Lodge Hill, part of a newly-expanded Site of Special Scientific Interest, is a proposed major development site on the Hoo Peninsula in Medway. The site supports approximately 1.3% of the national nightingale population as well as a wide variety of other scarce, declining and protected wildlife.
After a number of timetable changes the Inquiry has now been set for June 2016. Between now and then there are a number of stages. The first will be submissions of Statement of Case, where each party sets out the arguments they are going to make and the documents they will be refering to. After that, all parties agree a 'Statement of Common Ground', where they set out the bits they all agree on and that do not have to be examined at the Inquiry. Before the Inquiry itself, all parties submit Proofs of Evidence, which set out their full case. This will be supported by expert witnesses, and cross-examined, at the Inquiry.
Kent Wildlife Trust have registered as a 'Rule 6 party' in the Lodge Hill Inquiry. This means we will play a major role in determining timetables and presenting evidence. We will be doing this alongside the RSPB, Medway Countryside Forum and Natural England.
We are currently organising our case.
On 13th February 2015 The Secretary of State decided to call-in the Lodge Hill planning application. Kent Wildlife Trust welcomed this common-sense decision.
This means that the planning application and the issues surrounding it will be examined at a Public Inquiry, overseen by an independent planning inspector. A recommendation will then be made to the Secretary of State, who will then decide whether the planning permission stands, or is quashed.
On the evening of Thursday 4th September, Medway Council’s Planning Committee voted unanimously to approve a planning application to build up to 5,000 houses at Lodge Hill, one of the most important wildlife sites in the Country.
The same week that Medway Council leader Cllr Rodney Chambers decried the Thames Estuary Airport proposals because it would have “…resulted in the mass destruction of habitat and wildlife that could never be replaced” the Council have approved a development which will result in the mass destruction of habitat and wildlife that can never be replaced. The Council’s U-turn regarding the environment is extremely disappointing.
In making their decision, the Committee disregarded advice from experts such as Kent Wildlife Trust and the RSPB – the same organisations that they relied upon to help them fight Estuary Airport proposals. They also chose to ignore the views of the Government’s statutory nature conservation advisors, Natural England, and many others.
Kent Wildlife Trust were present at the meeting, but Council rules prevented us from speaking. In our opinion, the Committee misinterpreted the National Planning Policy Framework, and failed to take into account relevant statements regarding the site made by an Independent Planning Inspector.
Kent Wildlife Trust’s long standing offer to the Council to work with them in their search for a sustainable solution to their housing and employment needs still stands, but we will be asking the Secretary of State to ‘call in’ this decision, so the issues can be examined by an independent planning inspector, free of local politics and misinformation.
Despite confirmation of the site as a Site of Special Scientific Interest, the Ministry of Defence (contrary to their statutory obligations) and developer Land Securities have failed to withdraw this destructive planning application. We are encouraging people to object to this application to try and save this Nationally important area, and hope that Medway Council fulfil their duty to look after the environment, comply with the National Planning Polcy Framework, and refuse the application.
There are many reasons for Medway to refuse this development - not least of which is that this wonderful wildlife site should be protected for the people of Medway and the UK, and not destroyed owing to pressure from developers. We remain willing to help Medway find a sustainable location for their housing and employment needs, as we always have done, but Lodge Hill is the worst possible place. Providing habitat for nightingales off site has been proven unfeasible, and the proposing to locate habitat in Essex is absurd.
The development site is adjacent to large areas of ancient woodland, much of which was designated as a Site of Special Scientific Interest (Chattenden Woods) in 1984. The site itself, alongside the more ‘urban’ elements of the training areas, and areas of intensive grassland, contains an extensive mosaic of habitats, including large areas of neutral grassland and scattered and dense scrub. It has long been known as an important area for wildlife.
Medway Council’s Core Strategy (Local Plan) proposes five thousand houses for Lodge Hill. Kent Wildlife Trust, knowing the history of wildlife on the site and also that current information was limited, did not believe that that many houses could be delivered without huge impacts on wildlife, and requested that the number of houses be determined by what could be delivered sustainably (i.e. without impacts on wildlife).
At around the same time this was happening, an outline planning application for the site, for ‘up to 5,000 houses’ was submitted. From the limited ecological survey work undertaken, it was fairly clear that the wildlife value of the site was far higher than anyone had expected, and that those features for which the adjacent Chattenden Woods SSSI was notified were also present in the development site, particularly nightingales.
The biodiversity value of the site is extensive:
- Bat roosts present in 19 structures, and several species of bat foraging on site. The site is likely to be of at least county importance for bats.
- Populations of great crested newts, toads, lizards, slow worms, grass snakes and adders. The site is at least of county importance for reptiles.
- A wide range of breeding birds across the site.
- A number of badger setts present.
- The large areas of neutral grassland and other habitats is likely to support a good invertebrate fauna, and itslef is a declining habitat. Unfortunately adequate invertebrate and botanical surveys were not undertaken.
Kent Wildlife Trust objected to this planning application on a number of grounds, including low quality ecological surveys and inadequate mitigation of both direct and indirect impacts on wildlife. Owing to the problems encountered during the Examination of Medway’s Core Strategy (see below), a decision has yet to be made on this application.
In July 2012, during the ‘Examination in Public’ stage of the Core Strategy examination, British Trust for Ornithology survey data for nightingales became available. This showed not only that there were more nightingales in the area than was previously thought, but that the numbers present were likely to be nationally important, and that a significant proportion of these nightingales were on the development site, moreso than in the adjacent SSSI ancient woodland. Kent Wildlife Trust objected outright to the allocation of the site for housing.
Since that time, Medway Council and its consultants has gone through a process, including engagement with Kent Wildlife Trust, the RSPB and BTO, to complete the task set by the inspector responsible for examining the local plan. The task was to establish whether there is a reasonable prospect that adequate compensatory habitat could be established to reduce the residual impact of the development. The Council contracted the Environment Bank Ltd to apply ‘Biodiversity Offsetting’ to the proposals, and the resulting report came to the conclusion that around 650 hectares of habitat restoration or creation would compensate for the loss of the nightingale habitat at Lodge Hill, and that there is a reasonable prospect that this can be achieved in Kent. Kent Wildlife Trust’s extensive experience of ecology, habitat management, restoration and creation tells us this conclusion is wrong and we remain strongly opposed to development at Lodge Hill.
Regardless of the technical problems with mitigation impacts upon wildlife in this case, there is also a principle at stake. That is that nationally important wildlife sites should not be allocated for development. This principle is enshrined in National Planning Policy and legislation. The importance of such sites is recognised in the legislation governing Sites of Special Scientific Interest, and therefore Natural England has a duty to consider the designation of Lodge Hill as a SSSI (in this case, extending the adjacent SSSI to cover the development site, as they are ecologically connected).
Kent Wildlife Trust recognises the need for hounsing and jobs, but believes that these should be delivered without damaging the environment, which plays an important role in enhancing quality of life and supporting the economy. We believe Medway Council should protect the environment, and examine the alternative developent options that are available to them.
Chattenden Woods and Lodge Hill Site of Special Scientific Interest
Natural England notified the development site and existing SSSI as a new SSSI on the 13th March 2013 and confirmed this notofication in November 2013. The features for which the site is notified are ancient woodland, neutral grassland and the nightingale population. Subsequently, Medway Council withdrew their Core Strategy and have started work on a new one.