Policy S2: Conservation and Enhancement of the Natural Environment

Support

Representation ID: 4535

Received: 05/08/2025

Respondent: Ms Georgina Kosanovic

Although I support the idea that development is only allowed if it increases biodiversity, I don't think that it is possible, when adding 24,000+ new homes, which will include a huge increase in traffic, and the disruption through construction of current patterns of use of Medway by wildlife, both flora and fauna. Animals, especially, cannot adjust easily or at all to huge and sudden changes in their habitats, pathways to mates, nests/dens, food sources, etc.

Object

Representation ID: 4578

Received: 07/08/2025

Respondent: RSPB England

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We welcome references to a strategic, partnership-based approach, including acknowledgement of the importance of conserving and enhancing Chattenden Woods and Lodge Hill SSSI and Medway Estuary and Marshes SPA/ Ramsar/SSSI, as well as the need for buffers. We suggest altering the wording to be clearer.

We welcome support for the LNRS and BNG.

The RSPB urges a strategic approach to protecting the Chattenden Woods and Lodge Hill SSSI and its nationally important Nightingale population, including a 400m buffer around the SSSI, within which no net new residential units would be permitted.

Support

Representation ID: 4593

Received: 08/08/2025

Respondent: Ms Bridget Fox (Woodland Trust)

We generally support this policy in particular the wording recognising Ancient Woodland as an irreplaceable habitat and the integration with the emerging Kent and Medway Local Nature Recovery Strategy.

We recommend setting a 20% BNG target where appropriate, eg for strategic and/or greenfield sites. By setting a more ambitious target, the Local Plan increases the chances that an average net gain of at least 10% will be delivered across the Medway area, given the possibility that some sites may not be able to deliver net gain onsite or that BNG projects may fall short in practice.

Object

Representation ID: 4622

Received: 08/08/2025

Respondent: CPRE Kent

Agent: Mr Richard Thompson

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy should be amended to make reference to dark skies and tranquillity.

Object

Representation ID: 4764

Received: 10/08/2025

Respondent: Kent Downs AONB Unit

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Request BNG requirement of 20% in line with Principle BD9 of the adopted AONB Management Plan 2021 - 26. In particular we wish to see a BNG requirement of 20% for the strategic allocations at Strood West (SA6) and Capstone Valley (SA7)

Object

Representation ID: 4802

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Inconsistency with National Policy (NPPF)
Chapter 4’s policies fail to meet the requirements of the National Planning Policy Framework (NPPF), including:

Paragraphs 179–182, which require proactive and precautionary approaches to biodiversity protection and net gain.
Paragraph 186, requiring planning policies to “enhance the natural and local environment”.
Paragraphs 20 and 35, which require strategic policies to be deliverable, justified and effective.

The Plan also lacks adequate provisions for urban greening, air quality protection, and integrated green-blue infrastructure in line with government guidance.

Object

Representation ID: 4890

Received: 11/08/2025

Respondent: Swifts Local Network: Swifts & Planning Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The policy is welcome in principle but it is not sound as it is not consistent with national policy, specifically NPPG Natural Environment 2025 paragraph 017, which recommends at least one swift brick per dwelling on average for new developments. The Kent LNRS will focus on areas of habitat for Biodiversity Net Gain rather than species features such as swift bricks, so references to the LNRS can't be relied on to be effective.