Policy S2: Conservation and Enhancement of the Natural Environment

Medway has a number of areas of natural and scientific importance and development must be kept well clear of those areas. We need to link in with the National plans and ring fence those areas. I have noticed the diversity of wild flowers and areas where nature has been allowed to flourish encouraging more butterflies and moths and giving valuable green spaces alongside some of our busiest roads. We need to encourage more home owners to have space for nature whether it’s pots and window boxes or digging up driveway’s to revert to gardens. Maybe Medway Garden competition again.

Providing access to nature should be achieved by protecting and enhancing the areas of nature we have left. Sadly, all of your plans include a loss of nature and countryside. Not just any countryside, but beautiful countryside of rolling hills and valleys that are a continuation of the Downs.
Building houses and then just adding some cycle paths and small green areas is insulting compared to the few pockets of countryside we have left and enjoy. It is essential for our wellbeing.
Medway is a small borough and has little space left for building, unless building upwards.

Support. Developer contributions should be used to enhance and protect these features. Re dev of paths, river clean up etc.

Adverse site impact should consider connectivity of habitats and make sure these are not lost.

Medway has an inordinate number of conservation areas in the towns.
Plus the former golf range now a park, with no future development of the Army site near Hoo
due to protected birds, development will remain difficult.

I agree with the principles laid out here, but would push for the council to require ecological assessment at multiple points in the year. While animal activity is more commonly found throughout the year, many plants are only visible at certain times (especially orchids, the Lady orchid being one of the priority species) and so can be easily missed if a survey is completed in winter or late autumn.

More trees need to be planted in urban areas in order to encourage more wildlife as well as the cooling effect trees bring. They can also be used to help with flood management and erosion.

I accept all of this the most important aspect must be to avoid businessess profiteering from using such land

It would be nice to have a city farm somewhere in Medway to foster love & respect for animals and nature.

Affirm this policy

Agree the Natural Environment needs to be protected particularly AONB and Green Belt is not eroded further!

Policy S2 ‘Conservation and Enhancement of the Natural Environment’:- The aspirations of this policy are supported. The redevelopment of The Depot site provides an opportunity to contribute and enhance the natural environment and its networks in accordance with the policy wording. As set out in the response to section 2.3, the HHH41 site only has limited biodiversity value at the current time, and the redevelopment of the site provides an opportunity for positive biodiversity and habitat improvement.

"Development proposals must demonstrate their contribution and enhancement of the natural environment and provide a measurable net gain of 10% in biodiversity". FoRC are interested to know how Medway Council will effectively and accurately MEASURE this, and over what period.

Binney marshes have an area that is closed off part of the year due to nesting birds. This is yards away from the proposed building. Not only birds but hares badgers greater crested newts frogs There are also several horses. Will there be a duty of care for these animals? Also stupid ideas like filling ditches with weeds so they look aesthetically pleasing just adds to the flooding!

Wildlife assets need to be more joined up - with green corridors, not just isolated "islands" rich in biodiversity. Mammals, amphibians and reptiles need to be able to traverse the countryside in order to breed. Development, particularly housing has a negative effect - not just by the loss of land that may be rich in wildlife, but an increase in people will negatively impact on the environment - more people means more disturbance. River and estuary use has to be done in a way that does not cause disturbance, particularly to water birds, whether they are feeding, breeding or roosting.

I support Policy S2, but nature and the environment must come first. We are the most nature depleted country in Europe and we have a unique opportunity to lead nature recovery in England. We need more green and wildlife friendly linkages between sites to enable mammals, amphibians and reptiles to travel from one site to another in order to capitalise on the biggest gene pool possible. To avoid in-breeding, we don't want just isolated "pockets" of biodiversity, but need them to be more joined up.

In response to Q2

CPRE Kent welcomes policies which prioritise the natural environment and its biodiversity. As such we support the Council going beyond 10% BNG.

As set out in paragraph 4.3.7 of the Plan, a KCC commissioned study (Viability Assessment of BNG in Kent, 2022) found that an uplift from 10% to 15 or 20% would not materially affect viability.

Any construction work that takes place will drive away any wildlife from those areas, you can put in all the bat boxes you want etc. It won't bring them back to the area

Our client objects to the proposal to go beyond the statutory minimum 10% increase in BNG. Brownfield sites such as the Grays site have higher abnormal costs, and delivering biodiversity net gain above the statutory minimum requirement would place an unreasonable burden potentially causing viability difficulties for brownfield sites. It is above the legal requirements set out in the Environment Act which came into effect in February 2024 for major developments.

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.

Agree

Our client objects to the proposal to go beyond the statutory minimum 10% increase in BNG. Brownfield sites such as the Morgan Timber site have higher abnormal costs, and delivering biodiversity net gain above the statutory minimum requirement would place an unreasonable burden potentially causing viability difficulties for brownfield sites. It is above the legal requirements set out in the Environment Act which came into effect in February 2024 for major developments.

This policy cannot work such is the scale of the development. So much woodland, farmland, wildlife will be destroyed that no amount of carbon sequestration or drainage systems can make up for the negative impact on the environment.

How will the Council ensure BNGs of 10%+ are met? What happens to developers if it isn’t? Nothing. What’s happened with the new housing estates at Hoo? Did they have to make assessments of BNG before and after each housing estate was built? How have they measured the 10% BNG for each new estate? Was a BNG of 10% or more demonstrated?

We fully support the council's intention to provide a high level of protection for natural habitats and native species. However, it is important to strengthen this protection and to ensure that it is not diminished by "net biodiversity gains". Gains in other areas do not compensate for damage or loss of habitats associated with existing species. It is more important to protect existing species than to obtain net gains by "greenwashing".

Developers have destroyed so much.
They plant cheaper poor quality trees in so called green spaces and then walk away and allow them to die.
Natural environment is WITHOUT houses. Anything put in by developement is NOT NATURAL.

The singular failure of existing planning policies to protect and enhance special natural environments can be seen on the Hoo Peninsula.
Ratly Hills Wood, Berry Court Wood and Great Chattenden Wood form a tiny remnant of ancient woodland on the Hoo Peninsula. Instead of protecting this jewel of nature the LPA, since the 1960s, has been methodically nibbling away at the woods to provide space for housing, never protecting this irreplaceable asset. This ancient woodland should have been surrounded by a huge buffer zone ( of the order of Kilometres) which could have provided land for natural regeneration.

Dont build in rural areas as in option 2/3. This would have irreversible damage caused to the local eco systems and animals etc

if thats your policy are are you building on the Hoo peninsula

Promotion of technology to reduce the land use of agricultural allowing more land to be turned back to nature for promotion of biodiversity and climate mitigation

Policy S2 ‘Conservation and Enhancement of the Natural Environment’:- The aspirations of this policy are supported. The development of sites AS14, AS15 and AS17 provides a wider opportunity to contribute and enhance the natural environment and its network in accordance with the policy wording.