The RSPB’s preferred spatial growth option would be option SGO 1, as it avoids harmful development close to sensitive wildlife sites on the Hoo Peninsula, in particular Northward Hill SSSI and RSPB nature reserve and Chattenden Woods and Lodge Hill SSSI. However, we would broadly support the Council’s preferred option, option SGO 3, if the potential allocations close to Chattenden Woods and Lodge Hill SSSI and Northward Hill SSSI were removed, due to the likely negative impacts they will have on the designated sites. This includes allocations HHH3, HHH4, HHH6 (at least part of), SR14 and HHH26.

Should the Council select either option SGO 2 or the currently preferred option SGO 3, we consider that a strategic mitigation approach will be absolutely essential in order to protect the Chattenden Woods and Lodge Hill SSSI. A key feature of such a mitigation strategy should be a 400m buffer to prevent net new residential development in the closest proximity to the SSSI. As we have previously advised the Council, developers are unlikely to be able to mitigate urban impacts (in particular cat predation) within this distance of the SSSI. Therefore, housing development in this zone is highly likely to lead to adverse effects on the nightingale population, which will require compensatory habitat to be provided. In line with the ‘mitigation hierarchy’ set out in the NPPF, developments that cannot mitigate their impacts on the SSSI features will need to show there are no less damaging alternatives before they can proceed to the last resort of compensation. Given that the Urban Growth option, SGO1, demonstrates that alternative locations for new housing are available in Medway, we consider that such housing would not comply with the NPPF. Therefore, without a clear policy approach in place for the Chattenden Woods and Lodge Hill SSSI, the draft Medway Local Plan also strongly risks being found unsound due to a failure to comply with the NPPF.