The Natural Environment Policies

Strategic Policy 16: Protecting Designated Environment Sites

Protecting the District's Natural Environment

Dover District is home to natural assets of international, national and local significance. The district has a rich and diverse natural environment and supports most of the lowland habitat types found within Kent. It is particularly important for coastal habitats, much of which lie within Sites of Special Scientific Interest (SSSIs) and contains a significant proportion of the county’s calcareous grassland. The NPPF requires that planning policies should contribute to and enhance the natural and local environment and that Local Plans, in the first instance, should distinguish between the hierarchy of international, national and locally designated sites.

International Sites

Five internationally designated environmental sites fall, in full or in part, within the boundaries of Dover District:

• Dover to Kingsdown Cliffs SAC
• Lydden and Temple Ewell Downs SAC
• Thanet Coast and Sandwich Bay SPA
• Thanet Coast and Sandwich Bay Ramsar Site
• Sandwich Bay SAC

The District Council has a legal duty to consider potential significant impacts on these European sites. This duty is carried out through a Habitat Regulations Assessment (HRA) which accompanies the Local Plan. By virtue of their high-level designation these sites are protected from development, adverse impact and loss.

National Sites

Areas of Outstanding Natural Beauty are national areas of high scenic quality designated for their natural beauty. They have statutory protection in order to conserve and enhance the natural beauty of their landscapes. Approximately 22% of Dover District lies within the nationally protected landscape of the Kent Downs AONB.

Sites of Significant Scientific Interest are protected areas identified by Natural England under Section 28 of the Wildlife and Countryside Act 1981 as being of national importance for their flora, fauna, geological or physiographical features. The Countryside and Rights of Way Act 2000 imposes a duty on public bodies exercising statutory functions which may affect SSSIs to take reasonable steps to further enhance the features for which the site is notified as SSSI. There are five SSSIs in this district:

• Dover to Kingsdown Cliffs SSSI
• Folkestone Warren SSSI
• Alkham, Lydden and Swingfield Wood SSSI
• Lydden and Temple Ewell Downs SSSI
• Sandwich Bay to Hacklinge Marshes SSSI

National Nature Reserves protect the most important areas of wildlife habitat and geological formations in Britain, as well as being places for scientific research. As such, they are subject to management plans agreed with Natural England and can attract specific funding to help maintain these national assets. There are two National Nature Reserves in Dover District

• Sandwich and Pegwell Bay NNR
• Lydden and Temple Ewell Downs NNR.

A number of stretches of the UK coastline are designated by Natural England as Heritage Coasts, based on their notable natural beauty or scientific significance. Heritage Coasts are one of the few places which still offer a feeling of wilderness, with chalk cliffs, foreshores and seabed platforms that are home to distinctive wildlife influenced by the sea and such exposed habitats. Globally coastal chalk is a scarce resource; the UK holds 57% of Europe’s resource, Kent holds 35% of the UK resource. The only two areas of Heritage Coast within the county of Kent are found in Dover District:

• Dover to Folkestone Heritage Coast
• South Foreland Heritage Coast.

Marine Conservation Zones are designated under the Marine and Coastal Access Act, 2009. These protected marine areas aim to conserve the diversity of nationally rare or threatened habitats and species that are representative of the biodiversity in our seas. There are two Marine Conservation Zones (MCZs) in Dover District:

• Dover to Folkestone MCZ
• Dover to Deal MCZ.

Local Sites

Kent Wildlife Trust has identified, on behalf of the Kent Nature Partnership, 41 Local Wildlife Sites (LWS) within Dover. These are sites of county importance for their wildlife interest and complement designated SSSIs. They are on both public and private land and form an important element of the District’s network of green infrastructure, particularly the chalk grasslands which wrap around Dover town.

Local Nature Reserves are specifically designated by the Council for public access to nature, under Section 21 of the National Parks and Access to the Countryside Act 1949 and amended by Schedule 11 of the Natural Environment and Rural Communities Act 2006, with the purpose of increasing the public enjoyment and understanding of nature, as well as promoting nature conservation. They provide a significant and long-term contribution to nature conservation and are an important resource for the community, making a positive contribution to health and wellbeing. Dover District supports 4 Local Nature Reserves

• High Meadow (LWS),
• Princes Beachland (SSSI),
• Western Heights (LWS)
• Whinless Down (LWS).

