Rother Local Plan 2020-2040 (Regulation 18)

Supportive of this paragraph 11.67 but it should be more definite about what is required, in particular:
Swift bricks should be installed in all new developments including extensions in accordance with best-practice guidance such as BS 42021 or CIEEM. Swift bricks are a universal nest brick for small bird species.

Please add:
Existing nest sites for building-dependent species such as swifts and house martins should be protected, as these endangered red-listed species which are present but declining in Rother return annually to traditional nest sites. Mitigation should be provided if these nest sites cannot be protected.

This is because nesting sites in buildings are excluded from the Biodiversity Net Gain methodology so need their own clear policy.

In summary, the reference to bird bricks is welcome but please be more definite about what is required, as swift bricks are the only integral nest brick that meet best-practice guidance BS 42021.

Therefore please add to the policy:

Swift bricks to be installed in new developments including extensions, in accordance with best practice guidance such as BS 42021 or CIEEM which require at least one swift brick per home on average for each development. Artificial nest cups for house martins may be proposed instead of swift bricks where recommended by an ecologist.

In more detail, the reason for this is that bird boxes/ bricks and other species features are excluded from the DEFRA Biodiversity Net Gain metric,
so require their own clear policy.

Swift bricks are the only type of bird box specifically mentioned as valuable to wildlife in national planning guidance, along with bat boxes and hedgehog highways (NPPG Natural Environment 2019 paragraph 023). The National Model Design Code Part 2 Guidance Notes (2021) also recommends bird bricks (Integrating Habitats section on page 25, and Creating Habitats section on page 26).

Swift bricks are considered a universal nest brick suitable for a wide range of small bird species including swifts, house sparrows and starlings (e.g. see NHBC Foundation: Biodiversity in New Housing Developments (April 2021) Section 8.1 Nest sites for birds, page 42: https://www.nhbcfoundation.org/wp-content/uploads/2021/05/S067-NF89-Biodiversity-in-new-housing-developments_FINAL.pdf ).

Schwegler 1A swift bricks also support house martins.

Swift bricks are significantly more beneficial than external bird boxes as they are a permanent feature of the building, have zero maintenance requirements, are aesthetically integrated with the design of the building, and have improved thermal regulation with future climate change in mind.

Therefore, swift bricks should be included in all developments following best-practice guidance (which is available in BS 42021:2022 and from CIEEM (https://cieem.net/resource/the-swift-a-bird-you-need-to-help/)).

Many other Local Authorities are including detailed swift brick requirements in their Local Plan, such as Tower Hamlets Local Plan Regulation 18 stage (paragraph 19.70, page 311 - https://talk.towerhamlets.gov.uk/17424/widgets/82097/documents/50138 ),

which follows the exemplary swift brick guidance implemented by Brighton & Hove since 2020,

and Wiltshire Local Plan Regulation 19 stage, which requires an enhanced number of 2 swift bricks per dwelling (policy 88: Biodiversity in the built environment, page 246 - "As a minimum, the following are required within new proposals: 1. integrate integral bird nest bricks (e.g., swift bricks) at a minimum of two per dwelling;" https://www.wiltshire.gov.uk/article/8048/Current-consultation-Reg-19 ),

and Cotswold District Council are proposing three swift bricks per dwelling in their current Local Plan consultation (Policy EN8 item 6, and paragraph 0.8.4, https://www.cotswold.gov.uk/planning-and-building/planning-policy/local-plan-update-and-supporting-information/ ),

so such an enhanced level should also be considered.

Hastings & Rother Swift Conservation Group, and House Martin Conservation UK & Ireland which was founded in East Sussex, can provide advice on swift bricks and the red-listed bird species that use them such as swift, house martin, house sparrow, and starling.

We request that, for clarity, bird bricks are referred to as swift bricks. This is because, for example, national planning policy guidance NPPG Natural Environment 2019 paragraph 023 specifically refers to swift bricks -
swift bricks are the only types of bird bricks that comply with best-practice guidance BS 42021, as all small birds can safely use them. Swifts can become trapped in a standard starling box for example. Swift bricks are a universal nest brick for small bird species, as set out in NHBC Foundation: Biodiversity in New Housing Developments (2019) and elsewhere.