The Estates Department

(Rebecca Frier)
Kent County Council
Sessions House
Maidstone
Kent
ME14 1XQ

Kent County Council Consultation on the disposal of land

Local Government Act 1972
Section 123(1)(2a)
The Intended Disposal of Open Space Response from Kent Wildlife Trust
Kent County Council has announced that it intends to consult the public on the sale of a number of
sites that it owns in the County, in particular Park Wood, Preston Hill, Blue Bell Hill Picnic site, The
Larches and Dry Hill. Following a widespread expression of concern after the publication of the
Notices, KCC has issued a statement that it is proposing to suspend the process pending a further
consultation in due course.
Kent Wildlife Trust is greatly concerned about KCCs intentions, the process as it has been conducted
to date and possible outcomes. All the sites concerned are of great local interest, with exceptional
biodiversity value, designated as Sites of Special Scientific Interest or Local Wildlife Sites and
vulnerable to inappropriate management or neglect. It is important that their future is secured for
the long term. All the sites will have come into KCC control because at some time in the past there
was recognition of their wildlife, geological, landscape and amenity value. This is our heritage and
public ownership has been regarded as an appropriate way of securing its long term future.
For none of the sites has it been demonstrated that their importance has waned and all contribute
to the heritage riches that make the Kent countryside the glory it is. None of the sites appears to
offer a financial return to a buyer unless their current wildlife value is, at best, threatened.
KCC has been a responsible and careful owner of this land for many years; this has been one of the
proper and necessary roles of a local authority, but at a time when local government faces falling
budgets Councilors must make many difficult decisions. This does not absolve them from the need
for careful and responsible judgement with, in this case, the long term protection of Kents
landscape in mind.
Kent County Council has a duty under the Natural Environment and Rural Communities Act, 2006,
Section 40 (1) to conserve biodiversity. We believe that this requires the Council, if it chooses to
dispose of any publicly owned land of significant biodiversity value, to do so responsibly and ensure
that value is retained. The proposed process, apparently seeking a financial return, is in this context,
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untenable and unfair. It is likely that the only future owner of this land able to maintain the current
value of the sites to people and wildlife will be another public body (District or Parish Council) or a
charity such as Kent Wildlife Trust. Neither is likely to be in a stronger financial situation than KCC.
It is perverse for a public body such as KCC to compromise the security of these important local
landmarks that are already in public ownership and then await Parishes or charities to secure more
money from the people of Kent to rescue and then manage them.
This process appears to be contrary to KCCs policies. KCC is currently consulting on the draft Kent
Environment Strategy, the document that will direct KCCs approach to the environment for years
ahead. It points to the gradual loss of habitats and species in the county (which) represents a
significant threat to the intrinsic value of Kents natural environment and the economic and social
benefit it provides and commits to improve and enhance functional habitat networks .
protecting and enhancing our natural and historic landscape. These sites which are proposed for
disposal are at the very heart of the networks KCC wants to promote.
Blue Bell Hill and the Larches: The consultation includes the future of two sites that Kent Wildlife
Trust is actively managing on KCCs behalf, Blue Bell Hill and the Larches. This is a partnership KWT
values greatly. Both sites are important for their wildlife and geological value and both have
benefitted from a great deal of work by Trust volunteers and staff. The Trust would like to maintain
its involvement with these beautiful and cherished areas managing for people and wildlife - but we
do not believe that it is appropriate to seek the support of our members to purchase this land which
is already in public ownership. In both cases the nature and scale of the public use is such that we
believe the costs for that should not fall solely on our supporters.
Conclusion

We welcome KCCs decision to delay the consultation on its plans.

We recognize and applaud KCCs long-term custodianship of these important areas, all with
significant designations for their wildlife importance.
The important wildlife designations on all these sites must be given a high priority in KCCs
decision-making - this is in keeping with KCCs own draft strategy. The future of these sites
must not involve a loss of biodiversity.
We would encourage KCC to reconsider its decision to use this process to raise money and
that the financial viability of these sites is not used as the only measure of their
importance to the local economy.
The growing awareness of the value of access to natural open space for public health and
wellbeing is a matter that should be high in KCCs thinking about the future of these sites.
KCC must behave responsibly and with care to ensure the long term security of this land.
Very few of the possible future ownership arrangements could guarantee either the proper
management or integrity of the land beyond the short term.

Kent Wildlife Trust wants to build on long standing, established and productive arrangements with
the Council and would welcome further discussion. KCC should talk to the Trust and other possible
partners to seek solutions, but should not assume that it is appropriate for these partners to take on
all the costs that KCC wishes to lose.

John Bennett
Chief Executive
28.01.2016
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Appendix
Wildlife Status of KCC sites which we believe to be subject to consultation.
Site
Blue Bell Hill

Designation
Part of Wouldham to
Detling Escarpment SSSI
KWT reserve

Habitats
Chalk grassland
Broadleaved woodland
Scrub woodland

Notable species
Stinking hellebore
Box
Lady orchid

The Larches

Part of Wouldham to
Detling Escarpment SSSI
KWT reserve

Chalk grassland
Scrub
Woodland

Man Orchid
Meadow Clary
Chalk milkwort
Ground pine
Pyramid orchid
Fragrant Orchid

Broadleaved helleborine
Twayblade
Straw belle moth
Hallodapus montandoni
Bug
Bullfinch (Amber list)
Adder

Dry Hill

Dry Hill geological SSSI

LWS SE41 Dry Hill Country
Park, Sundridge

Ragstone Quarry

Sainfoin
Bee orchid
Pyramid orchid
Birds-foot

Didineis lunicornis wasp

Nomada fucata wasp
Cheilosia sosror
hoverfly
Lithophasia hyalipennis
small parasitic fly

Tiered tooth fungus

Pyramid Orchid
Man Orchid
Fragrant Orchid

Adder
Viviparous lizard
Great Heron
Wood

Part of LWS AS20

126 ha near Appledore

Ancient broadleaved
woodland

Badger
Heron still breed here
Early purple orchid
Nightingale
Hobby
Willow warbler
Goldcrest
Marsh tit
Willow tit

Park Wood
(Part of Great
Heron Wood?)

Part of LWS AS20 near

Appledore

Ancient broadleaved
woodland mainly
Hornbeam.
Standing water

Lesser skullcap
Early purple orchid
Climbing corydalis
Nightingale
Willow warbler
Hobby
Fieldfare

Preston Hill

Part of Otford to Shoreham

Downs SSSI

Chalk grassland
Chalk scrub
Woodland on a variety
of soils

Fragrant orchid
Man Orchid
Chalk milkwort
Ptilophora plumigera plume
moth
Eydonia delunella plume
moth

Goldcrest
Marsh tit
Willow tit
Green woodpecker
Smooth newt
Palmate newt