The District contains two other Nature Reserves, Gazen Salts Nature Reserve, Sandwich and Monks Wall Nature Reserve, Sandwich both of which are managed by Sandwich Town Council.

Strategic Policy 17: Green Infrastructure and Biodiversity

Green Infrastructure and Biodiversity

Recent years have witnessed a recognition that the planning system should move towards a more integrated landscape-scale approach to green infrastructure and to improving biodiversity, alongside the conservation and enhancement of individual sites and species. To this end Biodiversity Opportunity Areas (BOAs) now form the basis of the strategic biodiversity network. As these areas offer the best opportunities for connecting fragmented habitats, improving the ability of species to move through the environment and for establishing large habitat areas and/or networks of wildlife habitats, they are priority areas of opportunity for restoration and creation of priority habitats in line with requirements of the NPPF. The Dover Local Plan 2040 will support the aims and objectives of the Kent Biodiversity Strategy (2020 – 2045) as they relate specifically to the Biodiversity Opportunity Areas (BOAs) of this District (Kent Nature Partnership Biodiversity Strategy). In particular, the delivery of Kent Biodiversity Strategy targets will be focused on BOAs and the Dover District Green Infrastructure Strategy in the first instance, in order to secure maximum biodiversity benefits, and to deliver the greatest gains from habitat enhancement, restoration and re-creation, the need for which is accelerating with the climate change crisis.

Dover District includes three BOAs. The Lower Stour Wetlands BOA contains some of Kent’s most extensive water and wetland habitats. The area to the west of Dover Town lies in the Dover and Folkestone Cliffs and Downs BOA. This area encompasses a series of valleys around Dover, cliffs and cliff-top grassland, intertidal and subtidal chalk and the steep scarp slope of the North Downs at Dover. Much of the grassland is nationally or internationally important, and there are areas of locally or nationally important woodland. Finally, a small section of the East Kent Woodlands and Downs BOA falls within the district, in the vicinity of the village of Wootton. This BOA comprises a complex of woodland and grassland habitats, including several nationally and locally important sites. A map showing the location of the Districts BOAs can be found here http://kentnature.org.uk/boas.html

Irreplaceable Habitats

In addition to large scale landscape designations, ancient woodland and ancient or veteran trees represent significant elements of Green Infrastructure and are considered, for planning purposes, to be irreplaceable. Dover district has proportionately less woodland than many other districts in Kent. The district contains only 6.9% of broadleaved, mixed and yew woodland, but it constitutes 10.6% of this priority habitat type within the County with the majority consisting of small fragmented areas of ancient woodland. National guidance therefore requires that development resulting in the loss of deterioration of such irreplaceable habitats should only be permitted in exceptional circumstances where the public benefit would clearly outweigh the loss or deterioration and a suitable compensation strategy exists.

DM Policy 38: Biodiversity Net Gain

Biodiversity Net Gain

Historically, planning policy has focused primarily on protecting important designated habitats and species. However, it is increasingly apparent that the UK’s biodiversity decline is so severe that increased efforts to bring about recovery, as opposed to merely arresting loss, are essential. Since 2012 the NPPF has incorporated the principle of Biodiversity Net Gain (BNG) achieved through development, meaning that developments must fully mitigate any loss of biodiversity but then go further to provide a gain, leaving the environment in a better state than before the development. The requirement for the delivery of BNG will become mandatory once the Environment Bill currently progressing through final readings in the House of Commons is signed into law, and all developments that come forward during the Plan period, with some limited exemptions, will have to achieve BNG.

The draft Environment Bill mandates a 10% biodiversity net gain above the ecological baseline for development sites. It also requires the creation of nature recovery networks, which will operate at district level and will guide the delivery of biodiversity net gain projects. The objective is for new development to contribute towards the delivery of net gains for biodiversity, so that the environment, across the district as a whole, is improved by the end of the plan period.

