The Historic Environment Policies

Our preferred policy approach to conserving and enhancing the historic environment in the District over the Plan period, and the justification for this, is set out below:

Strategic Policy 18: Protecting the District's Historic Environment

Protecting the District's Historic Environment

The significant archaeological and historical heritage of Dover District is an irreplaceable resource which has played a major role in shaping the District’s development and identity and which offers outstanding opportunities to enhance the environment and economy of the District over the plan period. Heritage assets will therefore be protected and conserved in a manner appropriate to their significance.

The district is home to 1,926 listed buildings, 57 Conservation Areas, 50 Scheduled Monuments, 6 Historic Parks and Gardens and one protected wreck site in addition to a rich archaeological resource. Historic England’s Heritage at Risk Register (2019) lists 13 heritage assets at risk in this district. Non-designated assets also play an important role, contributing to the character and distinctiveness of the District and providing a focus for conservation and access projects, interpretation, education and research. The Kent Historic Environment Record records more than 12,000 entries for Dover District.

The Dover Heritage Strategy

The Dover District Heritage Strategy 2013 was developed and produced by the Heritage Conservation Group of Kent County Council for Dover District Council and English Heritage in order to promote a greater understanding of the heritage assets of the District. This Heritage Strategy is a substantial and comprehensive body of work and as such serves as the principal evidence base for the historic environment sections of the Local Plan. It was updated in May 2020 in order to take into account the revisions in 2019 to the NPPF. The Strategy divides the heritage assets into a number of themes with each theme study including a written description of the principal heritage assets, a list of key heritage assets and a statement of significance for that theme. Also highlighted are any significance vulnerabilities or opportunities connected with either the theme as a whole or to specific assets within that theme.

Local Listing

Local lists play an important role in celebrating non-designated heritage that is particularly valued by communities. The process of preparing a local heritage list allows local people, in partnership with the Council, to identify local heritage that they would wish to see recognised and protected. Such local lists once agreed by the local planning authority as having heritage significance, will merit consideration in planning matters, with the planning authority taking a balanced judgement having regard to the scale of any harm or loss and the significance of the heritage asset itself. Dover does not currently have a Local List. The council will therefore produce guidance which will set out a recommended methodology based on Historic England's Guiding Principles for Local Heritage Listing, in order to support local groups who wish to prepare a Local Heritage List.

Strategic Policy 18: Protecting the District's Historic Environment

The heritage assets of the District are an irreplaceable resource and should therefore be conserved and enhanced in a manner appropriate to their significance. The Council will work with partners to ensure that the heritage of the District can positively contribute to the character, environment and economy of the District and the quality of life of existing and future generations of residents and visitors.

DM Policy 44: Designated and Non-designated Heritage Assets

Designated and Non-designated Heritage Assets

Designated heritage assets in Dover District comprise Scheduled Monuments, Listed Buildings, a Protected Wreck Site, Registered Park and Gardens, and Conservation Areas as designated under the relevant legislation. Non-designated heritage assets include buildings, monuments, sites, places, areas or landscapes which have a degree of heritage significance meriting consideration in planning decisions, but which do not meet the criteria for designation as heritage assets. Specifically, these include sites that have been identified in the Kent Historic Environment Record, the Dover District Heritage Strategy, in a Local or Neighbourhood Plan or in Conservation Area Appraisals and Reviews. In some cases, non-designated heritage assets will be identified as part of the decision-making process on planning applications, for example, following archaeological investigations.

Proposed development affecting a heritage asset is assessed against the impact that such works will have on its significance. Development may have no impact on the significance of the listed building or conservation area, for example, or it may enhance its significance and therefore cause no harm to the heritage asset. Where potential harm to designated heritage assets is identified including from development within its setting, it will be categorised as either less than substantial harm or substantial harm, the latter includes total loss. It is the degree of harm to the asset’s significance, rather than the scale of the development, that will then be assessed when determining the application. In such assessment great weight will be given to the asset’s conservation; the more important the asset, the greater the weight will be. The heritage assets of Dover District are one of its richest resources and therefore any harm to designated heritage assets will require clear and convincing justification, while substantial harm to heritage assets in the district should be exceptional, and in the case of scheduled monuments, protected wreck sites, grade I and II* listed buildings and registered parks and gardens wholly exceptional.

