Policy S2: Conservation and Enhancement of the Natural Environment

Please add: Existing nest sites for building-dependent species such as swifts and house martins should be protected, as these endangered red-listed species which are present but declining in Medway return annually to traditional nest sites. Mitigation should be provided if these nest sites cannot be protected.

This is because nesting sites in buildings are excluded from the Biodiversity Net Gain methodology so need their own clear policy.

In summary, please consider endangered urban wildlife such as red-listed bird species which inhabit buildings in Medway.

Therefore, please add to the policy: Swift bricks to be installed in new developments including extensions, in accordance with best practice guidance such as BS 42021 or CIEEM which require at least one swift brick per home on average for each development. Artificial nest cups for house martins may be proposed instead of swift bricks where recommended by an ecologist.

In more detail, the reason for this is that bird boxes/ bricks and other species features are excluded from the DEFRA Biodiversity Net Gain metric, so require their own clear policy.

The Government's response in March 2023 to the 2022 BNG consultation stated that: "We plan to keep species features, like bat and bird boxes, outside the scope of the biodiversity metric... [and] allow local planning authorities to consider what conditions in relation to those features may be appropriate" (page 27, https://consult.defra.gov.uk/defra-net-gain-consultation-team/technicalconsultation_biodiversitymetric/).

Swift bricks are the only type of bird box specifically mentioned as valuable to wildlife in national planning guidance, along with bat boxes and hedgehog highways (NPPG Natural Environment 2019 paragraph 023). The National Model Design Code Part 2 Guidance Notes (2021) also recommends bird bricks (Integrating Habitats section on page 25, and Creating Habitats section on page 26).

Swift bricks are considered a universal nest brick suitable for a wide range of small bird species including swifts, house sparrows and starlings (e.g. see NHBC Foundation: Biodiversity in New Housing Developments (April 2021) Section 8.1 Nest sites for birds, page 42: https://www.nhbcfoundation.org/wp-content/uploads/2021/05/S067-NF89-Biodiversity-in-new-housing-developments_FINAL.pdf ).

Swift bricks are significantly more beneficial than external bird boxes as they are a permanent feature of the building, have zero maintenance requirements, are aesthetically integrated with the design of the building, and have better thermal regulation with future climate change in mind.

Therefore, swift bricks should be included in all developments following best-practice guidance (which is available in BS 42021:2022 and from CIEEM (https://cieem.net/resource/the-swift-a-bird-you-need-to-help/)).

The UK Green Building Council (UKGBC) is a membership-led industry network and they have produced a document entitled: "The Nature Recovery & Climate Resilience Playbook" (Version 1.0, November 2022) https://ukgbc.org/resources/the-nature-recovery-and-climate-resilience-playbook/ This document is designed to empower local authorities and planning officers to enhance climate resilience and better protect nature across their local area, and includes a recommendation (page 77) which reflects guidance throughout this document: "Recommendation: Local planning Authorities should introduce standard planning conditions and policies to deliver low cost/no regret biodiversity enhancement measures in new development as appropriate, such as bee bricks, swift boxes [and bricks] and hedgehog highways."

Many other Local Authorities are including detailed swift brick requirements in their Local Plan, such as Tower Hamlets Local Plan Regulation 18 stage (paragraph 19.70, page 311 - https://talk.towerhamlets.gov.uk/17424/widgets/82097/documents/50138 ),

which follows the exemplary swift brick guidance implemented by Brighton & Hove since 2020,

and Wiltshire Local Plan Regulation 19 stage, which requires an enhanced number of 2 swift bricks per dwelling (policy 88: Biodiversity in the built environment, page 246 - "As a minimum, the following are required within new proposals: 1. integrate integral bird nest bricks (e.g., swift bricks) at a minimum of two per dwelling;" https://www.wiltshire.gov.uk/article/8048/Current-consultation-Reg-19 ),

and Cotswold District Council are proposing three swift bricks per dwelling in their current Local Plan consultation (Policy EN8 item 6, and paragraph 0.8.4, https://www.cotswold.gov.uk/planning-and-building/planning-policy/local-plan-update-and-supporting-information/ ),

so such an enhanced level should also be considered.

It is difficult to see how Medway is preserving the natural environment by building in greenfield sites through the Capstone Valley.