The requirements of the Environment Bill are expected to be provided with a two-year transition period to enable local planning authorities, developers and others to prepare for the proposed requirement. Minor residential sites of fewer than 10 units are likely to be subject to longer transition arrangements or a lower BNG requirement, as well as a simplified process for calculating BNG, to be set out at a future date. As the specific requirements of the Environment Bill and associated guidance are still being produced, this policy will be subject to further revision to take account of emerging legislation and guidance and recommendations of ongoing work with partner organisations.

It is expected that some types of development are likely to be exempt from the policy requirements. The exceptions currently under consideration in ongoing work on the Environment Bill are national infrastructure projects, sites with no biodiversity value (e.g. site covered wholly by sealed surfaces), previously developed (brownfield) sites that don’t contain protected or priority habitats or face genuine viability difficulties, and permitted development and extensions. Where sites are exempt from the minimum BNG requirement, this will not mean that those sites should not still aim to maximise biodiversity enhancements to provide as much gain as possible, or at the very least avoid a net biodiversity loss.

Planning applications will be required to include the relevant information needed to demonstrate that the proposals will meet the requirements for a minimum of 10% net gain, informed by appropriate surveys and assessments carried out by suitably qualified persons. This should include a Biodiversity Net Gain Plan and supporting reports which should provide an assessment of the likely effects of the development and changes to the ecological baseline, whether they are positive or negative.

Net Gain will be measured using Defra’s Biodiversity Metric 2.0. This metric works by placing a value on different habitats based on their distinctiveness, area, condition and contribution to an ecological network, and in doing so, allows the biodiversity value (expressed as ‘biodiversity units’) before and after a development takes place to be measured. In this way, the level of biodiversity gain or loss can be clearly seen by comparing the two values. At the time of writing, Defra is consulting on the metric methodology. DEFRA is, at the time of writing, producing a simplified metric for minor development proposals, as set out above, which are likely to be subject to a simplified process.

Proposals for BNG must be acceptable to the Council in terms of design and location and should take into account local priorities set out in the Local Nature Recovery Strategy, Dover District Green Infrastructure Strategy and the Kent Environment Plan. Proposals should have appropriate delivery and funding mechanisms that are capable of being secured by condition and/or legal agreement. Monitoring of biodiversity net gain projects will be funded by the developer, with reports provided to the Council for inclusion in the Authority Monitoring report.

The delivery of Biodiversity net gain reinforces and supports adherence to the mitigation hierarchy of avoidance, mitigation and, as a last resort, compensation, which is already well established in planning policy. Proposals for BNG will therefore be expected to demonstrate the application of the mitigation hierarchy. Loss or damage to irreplaceable habitats cannot be offset to achieve a net gain.

It is expected that the requirement for BNG should be met on-site, within the application site boundary. If it can be clearly demonstrated that ecologically meaningful biodiversity net gain cannot be achieved within the development site boundary, the Council will consider off-site provision or a financial contribution to a biodiversity offsetting scheme.

Offsetting must follow the principle of ecological equivalence. There must be no trading down of habitat types. Habitat types, (particularly priority habitats listed under Section 41 of the Natural Environment & Rural Communities Act, 2006), will be required to be replaced on a like for like or like for better basis.

Offsetting schemes should be discussed and agreed in the first instance with the Council and will be expected to be strategically located for nature conservation, and be informed by local and national guidance and data sets, including The Kent Habitat Survey, the Kent Biodiversity Strategy and the Biodiversity Opportunity Area (BOA) in which the site is located, the Dover Green Infrastructure Strategy, and the Dover Nature Recovery Network. The Council will pursue net gains for biodiversity in and around BOAs and the emerging Nature Recovery Network. Projects which seek to connect fragmented habitats and improve the ability of species to move through the environment in response to predicted climate change will be supported.

As with on-site provision, proposals for offsetting schemes will be required use the appropriate DEFRA metric to demonstrate compliance with the policy, and should comprise the full calculations of the DEFRA metric results for both development site and offset location, combined with a qualitative assessment of their ecological baselines. The evidence will show how the offset is strategically located to offer the best opportunities for habitat creation, restoration and connectivity to other areas of habitat.