Energy efficiency improvements to heritage assets

Energy efficiency improvements to heritage assets can impact upon their heritage significance in a variety of ways. In such cases, the question of what is and what is not an acceptable change will depend on the measures proposed and their impact on a building’s significance. There are many measures that can be applied to traditionally built buildings to improve energy performance while protecting their heritage significance. However, because of the variability in traditional designs and construction methods, it is important that a one size fits all approach is not pursued and instead that energy improvement proposals demonstrate a ‘whole building’ approach, one that is based on an understanding of the construction and history of the building for example, in order to find a solution that sustains heritage significance, saves energy, and maintains a healthy indoor environment. Houses of traditional construction, for example, do not perform in the same way as their modern counterparts. Most modern buildings depend on impermeable barriers to control the movement of moisture and air through the building fabric. In contrast, traditional forms of building construction take up moisture from their surroundings and release it according to ambient conditions. They also tend to heat up and cool down more slowly.

For proposals which include the installation of energy efficiency measures and where planning permission and/or listed building consent are required, the nature and the scope of proposed measures will therefore be assessed both against their suitability for the particular property and against the risk of harming the significance of the heritage asset.

Heritage Statements

All applications affecting heritage assets are required to submit a Heritage Statement which should include an assessment of the significance of that asset. Significance in this context is defined as the value of the asset to this and future generations because of its heritage interest. Such interest may be archaeological, architectural, artistic or historic. In doing so it is important to note that significance derives not only from a heritage asset’s physical presence, but also from its setting; the surroundings in which a heritage asset is experienced. The level of detail should be proportionate to the asset’s importance and no more than is sufficient to understand the potential impact of the proposal on their significance.

Heritage Statements for applications in this district should make reference to the extensive evidence resource that Dover District Heritage Strategy provides, including categorising the asset against one or more the 13 Themes set out in the Strategy. To assist applicants with this requirement the Council will provide written guidance to accompany this Plan on what a Heritage Statement should comprise and will establish a clear methodology for checking proposals against the Heritage Strategy themes.

DM Policy 44: Designated and Non-designated Heritage Assets

Proposals which conserve or enhance the heritage assets of the District, sustaining and enhancing their significance and making a positive contribution to local character and distinctiveness will be supported. In particular, proposals that bring redundant or under-used buildings and areas, including those on the Heritage at Risk Register, into appropriate and viable use consistent with their conservation, will be encouraged.

Development will not be permitted where it will cause total loss or substantial harm to the significance of a designated heritage asset or its setting, unless it can be demonstrated that substantial public benefits will be delivered that outweigh the harm or loss caused, or

  • where the nature of the heritage asset prevents all reasonable or viable uses of the site, and no viable use of the heritage asset can be found in the medium term through appropriate marketing that will enable its conservation; and
  • conservation through grant funding is not possible, and the harm to or loss of the asset is outweighed by the benefits of bringing the site back into use.

Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, or where a non-designated heritage asset is likely to be impacted, harm will be weighed against the public benefits of the proposals, including, where appropriate, securing the optimum viable use of the heritage asset.

For development that involves the installation of energy efficiency improvements to heritage assets, applications should also demonstrate a whole building approach, including an assessment of the suitability of the proposed measures for the particular property, its construction and materials, in addition to the impact on its heritage significance.

All applications with potential to affect a heritage asset or its setting must be supported by a Heritage Statement, which should draw on the evidence contained in the Dover District Heritage Strategy, including referencing the heritage themes of the Strategy that apply. Such a Statement should include an assessment of the asset’s historic, architectural or archaeological significance and the likely impact of the proposals on its significance, proportionate to the importance of the asset.

DM Policy 45: Conservation Areas

Conservation Areas

Conservation Areas are designated in law for their “special architectural or historic interest, the character and appearance of which it is desirable to preserve or enhance”. There are 57 Conservation Areas in Dover District, including the very first Conservation Area to be designated in Kent, at Middle Street in Deal. The Dover Heritage Strategy concludes that the Conservation Areas of Dover District, covering amongst other areas the historically important towns of Sandwich, Dover and Deal, the substantial fortifications at Dover Western Heights, the Castles of Dover, Deal and Walmer, and the historic cores of many rural villages and estates across the District, represent an asset of outstanding significance.

There are currently 7 Conservation Area Appraisals in operation in the district. A programme of preparing Conservation Area Appraisals, to increase the numbers of Conservation Areas for which Conservation Area Appraisals have been completed, will therefore continue over the Plan period. Four Conservation Areas are currently afforded additional protection in part through Article 4 (2) Directions – Kingsdown, Deal Middle Street, Deal North Street and Sandwich Walled Town.

