Statement of Environmental Particulars for the Medway Estuary and Swale Shoreline Management Plan

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1 Statement of Environmental Particulars for the Medway Estuary and Swale Shoreline Management Plan Introduction This statement of particulars indicates how environmental and consultee considerations were taken into account during the preparation of the plan and how the Environment Agency selected the approach adopted in the final plan. The statement goes on to set out the monitoring procedures that have been set in place to monitor the significant environmental effects of the implementation of the plan/programme. The environment during the development of the plan Integration of environmental considerations Environmental considerations were integrated throughout the development of this plan by following the Environment Agency s SEA operational instruction. This document ensures the potential significant effects of the plan on the environment are considered throughout its development. Influence of the environmental report The environmental report that was open to public consultation influenced the development of the plan by identifying environmental enhancements and setting out requirements for mitigation, where significant negative effects were identified. Environmental Topic Population & Human Health Agreed Mitigation/Enhancement activity The opportunity exists for rerouting of footpaths (including the Medway Valley Walk, and Saxon Shore Way in some locations) or creation of new footpaths where MR is implemented. There may be opportunities to enhance recreation and amenity features. It may be necessary to relocate or raise roads where natural erosion will retreat the coastline. Need to develop an exit plan for relocation of people and removal of properties where these may be adversely affected. Responsibility for implementation on population & human health as part of SEA at strategy, and EIA at scheme Further assessment of opportunities to enhance recreation and amenity as part of SEA at strategy, and EIA at scheme Further assessment of access will be required as part of SEA at strategy, and EIA at scheme on population & human health as part of SEA at strategy, and EIA at scheme Biodiversity, Flora & Fauna The need for mitigation in HRA as part of SEA at

2 Water Historic Environment Landscape & Visual Amenity relation to impacts on European conservation designations will be considered within a Habitats Regulations Assessment (HRA) at strategy and scheme Compensatory habitat will need to be secured before any European designated habitat is lost as a result of MR. The effect of coastal squeeze/accelerated erosion on the transitional water body will be considered during the River Basin Management Plan (RBMP) review and may require further consideration at strategy or scheme level in order to comply with the Water Framework Directive (WFD). Need to further investigate the effect of groundwater extraction on groundwater levels. Need to monitor and record finds if unknown buried archaeology is discovered. Survey, monitor and record Cockham Wood Fort Scheduled Monument to proactively implement an exit plan strategy if and when required as a result of natural coastline erosion. Landscape and visual impacts associated with defence raising should be considered further at strategy or scheme Potential for visual enhancement with a more natural coastline as Managed Realignment (MR) is strategy, and EIA at scheme HRA as part of SEA at strategy, and EIA at scheme in RBMP and as part of SEA at strategy, and EIA at scheme Further assessment of the effects of groundwater extraction will be required as part of SEA at strategy, and EIA at scheme on historic environment as part of SEA at strategy, and EIA at scheme on historic environment as part of SEA at strategy, and EIA at scheme on landscape & visual amenity within Strategic Environmental Assessment (SEA) at strategy level, and Environmental Impact Assessment (EIA) at scheme on landscape & visual amenity as part of SEA at strategy, and EIA at scheme

3 Soils & Geology Land Use, Infrastructure & Material Assets established. Need to further investigate the potential for contamination of water resources, and issues associated with Rushenden disposal site and Hoo Island landfill site. No mitigation has been identified for losses of agricultural land. Further assessment of the potential for contamination of water resources, and the issue of Rushenden disposal site and Hoo Island landfill site as part of SEA at strategy, and EIA at scheme Appropriate mitigation for loss of agricultural land will need to be considered as part of SEA at strategy, and EIA at scheme Consultation responses Responses to consultation period (14 th May 2007 to 7 th September 2007) 29 consultation responses were received during the 17 week consultation on the draft plan and its accompanying environmental report. The majority of consultation responses related to specific issues with Policy Units, support for the SMP, environmental issues and defences. All comments received were thoroughly reviewed and considered, and answers or links to further information provided where possible. Following consideration of comments, in no instance was a case identified to justify a change in any of the SMP policies. The table below indicates where consultation responses led to alterations and additions to sections of the SMP. Consultee Summary of comments Action taken to finalise Plan Edward Vinson Ltd F.D. Attwood and Partners Friends of the North Kent Marshes Lower Medway Internal Drainage Board Lafarge RSPB Friends of the North Kent Marshes Natural England Lower Medway Internal Drainage Board Concerns about the extent of, impacts of, or objections to the policy of Managed Realignment (MR). Concerns / comments about the impact of MR on internationally designated freshwater habitat. A timetable of further studies to assess MR will be included in the SMP Action Plan. More detailed studies will be undertaken at Strategy Study A more detailed economic appraisal of the financial viability of defences will be undertaken at Strategy Study An Appropriate Assessment under the Habitats Regulations was undertaken to assess the impact of the SMP on internationally designated sites. SMP recognises that compensatory freshwater habitat needs to be secured before it is lost and therefore makes recommendations in the SMP Action Plan that