For development schemes, which are unable to provide ecologically meaningful net gains on site, the Council intends to provide an alternative mechanism for developers to achieve biodiversity net gain. This could include setting up one or more habitat banks within the district. They are areas of land, secured and managed appropriately for nature conservation, to offset the impacts of multiple developments. The developer fulfills their duty by making a financial contribution to the habitat bank.

Local Nature Recovery Strategies will be made available and a Dover District Biodiversity Net Gain Strategy will be produced as SPD to the Local Plan. In advance of this being produced, reference should be made to the latest guidance, Biodiversity Net Gain – Good Practice principles for development, a practical guide (CIEEM, CIRIA, IEMA, 2019) and and British Standard BS42020 Biodiversity - Code of Practice for Planning and Development, or subsequent revisions.

DM Policy 39: Landscape Character and the AONB

Landscape Character

The countryside and coastal landscapes of Dover District are one of its greatest assets. From the low-lying and marshland areas in the northern parts of the district to the extensive chalk grasslands of the interior and the iconic white cliffs along its southern and eastern coastlines, the landscapes provide a livelihood for the agricultural and tourism sectors, an attractive setting for settlements and an important recreational resource for residents and visitors. Approximately 22% of the District falls within the Kent Downs AONB, a nationally designated and protected landscape which the Council has a statutory duty, under the Countryside and Rights of Way Act, to conserve and enhance.

Dover District falls within the North Kent Plain and the North Downs National Character Areas as defined by Natural England. The Dover Landscape Character Assessment 2020 which accompanies this Plan provides detailed assessments at a district level. It defines eight generic landscape character types (LCTs) in the district, each representing a distinct identity and common geology, topography, land use and cultural pattern. The LCTs are subdivided into local landscape character areas (LCAs), which are discrete geographic areas that possess the characteristics described for the landscape type but have a recognisable local identity. The classification identifies 17 LCAs and defines issues of landscape management and development management which should be delivered over the plan period.

 Given the quality and importance of its natural landscape to this district, including its role in the wellbeing of residents and the local economy, it is important that all development, where acceptable in principle, should be designed in a way that complements the LCA in which it is located, works to deliver the landscape and development management guidance of the Dover Landscape Character Assessment 2020 and does not harmfully effect such a landscape setting. In doing so, particular attention should be paid to:

• Landform, topography and geology
• Natural drainage patterns
• Pattern and composition of hedgerows, woodlands and field boundaries
• Wildlife habitats and networks
• Settlement patterns
• Locally distinctive architecture

The Kent Downs AONB

An AONB is designated for the high scenic quality of its landscape, its importance for rare species and for tranquillity. AONBs embody a clear sense of place and are home to sites of historical, wildlife or architectural conservation interest. Proposals coming forward over the plan period within the Kent Downs AONB should, alongside the guidance listed above, have regard to the primary purpose of conserving and enhancing the natural beauty of this landscape and with the principles of the Kent Downs AONB Management Plan 2020 -2025 and its successors.

The setting of the AONB comprises land adjacent to or within close proximity of its boundary; land which is visible from the AONB and from which the AONB can be seen. In some cases the setting area will be compact and close to the AONB boundary, perhaps because of natural or human made barriers or because of the nature of the proposed change. The setting may be wider in certain circumstances, for example when affected by features such as noise and light. Within the setting of the AONBs, priority will be given over other planning considerations to the conservation or enhancement of natural beauty, including landscape, wildlife and geological features, while recognising that landscape considerations carry less weight than within the AONB boundary.

Regionally Important Geological Sites

Regionally Important Geological Sites are geological Earth Science sites of particular importance as an educational, research, historical or recreational resource. Identified by the Geo-Conservation Kent Group, there are three such Sites located in Dover District, all legacies of the East Kent coalfield; Betteshanger Colliery Tip, Tilmanstone Colliery Tip and Snowdown Colliery Tip. Betteshanger tip has now been landscaped to create Betteshanger Park.

