Hythe residents call to protect Britain’s only military canal from 291-home scheme

Once this remarkable openness has been filled, raised and built over, it cannot be recreated.

Hythe residents call to protect Britain’s only military canal from 291-home scheme

Historic England says housing would cause a “very high level of harm” and warns flood-related land raising would damage the nationally important Scheduled Monument even without buildings

HYTHE, Kent, 5 October 2026 - Community action group Hythe Save our Seafront is calling on Folkestone & Hythe District Council to reject plans by the owners of the Hythe Imperial Hotel to build up to 291 homes on part of the existing golf course.

The group recognises that the scheme includes affordable housing, investment in the hotel and new leisure facilities, and supports continued investment in the Hythe Imperial Hotel. But it says those benefits should not depend on building almost 300 homes on this particular open seafront, substantially raising existing ground levels and removing standard-length golf provision.

Historic England says the housing would cause a “very high level of harm” to the adjacent Royal Military Canal and recommends removing the residential component.

The Royal Military Canal is a nationally important Scheduled Monument and the only military canal in the country. Historic England says the open land between the canal and sea is “fundamental to understanding and appreciating the monument” and that this is the only section where its relationship with the sea and wider system of military defences can still be fully understood.

Historic England’s concern is not simply how far the proposed buildings are set back from the canal. It says harm would result from changing the open landscape historically and functionally associated with the monument, and says the applicant underestimates the contribution that open setting makes to its significance.

The site is also designated as Open Space in the council’s Local Plan. The applicant’s own assessment acknowledges that existing open space is safeguarded under local policy. National planning policy similarly says existing open space and sports land should not be lost unless specified tests are met, such as showing it is surplus or providing equivalent or better replacement provision.

The applicant claims those tests are satisfied. However, Historic England says residential development does not appear to be in the spirit of the Open Space allocation requirement of national policy, while Sport England says the golf-course land proposed for housing has not been shown to be surplus and adequate replacement sports provision has not been demonstrated.

The scheme also requires substantial land raising as part of its flood-risk strategy. The applicant estimates at least 58,606 cubic metres of fill will be required across identified areas.
The Environment Agency has not objected to the scheme’s flood-risk strategy.

But Historic England raises a separate heritage concern: it says the landscape changes required to address flood risk would themselves add to the harm to the Royal Military Canal and that “even without built form” those changes would harm its legibility and significance.

Jane Stymest, spokesperson for Hythe Save our Seafront, said:
“This is what makes this stretch of Hythe’s seafront so special. Historic England says nowhere else allows the relationship between the canal, its historic field of fire, and the sea to be understood in the same way.

“Once this remarkable openness has been filled, raised and built over, it cannot be recreated. Surely there is a better way to invest in the hotel without sacrificing it.”

Sport England has separately submitted a non-statutory objection.

It says the proposed hotel pool does not compensate for the loss of existing golf-course sports land, the housing would create additional demand for local sports facilities with no formal sports mitigation proposed, and changes are needed to the pool design to ensure Equality Act compliance.

England Golf, whose comments are supported by Sport England, says there is no needs assessment demonstrating that the existing standard-length golf provision is surplus to requirements.
The applicant has said its proposed academy, practice and adventure-golf facilities would broaden participation. However, its own Open Space Assessment confirms that the existing course already welcomes pay-and-play visitors as well as members.

Sport England and England Golf’s objection concerns the loss of standard-length golf, rather than whether a different mix of entry-level and leisure-golf activities might attract more visits.

Glyn Williams, a member of Hythe Imperial Golf Club, said:
“Hythe is unusually accessible and affordable, particularly for older golfers because of its flat terrain, while also giving younger players somewhere to learn.

“It is also a proper competitive course. An academy course cannot replace the competitive golf, exercise and social side that the existing course provides.”

The applicant lists both the proposed new hotel pool and nine-hole academy golf course among the scheme’s social and public benefits. Those benefits also form part of the planning balance against the harm identified by Historic England.
But both facilities replace existing provision. The new pool would replace the Hythe Imperial Hotel’s existing swimming facilities, while the academy course would replace the existing standard-length golf offer.

Sport England estimates that the 291 homes could accommodate around 727 to 1,018 people, generating additional demand for sport and recreation. It says no formal sports or recreational provision is proposed specifically to meet that additional demand.

