Member comments

Response

Officer recommendation

Philosophy behind document - very concerned that "fragmentation" of landscape proposed within the document flies in the face of NPPF and Natural Environment White Paper which seeks to engender "landscape scale" conservation and "networks for nature". The beauty of the landscape is that it is a patchwork of local difference that when seen as a whole is beautiful. Special Landscape Areas worked very well in this regard as they operated at a worthwhile scale. The proposed way forward will inevitably lead to an overall decline in landscape quality as protection of wider countryside becomes impossible under this "divide and rule" methodology.

The LCA follows up to date guidance (Landscape Character Guidance for England and Scotland, Scottish Natural Heritage/The Countryside Agency, 2002), which is nationally recognised. This methodology is consistent with the methodology used at county and national scale and across neighbouring boroughs. Using the same consistent approach allows the smaller landscape character areas to piece together into the larger areas, building up a hierarchy to cover a wider, landscape scale, area and to enable decision making at a strategic and local scale.  The assessment/methodology does not aim to fragment the landscape, but to draw out the diversity and richness of the landscape character. It is recognised under Considerations (Page 102/38) that ‘Changes in the natural landscape are often gradual…..It is therefore common to find some characteristics of one area overlapping into another’.

No change required

Page 8  A general point in response to several comments below-  the ‘Conserve’ guideline category does not mean that no intervention or ongoing management/restoration is required. To make this clear, the following could be added under Evaluation between ‘… from this analysis’ and ‘Many of these…’:

‘It should be noted that where the guideline is to ‘Conserve’ a landscape character area, ongoing good practice and management will be required to sustain the good landscape condition/high landscape sensitivity.’ 

Amend text as per  response

page 46  bullet point 5 insert "disused chalk pits" between "chalk grassland" and "grazing meadow". Rationale: these characteristic and often historic features are threatened by landscape rehabilitation projects with negative impacts upon local landscape character and biodiversity.

This is an acceptable addition

Amend text

Page 51 bullet point 4 add "through introduction of native hedgerows and" between "boundaries" and avoiding". Rationale: hedgerows have been lost from this area and were formerly a key landscape feature now largely grazed-out, burned-out or grubbed.

Bullet point 6 add "through delivery of appropriate architectural and landscape design, increasing native tree cover and "between "villages," and "by discouraging". Rationale: common-sense!

Bullet point 9 add "and introducing greater woodland structural diversity" after "coppice". Rationale: key objective in local Kent Downs woodlands.

Bullet point 11 add "reducing over-grazing" between "by" and "removing". Rationale: key objective in local Kent Downs woodlands.

This is an acceptable addition with minor amendment as follows:

"through the introduction of native hedgerows and" between "boundaries" and by avoiding"

This is an acceptable addition

This is an acceptable addition

This is an acceptable addition

Amend text as per response

Amend text

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Page 55 add new bullet points 5 and 6 as follows: * Establish wooded network incorporating scarp woodlands, Malling and Monkdown Woods. * Restore and expand extent of relict roadside field ponds, which were formerly a key feature of this part of dip slope. Rationale: key local landscape and biodiversity objectives.

This is an acceptable addition with minor amendment as follows:

* Restore and expand extent of relict roadside field ponds, which were formerly a key feature of this part of the dip slope.

Amend text as per response

Page 56 within key characteristics panel last bullet point remove "very" and "unkempt". Rationale: not in fact locally characteristic and perjorative.

This is an acceptable amendment

Amend text

Page 58 remove lines from 3.7 starting "Where the fields...." and ending at "moderate" and at end of 3.7 replace "poor" with "moderate".

Suggest addition to second paragraph as follows:

‘Visual detractors include the tall electricity pylons, large metal and concrete sheds and flytipping.’

Suggest deleting the following:

‘Where the fields are not managed as pasture, there are sometimes problems with scrub emerging, unmaintained gates and rubbish dumped which makes these fields appear abandoned’.

The overall landscape condition of ‘poor’ is based on a consistent and complex assessment approach and an analysis of a number of different factors. It is not possible to change the overall conclusion to ‘moderate’ without making changes to the analysis. The analysis is considered correct and consistent with other adjoining landscape character areas across this part of the Downs. Note that landscape analysis takes an average across each landscape character area and there may be pockets of different condition and sensitivity within.  These suggested changes are not appropriate.

Amend text as per response

Amend text as per response

No change required

Page 59 Summary of Analysis change Condition Assessment from "poor" to "moderate" and ecological integrity from "moderate" to "good".