DM Policy 40: Thanet Coast and Sandwich Bay SPA Mitigation Strategy

Thanet Coast and Sandwich Bay SPA Mitigation Strategy

The Thanet Coast and Sandwich Bay Special Protection Area (SPA) and Ramsar site is used by large numbers of migratory birds. Of particular importance are over-wintering Turnstones and European Golden Plovers. Surveys have revealed a significant decline in the populations of these birds over recent decades, which are protected under international law. Ongoing HRA work has concluded that wintering bird surveys will be required to be submitted as part of planning applications for site allocations identified as having a high or moderate suitability for qualifying bird species. This requirement is reflected in the Site Allocations policy of the Plan. Evidence shows that recreational activity, particularly dog walking, causes harmful disturbance to such bird species. Recreational activity is very likely to increase as a result of the increase in housing numbers that this Local Plan will deliver, and it is the impact of such additional activity that a mitigation strategy will need to address.

The Need for Mitigation

Much of this attractive coastal area is accessible and popular for walking and cycling. It is apparent from ongoing visitor disturbance studies at Pegwell Bay (Thanet District) and Sandwich Bay (Dover District) that such recreational activities are having an adverse impact on the species for which the SPA has been designated. The major concern is that of disturbance to over-wintering birds, particularly their ability to feed which, consequently, has an adverse effect on their breeding performance. The impact of recreational pressures here cannot therefore, when taken in combination, be ruled insignificant having regard to Regulation 61 of the Conservation of Habitats and Species Regulations 2010 and it is concluded that they could give rise to significant impacts on the Thanet Coast and Sandwich Bay SPA.

The Thanet Coast and Sandwich Bay SPA is divided by the estuary of the River Stour. This allows for a focused approach to a mitigation strategy. It is considered, on the existing evidence, that development in Dover is unlikely to have a significant impact on Pegwell Bay but may impact on the Sandwich Bay element of the SPA. In 2012 Dover District Council adopted a mitigation strategy to monitor potential impacts on the qualifying bird species of the Thanet Coast and Sandwich Bay SPA arising from development in the district, and to enable, if necessary, funding to be drawn down to support wardening at Sandwich Bay for a period up to 10 years. This mitigation strategy runs to 2022. As part of the preparation of a new Local Plan for the District, a new Habitat Regulations Assessment and a revised mitigation strategy are being prepared. As part of the evidence base for these reports, monitoring is being undertaken. When the results of such monitoring are finalised, the implementation of a new mitigation strategy to take effect prior to 2022 may be required.

The current mitigation strategy applies a tariff across the whole of Dover District, on developments of greater than 15 dwellings, in order to address the mitigation of the cumulative ‘in combination’ impact of such additional housing on the qualifying bird species. Work on the revision of this strategy has sought to evaluate whether a whole district approach remains appropriate, or whether a ‘Zone of Influence’ approach is more applicable or whether another approach is required. A Zone of Influence is the geographical area from which it is considered that an impact on the interest of a designated SPA is most likely to derive. A Zone of Influence approach has been adopted by neighbouring Thanet and Canterbury districts in respect of this SPA, although in the case of Thanet District the zone of influence covers the entire district.

To assess the harmful impact of recreational pressures visitor surveys are most commonly used. These identify where people who visit the site live, in order define a Zone of Influence. Generally, a core visitor area can be identified, albeit with some outliers of visitors from further afield. A Zone of Influence approach should then take into account such visitor patterns, as well as physical features of the site, current housing proposals and allocations and other relevant local features. A common approach to determine the extent of a Zone is to base the Zone on the area from which 75% of visitors originate.

Survey work to analyse the home destinations from which visitors travel to Sandwich Bay has been undertaken as part of the evidence base for the new Local Plan. This shows a Zone of Influence, based on the approach outlined above, of approximately 9km. A tariff schedule to deliver mitigation and monitoring contributions from new development within a Zone of Influence of 9km from the Thanet Coast and Sandwich Bay SPA is therefore considered appropriate. However, given the large proportion of proposed allocations in this Plan for Dover District which would lie just beyond a 9km Zone of Influence, and the high number of visitors shown to originate from within the district as a whole, it cannot be ruled out that development across the district will not also lead to an increase in visitors to Sandwich Bay. As a result, DM Policy 40 also proposes a tariff regime to collect monitoring contributions in line with a revised Strategic Access Management and Monitoring (SAMM) Plan from new development across the district.

