The current planning policy framework for the District includes only one historic environment policy (for applications affecting Historic Parks and Gardens, Policy DM19), and a strategic site policy for Dover Western Heights (Policy LA11). Such an approach is at odds with the NPPF which requires local planning authorities to set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. A strategic policy for protecting the rich historic environment of the district is therefore considered to be essential for the Local Plan 2040.
In considering the delivery of such an overarching strategy, policy options include separate policies for different categories of heritage assets; namely listed buildings, conservation areas, archaeological remains and scheduled ancient monuments, historic parks and gardens and protected wreck sites or one generic policy for all heritage assets. Given the exceptional wealth and diversity of the heritage assets that Dover District enjoys, policies for different categories of heritage assets is the preferred approach, with the exception of including a standalone policy for the one protected wreck site in the district, which it was felt would be adequately covered by both the strategic policy and a policy for designated heritage assets.
As this district is particularly rich in heritage assets, a number of them iconic, the option of having site specific policies for significant heritage assets was also considered. Of the principal assets, there is a substantial evidence base for the Dover Western Heights fortifications and therefore a policy for this important site is considered appropriate.
Finally, following the Council’s declaration of a climate change emergency and commitment to the delivery of a carbon neutral district by 2050, it is considered important that the Plan include clear policy to guide proposals for energy efficiency improvements to heritage assets in order to ensure that their heritage significance is sufficiently protected. Current advice from Historic England, which requires clear adoption of a ‘whole building’ approach, forms the basis of the preferred approach. It is considered that this best ensures that proposals are based on an understanding of the methods of construction, fabric and history of the individual building or assets, in order to deliver solutions that sustain heritage significance, save energy and maintain a healthy indoor environment for the occupiers. There is the option of a standalone policy for such retrofitting proposals or to include policy on this issue within the policy on designated and non-designated heritage assets. The preferred approach is for the latter, given that the majority of such proposals that will come forward will do so as applications for alterations to listed buildings or to non-designated heritage assets in conservation areas.