Draft Thanet Local Plan to 2031 - Preferred Options Consultation

A) Thanet Preferred Option Draft Local Plan

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Climate Change

15.1 Adaptation is an essential part of addressing the impacts and opportunities created by our changing climate. The Intergovernmental Panel on Climate Change (IPCC) defines adaptation as:

“adjustments in natural or human systems in response to actual or expected climatic stimuli or their effects, which moderate harm or exploit beneficial opportunities”.

Fluvial and Tidal Flooding

15.2 Flooding has become a significant issue and the National Planning policy Framework (NPPF) states that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but without increasing the risk of flooding elsewhere. This is known as the ‘Sequential Test’ and is accompanied by an ‘Exception Test’ to be applied where necessary.

15.3 Thanet has few areas of low lying land that are at risk of flooding from the sea. The two primary sources of flooding in the district are fluvial and tidal; fluvial flooding from the Wantsum Channel, and tidal flooding from extreme tide levels. The majority of development proposed in this Plan has been directed away from the identified Flood Risk Areas.

15.4 The densely populated Old Town area of Margate falls within an area of low lying land. The financial cost of damage to property in the Old Town area resulting from a major flooding event could be as much as £70m. Such a flooding event could also put the safety of residents and the public at risk. Recent flood defense works have significantly reduced this risk.

15.5 Areas at risk of flooding are shown on the flood maps on the Environment Agency’s website and are updated regularly – www.environment-agency.gov.uk.

The following policy seeks to ensure that development is not put at risk by flooding.

Policy CC01 – Fluvial and Tidal Flooding

The sequential test and exception test as set out in the NPPF will be applied to applications for development within identified flood risk areas. Development proposals in these areas will need a Flood Risk Assessment to be carried out by the developer.



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Surface Water Management

15.6 Management of surface water is important in terms of reducing the risk of pollutants draining into the groundwater and bathing waters, and reducing the risk of surface water flooding.

15.7 The Thanet Surface Water Management Plan (SWMP) 2013 assessed historic flooding incidents, and identified the causes of this flooding as surface water, sewer, tidal or blocked drains or gullys. SWMPs identify areas which may be vulnerable to surface water flooding as a result of flooding occurring elsewhere (eg excessive drainage into a site from flooding occurring further along a watercourse). An Action Plan has been developed which highlights tidally sensitive areas where action is needed, and the type of action that is considered necessary.

15.8 The following actions are identified for the Council, which could be achieved through the planning process:

  • Ensure all new developments, where possible, consider the use of Sustainable Urban Drainage Systems (SUDS)
  • Ensure new developments do not increase the risk of surcharge of sewer network within their catchment
  • Promote benefits of rainwater reuse and recycling
  • Support KCC in the use of SUDS in identified areas

15.9 SUDS are designed to efficiently and sustainably drain surface water, while minimising pollution. Surface water runoff in built up areas tends to flow rapidly into the sewer system, which places a burden on the sewerage network and increases flood risk downstream as piped systems have limited capacity. SUDS can slow the rate at which water disperses, thus reducing the risk of flooding.

SUDS are more sustainable than traditional drainage methods because they:

  • Manage run-off volumes and flow rates from hard surfaces, reducing the impact of urbanisation on flooding
  • Protect or enhance water quality by reducing pollution from run-off
  • Are sympathetic to the environment and the needs of the local community
  • Provide wildlife habitats

15.10 Applications to incorporate SUDS must be made to Kent County Council as the SUDS Approving Body (SAB). This includes the design, construction, operation and maintenance details of a drainage system to manage surface water which demonstrates compliance with the SUDS national standards. Developers are encouraged to agree all details with the SAB before submitting an application to the SAB. Kent County Council is preparing guidance on the process from the application to adoption of SUDS.

Methods of providing SUDS are described in the Climate Change Topic Paper.

15.11 Infiltration methods are unlikely to be appropriate in some parts of Thanet due to the quality of the groundwater. Groundwater from the chalk rock beneath Thanet is used to supply water for drinking water, agriculture, horticulture and industry. It also feeds the springs that emerge along the coast and near the marshes. The groundwater is extremely vulnerable to contamination as substances (natural substances and man-made chemicals) are able to pass rapidly through the thin soils and the natural fissures (cracks) in the chalk rock to the groundwater below the ground surface. The acceptability and construction details of infiltration devices is not only based on whether the site is in a Groundwater Source Protection Zone, it also depends on whether the ground conditions are suitable (i.e. free from contamination) and if there are adequate unsaturated area to help reduce any discharge. Proposals for infiltration methods within the Groundwater Source Protection Zone should be discussed with the Environment Agency as it may be possible for SUDS to be lined, or for water to be treated prior to infiltration.