The current tariff is applied across the whole of Dover District to developments of greater than 15 dwellings. An updated SAMM, which will establish the mitigation and monitoring measures for which these tariffs will be raised, as well as the details of the tariff structure itself, will be prepared as part of the evidence base for the Regulation 19 Draft Local Plan. Whilst a number of planning authorities have decided to apply a SAMM tariff to all new residential developments, it is proposed that a threshold of 10 or more dwellings is set at this stage in the Plan preparation, in line with the other S106 requirements of the Regulation 18 Dover Local Plan, and as a pragmatic transition from the current threshold to a potentially wider coverage. In such a scenario the cost of the mitigation necessary for development under 10 units would be met from those developments above this threshold. The updated SAMM will conclude on the appropriate threshold to be set for the collection of the tariff.

DM Policy 41: Air Quality

Air Quality

The main sources of pollutant emissions within Dover are linked to port activities, primarily regular cross-channel shipping, and large volumes of road traffic as a result of the associated transport of goods along the A2 and A20 entering and leaving the town and the port. There are currently two Air Quality Management Areas (AQMAs) declared in Dover District, due to exceedance of the annual mean Air Quality Strategy (AQS) objective for NO2; a situation caused primarily by road traffic emissions. These AQMAs are located along a stretch of the A20 at Dover (declared in 2004, amended in 2007 and 2009) and at the junction of the High Street and Landwell in Dover town centre (declared in 2007).

A new Air Quality Action Plan (AQAP) is currently under development for Dover District and will be finalised in 2021 when uncertainty over whether the UK will be leaving the European Union with a deal or without (with Dover likely to be significantly impacted by such decisions), together with the nature of the deal, and its associated border administration, will be clarified. A dispersion modelling assessment along the main roads in Dover, including both AQMAs will be undertaken as part of this Action Plan, utilising the latest monitoring data, alongside an updated source apportionment study to identify the extent to which different key sources are contributing to air quality exceedances in the area. The outcomes of this assessment will help ascertain whether AQMA adjustments will be required.

As part of the evidence base for both the Local Plan and the revised Dover AQAP, an Air Quality Assessment has been undertaken. The Assessment examined the exposure of existing residential and ecological receptors, alongside new local plan originated development receptors, to concentrations of Nitrogen Dioxide (NO2), Particulate Matter (PM10), CO2 and Nitrogen (as NOx). This work concluded that the implementation of the Local Plan is not predicted to significantly impact air quality or increase the number of sensitive receptors which are exposed to poor air quality, provided recommended mitigation measures are followed. In addition to the policy below, these mitigation measures are addressed by policies in the Climate Change Chapter of this Plan, specifically Strategic Policy 12 and DM Policies DM Policy 4 and DM Policy 9.

DM Policy 42: Water Supply and Quality

Water Quality and Supply

Water Supply

Dover District is underlain by chalk, which provides groundwater for the public water supply. As a result of such permeable geology, there are few main rivers in the District aside from the River Stour and the River Dour. The Stour, in the north, drains much of East Kent. The River Stour historically, and currently, is of poorer quality compared to the Dour, due to high nutrient concentrations, particularly nitrates and phosphates, which reduce biodiversity value. However, despite this, the catchment area has great nature conservation interest, which includes the last valley fen in South East England, together with some 280 km of dykes and drainage ditches, draining approximately 10% of the district. The River Dour, located in the south of the District, has a local catchment, draining the dry chalk valleys in the vicinity of Dover town and is one of only two pure chalk streams in Kent. The River Dour catchment has good water quality and is important ecologically as, being an isolated catchment, it provides a safe haven for native species including wild brown trout. Being an urban river, fed predominantly through groundwater, the river is susceptible to a mix of fluvial and pluvial flooding in periods of high rainfall.

