This additional allocation does not appear to affect any locally designated sites in the immediate area. However, we have been contacted by a concerned resident regarding the site. They state that this site has considerable bird interest, including skylark in the breeding season. Appropriate bird breeding survey must be carried out at this site prior to any approvals and adequate mitigation provided for loss of breeding opportunities and this includes for farmland birds.

Appropriate bird breeding survey must be carried out at this site prior to any approvals and adequate mitigation provided for loss of breeding opportunities and this includes for farmland birds. Please do refer to our previous advice on loss of arable land (provided as an end note in this letter) and the need for a specific policy.[i]

[i] Extract of previous comments:  “Kent Wildlife Trust is very concerned about the level of development proposed on agricultural land in Thanet and we are seeing considerable loss of this type of land across the whole of Kent. Arable and Horticultural land is a UK Biodiversity Action Plan Broad Habitat and Ancient/ Species Rich Hedgerows is a Priority Habitat for Kent. In particular, we are concerned about the resultant loss of habitat to support the Kent Biodiversity Action Plan species of the Brown Hare, Dormouse, Harvest Mouse and breeding birds associated with agricultural land, such as Skylark, Lapwing and Song Thrush. The loss and isolation of hedgerows and field margins, as supporting structures for breeding and feeding birds, foraging and commuting bats species and the loss of individual hedgerow species is also of real concern on a County scale.

The Trust notes reference to this particular issue in paragraph 4.2 of the document, under the heading “Protecting the Countryside”. However, any avoidance, mitigation or compensation for this loss is not explicit in the document at the present time and we would expect to see this in a Preferred Options document. The Trust would like to take this opportunity to remind Thanet District Council of the intention within the NPPF for the planning system to promote net gain for wildlife[i]. More detail is urgently required, preferably as a discrete, specific policy (or as a minimum within the text of each greenfield strategic site) and Kent Wildlife Trust would recommend the following approach:

• No net loss of field margins and boundary features and associated buffer strips should be 30m wide where possible, 15m at the minimum.

• Where loss is unavoidable, specific mitigation and compensation measures should be outlined in this policy document. This would include the replacement (in-situ or elsewhere), restoration and enhancement of hedgerows and field margins and positive land management for breeding birds associated with agricultural land. A contribution to a “package of support” for positive farming practices elsewhere on remaining arable land would help to compensate for any loss. This package of support (or specific land management projects) should be identified in this forward plan.

• Identifying potential open space within the Green Infrastructure Network, suitable for habitat creation of bird breeding sites and boundary features, in order to address any unavoidable loss of agricultural land, should also be included. These projects should be identified, lead agencies, costs and funding identified and projects should be monitored and reviewed, preferably through a Green Infrastructure Plan.”