Medway Local Plan (Regulation 19, 2025)

Support

Representation ID: 4570

Received: 07/08/2025

Respondent: RSPB England

The RSPB welcomes the inclusion of the following text in the Vision, recognising the need to connect, protect and enhance ecologically important areas and networks, and linking it with the Local Nature Recovery Strategy aims:

The countryside, coast and the urban open spaces are valued and benefit as joined up environmental assets in a resilient green and blue infrastructure network across land and water. Important wildlife and heritage assets are protected and enhanced, contributing to the Local Nature Recovery Strategy.

We welcome the Vision’s overarching aims to deliver enhanced biodiversity, in part by ensuring new development is in sustainable locations

Support

Representation ID: 4571

Received: 07/08/2025

Respondent: RSPB England

The RSPB welcomes that the Council policy embraces the Local Nature Recovery Strategy, Making Space for Nature in Kent and Medway, as an important evidence base to inform implementation of the Local Plan and for identifying priorities for nature, areas of importance and areas of opportunity.

Support

Representation ID: 4572

Received: 07/08/2025

Respondent: RSPB England

We welcome the following clarity about enhanced mitigation measures needed for developments close to designated sites, and functionally linked land. We have suggested a slight change to wording.

Support

Representation ID: 4573

Received: 07/08/2025

Respondent: RSPB England

We welcome that the Council will be looking to incorporate the LNRS guidance to enhance and develop the green and blue infrastructure and ecological corridors: This work will be further developed following publication of the Kent and Medway Local Nature Recovery Strategy.

Support

Representation ID: 4574

Received: 07/08/2025

Respondent: RSPB England

The RSPB supports Medway’s efforts to connect ecologically important sites, reflecting the ‘bigger, better and more joined-up’ Lawton Principles. These corridors should be given a status to support appropriately creating, restoring and maintaining them. This framework should look strategically to factor in potential disturbance impacts and include functionally linked land, and to help protect and enhance sites such as Chattenden Woods and Lodge Hill SSSI. The RSPB welcomes that the framework will be further fine-tuned in accordance with the Local Nature Recovery Strategy. Proposed ecological corridors and priority habitat enhancement must tally with key areas identified within the LNRS.

Object

Representation ID: 4576

Received: 07/08/2025

Respondent: RSPB England

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The RSPB remains seriously concerned that new residential development within 400m of the SSSI could have an adverse effect on the nationally important breeding Nightingale population that forms a key interest feature of Lodge Hill SSSI. Experience from elsewhere suggests that, for species such as Nightingales that nest on/low to the ground, acute urbanisation impacts (including cat predation and recreational disturbance) are unlikely to be mitigable where new housing is located in close proximity to breeding sites. In addition to the lack of a clear policy approach for the SSSI, we have concerns about two of the proposed allocation sites.

Object

Representation ID: 4577

Received: 07/08/2025

Respondent: RSPB England

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In accordance with our position that clear policy wording should be contained in the new Medway Local Plan in order to robustly protect the interest features of the Chattenden Woods and Lodge Hill SSSI, we have concerns about one of the proposed allocation sites listed under Policies SA11, which lies largely within 400m of the SSSI. We are unable to recommend additional policy safeguards to ensure that the following proposed allocation avoids or effectively mitigates potential harmful urban pressures on the SSSI Nightingale population and therefore we object to the following allocation:

SR14 Land south of View Road, Cliffe Woods

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: 4579

Received: 07/08/2025

Respondent: RSPB England

The RSPB considers that Bird Wise SAMMS reflects the current best available evidence on how to address in combination impacts from recreational disturbance from increased residential development close to coastal SPA/Ramsar/SSSI. For sites that may have an impact on these sites on their own due to proximity or size it is important that they may need to deliver additional bespoke mitigation plus the SAMMS contribution. There is a need to better understand functionally linked land and how this network of sites support the SPA. The findings of the SPA Review should be referenced in policy. Site SR51 is of concern.

Object

Representation ID: 4580

Received: 07/08/2025

Respondent: RSPB England

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

HHH26, is close to High Halstow National Nature Reserve (NNR) and to Northward Hill RSPB reserve and SSSI. We consider this creates a high risk of additional urbanisation pressures on the sensitive wildlife within the site (as well as on the RSPB’s ability to manage the site), in the form of increased recreational disturbance from people, including dog walking, vandalism and other urban impacts.

We would therefore recommend additional policy wording to recognise that appropriate mitigation will be essential to address the impacts on the SSSI.