At the end of Natural England’s press release confirming Lodge Hill had become an SSSI on tuesday were these words.
“The decision to extend the SSSI clarifies the environmental importance of the site but does not determine whether or not development can go ahead; this is a matter for the planning system. Natural England will continue to engage with the local planning authority (Medway Council), the landowner (Ministry of Defence) and its commercial partner (Land Securities) to contribute, as appropriate, to the planning process. In particular, and in order to contribute to sustainable development, we will consider carefully any proposals for a habitat creation scheme to offset the impacts on the special wildlife of the site, should development proceed.”
I thought – but how can Biodiversity Offsetting be applied to an SSSI? Except in the most exceptional circumstances….
The Biodiversity Offsetting Green Paper has this to say on the subject (para 31):
“For Sites of Special Scientific Interest the conditions of paragraph 118 of the National Planning Policy Framework would have to be met. The Government considers this could only be the case, depending on the circumstances, if the offset provided the same type of habitat as close as possible to the Site of Special Scientific Interest that would be harmed.”
now does this mean “close as possible” in a geographical sense, or close as possible in an ecological sense?
The NPPF para 118 states:
We cannot assume that the Offsetting Proposals in the Green Paper will proceed unchanged, though they may well do.
There are some key words/phrases in these policies which would benefit from more detail:
Benefit – as in benefit of the development clearly outweighing the impact on the SSSI.
Cannot be avoided – the top of the mitigation hierarchy. What circumstances would apply where an alternative location not on an SSSI was unsuitable?
depending on the circumstances – this could mean anything goes.
Vice Chair of Natural England, David Hill, who is also chairman of the Biodiversity Offset cheerleaders The Environment Bank, asked NE grassland specialist Richard Jefferson whether it was possible to recreate an equivalent grassland to the one at Lodge Hill in “about 40 years”. Richard stated that the recreated grassland would only be a facsimile of the grassland at Lodge Hill as it would be a much simpler grassland without all the complexities of the one at Lodge Hill. Of course, it was this very complexity that flummoxed the board in their gaining an understanding of the quality of the grasslands there.
How safe is Lodge Hill SSSI now from being developed and the impact offset?