It also says the hotel pool does not mitigate the loss of golf-course sports land, while England Golf says an entry-level academy course does not answer the loss of standard-length golf where that loss has not first been justified.

Meanwhile, Folkestone & Hythe District Council is already progressing a major redevelopment of the council-owned public Hythe Pool. It has GBP 6 million set aside and is developing and costing two options, including a more ambitious redevelopment with new changing facilities, gym and community space.

A GBP 5.5 million Section 106 contribution from Martello Lakes has also been identified as a potential funding source after that site was found unsuitable for a new leisure centre.

Paul Lomax, a volunteer British Swimming judge and parent of two swimmers who compete for Hythe Aqua, said:
“As someone involved in local swimming, what surprised me is how few people realise the council is already progressing a major redevelopment of the council-owned public Hythe Pool, with GBP 6 million set aside and two options now being developed in detail.

“The problem is that the same facilities seem to be counted over and over again. The hotel pool replaces swimming provision that is already there, but is then presented as a major new public benefit. The academy course is the proposed replacement for existing golf, but is also presented as another benefit.

“Meanwhile Sport England says the development itself would create additional demand for sports facilities which is not being formally provided for. You cannot keep counting the same benefit again and again.”

Hythe Save our Seafront hopes the council’s planning officers will recommend rejection of the application in its current form. The group says it would welcome the hotel owners working with the community on less harmful ways to invest in the Hythe Imperial Hotel and spa.

The deadline for public comment is 16, October 2026.

Full application documents and consultation responses can be viewed on Folkestone & Hythe District Council’s planning register under reference 26/1290/FH.

ENDS

NOTES TO EDITORS

HYTHE SAVE OUR SEAFRONT
Hythe Save our Seafront is a community action group of 84 active members, including local residents and members of Hythe Imperial Golf Club.

The group supports appropriate investment in the Hythe Imperial Hotel and improved leisure facilities while opposing the proposed residential development on the adjoining open seafront.

THE ROYAL MILITARY CANAL
The section immediately beside the application site is the 1.06km Scheduled Monument running from Twiss Road Bridge to Seabrook Lodge Bridge in Hythe.

The Royal Military Canal was constructed between 1804 and 1809 as part of Britain’s defences against an expected Napoleonic invasion. Historic England describes it as the only military canal in the country and a unique defensive work.

Historic England’s consultation response describes the section beside the golf course as being of exceptional significance and says the area to its south has remained “remarkably undeveloped”.
Historic England says this section is the only place where it is possible to understand the canal’s form and function, its direct relationship with the sea and its place within the wider system of military defences.

Historic England also says proposed heritage benefits including interpretation and a heritage trail are relatively limited and might partly be delivered independently of the development or through a less harmful proposal.

OPEN SPACE PLANNING PROTECTION
The applicant’s own Open Space Assessment acknowledges that the site is designated “Provision of Open Space” on the council’s planning policy map and that Local Plan Policy C3 safeguards existing open spaces.

Current National Planning Policy Framework Policy HC7 says development should not result in the loss of existing open space, sports and recreational land unless one of specified exceptions is met.
These include demonstrating that land is surplus to requirements, replacing it with equivalent or better provision in quantity and quality with comparable or improved accessibility, or demonstrating that alternative recreational provision clearly outweighs the loss.

The applicant argues that the relevant tests are met. Sport England disputes that conclusion in relation to the golf-course sports land.

LAND RAISING AND FLOOD RISK
The applicant’s Circular Economy Statement identifies a known requirement for 58,606m³ of fill, comprising:
Residential areas: 39,809m³
Residential roads and paths: 14,334m³
Golf building area: 679m³
Golf parking and access: 1,100m³
Swales: 2,684m³

Estimates have not yet been made for all other areas of the masterplan.

58,606m³ is equivalent to approximately 8.2 full-size 105m x 68m football pitches covered one metre deep.

On an illustrative assumption of 10m³ per loaded tipper, the identified fill would represent approximately 5,900 loaded deliveries, or around 11,800 HGV movements if arrivals and departures are counted separately. The application does not specify the period over which these fill deliveries would take place.

The Environment Agency has not objected to the flood-risk strategy. Historic England’s objection concerns a different issue: the heritage effect of the landscape changes required to implement that strategy.

Historic England specifically says those changes would cause harm to the Royal Military Canal even without the proposed buildings.

