Representation by Orpington Field Club (Orpington Field Club)
- Date submitted
- 25 March 2021
- Submitted by
- Non-statutory organisations
I am writing on behalf of the Orpington Field Club (members of which have a particular interest in the biodiversity of sites within the London Borough of Bromley and the adjoining boroughs) regarding the above. Members of the Orpington Field Club request that the proposed development of this site as a Theme Park (under the umbrella of a Nationally Significant Infrastructure Project (NSIP)) is reviewed; the previous application did not take into account the recent designation by Natural England of this area as a Site of Special Scientific Interest. This designation rightly recognises the area as a nationally important wildlife-rich site having a great diversity of habitats (coastal habitats, grasslands, scrub and wetlands) supporting an extremely rich fauna and flora. Our wildlife is under threat from many causes as the recent State of Nature Report 2019 has underlined and this area as one of the last remaining large examples of Open Mosaic Habitats on Previously Developed Land in the Thames Estuary must be protected. At present the site performs an important function in mitigating climate change by sequestering carbon in plants and in the soil. This will be lost if the site is built on; in addition the very act of development with all the associated carbon-excesses and pollution will severely impact on the carbon-zero policies of Greater London and beyond. Our particular concerns include the following • An extremely rich invertebrate fauna upon which animals higher up the food chain rely • 250 invertebrate species of Conservation Concern (Red Data Book or Nationally Scarce species) • the presence of the Critically Endangered Distinguished Jumping Spider and the Endangered Duffey’s Bell-head Spider • the aquatic invertebrate fauna is of significance at the county and regional level. • regionally important breeding bird assemblage including 15 red-listed Birds of Conservation Concern and 12 species of Principal Importance including Nightingale, Grasshopper Warbler, Cuckoo and Marsh tit • 13 nationally scarce vascular plant species including Man Orchid and 4 Vulnerable species including Yellow Vetchling and Slender Hare’s ear • Exceptional populations of Common Lizard and Slow Worm • Breeding populations of the Red-listed Water Vole and dormouse • Locally important area for bats with at least 9 species recorded including the Nationally Rare Barbastelle The huge double impact of biodiversity loss and increased carbon emissions makes this area unsuitable for development.