At Summary of Actions add at end of bullet point 4 "to enhance structural diversity."

At bullet point 7 delete "encouraging grazing within fields which appear abandoned and"

At bullet point 8 delete "by trimming the hedgerows more regularly". Rationale: very difficult to place some of this narrative within the correct landscape character area.

The overall landscape condition of ‘poor’ is based on a consistent and complex assessment approach and an analysis of a number of different factors. It is not possible to change the overall conclusion to ‘moderate’ without making changes to the analysis.  The analysis is correct and consistent with other adjoining landscape character areas across this part of the Downs. The extent of ancient woodland, chalk grassland and Local Wildlife Sites are detailed within the text and recognised as being ecologically important. The overall ecological integrity is moderate overall because of poor wildlife connectivity in places caused by gappy hedgerows and fenced field boundaries. The suggested changes are not acceptable.

This is an acceptable addition

This is an acceptable deletion

This is an acceptable deletion

No change required

Amend text

Amend text

Amend text

Page 62 at 4.6 remove "problems of" from line 10. Rationale: it isn't a problem, seasonal wet hollows at Friningham are a key landscape and biodiversity asset supporting rare stoneworts and higher plants!

This is an acceptable deletion

Amend text

Page 64 at Summary of Analysis replace Sense of Place: "weak" with "moderate".

At Summary of Actions add new bullet point "* Increase extent of tree coverage across intensively cultivated areas as opportunities arise.". Rationale: this character area has lost significant areas of (ancient) woodland and most of its hedgerow trees in the fairly recent past (since 1970s) and this fact is not recognised.

The Sense of Place is based on a consistent and complex assessment approach and an analysis of a number of different factors. It is not possible to change the Sense of Place without making changes to the analysis, and the analysis is considered correct.  The suggested changes are not appropriate.

This is an acceptable addition with minor amendment as follows:

"* Increase extent of native tree coverage across areas of intensively cultivated areas land as opportunities arise."

No change required

Amend text as per response

Page 69 at Guidelines table and header change "Conserve" to "Conserve and Restore". Rationale: a brief glance at JNCC Inventory of ancient woodlands or an old map starkly illustrates the loss of tree cover to arable cropping since the 1970s - this cover should be restored.

At Summary of Actions bullet point 4  add "and enhance structural diversity," between "woodlands" and "particularly".

At bullet point 6 add "and scrub" between "grassland" and "by ensuring"

and delete "sheep" between "appropriate" and "grazing". Add a new bullet point at end "* seek to extend woodland cover within intensively farmed landscape."

The overall Guideline of ‘Conserve’ is based on this landscape being in good condition and highly sensitive. To change the overall Guideline to ‘Conserve and Restore’, the Condition would need to be degraded to moderate.  The analysis for the landscape condition is considered correct and therefore these suggested changes are not appropriate. There is still a significant amount of woodland within this landscape and 78 hectares of new broadleaved woodland have been planted by the Woodland Trust at the Hucking Estate (as referenced in the text).

This is an acceptable addition

Scrub inhibits chalk grassland and scrub clearance is sometimes used as a management tool to help regenerate chalk grassland species, so to add that the conservation of scrub is desirable is not always appropriate.

These are acceptable changes with minor amendment as follows:

"* seek to extend native woodland cover within areas of intensively farmed landscape."

This bullet point would support the objective of restoring the woodland loss.

No change required

Amend text

No change to text on this point but add the following to the Landscape Description: “Uncommon scrub species occur locally such butcher's broom and unusual bramble species on the dip-slope.’’

Amend text as per response

Page 72 at 6.7 change "well" to "intensively". Rationale: subjective statement as they're not well maintained if you’re a bullfinch or noble chafer!

This is an acceptable substitution

Amend text

Page 73 add new bullet point at end of Summary of Actions stating "* Seek to extend woodland cover within intensively farmed landscape.". Rationale: again a big loss of woodland to agriculture since 1970s - see JNCC mapping!

This is an acceptable addition with minor amendment as follows:

"* Seek to extend native woodland cover within areas of intensively farmed landscape".

Amend text as per response

Page 78  add at bullet point 7 "and scrub" between "grassland" and "and reinforce" and bullet point 8 add "and extend" between "conserve" and "the good". Rationale: complies with local AONB landscape aspirations to achieve greater structural diversity.

