Response by the Friends of Betteshanger to the Cover Letter by Quinn Estates dated 29th October 2020 .
Betteshanger development 20/00419
Whilst we acknowledge the decision to retain the whole of Woodland block W4 it does not ‘solve’ the issue of Turtle Doves, just as not building at the A258 end of the site did not ‘solve’ the issue. Here are our reasons for this assertion:
1. The proposals are still going to result in the loss of Turtle Dove territory as shown in 5.10.8 of the Ecological Appraisal of July 2020, submitted by Aspect Ecology and commissioned by Quinn Estates. This is what it says in relation to Turtle Doves:
“The fourth territory is located within an area proposed for development ….. The development will also result in potential for increased disturbance and predation of Turtle Doves associated with the residential housing and domestic pets. Accordingly whilst suitable Turtle Dove habitat will be retained … the proposed development could result in the loss of some territories.”
Although Woodland W4 is to be retained this is not where Turtle Doves were found. Turtle Doves prefer to nest in thick scrub rather than woodland. The Cover letter tells us that, despite the changes, 0.16ha of woodland habitat will still be lost. This includes the ‘fourth territory’ of Turtle Doves, mentioned above and shown on map 5805/EC04 in the Ecological Appraisal. There is no apparent plan to change the proposed development to avoid this.
2. It is important to note that Turtle doves return to the same territory year after year. This has been proved by RSPB research into Turtle Dove migration using tracking devices fitted to individual birds, as the following link will show.
3. It is not possible to solve the problem of ‘increased disturbance and predation of Turtle Doves associated with the residential housing and domestic pets’ by mitigation measures. Only protecting the site from development will do this.
4. Turtle Doves do not just use the Betteshanger site for nesting. It is a feeding area too. The RSPB link above, ‘A year in the life of a Turtle Dove’ shows a picture of a typical Turtle Dove feeding area. It bears a very strong resemblance to the Betteshanger development platforms with sparse vegetation, bare areas and seeds from the many flowering plants. This food source will of course disappear under the proposals.
5. So Turtle Doves will lose territories, lose a food source and be subject to disturbance and predation if the development goes ahead. They will doubtless abandon the site. And their precarious hold in East Kent will be further jeopardised.
5. Why does all this matter ?
The latest information from December 2019 about the status of Turtle Doves from the British Trust for Ornithology says the following: (see link below)
“The Turtle Dove’s demise is now almost total showing a 98% decline. This is the largest decline of any UK species and suggests that this once familiar bird will soon disappear from the British countryside.”
We reiterate our view that given the perilous situation of Turtle Doves in the UK it is totally unacceptable to destroy or disturb any Turtle Dove territory or build where the result could be an even further diminishing of their numbers. The only solution here and the only way to protect the Betteshanger population of Turtle Doves is not to build on the site.
However Turtle Doves are not the only species of great conservation concern that are going to be negatively impacted by the proposed development. There are also, for example, Grey Partridge, which the East Kent Wildlife group identified on site in the summer of this year, and believed to be breeding on the proposed development site.
The most recent Breeding Bird Survey report by the British Trust for Ornithology, the RSPB and the Joint Nature Conservation Committee shows that the number of breeding pairs of Grey Partridge have declined by 64% between 1995 and 2018 in the UK.
We maintain that the Local Planning Authority also has a duty to conserve the Grey Partridge, given that it is one of the fastest declining birds in the whole of Europe.
We maintain that is has a duty to conserve all the other Red and Amber listed bird species, the Reptiles and Amphibians, the Bats and Badgers, the rare Plants and Invertebrates all of which have taken up residence at Betteshanger, where habitats have been establishing and rewilding, largely free of human interference, for many years.
We maintain it has a duty to conserve a site that would be very likely to qualify as a Local Wildlife Site such is the richness and quality of its wildlife and habitats.
Sue Sullivan for the Friends of Betteshanger