Representation by Butterfly Conservation (Butterfly Conservation)
- Date submitted
- 22 March 2021
- Submitted by
- Non-statutory organisations
Butterfly Conservation wishes to become an Interested Party to take part in the examination of the application for the London Resort for the following reasons: 1. We believe the NSIP application for the theme park must be reviewed in the light of the recognition by Natural England of the Swanscombe Peninsula area as a proposed Site of Special Scientific Interest 2. The recognition of the site as brownfield because of previous development does not in itself make the site any less valuable for its wildlife interests. The site has been substantially reclaimed by natural processes. In doing so this has led to the establishment of an area with an especially rich assemblage of wildlife. Natural England has recognised that the open mosaic habitat within the site supports an exceptional range of wildlife in the coastal habitats including grasslands, scrub and wetlands 3. Butterfly Conservation wishes the area to be retained and managed for its wildlife interests in line with the proposed SSSI designation 4. Our interests relate to, but not exclusively, the range of Lepidoptera (butterflies and moths) found at the site. We are particularly interested in the presence of the Wall butterfly, Chalk Carpet moth, and the micro-moth Pammene agnotana 5. The Wall is widely distributed in England but rarely occurs in large numbers. Over the last decade it has declined in distribution substantially in many inland areas of central England. Populations remain in coastal areas, including along the south shore of the Thames estuary, where brownfield land contributes to its presence 6. Chalk Carpet moth occurs on unimproved calcareous grassland, cliffs and quarries and in other places where there is sparse vegetation and an abundance of bare ground. The moth has been observed to seek out patches of bare ground basking and roosting. This moth has undergone a significant reduction in its distribution since 1990 7. Pammene agnotana is a rare moth confined to a few areas of southern and south-east England, and East Anglia. The moth is associated with isolated and old Hawthorn trees, and ancient hedgerows 8. It is our view that the Swanscombe Peninsula is not an appropriate place for the development of a theme park and would irretrievably lead to damage of the wildlife interests that the site holds, including for the moths and butterflies described