The RSPB considers that the Bird Wise SAMMS reflects the current best available evidence on how to address in combination impacts from recreational disturbance as a result of increased residential development close to the coastal Special Protection Areas/Ramsar/SSSI. This strategy includes monitoring to ensure that this approach continues to be effective and the Local Plan should ensure that it supports this strategy and any future updates. For sites that may have an impact on these sites on their own due to proximity or size it is important that they may need to deliver additional mitigation plus the SAMMS contribution. Therefore, we are pleased to see acknowledgement of the importance of functionally linked land and we agree with the statement All new development which is located within close proximity to the North Kent Estuary and Marshes designated sites (listed above) may also need to provide further mitigation measures to address urbanisation impacts.
The land allocated for potential housing to the SE of Cliffe Pools, Site SR6, raises concerns of exacerbating recreational disturbance impacts to RSPB Cliffe Pools (part of the Thames Estuary and Marshes SPA/Ramsar site) that may not be mitigable through Bird Wise contributions alone due to proximity and scale of the housing. We urge that evidence is sort to demonstrate that harmful impacts from recreational disturbance could be avoided or adequately mitigated before the site is put forward for allocation. There must be policy here to include further assessment to inform robust mitigation measures, in addition to the SAMMS.