4 Lafarge F.D. Attwood and Partners Upchurch Parish Council CPRE Kent F.D. Attwood and Partners Halling Parish Council Swale Borough Council CPRE Kent Port Werberg CPRE Kent South East Regional Assembly Tonbridge and Malling Borough Council Faversham Creek Consortium Management Group North Kent Rivers CFMP Project Manager Natural England Stoke Parish Council RSPB Port Werburg Comments / concerns about the economic assessment process. Comments concerning the lack of compensation to land and property owners, through potential loss of assets under the proposed policies. Comments were raised concerning the consultation process with stakeholders. Comments concerning the relationship of the SMP and other plans / policy. Comment on flood risk of Lower and Middles Stoke in Policy Unit E4 02 Colemouth Creek to Bee Ness Jetty. Comments about failure to mention impacts on intertidal habitat in Policy Unit E4 05 Hoo Marina to Lower Upnor. Comment about Hoo Marina and current flooding of the Saxon Shore Way in Policy Unit E Hoo Marina to Lower Upnor. further studies will be required to investigate mitigation measures for loss of designated freshwater habitat. SMP policies were not derived based solely on the economic assessment. More detailed economic assessments will be undertaken at Strategy Study As a non-statutory policy document for coastal defence planning the SMP is unable to provide solutions to issues such as compensation. Defra are investigating the best ways to help people adapt to situations where property is exposed to greater flooding and erosion. Further consultation will take place at Strategy Study levels. Text was added to the main SMP document explaining where the SMP sits in relation to Strategies and Schemes and how the SMP is used to inform spatial planning. SMP amended to reflect that fact that the villages of Lower Stoke and Middle Stoke are not all on higher ground. Predicted to be no adverse impact on the habitat as a result of the policy text in SMP amended to reflect this. Hoo Marina is actually in Policy Unit E4 04, the title of Policy Unit E4 05 Hoo Marina to Lower Upnor was considered misleading and was changed to E4 05

5 RSPB Lower Medway Internal Drainage Board Comment on lack of impact on SSSI in Poliy Unit E4 07 Medway Bridge to North Halling. Query over which is correct policy for Policy Unit E4 11 Wouldham Marshes. Chatham Maritime Trust MR in Policy Units E408, E4 09, E4 10 and E4 11 could result in more rapid deterioration of the historic masonry revetment around St Mary s Island. Upchurch Parish Council No mention of need to re-route Saxon Shore Way in Policy Unit E4 16 Ham Green to East of Upchurch. RSPB Habitat in Policy Unit E4 22 Milton Creek is saline lagoon not grazing marsh. Environment Agency - Groundwater and Contaminated Land RSPB The ability to Hold The Line in Policy Unit E4 22 Milton Creek, may be compromised by groundwater flooding behind the line under certain groundwater conditions. The National Nature Reserve (NNR) impacted in Policy Unit E4 27 North Elmley Island to Kingsferry Bridge is Elmley NNR not the RSPB reserve. Cockham Wood. Text changed in SMP to read Saxon Shore Way will become inundated more often as sea levels rise. Text in SMP altered to reflect no impact on nature conservation. Policies shown on the map in the consultation draft were incorrect, these were corrected in the final SMP. SMP text altered to reflect potential for impact on the historic environment in Policy Unit E4 13. SMP text altered to reflect the requirement to re-route the Saxon Shore Way footpath. SMP text altered to reflect the loss of saline lagoon instead of grazing marsh. The SMP text was altered to reflect this, which will also be considered in more detail at Strategy Study SMP text altered to reflect the fact that the NNR is Elmley NNR and not the RSPB reserve. Transboundary consultation responses The SEA did not identify any significant environmental effects that required trans-boundary consultation on this plan. Due to this, no consultation responses were received via this consultation route.

