Representation by Save Swanscombe Peninsula (Save Swanscombe Peninsula)
- Date submitted
- 24 March 2021
- Submitted by
- Non-statutory organisations
Save Swanscombe Peninsula (SSP) is a community group (643 members) founded to protect the Peninsula as a community asset due to its great environmental value. We oppose the Development promoted by London Resort Company Holdings (Promoter). 1. Adverse impacts a. Biodiversity The Peninsula is a SSSI* covering 264.1ha, recognising its biodiversity and irreplaceable mosaic of habitats. The Development would cause: - Permanent loss of 100+ha of SSSI; - significant harm to additional areas of the SSSI during construction; - damage retained terrestrial and marine habitat and species assemblages due to fragmentation, noise, light pollution and human activity. Specifically (not exhaustive): - Botany Marsh West and Black Duck Marsh – 15.5ha grazing marsh, of International conservation value would be lost (Environmental Statement [‘ES’] Appendix 12.1); - invertebrate populations - 7 separate areas would be lost, each independently of ‘national importance’ (ES Appendix 12.1); - overwintering bird assemblage of international importance (ES Appendix 12.3); - breeding birds – 99 species; 17 Red List species, 29 Amber List species (ES ch 12); - vascular plant assemblages of national importance (ES ch 12); - impacts a Marine Conservation Zone The scale of SSSI loss is without precedent and contrary to the NPPF (S.175) and Dartford and Gravesham planning policy. In the ‘Site Option Assessment’ (ES Volume 2, Appendix 4.1) avoiding SSSIs was a material consideration. The same criteria must properly be reapplied, with the inescapable conclusion that the site, now a SSSI, is inappropriate for the Development. The principal mitigation strategy (to provide ‘biodiversity net gain’ through off-site habitat compensation) is inadequate. ‘Net gain’ has no policy relevance for an NSIP and the Promoter has failed to demonstrate how a habitat mosaic of such scale, diversity and richness is possible to compensate. The Promoter contends without the Development (ES, 12.205) the site will be neglected with further scrub encroachment. Actually, now designated a SSSI, with access to ‘net gain’ funding sources, and in context of Nature Recovery Network policy, the Peninsula will be positively managed for nature, further benefitting local communities. b. Local communities The local area is highly urbanised and undergoing rapid further development. The Peninsula is a vital resource for recreation, bird watching, naturalism and education, contributing to the health and wellbeing of local communities (both existing and planned) as recognised in the SSSI designation. The local loss of nature and urbanisation reported in the ES is contrary to the 25 Year Environment Plan and the Dartford Core Strategy. Off-site habitat compensation is proposed in a remote part of Swale, over 30 minutes’ drive away and inaccessible by public transport. This will not compensate the negative impact on local communities due to the adverse environmental impacts at the Kent Project Site. c. Socio-economic Thousands of existing jobs are risked in the estimated 140 businesses affected by compulsory acquisition (‘CA’). It would compound blight caused by the shadow of CA over the businesses since the NSIP designation (2014). There is a known scarcity of local commercial property. The dislocation of businesses over a short period can be expected to further imbalance supply / demand locally, increasing values. We consider the ES may over-state the economic benefits of the Development by: - Over-estimating job creation, particularly locally; - Under-estimating the economic impact of competition with local retail and town centres, and theme park / leisure businesses nationally. - Not adequately accounting for economic costs (in accordance with Natural Capital accounting principles [25 Year Environment Plan]). d. Traffic The Development would significantly increase local traffic (ES) with an associated air pollution health risk in one of the most congested parts of the UK and worst for air quality. It will create severance and amenity impacts on the community and adversely impact the SSSI. e. Visual The Development would cause a significant adverse visual impact on an important and unique landscape. Approximately 50% of the Botany Marsh LCA would be lost. f. Climate Change The Development is incompatible with Net Zero policy commitments. g. Heritage and Archaeology The Development risks damage to known archaeological features and those as yet undiscovered in a location rich in history. h. Hydrology The Promoter should be required to demonstrate it has robustly modelled and reported the impact on hydrology on a ‘cumulative effects’ basis, accounting for climate change. 2. Adequacy of DCO Application SSP have the following concerns (not exhaustive): a. ES Conclusions Many are difficult to reconcile with the data and risk understating impacts. Regards mitigation, the ES is considered likely to either (i) provide insufficient detail to draw objective conclusion (ii) or overstate the likely effect. b. Site selection Assessment This underestimated the biodiversity value of the site. The Promoter should demonstrate it has objectively re-assessed the options based on updated relevant evidence and the subsequent environmental designations (SSSI, MCZ). c. Biodiversity off-setting The Promoter provided insufficient detail during the Statutory Consultation (and in the ES) on ‘biodiversity offsetting’ on which Consultees could reach an informed conclusion. * Natural England designated the Swanscombe Peninsular to be an SSI on 11th March 2021 - https://www.gov.uk/government/news/swanscombe-peninsula-gets-national-recognition-as-an-sssi