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
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
‘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
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
We are further concerned that the allocation of
houses in Canterbury
·
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]
2.54: We 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].
3.5: We 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.
3.6: As 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.
3.17: With reference to Herne Bay Herne Bay
3.20: We 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.
3.26: We 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.
3.37: Any flexibility around sites for
disparate needs should be based very clearly on proven community need for those
businesses or developments.
3.39 and 3.40: We 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.
3.50: We 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.
3.63: We 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
·
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
·
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.
4.24: We 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
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 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.
4.44/5/6: We 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
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 Dover Road
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
e) a cycle lane along the Whitstable
Road
f) direct, easy cycle and pedestrian access from Thanington Without to the Great Stour Way
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
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
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
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
5.64 to 5.66:
These paragraphs begin “In order to assess the transport implications of future development,Canterbury City
These paragraphs begin “In order to assess the transport implications of future development,
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 St
George’s Street New Dover Road
Policy TV5 on marinas: f. “If any proposals relate to Whitstable 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
7.44:
Since most of the residents of Faversham Road
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
·
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
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
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
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
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
“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
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 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
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.
12.3: We 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
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
(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
[3] Sheila Kesby, UNA Canterbury
[4] http://www.transportforqualityoflife.com/u/files/Thriving_Cities_Report_WebFINAL.pdf
Policy recommendations p.22
[7] Nef (New Economics Foundation): http://www.neweconomics.org/blog/entry/the-natural-solutions-to-our-economic-problems
[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] 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
[18] Dr Lynn Sloman, “Comments on the draft Local Plan
for Canterbury
[19] Report to the Overview Committee, 13th May 2013
[20] Building
for Life 12, Building for
Life Partnership 2012 http://www.designcouncil.org.uk/Documents/Documents/OurWork/CABE/Building%20for%20Life/Building%20for%20Life%2012.pdf
[30] The State of Nature
[34] Dr Lynn Sloman, “A Sustainable Transport Blueprint for Canterbury ”, Transport
for Quality of Life, 2013 - Report for the Canterbury Society and Canterbury
