23rd July 2013
Mr J Chambers
Head of Strategic Project
Shepway District Council
The Civic Centre
Castle Hill Avenue

Folkestone

Kent

CT20 2QY

DearMr Chambers

Princes Parade Project

Kent Wildlife Trust has been informed of the study to identify possible development on Princes Parade by members of the public. As currently we have had no input into this process, and due to the proximity of the Royal Military Canal to the proposed development, we would like to make the following comments which we hope you will feel able to consider during any future stage of the project.

The Ecological Value of the Royal Military Canal Local Wildlife Site

The Royal Military Canal Local Wildlife Site is designated for itsrare flora species and is also notable for supporting 12 species of odonata, dragonflies and damselflies. The site provides an important linear linkage for a number of species and a wide variety of birds have been recorded in the area. The site is known to support grass snake and common toad and is used for foraging by pipistrelle and Daubenton’s bats.

The Ecological Value of Princes Parade

Princes Parade contains important areas of natural habitat both within and adjacent to the study area. The ARCH project 2012 has identified Festuca Rubra maritime grassland running adjacent to the road and promenade and extending into the site at the western end. This maybe a Biodiversity Action Plan habitat and a Habitat of Principal Importance under the Natural Environment and Rural Communities Act 2006 and should be surveyed thoroughly and conserved within any development proposed. This habitat has not been identified within the Phase 1 Habitat survey undertaken.

Adjacent to the car park, outside the area to be developed, fixed sand dunes with herbaceous vegetation are present. This is an extremely rare habitat and impacts will need to be considered. It will be important that thorough investigations are undertaken to ensure that both the maritime grassland, the sand dunes and the flora and water quality of the Royal Military Canal are not impacted by any release of contaminants as a result of development. Due to the contamination present we are concerned that these valuable habitats could be impacted by the proposals.

It will also be important that the sites value as a supporting habitat for migratory and wintering birds is investigated. Due to the value of the Kent coast for these species and the location of the site between two important SPAs at Dungeness and Sandwich Bay, coupled with the built up nature of the coast between these SPAs, it will be important to be clear regarding the function of this site as a stop off point for SPA bird species.

Princes Parade is also likely to function as an extension of the natural habitat within the Royal Military Canal LWS. Within the Phase 1 survey dragonflies were noted and the site was identified as providing habitat for protected and priority species which contribute to the biodiversity of the LWS. We do not feel that the proposed buffer of 8m would be adequate to protect the species that are using the canal and would recommend that a more extensive buffer is designed into any development with any habitat lost being provided elsewhere along the canal if at all possible.

The maritime grassland and the proximity of the sand dunes and its possible importance as a stopping off point for SPA bird species, combined with the sites function as an extension of the wildlife corridor formed by the Royal Military Canal LWS means this site is likely to be of high importance ecologically.Kent Wildlife Trust is concerned that the proposed development could impact on important habitats of Principal Importance and limit the ecological diversity within the Royal Military Canal. Any development proposed will need to conserve the important maritime habitats on site, provide an extensive buffer to the LWS and protect the habitats on and adjacent to the site from possible contamination. Due to the likely biodiversity value of the site, the lack of coastal habitat left outside the designated areas adjacent to the coast and the possible value for SPA and protected species we would request that we are consulted on any further proposals for development.

We would be happy to meet to discuss our concerns.

Yours sincerely

Debbie Salmon

(Conservation Officer, Policy and Planning)