Representation by Forestry Commission (Forestry Commission)
- Date submitted
- 26 March 2021
- Submitted by
- Other statutory consultees
The Forestry Commission is a non-ministerial government department, and the government’s forestry expert. We are a statutory consultee for all Nationally Significant Infrastructure Projects, including the London Resort. We also form part of the wider DEFRA group, which includes our partner organisations: • Natural England • Environment Agency • Marine Management Organisation Our partners above will also be submitting individual relevant representations, but we speak with one voice within the DEFRA group. The Forestry Commission’s main points regarding this application are as follows: This project will result in the direct loss of trees and woodland. There is also the risk of indirect impact upon woodlands (including ancient woodlands and SSSI woodlands) adjacent to the project boundary through air pollution from the increase in vehicular traffic to the area which may be generated by this attraction. This is particularly pertinent to the area as it is in close proximity to another proposed NSIP, the Lower Thames Crossing, which will also affect the levels of traffic in the area. We would also expect to see inclusion of how this project will affect, be affected by, and otherwise interact with the Lower Thames Crossing project. The consultation documents have mentioned off-site mitigation for habitat loss which will arise from this project’s construction. However, although we have been advised that the area will be ‘significant’, we have received no further details or consultation about the mitigation area, other than there will be woodland created. We will not be able to progress a Statement of Common Ground without details of what this site will contain, species mix, how it will be implemented, and its long-term management. We do not feel enough information has been presented by the applicant as to their proposed habitat creations actions, both in terms of processes in creation and management, and also which parts are mitigation for lost habitat, which are serving as carbon offsetting, and which will be potential net gain. We have been informed by the Resort’s contracted arboricultural consultant that the Resort intend for the operational phase of the resort to be carbon neutral, with the potential for some net gain. We would be keen to see more detail on how this will be achieved. As mentioned, the detail we have seen has been limited, and has raised concerns about mitigations which have been proposed. For example, within the landscape strategy document, the landscape strategy section regarding tree planting talked about planning ‘predominantly native’ species, and then headed their brief list with Turkey Oak, which is both non-native and a known invasive tree species. Since our response to the statutory consultation, and the acceptance of the scheme for Examination, we are aware that the majority of the landholding for this project has since been designated by Natural England as a Site of Special Scientific Interest (SSSI). We are concerned that what has been proposed by the applicant may no longer be acceptable in the light of this new designation, and that the applicant, the Planning Inspectorate and the Secretary of State should take this into account. We and our partners within the DEFRA group would be pleased to assist in any re-evaluation work which may be required. Overall, we are somewhat disappointed at the minimal amount of engagement we have had with the London Resort. We are concerned at the minimal level of detail within the application, which is well below what we would expect of documents submitted for Examination. We also question whether there is enough time within the Examination timetable to resolve the issues which we and our partner organisations have.