Appendix 2 : Officer recommendation & responses to Biodiversity & Climate Emergency Working Group Observations


Summary Observation from Working group



1 Executive Summary



1.1   & 1.2 Vision statement and increased period to 25 years

1.3   & 1.4 Holistic approach should be emphasised restoring natural processes & fragmentation of landscapes. Including a holistic approach to townscape too. Habitats should not be the focus



1.5   Title could be ‘Maidstone Biodiversity & Biomass Strategy’, emphasis on importance of quantity of living material (mass) as well as diversity.


1.6   Expand to include contractors and partner organisation 

1.7   The 2019 State of Nature Report should be referenced

Case Study suggestion: Wildwood & Wetland Connect – proposal for Strategy to promote an ambitious proposal to expand tree cover & re-naturalisation of water courses over 200 year timescale.



1.1   Agreed 1.2 10 year strategy proposed

1.3 & 1.4 Agreed – ambitions for land & townscape will be incorporated but a number of responses from workshop and engagement highlighted the desire to maintain basic descriptors of habitats to make biodiversity accessible – this strategy has evolved from the 2008 Plan that cited 15 habitat types for action.

1.5 There is potential for confusion; few people know the term biomass and the majority who are familiar with it are referencing material as a source of fuel.  Document was entitled ‘Saving Nature in Maidstone’ to be accessible and attention grabbing.

1.6 Duty of care exists in law – this will be made clear in document.

1.7 Agreed

Case study suggestion:  Further discussion required to establish status of project, is it a case study or a future action point?


2 Why do we need a biodiversity Strategy?



2.1 – 2.6 Request to emphasise that shifting baseline of accepting recent poor diversity, quality & quantity as a reference point stifles ambition. Also typo noted.


2.1 Noted and statement will be incorporated.

3 What are the aims of this strategy?



3.1 & 3.2 Request for statement/vision to underpin the strategy and suggestion governance, resources and accountability are incorporated in this section.

3.1 & 3.2 Vision statement will be restated here. Governance will be expressed within Strategy.


4 Ecosystem Services



4.1- 4.6 Suggestions to improve examples of Ecosystems Services

4.7 Ea map  


4.1-4.6 Agreed and will be incorporated


5 Pressures on Wildlife



5.1 – 5.1.6 Suggestions for more local examples of development gains for wildlife.

5.1.7 reference Honeyhills Wood

5.2.1 – 5.2.4 Pollution Issues – expand section to reflect breadth of problems.

5.3 Invasive Non-Native Species – reduce section or delete as felt the species list was subjective and misleading. The importance of native species is made and the need to understand the risks of introduced species and pathogens. Also highlighted is the risks of dogs and cats to biodiversity.




5.1-5.1.6 Agreed to incorporate local examples.


5.1.7 Agreed

5.2.1 – 5.2.4 Expand section to reflect range of pollution issues: action plan to identify priority areas.

5.3 The section is relevant and should be retained as it specifically relates to Invasive species and reflects the 2018 Regional Invasive Alien Species Management Plan.   Table 2 will be edited to clarify presence /absence. Working group comments relate to non-native species whilst an interesting narrative not entirely relevant when this section is focussing on species known to be ‘Invasive’.


6 How can I help?



6.1 – 6.2.2 Request to state businesses, landowners, farmers and land managers rather than current statement of ‘people across sectors.’ Pledge to be called Maidstone Nature Pledge rather than Biodiversity Nature Pledge.

6.3.1 Information on funding sources


6.4.1 Partnership Working – request to expand list






6.1 – 6.2.2 Agreed




6.3.1 Information is presented in Appendix 2, addendum required in text.

6.4.1 Current list reflects those who have currently expressed an interest not those that we wish were engaged.  Additional text to be inserted referencing Go Green Go Wild and opportunities to expand influence to broader set of partners.


7 What will MBC do ?



7.1 Strong support and request for more detail on delivery.


7.1 Noted and detail on delivery will be expressed in Action Plan


8 What have we got in Maidstone?



8.1 Misleading statement & suggestion of additional species of note and habitats.



8.2 Concern that Biodiversity Opportunity Areas (BOA)do not reflect the local nor urban opportunities and ‘Whole Borough Mapping Exercise’ could be undertaken to identify opportunities. In particular the local potential along the urban Len Valley and the Loose area.

Proposal that the Strategy focuses on trees/woodland and wetlands as the greatest potential to increase landscape scale biodiversity improvements.


8.3 Species of Note. Strong dislike of presentation of species data gathered in the borough as not scientifically rigorous. Suggestion to include the promotion of other wildlife campaigns.








8.1 Clarify statement to make it explicit that Maidstone makes a significant contribution to the listed statistics of species & habitats of international importance. Additional notable species and ancient woodland summary data will be added.

8.2 The Kent BOAs exist in the Kent Nature Partnership frameworks and are referenced to reflect the existing regional position - a new local borough exercise could be undertaken as an outcome in the action plan or known additional opportunities such as the urban River Len and Loose area included now. 




8.3 Data is validated and has value in a representation of ‘citizen science’.  Recommend it is retained to express interest and engagement that already exists but further clarify limitations. The Kent Nature Partnership selected the priority species and the ongoing call for submission of amateur naturalist or citizen science data is cost effective and a tool for engaging with a new audience.  Recommend data is retained within strategy as an appendix.

