Medway Local Plan (Regulation 18, 2023)

The RSPB understands the pressures of national targets on housebuilding in Medway, and that the HIF funding has been revoked, requiring the Council to re-examine a broad range of potential locations for development across the area. This includes assessing what level of housing can be sustainably delivered across the Hoo Peninsula given the impact of the withdrawal of this infrastructure funding. We believe this is an opportunity to reassess development needs and options and to ensure development is located in the most sustainable locations, to establish a truly sustainable strategy for the long term. We welcome the steps the Council has taken to reassess potential development sites via the Stage 1 Land Availability Assessment (LAA), the broad results of which are presented in the draft local plan consultation. It is critical that a Sustainability Appraisal (SA) of these sites is undertaken (individually and cumulatively) in order to properly understand the relative impacts of new development in the broad locations shown. This would require an evidence base for site allocation. We have serious concerns that this updated SA is not yet available for review. Given the Government guidance on the need for the SA to be undertaken iteratively and to allow assessment of reasonable alternatives to any preferred option, we anticipate that the Council will need to undertake a further consultation including this important assessment work ahead of the Reg 19 consultation, to avoid risks of the final submission draft being found unsound. We request confirmation of the Council’s intention to carry out a consultation on a revised SA well in advance of a future Reg 19 consultation.

Urban regeneration also brings opportunities to improve biodiversity. These could include mandatory swift bricks for all new buildings of two storeys or higher (apart from rare exceptions), SUDS pond/drainage schemes, native and locally-sourced planting or natural regeneration where appropriate, allowing less managed areas in places with paths through and edges trimmed to show they are deliberate, planning around green spaces, connecting through green corridors, limiting light pollution, and making these aims clear in policy wording. The importance of wildlife and green spaces to human wellbeing should be recognised and also that some brownfield sites can be biodiverse.

The RSPB considers that any increase in development, especially residential, close to the Special Protection Areas/Ramsar/SSSI must show that the corresponding increase in recreational disturbance pressures on the site and its waterbird assemblage and designated features must be fully assessed and mitigated, and this may not necessarily be possible simply through RAMS contributions.

The RSPB would like to see 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 residential units would be added. This buffer zone, designed to ensure the nightingales are protected, has been our consistent position for many years and is based on the best available evidence from comparable situations elsewhere, such as the Thames Basin Heaths. The RSPB’s primary concerns relate to indirect impacts of cat predation and recreational disturbance impacting nightingales on the SSSI and the direct loss of undesignated scrub which supports breeding nightingale. This strategic and landscape-scale approach would be an effective, sustainable, coherent and readily implementable policy approach that allows necessary development to continue to come forward in the wider area, while protecting the vulnerable, nationally important nightingale population. Crucially, it would offer clarity for developers and protect Medway Council from a deluge of applications for inappropriate development.

Given suitable light pollution controls and other wildlife-friendly designs, the RSPB is not necessarily opposed to non-residential development within 400m of the SSSI. For example, site HHH1 is proposed for non-residential development, and we would therefore not object to this scheme in principle should it progress, although we would still need to examine the details of any application to understand its potential impacts on the SSSI. Developers may need to coordinate their plans to adjust for the buffer zone. This could also be done within large allocations that partly overlap the 400m buffer: the closer areas could be for non-residential, with those parts of the allocated site that are beyond 400 metres allocated for housing. This clear policy would help ensure the protection and conservation of Chattenden Woods and Lodge Hill SSSI for the future.

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.

We have looked at all of the HHH prefix sites around Chattenden Woods and Lodge Hill Site of Special Scientific Interest (SSSI) that are partly or entirely in close proximity to the 400m buffer that the RSPB considers necessary to protect the nightingales for which the SSSI is designated. If all the current potential sites, such as HHH3, HHH6, HHH7 and HHH14, were to be taken forward, this would place around 1,500-2,500 new houses within 400m of the SSSI, which would create a permanent threat to the nightingale population by placing a population of 3,600-6,000 people within the immediate area, with c26% of the new households owning at least one cat i.e. this would represent the unsustainable potential addition of over 500 cats to the immediate vicinity of the SSSI and the nightingale population, i.e. within 400 metres. We consider that the revised SA required needs to recognise the impacts of these sites individually and cumulatively on the SSSI, and only those that can be effectively mitigated should be taken forward to the Reg 19 draft.

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. There also a few other smaller sites with the HHH prefix identified which are close to these designated sites that will likely add to the recreational pressure. 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 until measures can be identified that would ensure the effective protection of the Northward Hill SSSI, High Halstow NNR, and other wildlife interests in the area.

The land to the SE of Cliffe Pools, Site SR6 – potentially up to 600 homes (Form Submission 167, p.840) - 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 RAMS/Birdwise due to proximity and numbers. We also note SR2 landfill waste (Form Submission 194, p.826) - we would need to see evidence from the Council to demonstrate that harmful impacts could be avoided or adequately mitigated before the site is put forward for allocation. The revised SA should address both of these sites and their potential impacts on the SPA/Ramsar site.

There are several possible allocations to the south of Riverside Country Park where the RSPB has concerns regarding cumulative recreational disturbance impacts that may not be mitigable through RAMS/Birdwise. The RSPB is particularly concerned about site RN26 (Form submission ID: 185, p.651) for housing near Riverside Country Park as it is immediately adjacent to Nor Marsh and Motney Hill RSPB reserve and within Medway Estuary and Marshes SPA, Ramsar and SSSI. This development would have potentially serious impacts on the reserve and its waterbird assemblage through increased recreational disturbance.

Potential site allocations RN 1-10 and RN16, RN21 are close to Riverside Country Park and Nor Marsh and Motney Hill RSPB reserve – in combination, the recreational pressures on the coastal habitats and waterbird population from dog-walkers and visitors would be considerable and difficult to mitigate and we would need to see evidence from the Council to demonstrate that harmful impacts could be avoided or adequately mitigated before these sites are put forward for allocation.