6 Reasons for selecting the adopted plan in light of reasonable alternatives The approach adopted in the final plan was considered against a number of reasonable alternatives during its development. The major reasons for selecting the adopted plan over the reasonable alternatives are shown in the table below. Further details on the selection of the preferred option, which was developed into the adopted plan, are presented in its environmental report. Information on how to access a copy of the environmental report can be found in the post-adoption statement, which can be found at

7 HTL = Hold The Line MR = Managed Realignment NAI = No Active Intervention Preferred Policy Unit E4 01 Grain Tower to Colemouth Creek E4 02 Colemouth Creek to Bee Ness Jetty E4 03 Kingsnorth Power Station E4 04 Power Station to Cockham Wood E4 05 Hoo Marina to Lower Upnor E4 06 Lower Upnor to Medway Bridge Epoch Years Epoch Years Epoch Years Reasons for selecting the adopted plan in light of reasonable alternatives HTL HTL HTL Nationally important industry and infrastructure in the area (Power Station, Thamesport). Area proposed as a Thames Gateway regeneration area. Internationally important intertidal habitat. Nationally important infrastructure in the area (pipelines, road, railway) therefore NAI not suitable. Some opportunities for managed change to defence line. Internationally important intertidal habitat. HTL HTL HTL Nationally important Power Station / infrastructure, also proposal for a new power station along the frontage, therefore NAI / MR not suitable. Internationally important intertidal habitat. Marina and residential community south of Hoo St Werburg. Some areas identified as being suitable for habitat creation. will enable more flexible estuary management and better flood and erosion risk management in the future. NAI NAI NAI NAI is the current policy for this unit. Some important cliff top Heritage assets will continue to be exposed. HTL HTL HTL Urban area with a large number of built residential and commercial assets. E4 07 HTL HTL HTL Sub-regionally important infrastructure. for epochs 2 and 3 to enable more flexible estuary management and better flood and

8 Medway Bridge to North Halling E4 08 North Halling to Snodland E4 09 Snodland to Allington Lock E4 10 Allington Lock to north Wouldham E4 11 Wouldham Marshes E4 12 Medway Bridge to east St Mary s Island E4 13 St Mary s Island to the Strand E4 14 The Strand to west Motney Hill HTL HTL erosion risk management in the future. Localised Settlements. will enable more flexible estuary management and better flood and erosion risk management in the future. A proposal for MR at Halling currently exists. Nationally important Aylesford Conservation Area & Holborough to Burham Marshes SSSI. Localised Settlements. Some areas are identified as suitable for habitat creation. for epochs 2 and 3 will enable more flexible estuary management and better flood and erosion risk management in the future. Nationally important Aylesford Conservation Area. Localised Settlements. Some areas are identified as suitable for habitat creation. for epochs 2 and 3 will enable more flexible estuary management and better flood and erosion risk management in the future. MR MR MR Frontage suitable for habitat creation. Pylons across this frontage render NAI unsuitable. MR will enable more flexible estuary management and better flood and erosion risk management in the future. HTL HTL HTL Urban area with a large number of built residential and commercial assets. Internationally important Chatham Dock. Frontage includes multiple areas of proposed regeneration / development. HTL HTL HTL Urban area with a large number of built residential, commercial and recreation assets therefore MR / NAI not suitable. HTL MR MR Intertidal internationally designated as SPA and Ramsar and nationally as a SSSI. Potential contaminated land. Sewage pipes run parallel to the shoreline along this frontage. HTL should be implemented in the short term to allow for further study regarding infrastructure & contamination. MR should be the favoured policy for the second and third epochs for