DM Policy 45: Conservation Areas

Applications for development or redevelopment in Conservations Areas will be supported provided that such proposals preserve or enhance the special architectural or historic character and appearance of the Area and its setting. Applications should be guided by and make reference to the appropriate Conservation Area Appraisal where one is in operation.

All new development and alterations in Conservation Areas should:

  • Respect the plan form, architectural features, materials, height, massing, building lines, roofscapes, scale, relationships between buildings and the spaces between them of the Area; and
  • Retain trees, open spaces, walls, fences and other features where they contribute positively to the character and appearance of the Area; and
  • Be appropriate in land use to the character, appearance and historic function of the Area; and
  • Not generate levels of traffic, parking or other environmental problems which would result in unacceptable harm to the character, appearance or significance of the Area; and
  • Not prejudice important views into or out of the Area.

DM Policy 46: Archaeology


As the closest point to the continent, archaeological evidence demonstrates that Dover District has been central to the transmission of ideas, goods and people between continental Europe and England since at least the Bronze Age. This has led to a rich and diverse archaeological record that includes numerous archaeological sites of national significance and both designated and non-designated heritage assets. Non-designated archaeological sites are often less visible than designated sites but nonetheless play an important role, contributing to the character and distinctiveness of the District and providing a focus for conservation and access projects, interpretation, education and research.

A number of the archaeological assets of the District can be considered to be iconic, including Dover Castle itself, Richborough Castle, the Roman Pharos in Dover Castle and the immense fortifications of the Western Heights. Others are less well known but nonetheless play an important role in the contributing to the historic character of the District. Many of the district’s archaeological remains are also remarkably well preserved, particularly in former marshy areas of the northern part of the District and along the River Dour.

The urban archaeology of the District is particularly rich. The archaeological discoveries at Dover have recently been modelled to form an Urban Archaeological Database by Kent County Council, one of only 30 such databases across the country, following grant funding from Historic England and the District Council. This analysis provides a record and maps of all the individual pieces of archaeological work which have taken place in the urban area, along with a summary of all the monuments which have been identified. This work will provide an excellent resource for applicants, reducing the research required for individual desk-based site assessments, and will form the basis of a Dover Town Archaeology Supplementary Planning Document, to be brought forward early in the Plan period. This will set the story of the development of the town and is likely to set out Areas of Archaeological Significance and Primary and Secondary Archaeological Character Zones, as defined by their predominant archaeological character, with such Areas being identified on an interactive map.

Individual archaeological sites have their own particular vulnerabilities but the archaeological resource of the district is in general vulnerable to natural processes such as erosion and climate change, activities such as ploughing, construction and development, including utilities, services and infrastructure works, change of use and general neglect. All of these serve to degrade the archaeological resource and reduce its significance and potential for creating attractive and distinctive places as well as the economic benefits, which arise either directly from people visiting monuments or indirectly by increasing the attractiveness of places containing archaeological sites.

Should significant archaeological finds occur during development, the Council will seek specialist advice and encourage appropriate action, including recording, preservation in situ (the preferred option) or limited or full excavation. In some cases approved schemes may need to be amended to avoid excessive damage to archaeological remains. In all instances copies of evidence should be deposited with the Kent Historic Environment record managed by Kent County Council, and, along with any archives, with a local museum or other public depository.

DM Policy 46: Archaeology

The archaeological and historic integrity of Scheduled Monuments and other important archaeological sites, together with their settings, will be protected and where possible enhanced. Development which would adversely affect such heritage assets will be assessed in line with DM Policy 44.

Planning applications, on sites where there is, or is the potential for, an archaeological heritage asset, must include an appropriate desk-based assessment of the asset.

In addition, where the assessment reveals that important or potentially significant archaeological heritage assets may exist, developers will be required to, where necessary, arrange for field evaluations to be carried out by an appropriately qualified contractor in advance of the determination of the planning application. Such an evaluation should define:

a. The character, significance and condition of any archaeological deposits or structures within the application site; and

b. The likely impact of the proposed development on the archaeology, its significance and setting (including the limits to the depth to which groundworks can go on the site); and

c. The means of mitigating the effect of the proposed development including a statement setting out the impact of the development.

Where the case for development affecting a heritage asset of archaeological interest is accepted, the archaeological remains should be preserved in situ. Where this is not possible or justified, appropriate provision for preservation by record may be an acceptable alternative dependent upon their significance. In such instances archaeological recording should be undertaken by an approved archaeological body, deposited with the Kent Historic Environment Record and should take place in accordance with a specification and programme of work to be submitted to and approved by the District Council in advance of development commencing.