Other campaigns will be promoted.



9 Habitats



9.1 A call for ambitious re-wilding and landscape scale project for Maidstone. Creation of wilderness and support for keystone species



9.4 Suggested case study of 3500 acres Knepp Estate, West Sussex

9.5 Caingorms Connect Case Study


9.6 Request to amend/redefine the Kent Habitat Survey (KHS) categories to closely reflect that found in Maidstone





9.7 Request for biodiversity/biomass comparative study data to illustrate the merits of natural climax woodland and wetland habitats.


9.8 Cairngorms Connect – use high quality images and bold statements to illustrate concepts




9.1 Re-wilding could have major biodiversity gains, but it is not yet policy and is fraught with legal challenges. Nor is there a likely opportunity within the borough.  This will need to be held over for future strategy or action plan.

9.4 See above

9.5 See above and additionally examples from lowland England would be most relevant

9.6 The KHS categories are used across the region and furthermore are shown only to illustrate the broad categories now expressed in the Strategy ie Woodland, Wetland, Urban & Grassland/Agriculture.

Previous comments have supported the move away from a focus on the many types of habitat classifications and sub-classification available to us. Recommend retaining the KHS list.

9.7 Question the merits of this exercise as an interesting academic concept rather than an aid to influence policy and practical implementation.  Natural climax habitat would require large scale sites with mega-fauna and apex predators; not likely in Maidstone.

9.8 Agreed


10 Woodland



10.1 .1 Request to reference the importance of protecting and expanding certain woodlands


10.1.2 Practical suggestions /interventions for woodland management

10.1.3 Suggestion for further case study: Wealden Wildwood


10.1.4 Scramblers & climbers

10.1.5 Game shooting issues & management of woodlands




10.1.1 Strategy has referenced woodlands in trust or public ownership – very little opportunity to influence private landowners.


10.1.2 Can be incorporated into Actions & delivery


10.1.3 For brevity and conscious of document size not all case studies included.

10.1.4 More relevant for actions rather than strategy

10.1.5 Do not agree this is a strategically important outcome; could be addressed as an action to support national initiatives with BASC.



11 Urban Nature



11.2.1 – 11.2.2 Suggestion to expand content regarding connecting residents to nature and proposals for management prescriptions for towns and villages.


11.2.1-11.2.1 Agree but would more naturally sit in a follow-on action plan highlighting to the decision makers & residents what can done to help and how this will aid nature and personal physical and mental wellbeing.



12 Water & Wetlands



12.3.1 Query why advocating removal of fish pass at Yalding



12.3.2 Removal of man-made obstacles and re-naturalisation of water courses



12.3.3 Green & Blue Infrastructure Delivery Plan – flawed.


12.3.4 Re-naturalising catchment

12.3.5 Low flows, enforcement & abstraction

12.3.6 Pond creation targets



12.3.7 Groundwater recharge & quality


12.3.8 Marsh frog

12.3.9 Hammer Stream photograph

12.3.10 Invasive species comment & banner


12.3.1 Agreed – though this was taken from the Maidstone Infrastructure Delivery Plan – recommend this is investigated and not repeating an error.

12.3.2 This is already national policy and an EA objective driven by Water Framework Directive (WFD)so strategically covered elsewhere. Where MBC can lead or enable actions this will be captured in the action/delivery plan.

12.3.3 It exists and is still a strategic document and it is appropriate to reference it.

12.3.4 See 12.3.2 above

12.3.5 See 12.3.2

12.3.6 Incorporate targets in action plan - work is already happening in partnership with Natural England but space constraints mean we cannot list every initiative currently under way.

12.3.7 Embedded within WFD, ( See 12.3.2 above ) but a line for ground water quality in Kent would, we agree, be relevant.

12.3.8 Remove reference

12.3.9 Replace with River Len photo

12.3.10 Remove




13 Grassland & Agriculture



13.4.1 -13.4.2 Request to include Boxley Warren LNR and Marden Meadow as exemplar sites

13.4.3 Commentary on limitations of hay/wildflower meadows for invertebrates.









13.4.4 Decline in rabbit population


13.4.5 Use of wormers



13.4.1 – 13.4.2 Agreed


13.4.3 This is a specific technical comment relating to invertebrates and does not consider comparative merits of diverse created meadow with for example amenity turf. Nor the benefits for mammals, farmland birds & raptors. Indeed, the B-Lines South East (Buglife Uk) project promoted in comments is specifically about the creation of new flower rich habitats for pollinator species. The strategy is trying to encourage more active appropriate management of grassland. Arguably optimum management would include extensive grazing by cattle, but this is often not feasible owing to cost, logistics and availability of animals.

13.4.4 Not strategic, too specific and unable to influence outcome


13.4.5 Very specific but comment can be inserted


14 Projects & Summary



14.1 Potential project partners/delivery agents


14.1 Projects & potential will follow in action/delivery plan. The authors contacted many conservation organisations during the production of this document, without specific objectives, sites and initiatives in mind, they cannot all be listed. They could be referenced under relevant bodies.



15 Other


15.1 Governance, targets and milestones


15.2 Appearance – high quality finish requested


15.1 To be expressed at next iteration; targets will form part of action/delivery plan

15.2 Layout & graphics will be reviewed for professional print publication and online version.