal and informal recreational facilities and open space, which is informed by a district wide audit, to identify areas of need for all forms of open and recreational space”
Policy OS1
This policy outlines the conditions which need to be met before development can be allowed which would result in the loss of playing fields.  In theory, these conditions appear robust.  However, on the basis of the Kingsmead Field experience, it is clear that they are relatively easy for the Council to circumvent. 
Of particular concern is clause b) which states that the loss of a playing field can be justified if: ‘There is an overriding need for the proposed development which outweighs the loss of the playing field.’ 
This Policy should also specify what proportion of a development site must be left as open space.
Specific recommendations about the provision of play places and open spaces − both within existing settlements and in new developments − should be included as well.
11.25: They are laudable aims that children should have a place to play within 300 metres of their homes and there should be 1.3 hectares of open space for every thousand people.  These are extremely welcome objectives. However, many recent developments in the city have allowed no space for play at all. Moreover, no maps are available which would enable us to judge how near the city is to achieving this standard.
Wincheap and Barton wards have very little open space available. One solution would be for the Council to ensure school and college playing fields in these areas are made accessible for local residents’ use.
11.30: Now that the plans for a Football Hub at Ridlands Farm have been rejected, we suggest the Council provide land for a similar use at Howe Barracks. However, it would need to include other uses of open space, such as a playground and dog walking.
It is certainly important that more provision is made in the city for children and young adults, especially for playing sports.
11.37: Sturry Road Community Park does indeed provide a wide range of leisure provision within Canterbury.  However, since it is located on the very edge of the city, it is not accessible to many local residents.  Moreover, many of its facilities are now in a state of serious neglect and must be renovated.
Its future regular maintenance − as well as that of all the District’s parks and play places − should be enshrined in policy.
11.38: “The riverside pathways and corridors in and around Canterbury from Chartham to Fordwich provide links to more than 25 hectares of open space along the river and provide pocket parks. The Riverside Strategy aims to protect and enhance the land alongside the River Stour corridors and Policy OS11 seeks to implement this.”
Canterbury & District Green Party trust that this commitment on the part of the Council will mean protection of the Great Stour Way for public access and use if the land is sold.
11.50 and OS5:
We very much welcome the provision of Green Gaps and hope this will develop into a robustly protected Green Belt around the City.
Policy OS8:

“Development which would involve the loss of open spaces and play areas within residential areas which contribute to the visual or recreational amenity of the area will be refused.”

The proposal to develop Kingsmead Field is an example of the sort of development which should therefore be refused.

Policy OS12:

Land ... along the River Stour … will be protected from development to enable its future use and contribution towards the riverside corridor, as set out in the Riverside Strategy adopted by the City Council.”

This policy would again refer to Kingsmead Field, which could be a semi-natural area and form part of the riverside corridor, as well as having a children’s playground, sports field and skateboard park.



CHAPTER 12: QUALITY OF LIFE

Canterbury and District Green Party welcomes the focus throughout much of this chapter on facilities and services that are developed and delivered locally, involving the community and encouraging active citizenship. This is the most effective, sustainable and egalitarian approach. However, we do feel that the City Council could be even bolder in its expectations and do more to insist that new developments follow these guidelines rather than simply encourage them.
We also feel that the City Council should be more vocal in its opposition to central government austerity measures which are, inevitably, impacting disadvantaged groups and those on low incomes disproportionately. These measures are inhumane, unsustainable and, in the medium to long term, will not make economic sense.

Community Development:
12.1: We are pleased to see social, economic and environmental wellbeing included in the same sentence, as they are equally important and inextricably linked.
12.3We agree that community facilities must be delivered in the right locations and that all facilities must be accessible for all. We feel that the Local Plan could make an even stronger commitment to these aims by disallowing any new developments which do not meet these criteria.

12.4: We fully agree that planning policy “should facilitate and promote sustainable and inclusive patterns of development, contributing to the creation of safe, sustainable, liveable and mixed communities”.
We would add diverse to this list.
12.6: We agree that we need a high quality integrated transport system accessible to all and that we need to dramatically reduce pollution and congestion. To these ends we urge the City Council to fully embrace the recommendations laid out in Dr. Lynn Sloman's report, “A Sustainable Transport Blueprint for Canterbury”.
12.7: In order to truly move towards more resilient communities and encourage more community involvement, we need to develop effective ways to involve all sections of the community. Elected representatives need actively to seek the views of those who do not readily make their views known, or are harder to reach, rather than mainly listening to those who shout the loudest. We need to identify and develop ways of encouraging active citizenship, civic pride, participatory democracy and consensus decision-making.
We suggest that the Council introduce a "register" of their localism/community initiatives as a means of demonstrating what they are doing/encouraging in this direction. This register would be public and would show which sectors (among other things) had been involved in an initiative.