15.12 Under the Water Framework Directive (WFD), the Kent Isle of Thanet Groundwater Body has been classified as poor status for the groundwater quality and quantity.The groundwater is impacted by nitrates, pesticides, solvents and hydrocarbons at levels that are of concern.

15.13 The quality of the groundwater also has an impact on Thanets bathing waters. Thanet has 13 beaches which have been designated as ‘Bathing Waters’ under the Bathing Water Directive which aims to protect public health and the environment from pollution. Thanet received eight blue flag awards for its beaches in 2013 for reaching the ‘Excellent’ standard required under the new EU Bathing Water Directive. In addition to this Thanet has been awarded two Seaside Awards for Ramsgate Main Sands and Viking Bay, Broadstairs, which recognises and rewards beaches in England that achieve the highest standards of beach management and, in the case of bathing beaches, meet guideline water quality. There are also 2 shellfish waters designated under the EU Shellfish Waters Directive.

15.14 Bathing waters can be nominated for designation or delisting from the designations list in the annual DEFRA review.

15.15 Walpole Bay has previously failed to meet current EC mandatory bathing water standards and is therefore considered to be at significant risk of not meeting the revised Bathing Water Regulations.

The following factors could contribute to poor bathing water quality in Thanet:

  • Pollution from sewerage – bacteria from sewage can enter our waters as a result of system failures or overflows or directly from sewage works.
  • Water draining from farms and farmland – manure from livestock or poorly stored slurry can wash into rivers and streams resulting in faecal material entering the sea.
  • Animals and birds on or near beaches - dog, bird and other animal faeces can affect bathing water as they often contain high levels of bacteria (much higher than treated human waste).
  • Water draining from populated areas - water draining from urban areas following heavy rain can contain pollution from a variety of sources, including animal and bird faeces
  • Domestic sewage – misconnected drains and poorly located and maintained septic tanks can pollute surface water systems.

15.16 As well as pollution by the water industry from sewer system overflows or failures, the quality of bathing water quality can be affected by pollution that arises from a very varied number of sources. Diffuse pollution, from agricultural or other sources, can run off land or percolate through it in to rivers which drain into the sea. The amount of pollution from individual sources may be small but the combined effect can be significant. Water draining from farms and farmland into rivers can contain faecal material coming directly from livestock or indirectly from either the poor storage of manure or poor practices in the application of manure on to land. Non-agricultural diffuse pollution arises from a variety of sources including: wrong connections of waste water from houses and businesses into surface water drainage; road runoff containing animal faeces reaching water courses and septic tanks polluting rivers.

15.17 The loss of blue flags or the failure of any of Thanet’s beaches to meet the requirements of the revised Bathing Water regulations or for Shellfish water failure could have knock-on implications on perception of water quality at neighbouring beaches as well as the local economy and tourist and fishing industry. To ensure development does not negatively impact bathing and shellfish water quality it is important to ensure drainage infrastructure is adequate i.e. sewer capacity is available (or financially viable to increase) and surface water drainage is managed.

The following policy seeks to ensure surface water run-off is managed appropriately.

Policy CC02 – Surface Water Management

New development will be expected to manage surface water resulting from the development using sustainable drainage systems (SUDS) wherever possible. SUDS design should be considered as an integral part of the masterplanning and design process for new development.

Proposals for SUDS at sites within the Groundwater Source Protection Zone as shown on Map 19, or sites near the Groundwater Source Protection Zone, must demonstrate that the methods used will not cause detriment to the quality of the groundwater.

Sites identified as a Tidally Sensitive Area (as identified in surface water management plans) will need to incorporate Sustainable Drainage Methods and a maintenance schedule where appropriate, at the design stage of a planning application, and a Flood Risk Assessment will be required before planning permission can be granted.


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Coastal Development

15.18 There are a number of other discreet areas of flood risk around the coastline; however, the majority of coastline is at risk of erosion and not flooding. Coastal defences have an approximate lifeline of 50 years. If there appears to be an economic justification for maintaining them then they will be maintained; however, feasibility work does not always indicate that a project will be successful in achieving funding, and in such cases defences may cease to be maintained.

15.19 The Isle of Grain to South Foreland Shoreline Management Plan (SMP) provides a large-scale assessment of the risks associated with coastal evolution and presents a policy framework to address these risks to people and the developed, historic and natural environment in a sustainable manner. It also includes an action plan to facilitate implementation of the SMP policies and monitor progress.

The following seeks to ensure that new development is not put at risk from coastal erosion,

Policy CC03 – Coastal Development

Proposals for new development within 40 metres of the coastline or clifftop must demonstrate to the satisfaction of the Council that it will not:

1) expose people and property to the risks of coastal erosion and flooding, or

2) accelerate coastal erosion due to increased surface water run off before planning permission can be granted.