The Kent Environment Strategy identifies Kent as one of the driest regions in England and Wales. At the same time, Kent’s household water use is above the national average (154 litres per person per day compared with 141 litres nationally). Kent's water resources are therefore under particular and continued pressure, requiring careful management and planning. Dover falls partly within the Dour Water Resource Zone (Affinity Water) and the Thanet Water Resource Zone (Southern Water), both of which will experience a shortfall in supply relative to demand up to 2031.Drinking water is supplied wholly by groundwater sources from the underlying chalk. Dover is located in the Environment Agency’s Stour Catchment Abstraction Management Strategy, which identifies all the groundwater sources as over-abstracted.

Groundwater Source Protection Zones

The Environment Agency has defined Source Protection Zones (SPZs) for groundwater sources such as wells, boreholes and springs used for public drinking water supply. These zones show the risk of contamination from any activities that might cause pollution in the area. The closer the activity, the greater the risk. A number of Source Protection Zones 2 and 3 are located within Dover district, protecting the district’s rivers and aquifers from pollution. The majority of the zones are concentrated in the southern third of the District, with a significant concentration to the north-west of Dover. In order to ensure that as much rainfall as possible returns to the ground to re-charge groundwater sources, to control rainwater runoff at source and alleviate pressures on sewer systems and treatment plants, the Local Plan will be promoting sustainable urban drainage systems (SUDS) which aim to mimic natural drainage as far as possible. These are, however, only acceptable in Source Protection Zones when it can be demonstrated that there will be no environmental risks to water quality.

Water Quality

The Dover District Water Cycle Study found that while the River Dour catchment has good water quality, the lower reaches of the River Stour have poor water quality, both in recent years and historically.

In July 2020 Natural England issued advice to local authorities for development proposals with the potential to increase nutrient impacts to nationally and internationally important wildlife sites within the Stour Valley catchment. The Stodmarsh wetland sites rely on a high quality of water and stable water levels, in particular the lake habitats. Some of the lakes are currently impacted by an excess of both Nitrogen and Phosphorus and are not achieving the required standard to support their favourable condition. This is because both Nitrogen and Phosphorous can have a range of negative impacts, including promoting algae growth, which can lead to reduced light and oxygen available for aquatic plants and animals and affect those birds that feed on them. Increased nutrients can also promote changes in structure which make it unsuitable for wetland species, including the main SAC feature. Natural England’s advice is that a likely significant effect on the Stodmarsh designated sites from development that increases these nutrients cannot be ruled out, on objective evidence, at this stage.

At the time of writing, the Council is taking expert hydrological advice to determine whether or not areas of Dover District should be included within this guidance, as the catchments that lie with Dover District are upstream of the Stodmarsh Lakes and there may therefore not be a hydrological connection. However, in the absence of evidence to the contrary, at the current time, all new housing development proposals, will therefore need to consider, via an appropriate assessment, the impact of adding to the existing water quality target failures in the Stodmarsh European sites.

Negative impacts upon water quality, could occur either directly, through pollution of surface or ground water or indirectly through the treatment of waste water. In line with the objectives of the Water Framework Directive, development must not result in a water body failing to meet the class limits for the status class listed in the current South East River Basin Management Plan. Development schemes affecting the river will be expected to undertake a Water Framework Directive Assessment, setting out the potential impact of the new development.

DM Policy 43: The River Dour

The River Dour

The River Dour is an important feature in the town of Dover. Public access to the river however is fragmented and many existing developments have turned their frontages away from it, rather than making it an integral feature. The river poses flood risk issues which need to be addressed in development proposals. Water quality is also an issue for this river, with historic culverting over the river having a harmful effect on water quality and wildlife. As a result, there is a need to give more prominence to the river and allow it to fulfil its potential to help enhance the distinctive environment of the town Dover.

To deliver on such an objective, opportunities to link up fragmented sections of the existing riverside walk for walking and cycling and to promote increased usage will be encouraged as a means of achieving, in the longer-term, a publicly accessible spinal route through the town which follows the river. In addition, development proposals that physically relate to the river will be encouraged to incorporate an active river frontage whilst protecting and enhancing water quality and wildlife interest.