12.8: We fully agree that the civil society sector needs more support in order to effectively deliver public services, including what were formerly statutory services. However, this must be properly funded. Charities and social enterprises still need start-up and pump-prime funding and not all public service activities can be run using a business approach. In other words, not all activity can be made to be ‘profitable’ and will always need some subsidising from the taxpayer. Supporting the development of social enterprise should not be at the expense of investing in important, good-quality public services.
Furthermore, contracts with the civil society sector must reflect full cost recovery so that these organisations can be viable and truly sustainable in the medium to longer term. Contracts/funding should be for at least 3 years and be in line with standards laid down by The Compact[31] to enable organisations to focus on good work and not have to spend precious time on fundraising and re-tendering. Service delivery should be outcome-focused and co-produced and co-delivered with beneficiaries[32]. Indeed, co-production needs to be the default approach for developing and delivering community services and this should be made clear in grants, contracts and tenders. Monitoring and quality assurance should be robust but not overly onerous.

Social Infrastructure:
12.11: We fully agree that formal and informal community, leisure, health and educational facilities must be accessible, local and sustainable. To this end, we would like to see the City Council put more pressure on Kent County Council to reverse their decision to close five Sure Start Children's Centres in the Canterbury District (the highest number of closures planned out of all 12 Kent districts).
Policy QL1:
We agree with this policy but would add that new developments should be located close to public transport hubs and not near major road junctions or in isolated locations, with no/little access to public transport. This would have the dual benefit of reducing congestion/improving air quality while simultaneously ensuring that facilities are truly accessible to all (many poorer or disadvantaged families do not own a car).
Services and facilities for sustainable communities:
12.14: Canterbury & District Green Party fully supports this statement.
12.15: We fully support this policy. However, we would like to ask whether it refers to absolutely every unit of housing. We would advocate that this be the case.
12.16: This is very encouraging to see. We completely agree with this statement and with policies QL2 and QL3.
Farm Shops:
Policy QL4:
We agree with this policy but would like to add that the City Council will give preference to certified farmers’ markets (based on the widely accepted definition approved by FARMA[33]). This will encourage the sale of local produce and facilitate better knowledge and understanding among consumers about the origin and supply chain of what they are buying, in turn ensuring demand for healthier, more ethically grown produce and compassionately reared meat and fish.
Transport, community services and community buildings:
12.23 and 12.24: We fully support this statement. Disabled people need to be able to access mainstream public transport rather than having to rely on others to support them, or on specialist/segregated transport.
12.25: We feel that KCC possibly implying that people who need support have a culture of dependency is misleading and insulting.  Our experience is that most disabled (or otherwise disadvantaged people) want to be as independent as possible but need good support. The Supporting Independence programme cannot succeed where it takes away vital funding and support services from people and continues to tighten eligibility criteria. Furthermore, KCC uses the rhetoric of personalisation but has still made little/no real progress in introducing individual budgets or support brokerage.
12.26: This needs to include ensuring that paving is accessible for people using wheelchairs, those with mobility problems, the old and very young.
Policy QL5:
We fully support this policy. We would like reassurance that CCC has the power to enforce this i.e. that developers pay on time and an appropriate amount towards community facilities.
12.28: We fully support this statement. It is important to acknowledge that equality can often only be achieved through providing differentiated support and community services.
Community spaces and facilities:
12.32: We fully support this aim. Connectivity between spaces needs to be improved, both to benefit wildlife and to make it easier for people to get around the city/district without using a car.
12.33, 12.34 and 12.36:
We agree with these statements, particularly as they seem to strongly preclude any development on Kingsmead Field. Canterbury & District Green Party would certainly prefer to see development on the brownfield sites in Kingsmead: the Old Coach Park and Serco Depot. These statements would also seem to preclude any development on Chaucer Fields. 
We welcome the establishment of the Friends of Westgate Parks and, more recently, the emergence of the Friends of the Riverside group. We would welcome the development of other such groups whose mission is to champion, improve and connect our green open spaces as well as identifying and applying for sources of funding in order to better manage the spaces to improve biodiversity (for the benefits of wildlife and people). We would particularly like to see the development of such groups in more deprived areas and not just city centre/conservation areas.
Health Facilities:
Policy QL8:
We support this policy but we would also like to see an assurance of good quality health services in existing neighbourhoods, especially deprived or isolated areas.
12.44 onwards:
The Westgate Towers Traffic Trial took two roads out of an AQMA. We need wider measures to improve air quality across the whole city. The Council is under a legal obligation to meet various EU directives by 2015 with regard to reducing air pollution levels, especially pollutants such as NO2 from vehicle exhausts.
We strongly urge the City Council to adopt the recommendations of “A Sustainable Transport Blueprint for Canterbury[34], which also addresses air quality issues.  One simple measure that should be taken immediately is to reduce speed limits to 20mph in all residential areas and around schools. This will improve air quality and road safety, as well as reducing traffic congestion.
12.54: We agree with this statement but wonder how this fits with the recent Churchill Homes retirement development on St Dunstan’s Street, which includes habitable rooms for the elderly very close to the road and particularly where traffic stops (most with engines still running) at the level crossing.
We recommend the Council undertake research into ways of instructing/persuading all drivers to switch off their engine while waiting[35]. For example, an electronic information board (“The next train will be along in 5 minutes so switch off your engine while you wait”) might be used at railway crossings and at light-controlled crossroads eg by the junction of Lower Chantry Lane and New Dover Road.
Potentially Polluting Development:
12.56, 12.57 and Policy QL12:
We absolutely agree but would also strongly urge the City Council to follow other areas and take a clear stance on fracking, as, apart from the huge negative environmental impact (air pollution, ground pollution, water contamination, increase of greenhouse emissions), it also poses a serious risk to human health[36].  The City Council should put enormous pressure on KCC to ban fracking in the Canterbury District (indeed, all over Kent).
Additions to the Local Plan:
·        There seems to be no specific mention of community safety within this Local Plan. There are several areas regarding community which need some attention, including the real and/or perceived increasing problem of heroin addiction in the City, as well as aggressive begging and aggression and noise disturbance related to alcohol.
To this end we would urge the City Council fully to take on board the recommendations made in the Community Safety Chapter of the Canterbury Society’s “Residents’ Vision for Canterbury”.