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Sustainable Design

15.20 The design of a building or development can help adapt to climate change by increasing solar gain and reducing winter heat loss.

15.21 The Code for Sustainable Homes is the current national standard for the sustainable design and construction of new homes. The Code aims to reduce carbon emissions and create homes that are more sustainable. There are 6 Code levels which new developments can aim to achieve. This relates to the minimum percentage reduction in emissions; Level 1 is a 10% reduction and Level 6 would be a Zero Carbon home.

The Code for Sustainable Homes levels are set out in Table 8 below.

Table 8 - Code for Sustainable Homes


% energy efficiency higher than Part L1A of the Building Regulations

Daily water usage (litres)per person

















Zero carbon


Source: www.gov.uk

15.22 The requirements to provide these could have an impact on the viability of development in Thanet. The Council commissioned a Whole Plan Viability Study to ensure that policies in the Plan and development in Thanet remain viable. The study assumes build costs to current building regulations and an additional uplift of £2,550 per unit to accommodate CSH Level 5 on water resources management.

15.23 Government has consulted on a review of Housing Standards to rationalise the large number of codes, standards, rules, regulations and guidance currently used by different authorities and provide new national standards. This included a review of the Code for Sustainable Homes. The national standards, when published, will replace the Code for Sustainable Homes.

15.24 Government has also consulted on new building regulations as part of their Zero Carbon Homes Policy which will increase the energy efficiency of buildings and is expected to come into force this year. The new regulations aim to introduce zero carbon standards from 2016 for homes, and by 2019 for non domestic buildings by:

  • Developing and driving a prioritised programme for the energy efficiency aspects of low carbon homes leading to the delivery of mainstream zero carbon homes from 2016.
  • Developing and driving a prioritised programme that deals with the energy supply aspects of delivering low and zero carbon homes.

15.25 There are measures that can be taken in the design of new development that will help reduce energy consumption and provide resilience to increased temperatures, such as:

  • the use of landform
  • layout
  • provision of adequate space for recycling and composting
  • building orientation
  • tree planting
  • landscaping

15.26 Landscaping can be particularly beneficial as it can provide stepping stones, wildlife corridors or new habitats, and contribute to Thanet's green infrastructure network. In terms of adapting to climate change, integrating vegetation (i.e. planting on building walls and roofs) can help to reduce solar gain as vegetation has a much higher reflective capacity than masonry, as well as providing a cooling effect through evapo-transpiration. Planting can also help mitigate against poor air quality by presenting a large surface area for filtering air. A large tree can deliver the same cooling capacity as five large air conditioning units running for 20 hours a day during hot weather. New planting can help provide more comfortable, cooler spaces via summer shading.

15.27 Within the context of an established development pattern, the most significant change likely to generate demand for travel will result from new housing development. It is necessary, therefore, to consider the location of development in areas accessible to a range of services on foot and by public transport, preventing urban sprawl and improving local high streets and town centres. Methods such as providing showers and changing facilities in employment related development and locating cycle parking close to town centres/entrances will also help reduce the need to travel by car.

The following policy seeks to ensure that new development achieves the necessary levels of sustainable design and construction.

Policy CC04 – Sustainable Design

All new buildings and conversions of existing buildings must be designed to reduce emissions of greenhouse gases and function in a changing climate. All developments will be required to:

1) achieve a high standard of energy efficiency in line with most recent government guidance;

2) make the best use of solar energy passive heating and cooling, natural light, natural ventilation and landscaping.

All new buildings and conversions of existing buildings must be designed to use resources sustainably. This includes, but is not limited to:

3) re-using existing buildings and vacant floors wherever possible;

4) designing buildings flexibly from the outset to allow a wide variety of possible uses;

5) using sustainable materials wherever possible and making the most sustainable use of other materials;

6) minimising waste and promoting recycling, during both construction and occupation.

New developments must provide safe and attractive cycling and walking opportunities to reduce the need to travel by car.


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Renewable energy installations

15.28 There are a number of options for obtaining energy from renewable sources in new or existing developments. These include:

  • Solar photo-voltaic panels
  • Wind turbines
  • Solar water heating
  • Ground source heat pumps
  • Biomass and biofuel

The following policy seeks to encourage the use of renewable energy installations in new and existing development whilst mitigating against any detrimental effects.


Policy CC05 – Renewable energy installations

Proposals for renewable energy installations incorporated in new developments or existing buildings will be permitted, subject to there being no unacceptable detrimental visual or environmental impact.


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District Heating

15.29 District heating schemes supply heat from a central source directly to homes and businesses through a network of pipes carrying hot water. This means that individual homes and business do not need to generate their own heat on site.