9 E4 15 Motney Hill to Ham Green E4 16 Ham Green to east of Upchurch E4 17 East of Upchurch to east Lower Halstow E4 18 Barksore Marshes E4 19 Funton to Raspberry Hill E4 20 Chetney Marshes E4 21 Kingsferry Bridge to Milton Creek E4 22 Milton Creek sustainability. Nor Marsh and Motney Hill are an RSPB Nature Reserve. Localised Settlements. will enable more flexible estuary management and better flood and erosion risk management in the future. NAI NAI NAI Frontage has a very narrow floodplain due to higher land therefore any built assets will not be at risk from NAI. Intertidal internationally designated. Localised Settlements. for all three epochs to enable more flexible estuary management and better flood and erosion risk management in the future. MR NAI NAI Coastal grazing marsh internationally designated. Intertidal habitat internationally designated. Areas identified as suitable for habitat creation. MR should be implemented in the 1st epoch to ensure that the habitat landward of the defences could be appropriately managed followed by NAI for the second and third epochs. NAI NAI NAI There is no flood or coastal protection issue along this frontage (frontage backed by small road and orchards); therefore HTL would not be sustainable. There are alternative roads to use if this road were to be lost. MR MR MR Part of Chetney Marshes is a compensatory habitat area for the A 249 road. Coastal grazing marsh internationally designated. MR will enable more flexible estuary management and better flood and erosion risk management in the future. HTL HTL HTL Coastal grazing marsh & Intertidal internationally designated Regionally important industrial and commercial area. HTL HTL HTL Large number of industrial and built assets, and infrastructure along creek, therefore NAI / MR rejected.

10 E4 23 Murston Pits to Faversham E4 24 Faversham to Nagden E4 25 Shell Ness to Sayes Court E4 26 Sayes Court to north Elmley Island E4 27 North Elmley Island to Kingsferry Bridge E4 28 Kingsferry Bridge to Rushenden HTL Coastal grazing marsh & Intertidal internationally designated. Areas along the frontage identified as suitable for habitat creation. localised HTL (specifically at Conyer and Oare) will enable more flexible estuary management and better flood and erosion risk management in the future. HTL HTL HTL Coastal grazing marsh & Intertidal internationally designated. Large number of industrial, commercial and residential assets at Faversham, therefore NAI / MR rejected. MR MR MR Coastal grazing marsh & Intertidal internationally designated. National heritage feature at Sayes Court located on high land. Large floodplain, therefore NAI rejected due to uncontrolled flooding of large area of land which may have negative implications on the estuary as a whole. MR will enable more flexible estuary management and better flood and erosion risk management in the future. MR MR MR Coastal grazing marsh & Intertidal internationally designated. National heritage feature at Sayes Court located on high land. Large floodplain, therefore NAI rejected due to uncontrolled flooding of large area of land which may have negative implications on the estuary as a whole. MR will enable more flexible estuary management and better flood and erosion risk management in the future. HTL MR MR Coastal grazing marsh & Intertidal internationally designated. Large floodplain, therefore NAI rejected due to uncontrolled flooding of large area of land which may have negative implications on the estuary as a whole. HTL should be implemented in the short term to allow for further study regarding MR along the frontage, due to possible implications regarding essential infrastructure (i.e. railway line and A249). HTL MR MR Coastal grazing marsh & Intertidal internationally designated. Rushenden dredging disposal site may be contaminated, consequently NAI not suitable. HTL should be implemented in the short term to allow for further study regarding MR along the frontage, due to possible implications regarding essential infrastructure (i.e. railway line, A249 and sewage works) and contamination of land at Rushenden disposal site.

11 E4 29 Rushenden to Sheerness E4 30 Medway Islands HTL HTL HTL Intertidal internationally designated. Large number of heritage, commercial and residential assets along the frontage, therefore NAI / MR not suitable. Proposed regeneration and residential development areas along the frontage. NAI NAI NAI Monitoring programme will be required to assess future management of the islands.

12 Environmental monitoring measures during Plan implementation Monitoring of mitigation measures and environmental effects is described at a high level in the SMP Action Plan, and will be developed in detail under future strategy studies and schemes emerging from the SMP. In a general sense, environmental monitoring will comprise: Development of habitat management and monitoring plans, where appropriate; The need to carry out Habitat Regulations Assessments at strategy/scheme level for some European designated nature conservation sites; Investigating opportunities for habitat creation where managed realignment is proposed; Continuing to consult key stakeholders and the general public during strategy development; and, Further studies at strategy or scheme level to investigate the potential impacts of flooding and erosion on important heritage features (known and unknown) at risk and to consider an appropriate programme of survey, recording and investigation to record these important sites, and those potential features not yet identified. Developments implemented as a result of the plan will be subject to environmental impact assessment at project and strategic level as appropriate. Additional environmental monitoring required will be identified from these assessments.