For applications in the Dover Urban Area (as shown on the Proposals Map) the Dover Town Archaeology SPD should be consulted and applicable requirements in such detailed advice should be followed.

DM Policy 47: Dover Western Heights

Dover Western Heights Fortifications Scheduled Monument and Conservation Area

The Western Heights fortifications are located along the crest of a prominent, steep chalk ridge, directly to the west of Dover town centre, overlooking the harbour. The fortifications represent one of the largest and most elaborate surviving examples of nineteenth century fortifications in England and evidence an exceptional record of continuous military occupation over a period of some 170 years, which is unique in scale in the UK. They are designated as a Scheduled Monument, contain a number of Grade II listed structures and the whole site is designated a Conservation Area.

Furthermore, the broad expanse of green slopes around the monument forms a notable backdrop to the town of Dover itself, making a key contribution to its urban identity and providing large areas of open space. The majority of these slopes are designated as a Local Nature Reserve and a Local Wildlife Site for their unimproved chalk grassland, which is a priority habitat. Protected species are present, or likely to be present, within the site and its structures. The landscape characteristics, ecology and heritage value of the military site are intrinsically connected.

Since World War II, following the departure of the military, the fortifications have fallen into disrepair, decline and invasion by scrub and woodland. Demolition and vandalism have added to the general neglect. The Scheduled Monument is currently on the Historic England ‘At Risk’ register. The site is currently in multiple ownerships.

A Masterplan for Dover Western Heights was prepared by representatives of Dover District Council, Kent County Council, Medway Council, Historic England and the At Fort Partnership in 2015 and is an adopted Supplementary Planning Document to the Local Plan. The masterplan provides a strategic framework for action in order to secure a sustainable future for this unique site through the unlocking of the value of its military heritage and its unique setting and by widening its appeal as a strategic location for inward investment, enhancing the Western Heights as a destination of national and international significance which one which complements Dover’s other heritage attractions.

Dover Heights Map

DM Policy 47: Dover Western Heights Fortifications Scheduled Monument and Conservation Area

Viable uses which conserve and enhance the significance of the Dover Western Heights heritage asset, and which contribute to delivering a sustainable future for the site including its landscape and biodiversity, will be supported. In particular developments should:

a. Make a positive contribution to the character and distinctiveness of this significant heritage asset;

b. Optimise the opportunities presented by this site to enhance the economic well-being of the town;

c. Promote and enable the constructive conservation of the built heritage of the site including those elements which are on the Heritage at Risk register;

d. Respect the overall historical coherence of this heritage asset and provide support for heritage restoration which delivers exemplary standards of conservation, design and sustainable construction;

e. Conserve and enhance the natural environment, ecology and biodiversity of the site;

f. Enhance awareness and accessibility of this asset for residents and visitors;

g. Improve connectivity between the fortifications and the town, including, where possible, the delivery of links with the town centre, Dover Priory railway station and the Dover waterfront; and

h. Comply with the Delivery Principles of the Dover Western Heights Masterplan (2015) and any successor.

Development within the boundary of the Western Heights which would have a detrimental impact on the heritage significance, settings, views, biodiversity, character or coherence of the components and elements of this complex, will not be permitted.

Inter-visibility between different elements of the fortifications within the site and with key features in the surrounding landscape is a key aspect of the significance of this heritage asset and of its potential visitor appeal. New development should therefore not harmfully intrude on key views as identified in the Dover Western Heights Masterplan SPD.

DM Policy 48: Historic Parks and Gardens

Historic Parks and Gardens

Historic Parks and Gardens are a valuable part of the District’s heritage, as well as being important areas of open space providing benefits for biodiversity, tourism, recreation and education. Dover District has six historic parks and gardens on the register of Parks and Gardens of Specific Historic Interest produced by Historic England. These are Goodnestone Park, Kearsney Court, Northbourne Court, The Salutation, Sandwich, Waldershare Park and Walmer Castle. In addition, Kent County Council has identified Betteshanger House, Fredville Park at Nonington and Knowlton Court at Nonington in its Kent Gardens Compendium.

DM Policy 48: Historic Parks and Gardens

Proposals which protect and enhance the character, fabric, features, setting or views into and from the district’s Historic Parks and Gardens as included in Historic England’s register of Parks and Gardens of Specific Historic Interest and the Kent Gardens Compendium will be supported.