Scrub inhibits chalk grassland and scrub clearance is sometimes used as a management tool to help regenerate chalk grassland species, so to add that the conservation of scrub is desirable is not always appropriate.  Aspirations set out within the Kent Downs AONB Management Plan are referenced in bullet point 3.

No change to text on this point but add the following to the Landscape Description: “Uncommon scrub species occur locally such butcher's broom and unusual bramble species on the dip-slope.’’

Page 80 at 8.2 add  "including large coppice stools of both our native limes" between "block of trees" and "as well as pasture". Rationale: very special landscape features.

This is an acceptable addition

Amend text

Page 83 at bullet point 4 add "and enhance structural diversity within" between "conserve" and "and reinforce" and add new bullet point at end "* propagate by layering relict native lime to facilitate re-introduction programme within local Kent Downs AONB landscape." Rationale: these trees are very, very old and dying out - they must be assisted to prosper.

These are acceptable additions

Amend text

Page 149/85 bullet point 8 add "and scrub" between "grassland" and "and to restore".

Scrub inhibits chalk grassland and scrub clearance is sometimes used as a management tool to help regenerate chalk grassland species, so to add that the conservation of scrub is desirable is not always appropriate.

No change to text on this point but add the following at page 148/84 (18^th sentence):  “unimproved chalk grassland, with locally common wild box and purging buckthorn, but it is …..”

Page 87 at 9.2 change "from" to "on" i.e. "on 'wild' relic". Delete "kestrels and sparrowhawks" and change "feed" to "prey" and "many" to "local" and delete "rabbits in the area" and replace with "rabbit population". Rationale: factual kestrels and sparrowhawks don't eat rabbits!

These are acceptable amendments but it is assumed it should read, ‘….utilising cuttings grown from ‘wild’ relic populations…’

Amend text as per response

Page 88 at 9.7 insert ", pylons and overhead powerlines" between "barriers" and "as well as".

These are acceptable additions

Amend text

Page 94 bullet point 6 change to “Mark, protect and grown-on new standard native trees within hedgerows.’’

Bullet point 7 at “and scrub” between “grassland” and “by”.

This is an acceptable change with minor amendment as follows:

 “Mark, protect and allow to grow on grown-on new standard native trees within hedgerows, and plant new native standard specimens where appropriate.”

Scrub inhibits chalk grassland and scrub clearance is sometimes used as a management tool to help regenerate chalk grassland species, so to add that the conservation of scrub is desirable is not always appropriate.

Amend text as per response

No change to text on this point but add the following to the Landscape Description: “Uncommon scrub species such as wild box and purging buckthorn occur locally at Thurnham”.

Page 97 at 11.7 add “and few hedgerows” between “cover and “limit”.

Add at end of 11.8 “However, the loss of hedgerows and hedgerow trees to agricultural intensification is a detracting factor that should be addressed, whenever opportunities arise, through re-instatement of historic hedge-lines.”.

This is an acceptable addition

This should be set out as an aspiration under Summary of Actions rather than included under the analysis of landscape Sensitivity.

Amend text

Amend text as per response

Page 98 Guidelines “Conserve and Restore” rather than “Conserve”.

Summary of Actions bullet point 5 start sentence “ Conserve, enhance and re-instate……..”.

I am satisfied that the analysis is correct, fully justified by the text and is consistent with adjoining scarp landscapes. These suggested changes are not considered appropriate.

Update bullet point 5 to read, ‘Conserve and enhance hedgerows, infilling sections which are missing and reinstating historic hedge-lines.’

No change required

Amend text as per response

Page 104 bullet point 2 add “through relaxation of mowing regimes” between “park” and “and consider” at bullet point 3 add “….Enhance structural diversity within”  and add new bullet point “* Utilise opportunities arising from development and land-use changes  to re-establish semi-natural habitats.”.

These are acceptable additions with minor amendment  to point 3 as follows:

“….through appropriate management and enhanced structural diversity”

Amend text as per response

Page 107 Summary of Actions add new bullet point “* Reduce mowing frequencies at Cobtree Manor Park to enhance landscape structure and benefit wildlife.”.

This is an acceptable addition

Amend text

Page 110 add at conclusion of Biodiversity section “Recent development close to M20 Junction 6 has led to the translocation of the large resident great crested newt population to Allington Castle and the destruction of exposed sandy substrates that formerly supported endangered invertebrate populations. More positively ancient Cuckoo Wood is now managed as a nature reserve with management interventions delivering enhanced vegetation structure to benefit flora and fauna”.

