The RSPB urges the implementation of a strategic approach to protecting Chattenden Woods and Lodge Hill SSSI with protection of the existing nightingale population as a key objective, including the stipulation of a default minimum 400m buffer around Chattenden Woods and Lodge Hill SSSI within which no net new residential units would be permitted. Nightingales are a key reason why the SSSI is designated. This buffer zone has been our consistent position for many years and is based on the best available evidence from comparable situations regarding urbanisation effects elsewhere, such as the Thames Basin Heaths. Unless robust new evidence is forthcoming to demonstrate that the SSSI and its nightingale population can be effectively and sustainably protected from the long-term, insidious impacts of urbanisation, alternative sites must be identified for the relatively small quantity of new housing being considered in this zone. Instead, these sites could be considered for green infrastructure or non-residential development which would safeguard the nightingale populations in perpetuity and support local communities.

In accordance with the National Planning Policy Framework (NPPF) paragraphs 179 and 180, it is our view that there should be a strategy created to incorporate a buffer zone (applicable to residential development) of at least 400 metres around the length of the SSSI’s boundary in order to avoid likely harm. This distance is based on our understanding of the available scientific evidence of cat roaming distances and the acceptance by decision-makers that it is generally not possible to mitigate the acute impacts of housing located in such close proximity to the protected sites. In addition, it would reduce a number of other well-documented urban effects, including recreational disturbance (where access to the SSSI allows), noise, artificial light and uncontrolled fires. This clear policy would help ensure the protection and conservation of Chattenden Woods and Lodge Hill SSSI for the future and would also be consistent with Policy S5 in the Regulation 18 plan, in that: a high level of protection from damaging impacts of development will be given to Sites of Special Scientific Interest and Ancient Woodland.

Without a robust strategy in place, the Council can expect more housing developments coming forward around the SSSI with unevidenced, untested and/or unenforceable mitigation, such as the pet covenants which have controversially been agreed as part of the Cliffe Woods development, despite the lack of evidence or mechanism for enforcement. We find it difficult to understand how the proposed allocation sites around the SSSI can be justified given the clear alternative, less damaging locations for this quantum of housing, or why less impactful non-residential uses are not instead being considered for these sites. Crucially, such a strategy would offer clarity for developers and protect Medway Council from a further applications for inappropriate and unplanned development, and the challenge for those developers to show there are no less damaging options available to them. For example, the recent developer appeal for housing at Lodge Hill Lane alongside the SSSI that was turned down in March by the Planning Inspectorate, in which the RSPB fully supported Medway Council’s initial refusal on the grounds of unmitigated damage to the nightingale population. This is a case where a clear Council strategy would have helped.

The RSPB is keen to see the wildlife interest of the SSSI and other sites promoted and celebrated as a positive asset that will boost pride in the area, as opposed to the notoriety of losing the country’s most important site for nightingales if these concerns are not heeded.

BNG: Canterbury City Council has an aim of 20% and Medway could be ambitious and aim for 20%, which would prove better value for money. We are in a biodiversity crisis and therefore we would encourage the Council to be ambitious in measures to help address issues threating biodiversity, including habitat loss and to restore nature’ give the high number of priority species and designated nature sites across the Medway area.

Northward Hill/High Halstow:
A large site identified in High Halstow at Britannia Road, HHH26, is close to High Halstow National Nature Reserve (NNR) and in close proximity to Northward Hill RSPB reserve and SSSI. We consider this creates extra pressures on the wildlife and the maintenance of the site, in the form of increased recreational disturbance from people, including dog walking, vandalism and other urban impacts. The RSPB has not yet been able to agree a suitable mitigation strategy with the applicant of the Britannia Road site and we would therefore caution allocation of this and other sites in the area. If progressed, policy wording will need to added to ensure these impacts are appropriately assessed and mitigation designed to address and appropriately protect these sites.