12 June 2020

A letter of objection to planning proposal 18/506460/FULL: Erection of 24 dwellings together with associated infrastructure, open space, landscaping, access works and bird viewing tower.

I am writing with my OBJECTION to the planning application ref. 18/506460/FULL

The application site is directly adjacent to the Swale SPA/Ramsar/SSSI. KCC Ecological Advice Service report states that among “at least 41 species of confirmed, probably or possible breeding birds recorded”, the Nightingale, Cetti’s Warbler and the Turtle Dove were recorded.

There were also 434 species of invertebrate, evidence of watervole, 7 species of foraging/commuting bat, common lizard, grass snake and slow worms recorded on the site.

As outlined in the KCC ecological report, the air, noise and light pollution created during the construction and use as a residential development will have a significant negative effect on this unique habitat.

In the Swale Landscape & Biodiversity Appraisal, the guidelines given for the Luddenham & Conyer Marshes are to “Conserve the undeveloped and distinctive Character of the marshland, to maintain the integrity of the wider North Kent Marshes” and to “Conserve the distinctive maritime exposed and remote landscape character around the marsh…”

I respectfully ask that due consideration is taken to this guidance, as well as the Swale Borough Local Plan and NPPF. Priority should not be given to supply of luxury housing, when rare and important habitats are put at risk. The Swale Borough Local Plan states that planning approval is subject to:

DM 22: The Coast:

2. “The protection, enhancement or management as appropriate of biodiversity, landscape, seascape and coastal processes”

3. “Enabling wildlife to adapt to the effects of climate change, contributing towards the Local Plan’s Natural Assets and Green Infrastructure Plan..”

DM 24: Conserving and enhancing valued landscapes

2.1 “conservation and enhancement of the landscape being demonstrated”
2.2 “avoidance, minimisation and mitigation of adverse landscape impacts as appropriate and, when significant adverse impacts remain, that the social and or economic benefits of the proposal significantly and demonstrably outweigh harm to the Kent or Swale level landscape value of the designation concerned”.

The social benefits of providing affordable housing has gone because this element of the application has already been removed; the applicant is now requesting the removal of the element of “mitigation of adverse landscape impacts”.

Through removal of both the social benefit and the mitigation of adverse impact on the environment, this application no longer conforms to the requirements of the Swale Borough Local Plan or NPPF. It should, therefore, be refused.

Swale Borough Council last year declared a Climate and Ecological Emergency; and I hope that they will demonstrate their commitment to this by giving due consideration to planning policy that protects and enhances the environment.

Miriam Layton

(You can find and comment on the application by searching for application no. 18/506460/FULL here: https://pa.midkent.gov.uk/online-applications/ before 24 June 2020 )

The KCC ecology report can be found here.


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