The inclusion of these issues is acceptable with amended wording as follows:

'Development close to M20 Junction 6 has led to the translocation of legally protected species and the destruction of exposed sandy substrates that formerly supported endangered invertebrate populations. More positively, ancient Cuckoo Wood is now managed to deliver enhanced vegetation structure to benefit flora and fauna'.

Amend text as per response

Page 116 Key Characteristics panel new bullet point “Wetlands include ‘The Sheep-wash’ stream system and the historic deep pond at Cooks Cottage.”

This is an acceptable addition

Note: On the OS base, this is spelt ‘Cookes Cottages’.

Amend text as per response

Page 117 at end of 13.10 add “A stream system known locally as ‘The Sheep-wash’ runs under Grange Lane towards the M20 motorway.  An historic and deep pond is situated north of Cooks Cottage is another local landscape feature. Prior to extensive land drainage in the early Twentieth Century this area was seasonally flooded and supported lapwing and European eel.

This is an acceptable addition with amended wording as follows:

‘…motorway, and an historic and deep pond is situated north of Cookes Cottages is another local landscape feature. Prior to extensive land drainage in the early 20^th century

Amend text as per response

Page 118 at Biodiversity section 13.16 delete “Drainage ditches and the pond” and replace with “Streams and the pond at Cooks Cottage”. Further reference to “drainage ditches” should be replaced with “streams”. Add new penultimate sentence Prior to extensive land drainage interventions farmland in this area was annually inundated by floodwater.” At Condition add “streams, ponds” between “with” and “tree belts”. At Summary of Actions change last bullet point to “Conserve and reinforce wetland habitats by ensuring protection and encouraging appropriate management.”

These are acceptable changes with amended wording as follows:

‘… Cookes Cottages”. Further reference to “drainage ditches” should be replaced with “streams”. Add new penultimate sentence Prior to extensive land drainage interventions farmland in this area was annually inundated by floodwater.” At Condition add “streams, ponds” between “with” and “tree belts”. At Summary of Actions change last bullet point to “Conserve and improve reinforce…’’

‘Improve’ should be used rather than ‘reinforce’ to be consistent with wording in overall guideline.

Amend text as per response

Page 119 at Key Characteristics add new bullet point “Streams and stream-fed ponds south of Park House.”

This is an acceptable proposal based on an aerial photo. However the OS base shows the ponds to be isolated but with some very linear, man made ditches to the west. Suggest ‘Streams and stream-fed ponds’ may be better to include recognition of streams within Boxley to the north.

Amend text as per response

Page 120 at 13.20 add at end of paragraph “Streams and the stream-fed ponds at Park House are attractive and locally characteristic features.”

This is an acceptable addition with amended wording as follows:

‘…ponds where the Chalk meets the Gault Clay at…’

Amend text as per response

Page 121 at Biodiversity 13.26 delete “water bodies” and replace with “stream-fed ponds supporting rare stoneworts and invertebrates” and change “in” to “at”. At Summary of Actions add new bullet point “Conserve and enhance stream network and stream-fed ponds.”

These are acceptable changes with amended wording as follows:

‘… point “Conserve and enhance stream …’

 ‘Conserve’ should be used to be consistent with wording in overall guideline.

Amend text as per response

Page 122 at Key Characteristic panel add new bullet point “Pond at Stone House and ‘Acre Pond’”.

There are several ponds within this area – suggest ‘Scattered ponds’ is added to key characteristics to include recognition of all ponds.

Amend text as per response

Page 123 at 13.31 add “locally known as the ‘Acre Pond’,” between “pond,” and “enclosed”

This is an acceptable addition

Amend text

Page 125 Biodiversity 13.36 add a penultimate sentence “Park Wood retains a notable ground flora and some exceptionally large and ancient coppice stools.”. At Summary of Actions add extra bullet points “ Ensure retention and sympathetic management of wetland features” and “Seek appropriate management for Park Wood to maximise biodiversity”.

These are acceptable changes

Amend text

Page 127 at 14.2 add “and supports stand of the Red Data Book plant common cudweed and legally protected common lizard” after “heathy characteristics”.

Add “aspen” between “hazel,” and “holly”.

Change sentence to incorporate: ‘Heath Wood is a small wood with historical chestnut coppice. The wood sits in the vicinity of a small field which displays heathy characteristics and supports the Red Data Book plant common cudweed and legally protected common lizard’.