Policy S2 ‘Conservation and Enhancement of the Natural Environment’:- The aspirations of this policy are supported. However, the consideration is inconsistent in relation to site HHH19. It is observed that one of the reasons that site HHH19 is not included for allocation is its perceived proximity to a Site of Special Scientific Interest. However, the following sites are all equidistant or closer in proximity to a Site of Special Scientific Interest around the Hoo Peninsula: - Sites SR14, HHH3, HHH6, HHH4, HHH5, HHH12, SR47, SR48, S459, SR50.

Notwithstanding this point, Site HHH19 provides a wider opportunity to contribute and enhance the natural environment and its networks. The interim Land Availability Assessment for Medway (September 2023) does include an assessment of the site, which recognizes the site does not comprise “Habitats Sites”, Irreplaceable habitat” and was/is therefore capable of delivering 5 or more dwellings and or economic development of over 0.25 ha.

Agree with his policy.

As already mentioned the plan shows absolutely no consideration for the natural environment. The best to do would be to leave the area to create and develop biodiversity natural as in other areas of the country. This plan destroys the natural environment and then proposes a feeble token gesture to try a restore it. You cannot enforce plans on nature you only destroy it. The plan goes against all the ecological evidence of increasing biodiversity and increasing the variety of wildlife species and vegetation. In fact there is no mention of doing this in the plan.

If there's money to be made by developers this will all be forgotten or weakened.

Set a clear strategy for a clean river, for bathing, for sport and for pleasant access. To include nursery areas for fish, no take zones, safe learn to sail areas, with no jet ski risks in the restricted speed areas of the river Medway.

The Council’s pledge to promote the conservation, restoration, and enhancement of priority habitats and species is contradicted by the plan to build in Allhallows. The proposed development will destroy habitats critical to foxes, hares, badgers, and birds of prey. Despite the Council's vision to conserve and strengthen Medway's wildlife sites and nature networks, this plan undermines those goals. Building on green spaces, rather than using brownfield sites, does not align with your goal of conservation and enhancement of the natural environment. How can you claim to value the natural environment while simultaneously planning to destroy vital habitats and green spaces?

If there is ANY impact on the natural habitat then it should not happen. It seems bizarre that there is a way to get around it with mitigation or compensation.

Air Quality should feature prominently and should be measured throughout Medway with results posted on Medway's website (not only Kent Air)

The 10% requirement for diversity is welcome although what it means in practice is not clear.
Local nature reserves need room round them in order to thrive. Building up to their boundaries will reduce their sustainability.
Consideration should be given to sites outside official designations but of importance to local communities to protect green spaces and biodiversity.

BNG needs to be genuine and lasting, not a tick-box requirement - a genuine desire by the developer to improve our existence.
In a planning application which used kilometres of new hedgerow as part of the mitigation, the majority of the whips died within a year and have not been replaced. What teeth does the Council have should such mitigations be a temporary show?
We all need to be genuinely working towards replacing the biodiversity which has been lost. I would like to see KCC's Viability Study recommendations to implement 20% BNG put in place.

While accepting that Medway needs to develop areas of new housing, it is important to confine these to urban and brownfield sites without encroaching further into rural areas already lacking in local amenities.
Business owners, such as Silverhand must not be allowed to create a winery on AONB and Metropolitan Greenbelt land. It is a vanity project and is totally unnecessary and in an unsuitable location. It would be much more suitable in an area such as Medway City Estate.
I cannot stress how important it is to retain the peace and tranquility of our natural landscape and environment.

Fully agree

A simple influx of people to an area has a negative effect on SPA / Ramsar sites due to the recreational activities and most notably dog walking. Developments ideally should be as far from these protected sites as possible and not build on arable land. We lack food security as it is and building on farmland is wholly irresponsible.

I disagree with the strategy for developments compensating loss of environments, habitats, and biodiverse areas. We have already seen the marring of sites like these which have been passed with "mitigations and compensations" which prioritise development over our already struggling eco systems, further S106 money is not a suitable compensation.

I strongly endorse this policy

After much consideration option 3 for planning proposal is favourable. As transportation for Medway areas , would creating and using a River Medway bus service connecting the Medway areas be an option to consider . Infrastructure in Medway must be considered due to possibly future flood risks. Medway needs to have replaced outdated water/drainage sewerage systems before the future of housing is built. Alongside recreational facilities and services needed to accommodate a rising population level in Medway towns/areas. More importantly its the environment green spaces /nature reserves for all to benefit living in Medway Towns.