SPORT ENGLAND AND GOLF
Sport England submitted a non-statutory objection on 18 September 2026. It says the loss of sports land has not been adequately justified or mitigated and that the application fails, in part, to accord with NPPF Policy HC7.

England Golf says that although entry-level facilities such as an academy course have value, the application does not contain a needs assessment demonstrating that the existing standard-length golf provision is surplus. Sport England supports that position.

The applicant’s own Open Space Assessment confirms that the existing course is already open to members, guests and pay-and-play visitors.

It lists full adult membership at Hythe Imperial Golf Club at GBP 895, compared with GBP 1,468 at Sene Valley and GBP 1,404 at Etchinghill, while also recording lower-cost membership categories at Hythe starting from GBP 255.

The existing course is relatively flat and the club participates in competitive golf against other Kent clubs.

PGA AND ENGLAND GOLF
GSE has cited support from the Professional Golfers’ Association for its proposed academy course, which forms part of the applicant’s development scheme.

However, Hythe Save our Seafront has not identified within the application documents any material explaining the information on which that support was based.

It is therefore unclear whether the PGA was asked to consider the proposal specifically in the context of it replacing the existing standard-length golf provision, rather than simply commenting on the merits of the proposed academy concept.

The PGA letter of support states that “Hythe GC [Golf Club]” presented the plans, but plans were presented by the developer, GSE, not the golf club.

By contrast, Sport England specifically consulted England Golf, the national governing body, on the proposed loss of the existing golf provision.
England Golf said there was no needs assessment demonstrating that the standard-length provision was surplus and that, although academy facilities have value, it could not support the application if that loss had not first been justified. Sport England supports that position.

PUBLIC BENEFITS AND ADDITIONAL SPORTS DEMAND
The applicant’s Planning Statement lists the proposed 25m swimming pool and nine-hole academy golf course among the scheme’s social benefits.
Historic England says it will be for the council to decide whether the identified harm to the Royal Military Canal is outweighed by the public benefits secured by the development.

Sport England estimates that the proposed housing could generate a population of between 727 and 1,018 people. It says that population would create additional demand for sports facilities and physical activity opportunities, but that no formal sports or recreational provision is proposed specifically to serve the future residents.

The proposed Hythe Imperial Hotel pool would replace the hotel’s existing pool and leisure facilities.

Sport England says that the pool is on the hotel site rather than the golf-course sports land and therefore does not mitigate the loss of that sports land.

HISTORIC GOLF-COURSE DESIGN
Historic England-commissioned research into golf courses as designed landscapes lists Hythe Imperial Golf Club among the key English courses associated with golf-course architect Philip MacKenzie Ross.

MacKenzie Ross is particularly known for his post-war restoration of Turnberry and was the first president of the British Association of Golf Course Architects.

The Historic England research is available at Golf Courses as Designed Landscapes of Historic Interest.

HYTHE POOL
Folkestone & Hythe District Council has GBP 6 million set aside for work at the council-owned Hythe Pool.

The council is progressing two options through further design and costing. One involves a substantial remodel of the existing building.
The more ambitious option includes a new two-storey extension, modern reception and changing village, gym and community studio.

The council has also identified a GBP 5.5 million Section 106 contribution from the Martello Lakes development as a potential contribution towards improved district sport and leisure facilities, with priority given to Hythe.

The Martello Lakes site itself was considered unsuitable for a new leisure centre because of its limited customer catchment.

SOURCES AND FURTHER INFORMATION

Historic England: Royal Military Canal, Twiss Road Bridge to Seabrook Lodge Bridge

Folkestone & Hythe District Council: Future of swimming pools under spotlight

Folkestone & Hythe District Council Cabinet, 22 July 2026: Hythe Pool refurbishment options

National Planning Policy Framework, Policy HC7

PLANNING APPLICATION
Application: 26/1290/FH
Site:
Hythe Imperial Hotel & Golf Course East & West
Princes Parade
Hythe
Kent
CT21 6AE
The hybrid application includes outline permission for up to 291 homes on part of the existing golf course, alongside proposals for redevelopment of the hotel, leisure facilities and golf provision.

MEDIA CONTACT
Hythe Save our Seafront
Sarah Barnes
0774 0552884
sarahcornes@live.co.uk

MEDIA MATERIALS
High-resolution photographs of the open seafront, Royal Military Canal and golf course, together with relevant application plans and drawings, are available on request.