This is an acceptable addition

Amend text as per response

Amend text

Page 132 at 14.12 add “and relict heath” between “rough pasture” and “are”.

This is an acceptable addition

Amend text

Page 134 at Biodiversity 14:17 add a penultimate sentence “Rough grass and relict heathland (including rare lichen heath) at Weavering Heath supports significant reptile populations.”

Summary of Actions add new bullet point “Conserve and expand relict heathland at Weavering Heath”

This is an acceptable addition

Wording should be in accordance with the overall guideline as follows:

“Conserve and expand Improve and reinforce …’

Amend text

Amend text as per response

Page 150 at 15.8 delete “ditches” and substitute “streams”.

There is a difference between ditches and streams, the former being man made. Suggest ‘watercourses’ is used.

Amend text as per response

Page 151 Summary of Actions bullet point 8 delete “ditches” and substitute “streams” and finish sentence after this word. Rationale: reference to willow species makes no sense.

As above

Amend text as per response

Page 159 at Guidelines delete Conserve status and instead “Restore and Improve”.

At Summary of Actions bullet point 5 add “and field headlands” between “boundaries” and “where practicable”.

Delete last bullet point (which is undesirable)

Add new bullet point “Restore historic hedgerow and shaw pattern when opportunities arise.

At Summary of Analysis make Condition Assessment “Moderate”, Detracting Features “Some”, Ecological Integrity “Poor”, Continuity “Recent”. Rationale: this landscape is far from historic and has changed beyond recognition in the last 40 or so years - from small grazed fields with hedgerows and multiple shaws to featureless open arable land. A cursory glance at historic maps reveals the extent of change (as does local knowledge).

The overall landscape guideline of ‘Conserve’ is based on a consistent and complex assessment approach and an analysis of a number of different factors. It is not possible to change the overall guideline without making changes to the analysis. The analysis is considered correct. The suggested changes are not appropriate.

This is an acceptable addition

This bullet point is appropriate and should be retained but suggest that ‘crisp’ is replaced by ‘defined’.

This is an acceptable addition with amended wording as follows:

 ‘… when where opportunities…’

The analysis is considered correct and well justified in the Landscape Analysis section and therefore these suggested changes are not appropriate. Arable intensification is acknowledged but suggest amending 17.7 3^rd sentence to ‘Despite significant loss of historic hedgerow boundaries and shaws, a good hedgerow network and frequent woodland blocks remain’

No change required

Amend text

Amend text as per response

Amend text as per response

No change to text on condition assessment but

amend general text as per response

Page 162 at Key Characteristics panel at 3rd bullet point add “ and dense stands of aspen adjacent to railway” and at 4th bullet point add “, woodland and grassland”.

These additions are acceptable

Amend text

Page 163 at 18.2 last sentence should read “At Bridge Nursery, regenerating aspen, ash, hornbeam hazel, pedunculate oak and hawthorn woodland and gorse, bramble and dogwood thickets intersperse the rough grassland and relict derelict orchard.”

At end of 18.4 add additional sentence “Views to and from the Kent Downs AONB to the north are a key feature of Bridge Nursery.

These are acceptable changes with amended wording as follows:

“To the west of the sports ground, at an area locally known as ‘Bridge Nursery’, regenerating…’

‘… feature of the area locally known as ‘Bridge Nursery’.’

Add this latter sentence to ‘Views’.

Amend text as per response

Amend text as per response

Page 164 at 18.6 add new sentence at end “Views from the Ashford to London railway line are a significant consideration within this landscape area – effectively serving as the visual gateway to the Borough for rail passengers.” At 18.7 add “derelict orchard, rough grassland” between “vegetation,” and “a woodland belt”

and delete sentence beginning “The cultural heritage is poor….”

and substitute “Bridge Nursery supports a notable flora and fauna, including the Red Data Book common cudweed, and at least three reptile species

These are acceptable additions with amended wording as follows:

‘… line are also a significant…’

The assessment and justification of poor cultural heritage is considered correct.  The suggested changes are not appropriate.

This is an acceptable addition between ‘habitat network’ and ‘The cultural heritage’  with amended wording as follows:

‘Bridge Nursery is thought to supports a …’

Amend text as per response

No change required

Amend text as per response

Page 165 at Summary of Analysis change Condition to “Good”, Pattern of elements to “Coherent”, Cultural integrity to “Variable”, Functional Integrity to “Coherent”, Sensitivity Assessment to “Moderate”, Distinctiveness to “Distinct”, Landform to “Apparent”. At Guidelines change “Improve” to “Conserve and Improve”

Add new bullet point at Summary of Actions “* Conserve mosaic of wildlife habitats at Bridge Nursery”.

