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Representation by Dr Chris Down

Date submitted
11 March 2021
Submitted by
Members of the public/businesses

This objection relates to Document BC0800001-000502-6.2.14.1 ES appendix 14.1, Archaeological Desk-Based Assessment. The DBA substantially underplays the development’s potential to cause archaeological harm to remains from the nineteenth/early twentieth century cement works and in particular its railways. From c1825 to c1928, Swanscombe cement works operated a very extensive railway system of 3ft 5½in gauge and having about 21 miles of track in 1924. This was unique in the world, other than one or two trivial and temporary examples. Every railway in the world employs (and most have employed for some two centuries) plain rails on which run wheels with inside flanges. Swanscombe used plain rails and outside flange wheels. There is no good explanation for this, although my research has identified some hypotheses, but it is very possible that targeted archaeological excavations could (a) uncover some surviving track and (b) help to identify the reason for this remarkable choice. The DBA fails to refer to this matter. Over the period 1927-29, the railways were modernised to conventional standard (4ft 8½in) gauge and those remains present no special archaeological potential. However, the modern rails ran on rather different routes and there is considerable potential for discovering remains of the original track, buried but surviving, where it was not built over or removed for scrap. My full objection will include a detailed historical assessment and a draft of a targeted investigation programme. If adopted, not only might this development considerably increase the knowledge of UK railway history, were it actually to discover physical remains they could provide a unique public exhibition that would be a visitor attraction in itself. No DCO should be granted until an archaeological investigation and mitigation programme to investigate this unique aspect of the site’s history has been required. This is the best and probably last chance to obtain better knowledge of this railway system. I am willing and able to provide information which will assist such an investigation.