15.30 Large energy users, or ‘anchor loads’ are an essential part of a district heating network to provide a base heat demand that will allow a system to run efficiently. Anchor loads could be large energy users such as industry, schools, hospitals or leisure centres with heated swimming pools. Map 17 is a heat map for Thanet showing potential areas suitable for district heating.

Map 17 - Thanet's Heat Density

Heat map for thanet

15.31 District heating is most suitable where there is a high density of built development, and especially where there is a mix of building types. (The high heat density shown outside the urban boundary is the airport.) This diversity of energy demand helps to keep combined heat and power (CHP) or boiler plant running in a more steady state for longer – which is more efficient.

15.32 The Renewable Energy for Kent report identifies the following scale and types of district heating networks which may come forward:

Small local networks: Typically between 10 and 50 homes in a street or a block. Gas fired boilers or biomass boilers supplying heat only

Medium size networks: Typically over 200 homes and normally with an ‘anchor building’ (i.e. a school, hospital or leisure centre)

Large networks – A number of small and medium sized networks linked up and perhaps taking heat from a large biomass or energy from waste power station

The following policy seeks to encourage district heating schemes where appropriate and feasible.

Policy CC06 – District Heating

Support will be given to the inclusion of district heating schemes in new development. Major development proposals should be supported by an Energy Statement to demonstrate why district heating can or cannot be delivered.


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Solar Parks

15.33 There have been a number of developments for renewable energy applications in the district to help reduce emissions.

15.34 A number of solar parks have been granted permission – these are mainly located in fields, or parts of fields, are temporary (most have a 25 year lifespan), and the land can revert to its original use when the panels are removed.

 Map 18 - Solar Parks

Solar parks map

15.35 The siting for a solar park will usually be near to a connection to the national grid due to cost implications for connection, and will require the erection of a fence surrounding the site for security reasons.

15.36 Map 18 shows sites where permission has been granted for solar parks. It may be possible that other sites could be considered for further development of solar parks. Further sites should be located on previously developed land or non-agricultural land wherever possible.There are potential negative impacts to the countryside, landscapes, and to best and most versatile agricultural land. For proposals on agricultural land, the developer will be expected to demonstrate how the land can still be used for agricultural purposes.

15.37 The developer will be required to outline a management programme to demonstrate that the areas beneath and around the panels will not become overgrown, and to assist with the eventual restoration of the site, normally to its former use.

Policy CC07 – Solar Parks

Applications for solar parks will only be permitted if there is no significantly detrimental impact on any of the following:

1) Thanet's historic landscapes

2) Visual and local amenity, including cumulative effects

3) Heritage assets and views important to their setting

Proposals on agricultural land must demonstrate that the proposal will comply with all of the following:

5) Cause minimal disturbance to the agricultural land and

6) Be temporary, capable of removal and reversible, and allow for continued use as such on the remaining undeveloped area of the site.

8) Provide biodiversity enhancements.

The need for renewable energy does not automatically override environmental considerations.


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15.38 The Richborough area, which straddles the district boundary with Dover, has become a focus for waste treatment, renewable and low carbon energy industries. The former Richborough Power Station provides a potential location for such facilities, as well as a connection to the national grid. Thanet and Dover Councils have approved applications for solar parks and anaerobic digesters in the surrounding area, and a peaking plant facility and site-wide infrastructure to facilitate the creation of energy from waste site, on the former Richborough Power Station site.

15.39 The Council recognises the potential of the site to help to mitigate against climate change. Therefore in liaison with Dover District Council and Kent County Council (as the Minerals and Waste Authority), the Council will continue to explore, with the promoters of any schemes, how this potential can be realised. Particular regard would need to be had to environmental, transport and wildlife impacts together with visual impact on landscape and on the gateway location to and from Thanet.

15.40 The emerging Kent Minerals and Waste Local Plan 2013-2030 and Waste Sites Plan look to this area as a potential location for energy from waste, green waste treatment and for the treatment/material recycling facilities. Development proposals in this area should also refer to these plans and the relevant National Planning Statements.

15.41 The Secretary Of State for Transport has issued directions under the Town and Country Planning (General Development Procedure) Order 1995 to safeguard the route corridor of the Channel Tunnel Rail Link Project. This includes additional land that may be required for associated works/development. (Such direction and works are not proposals of the District Council, and the routes in question will not be determined through the development plan process but through other statutory procedures which will provide appropriate opportunities for any objections by those directly affected by the project).

15.42 Safeguarding directions for development affecting the route corridor for the channel tunnel rail link project apply to land at Richborough. In accordance with the direction, the Council will consult HS1 (south) limited before granting planning permission or resolving to carry out/authorise development within the limit of land subject to consultation.

Policy CC08 – Richborough

Proposals for the development of renewable energy facilities at Richborough will be permitted if it can be demonstrated that the development will not be detrimental to nearby sites of nature conservation value, or that any potential effects will be fully mitigated.


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