The analysis is considered correct and well justified in the Landscape Analysis section.

The suggested changes are not appropriate.

This addition is acceptable but suggest the use of ‘maintain’ in place of ‘conserve’ for consistency.

No change required

Amend text as per response

Page 168 at19.7 add new sentence after “good bases for wildlife.” stating “Establishment of semi-natural habitat link between Fullingpits Wood and Oaken Wood and Ditton Common to the west is a priority if the ecological integrity of this now isolated ancient woodland is to be protected.”

At end of this section delete “and some of these trees may be over mature.” Rationale: policy compliance / irrational statement. At Summary of Actions add new bullet points “* strengthen and restore hedgerows and tree lines fronting Hermitage Lane.” And “* Seek to establish semi-natural habitat link between Fullingpits Wood and Oaken Wood and Ditton Common.”

This would be better placed under Summary of Actions rather than the analysis for consistency.

These changes are appropriate.

Amend text as per response

Amend text

Page 178 at Summary of Actions add to last bullet point “through restoring hedgerow along fence lines and along road corridors.”

This is an acceptable addition with amended wording as follows:

‘… hedgerows boundaries along …’

Amend text

Page 187 and 203

The description of the landscape character area around and opposite Fant Orchard should emphasise the  importance of the views to the South from Gatland Lane.

The views of the opposite side of the valley are what takes your attention when you walk through the site. They're unique to these two sites, because of the gradient of the land and the route the access takes.

The views are mentioned in the overall description for LCA 24 and 24-2, as well as LCA 27, 27-2 and 27-4 which are on the opposite side of the Medway but not in the key characteristic boxes for these areas. Add 'Views across Medway Valley to opposite valley side' to key characteristics of each of these areas.

Amend text

Page 197 at 25.2 add “(including ancient woodland)” between “clumps” and “throughout the park”

and add “recently built in ancient woodland” between “parking” and “has been designed”. Rationale: this places in context.

This is an acceptable addition

This is an acceptable addition with amended wording as follows:

‘… in ancient woodland”

The ancient woodland at Oakwood Park was not formally designated until after the assessment of the area had been undertaken. The description should not therefore refer to data collected after the original survey work for the sake of consistency.  No change required.

Amend text as per response

Page 198 at Summary of Actions bullet point 5 delete “its mature” and replace with “ancient”.

Add at end of bullet point 7 “and enhanced grassland management interventions should be prioritised to re-introduce a mosaic of sward-types”. Add at bullet point 8 “and semi-natural landscape features” between “buildings” and “on site”. Add a new bullet point stating “* Seek to safeguard the wildlife-rich rough grassland and scrub at the south east corner of the site.”

At 25.6 Condition last line state after “network of parkland trees, ancient woodland and the rough grassland and scrub within the south east sector of the site.”

Only part of the woodland is recorded as ancient. Suggest adding ‘some of which is ancient’  between ‘mature woodland’ and ‘isolated trees’

These are acceptable additions with amended wording as follows:

‘Seek to safeguard the rough grassland and scrub to the southeast corner of the site, thought to be wildlife-rich’.

This is an acceptable addition

Refer to comment on Ancient Woodland above.  No change required.

Amend as per response

Amend text but omit ‘ancient’.

Page 200 at 26.3 delete “This area supports lowland acid grassland and woodland flora, and populations of invertebrates and protected reptile species.” as it is repeated and clumsy.

This is an acceptable deletion

Amend text

Page 202 Summary of Analysis at Sense of Place state “Moderate” at Condition change from “Improve” to “Restore and Improve”.

The analysis is considered correct and fully justified by the text. These suggested changes are not appropriate.

No change required

Page 231 at Biodiversity section add new last line “Man-made barriers to wildlife movement and poor water quality detract from the biodiversity value of the Loose Stream and riparian habitat improvements should be a priority.

Add new bullet point 3 at Summary of Actions stating “Seek to restore the ecological integrity of the Loose Stream and its corridor.”

At Guidelines I suggest should be “Conserve and Restore” rather than “Conserve”. Ecological Integrity should be “Moderate” – as has declined rapidly in recent years and is far from strong!

