Whitfield Action Group is currently reviewing the Core Strategy Submission Document, Core Strategy Sustainability Appraisal Non-Technical Summary and the Core Strategy Habitat Regulations Assessment, that have been published for Public Consultation by Dover District Council as the next stage of the LDF Process.

These Development Plan Documents (DPD) are published in order for representations to be made prior to submission to the Government.  The representations made will be considered alongside the published DPD when submitted, which will be examined by a Planning Inspector. 

This consultation has already started and will finish on Wednesday, 25^th March 2009.

Anyone who feels that DDC plans are too excessive or are unsound has to respond now or it will be too late. The representations will go forward to the Government Inspector's examination of the DPD later in the year - after scrutiny by DDC and any final amendments they deem necessary to the Submission Document.

After that the decision has been made. There is no going back - no further consultation and discussion.

You can make your own representation or, if you wish, you can support our representation.

Details will be made available once the full response is completed.

The Planning and Compulsory Purchase Act 2004 states that the purpose of the examination is to consider whether the DPD complies with the legal requirements and is ‘sound’.

These documents are complex and the format of all responses require knowledge of the Government and Planning Inspectorate guidance on ‘Legal Compliance’ and tests of ‘Soundness’ as well as extensive research of the Development Plan Documents and DDC’s Evidence Base.

·         ‘Legal Compliance’ relates to the way in which Dover District Council has prepared the published DPD.

Whitfield Action Group believes that the DPD is not ‘Sound’. Our opinion is that:

The DPD are not justified and are not founded on a robust and credible evidence base and that opinion from the local community has been discounted.

·         Public Consultation has not been taken fully into account.  DDC are ignoring the preferred option indicated by the 11,000 responses received from the March 2008 consultation in favour of the ‘stage managed’ focus groups (39 people attending 6 workshop events) and public opinion polling (612 people polled in their homes) that were orientated towards extracting support for the higher options.

·         Sections of the Submission Document have changed significantly from the draft document agreed upon by the LDF Group, the Cabinet and the Full Council during December 2008.

·         The opinions of developers, consultants and landowners are being given more weight than Local Residents who will have to live with the consequences of bad planning.

·         Much of the evidence base is out of date and makes assumptions that are not based on what would normally be an acceptable definition of evidence. Factual detail is lacking in most of the documents and reports:

DDC predictions for job creation have increased from 4,000 (March 2008) to 6,500 in the new DPD without any new evidence. The only recent news is further job losses at the docks, with more expected, and at Pfizer, where manufacturing is already on target to pull out almost entirely by the end of 2009 with rumours that Key Research and Development activities are to be lost.

The DDC predicted 2,540 new jobs in business and financial services and the 1,770 new jobs in Government and other services are only theoretical, based on trends and assumptions. 

·         Dover District Council has not completed its Strategic Housing Land Availability Assessment (SHLAA).

·         There is no indication or analysis as to where the significant new population will come from or what will attract people to Dover - given that there is to be an increase in new housing throughout the South East.

·         There is no indication or analysis on the adverse effect that out of town development will have on Dover Town Centre regeneration.

·         The increase in traffic and out-commuting for work and non food shopping has been underestimated and the proposed ‘highways improvements’ will not address this.

·         Greenfield land use is excessive. All housing over 5,000 will be built on Greenfield land.

Use of Greenfield land has been brought forward in the delivery schedule: Whitfield construction now to commence in 2010 (was due in 2013 in the March 2008 Core Strategy).

Greenfield sites should only be used after all Brownfield sites have been identified and used.

·         The DPD does not provide the most appropriate strategy when considered against reasonable alternatives. The whole process should be employment lead. An allocation of 14,000 new houses is far too many and must be taken out of the plans. 10,000 may be pushed on us as Dover is now a Growth Point, but 6,100 or 8,100 would be more reasonable as a starting point to be increased once genuine, full time, new jobs have been created in the District creating a need for new homes.

The DPD are not effective and are not deliverable.

·         The infrastructure and community service delivery planning is unsound. There is no analysis of the current shortfall in the present provision, which should be taken fully into account in the DPD.

The proposed infrastructure and community service provision in the DPD is vague, has not been costed and does not specify commitment to funding from the providers or timely provision. To state that Growth Point status gives the District access to further grants is not enough. There must be guaranteed commitment and funding in place before any building commences.

Provision of infrastructure and community services is outside of DDC's powers to provide or directly influence.

·         Concentrating development at large sites (to maximise developer profits) should not happen until all Parishes have been contacted and asked if they want rural housing to support and sustain their communities (and if they do, then this housing should be put into the plan).

·         Building so many houses before infrastructure and community services are in place and before new medium and higher value employment is created in the District is a fundamental mistake and makes the plan ineffective and undeliverable.

·         The plan should be flexible to deal with changing circumstances. Safe guards must be built in to respond to problems such as lack of funding for major infrastructure proposals.