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Representation by Dan Bramwell

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

I am a private individual who, prior to retirement, advised the businesses on the Swanscombe Peninsular, as a Public Affairs Consultant, and have grave concerns about this application, namely: * How the pre-application process was handled by the Applicant and the ability to get a clear understanding of their intentions ; * The failure of the Applicant to fully engage and work co-operatively with interested landowners and the businesses; * The use of inaccurate information to seek NSIP powers and subsequent presentation thereafter; * Inaccurate description of site, including failure to recognise existing uses on site and valued biodiversity resources; * Hence, highly flawed site assessments in the Applicant’s November 2014 and June 2020 Scoping Reports; * Very grave concerns that neither MHCLG or PINS validate the site information presented by the Applicant in accepting request for NSIP status and thereafter, thus unnecessarily wasting civil servants time and taxpayers money; * Initial plan submitted with NSIP correspondence indicates only west industrial estates will be required and included within the red line boundary. However, final DCO Application plan incorporates all industrial estates, both to west and east of HS1 route accommodating approx 140 businesses; * There was no specific engagement and/or detailed consultation with the businesses and/or landowners prior to this change and, furthermore, such a critical and major change should have been referred back to the Secretary of State MHCLG detailing the impacts and consequences of such a change so that the use of NSIP powers could be reviewed; * Lack of credibility and financial robustness of Applicant, especially in dealing with businesses, and lack of respect for existing landowners and businesses; * Impact on existing businesses and landowners, including blight and financial impact on individual businesses leading to long-term uncertainty due to inability of Applicant’s intentions and development strategy. This is demonstrated by the fact that LRCH’s latest Chief Executive hasn’t even visited or had any contact with the industrial estates whilst his predecessor was not even aware that the businesses existed until he visited them; * Lack of adequate public consultation, especially with businesses, some receiving notification of events AFTER closing dates and others not being advised about events at all; * Impact on adjacent Swanscombe Marshes and the wider area, its wildlife resources and the long-term impact should the development be allowed - once the site is lost it can never be replaced and there is no such thing as an alternative replacement site of equivalent value; * Grave concerns as to why the Government is granting loans under the British Business Bank to help fund the Application when it will also be the eventual juror - stinks of political interference; * In summary, this project is not of national significance but is a private commercial venture which has no national importance. If this Application is permitted, it will set a dangerous precedent for all landowners, both residential and commercial, in the future and no land will be safe from unwanted and unnecessary development, drastically weakening the importance of NSIP applications!