It is unclear whether there is recent evidence of the water quality being poor. The ecologist had assumed under Biodiversity that the water quality was good at the time of assessment. I suggest the action is incorporated under Summary of Actions rather than under the Biodiversity description section.

The amendment is appropriate to reflect Local Wildlife Site status but should be amended as follows to ensure consistency:

“Seek to restore Conserve the …’

The analysis is considered correct and fully justified by the text. The valley is designated as a Local Wildlife Site. The suggested changes are not appropriate.

Amend text as per response

Amend text as per response

No change required

Page 234 at Summary of Actions 2nd bullet point delete “planting” and replace with “and wood pasture”.

This is an acceptable substitution

Amend text

Page 239 at 27.102 add new sentence at end “Relict parkland and remnants of ancient woodland survives at the northern extent of this character area on the north east side of Boughton Lane within the school campus.

The northern (urban-edge) sector of this landscape area retains the most historic features.”

This is an acceptable amendment to 27.102 between ‘Boughton Mount’ and ‘Development’.

The ancient woodland was not formally designated until after the assessment of the area had been undertaken. The description should not therefore refer to data collected after the original survey work for the sake of consistency.  Amend text as follows:

“Relict parkland and remnants of ancient woodland survives at the northern extent of this character area on the north east side of Boughton Lane within the school campus.

Page 240 at Biodiversity 27.106 add “ancient” “between “of” and “woodland”.

Delete 5th bullet point regarding development (nowhere else in the document does it talk about development)

and add new bullet points “* Restore hedgerow network and increase coverage by parkland trees”

and “* Intensification of development and associated lighting within the school campus has had an urbanising impact and this should be addressed as a priority.”

This is an acceptable amendment

This is an acceptable amendment and should be treated consistently where repeated elsewhere in the LCA as follows:

·         24-2 ‘Respect the setting of Rectory Lane Orchards to the west and the Medway Valley to the south in any development proposals’

·         27-6 ‘Encourage appropriate and sensitive use development of disused quarry workings to the north’

·         27-9 ‘Enhance and respect the built and natural environment through the sensitive integration of any further development’

·         30-2 ‘Respect the settings of the Len valley and Stoneacre Springs in any further development proposals’

·         30-5 ‘Reinforce the existing local character through sensitive building conversions which utilise local materials’

·         30-7 ‘Conserve the rural character of the landscape and rural views consider the high visibility of the area in any development proposals’

·         33 ‘Where development is permitted, Buildings and structures should be sensitively designed’

This is an acceptable addition with amended wording as follows:

‘… coverage by of parkland …’

It is suggested that for consistency this reads, ‘Reduce visual intrusion of development and associated lighting through native planting where practicable’’

Amend text

Amend text as per response

Amend text as per response

Amend text as per response

Page 250 at Summary of Actions add new bullet point “* Facilitate natural regeneration and expansion of relict oak woodland adjacent to Park Wood open space.”

This is an acceptable addition

Amend text

Page 256 at Summary of Actions at 2nd bullet point delete “balance” and replace with “enhance value for”.

This is an acceptable addition

Amend text

Page 279 at 30.11 delete “, unmanaged land between the urban edge and he stream”. Rationale: a very subjective statement.

This is an acceptable deletion

Amend text

Page 280 at Summary of Actions add new bullet point “Seek opportunities to restore quality and ecological function of the River Len and is corridor.”.

A central band of mature woodland along the Len and an area of ancient woodland to the east are designated as Local Wildlife Sites. An additional bullet point is suggested which reads, ‘Conserve and seek to restore where necessary the quality and ecological function of the River Len’.

Amend text as per response

Page 295 at Summary of Actions bullet point 3 add to end of sentence “…., and vegetation enhance structure through favouring longer grass sward.”

This is an acceptable addition with amended wording as follows:

 “…., and vegetation enhance vegetation structure …’

Amend text as per response

Page 305 at Key Characteristics panel add new bullet point “Species rich ponds west of Platts Heath.”.

The revised bullet point wording is suggested as follows:

‘Ponds, some of which are species rich’, to incorporate other ponds within the area eg west of The Ridge Golf Club.

Amend text as per response

Page 308 at Summary of Actions add new bullet point “Conserve and if opportunities arise extend pond complex west of Platts Heath.”.

This is an acceptable addition

Amend text

Page 311 at Summary of Actions  last bullet point insert at end “and, where opportunities arise, facilitate  ‘heathy’ woodland extensions .”.

