APPENDIX A MAIDSTONE LANDSCAPE CHARACTER ASSESSMENT 2012 Response to comments from Member workshop 11 March 2013 Member comments Response Officer recommendation Philosophy behind document - The LCA follows up to date No change very concerned that guidance (Landscape required "fragmentation" of landscape Character Guidance for proposed within the document England and Scotland, Scottish flies in the face of NPPF Natural Heritage/The and Natural Environment Countryside Agency, 2002), White Paper which seeks to which is nationally recognised. engender "landscape scale" This methodology is consistent conservation and "networks for with the methodology used at nature". The beauty of county and national scale and the landscape is that it is a across neighbouring boroughs. patchwork of local difference Using the same consistent that when seen as a whole is approach allows the smaller beautiful. Special Landscape landscape character areas to Areas worked very well in this piece together into the larger regard as they operated at a areas, building up a hierarchy worthwhile scale. The to cover a wider, landscape proposed way forward will scale, area and to enable inevitably lead to an overall decision making at a strategic decline in landscape quality as and local scale. The protection of wider countryside assessment/methodology does becomes impossible under not aim to fragment the this "divide and landscape, but to draw out the rule" methodology. 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’. Page 8 A general point in Amend text as per response to several comments response 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.’ page 46 bullet point 5 insert This is an acceptable addition Amend text "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. Page 51 bullet point 4 add This is an acceptable addition Amend text as per "through introduction of native with minor amendment as response hedgerows and" between follows: "boundaries" and avoiding". Rationale: hedgerows have "through the introduction of been lost from this area and native hedgerows and" were formerly a key landscape between "boundaries" and by feature now largely grazed- avoiding" out, burned-out or grubbed. Bullet point 6 add This is an acceptable addition Amend text "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 This is an acceptable addition Amend text introducing greater woodland structural diversity" after "coppice". Rationale: key objective in local Kent Downs woodlands. Bullet point 11 add "reducing This is an acceptable addition Amend text over-grazing" between "by" and "removing". Rationale: key objective in local Kent Downs woodlands. Page 55 add new bullet points This is an acceptable addition Amend text as per 5 and 6 as follows: * Establish with minor amendment as response wooded network incorporating follows: scarp woodlands, Malling and Monkdown Woods. * Restore * Restore and expand extent and expand extent of relict of relict roadside field ponds, roadside field ponds, which which were formerly a key were formerly a key feature of feature of this part of the dip this part of dip slope. slope. Rationale: key local landscape and biodiversity objectives. Page 56 within key This is an acceptable Amend text characteristics panel last bullet amendment point remove "very" and "unkempt". Rationale: not in fact locally characteristic and perjorative. Page 58 remove lines from 3.7 Suggest addition to second Amend text as per starting "Where the fields...." paragraph as follows: response and ending at "moderate" and at end of 3.7 replace "poor" ‘Visual detractors include with "moderate". the tall electricity pylons, large metal and concrete sheds and flytipping.’ Suggest deleting the following: Amend text as per response ‘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 No change a consistent and complex required 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. Page 59 Summary of Analysis The overall landscape No change change Condition Assessment condition of ‘poor’ is based on required from "poor" to "moderate" and a consistent and complex ecological integrity from assessment approach and an "moderate" to "good". 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. At Summary of Actions add at This is an acceptable addition Amend text end of bullet point 4 "to enhance structural diversity." At bullet point 7 delete This is an acceptable deletion Amend text "encouraging grazing within fields which appear abandoned and" At bullet point 8 delete "by This is an acceptable deletion Amend text trimming the hedgerows more regularly". Rationale: very difficult to place some of this narrative within the correct landscape character area. Page 62 at 4.6 remove This is an acceptable deletion Amend text "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! Page 64 at Summary of The Sense of Place is based on No change Analysis replace Sense of a consistent and complex required Place: "weak" with assessment approach and an "moderate". 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. At Summary of Actions add This is an acceptable addition Amend text as per new bullet point "* Increase with minor amendment as response extent of tree coverage across follows: intensively cultivated areas as opportunities arise.". "* Increase extent of native Rationale: this character area tree coverage across areas of has lost significant areas of intensively cultivated areas (ancient) woodland and most land as opportunities arise." of its hedgerow trees in the fairly recent past (since 1970s) and this fact is not recognised. Page 69 at Guidelines table The overall Guideline of No change and header change "Conserve" ‘Conserve’ is based on this required to "Conserve and Restore". landscape being in good Rationale: a brief glance at condition and highly sensitive. JNCC Inventory of ancient To change the overall woodlands or an old map Guideline to ‘Conserve and starkly illustrates the loss of Restore’, the Condition would tree cover to arable cropping need to be degraded to since the 1970s - this cover moderate. The analysis for should be restored. 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). At Summary of Actions bullet This is an acceptable addition Amend text point 4 add "and enhance structural diversity," between "woodlands" and "particularly". At bullet point 6 add "and Scrub inhibits chalk grassland No change to text scrub" between "grassland" and scrub clearance is on this point but and "by ensuring" sometimes used as a add the following management tool to help to the Landscape regenerate chalk grassland Description: species, so to add that the “Uncommon conservation of scrub is scrub species desirable is not always occur locally appropriate. such butcher's broom and unusual bramble species on the dip-slope.’’ and delete "sheep" between These are acceptable changes Amend text as per "appropriate" and "grazing". with minor amendment