[1] Michael Redclift, Economic Growth, Sustainable Development and the Earth’s Eco-Cycles & Systems, UNA Conference. 16 April 2011
[2] Wild Law UK: www.wildlawuk.org
(Wild Law UK is a group of lawyers, activists, students, academics and others committed to securing laws that are for the Earth, not against it. In order to achieve this, the legal system must radically shift from being anthropocentric to being eco-centric in approach. We believe that nature has inherent value and that to bring about Earth Justice, our legal systems must recognise the Rights of Nature. Wild Law UK supports the proposed Universal Declaration of the Rights of Mother Earth and seeks the advancement of the same rights in the UK. The group also supports the campaign to get Ecocide recognised as the 5th Crime against Peace.)
[3] Sheila Kesby, UNA Canterbury Earth Day Conference 2012: Think Global, Act Local – Revisited
[8] Michael Redclift, 2010, Economic Growth, Sustainable Development and the Earth’s Eco-cycles and Systems, paper presented to the UNA LaSER Spring Conference in Canterbury, 16 April 2010.
[16] Dr Lynn Sloman, “A Sustainable Blueprint for Canterbury”, Transport for Quality of Life, January 2013,  Chapter 6, p.62, 7.9
[17] Dr Lynn Sloman, “A Sustainable Blueprint for Canterbury (Executive Summary)”, Transport for Quality of Life, January 2013
[18] Dr Lynn Sloman, “Comments on the draft Local Plan for Canterbury”, Transport for Quality of Life, July 2013
[19] Report to the Overview Committee,  13th May 2013
[34] Dr Lynn Sloman, “A Sustainable Transport Blueprint for Canterbury”, Transport for Quality of Life, 2013 - Report for the Canterbury Society and Canterbury 4 Clean Air