This is an acceptable addition with amended wording as follows as not all soils in this area are considered acidic/suitable for heathy vegetation:

“and, where appropriate and where opportunities ...’

Amend text as per response

Page 335 at Summary of Actions add new bullet point “Safeguard  and, where opportunities arise, extend relict areas of lowland acid grassland and wood pasture.”.

This is an acceptable addition with minor amendment as follows for consistency:

“Safeguard  Conserve and …’

Amend text as per response

Page 342 Generic Guidelines at 6th bullet point start sentence “Conserve, enhance and extend the pattern of small ponds…………” and at 9th bullet point start sentence “Conserve the abundance of English oak and wild service trees within………………………….”.

These are acceptable amendments.

Amend text

Page  348 at 37.7 delete “well” from between “to be” and “managed.”.

This is an acceptable deletion

Amend text

Page 349 at Summary of Actions 5th bullet point add “with characteristic standard English oaks” between “hedgerows” and “where possible”.

This is an acceptable addition

Amend text

Page 357 at Summary of Actions add another bullet point “Safeguard and, where possible, extend native woodland blocks.”.

This is an acceptable addition with amended wording as follows for consistency:

“Safeguard Conserve and …’

Amend text as per response

Page 360 at Summary of Analysis change condition assessment to “Good” (from “Very Good”) and detracting features to “Some”.

The analysis is considered correct, fully justified by the text and consistent with surrounding Low Weald areas.  The suggested changes are not appropriate.

No change

Page 361 at Guidelines change to “Conserve and Restore” from “Conserve”

at Summary of Actions 3rd bullet point insert “, extend” after “Conserve” and before “and enhance”.

The analysis is considered correct and fully justified by the text. The suggested changes are not appropriate

This is an appropriate addition

No change

Amend text

Page 365 at Summary of Analysis change condition assessment to “Good”, cultural integrity to “Variable” and functional integrity to “Coherent”,at Guidelines box change to “Conserve and Restore” from “Conserve” and

at Summary of Actions at bullet point 4 add “and facilitate arable reversion to grassland where possible.” at end of sentence and add new bullet point “Establish new clean water ponds where opportunities arise.”.

The analysis is considered correct, fully justified by the text and consistent with surrounding Low Weald areas. Another point to bear in mind is that Cultural Integrity incorporates the built environment as well as natural elements. The suggested changes are not appropriate

These additions are appropriate and bullet points should be updated for the Generic Guidelines for the Low Weald for consistency and to avoid repetition as follows:

·             ‘Promote the conversion of intensively managed grassland and arable land to species rich neutral grassland where there is potential

·             Conserve, enhance and extend the frequent pattern of small ponds.’

No change

Amend text as per response

Page 369 at Summary of Actions add new bullet points “Conserve and increase extent of clean water ponds and small farm reservoirs.” and “Avoid widening of characteristic narrow lanes and ensure retention and appropriate management  of floristically diverse verges and banks.”.

The additions are appropriate.  New bullet points should be added to all Low Weald areas for consistency and similar bullet point 10 of the Low Weald Generic Guidelines should be replaced with suggested wording for second point.

Amend text as per response

Page 395 at 48.2 change penultimate line to following “This is low-lying with expanses of woodland with some significant stretches of fenland and open standing water adjacent to the river channel.”

This is an acceptable change

Amend text.

Guideline

Conserve

Conserve & Reinforce

Reinforce

Conserve & Restore

Conserve & Improve

Improve & Reinforce

Restore

Restore & Improve

Improve

Action

Encourage the conservation of distinctive features and features in good condition.

Conserve distinctive features and features in good condition and strengthen and reinforce those features that may be vulnerable.

Strengthen or reinforce distinctive features and patterns in the landscape.

Encourage the conservation of distinctive

features and features in good condition, whilst restoring elements or areas in poorer condition and removing or mitigating detracting features.

Conserve distinctive features and features in

good condition, whilst creating new features or areas where they have been lost or are in poor condition.

Strengthen or reinforce distinctive features and

patterns in the landscape, whilst creating new features or areas where they have been lost or are in poor condition.

Encourage the restoration of distinctive landscape features and the removal or mitigation of detracting features.

Restore distinctive features and the removal or

mitigation of detracting features, whilst creating new features or areas where they have been lost or are in poor condition.

Strengthen new features or areas where existing elements are lost or in poor condition.