Representation by Geoffrey Kitchener
- Date submitted
- 26 March 2021
- Submitted by
- Members of the public/businesses
I write to request that the London Resort Project’s NSIP submission be rejected, as fundamentally flawed. It is predicated on the basis that the site is not an SSSI, and the Project downplays its evaluation of the site’s biological interest accordingly. The notification by Natural England of the SSSI takes immediate effect, even though there is a consultation process running until July, and so it is necessary to treat it as an SSSI, which the NSIP submission is defective in not doing. The special biological interest of this site should now be regarded as of national importance. The remarkable invertebrate list noted by Natural England in its reasons for SSSI designation includes an extraordinary range of national rare and scarce (even Critically Endangered) bees, wasps, spiders and beetles. The bird list given in those reasons is also remarkable, including bearded tit, marsh harrier and water rail. The flora is even more important than indicated by the Natural England reasons, which mention four species Vulnerable to the risk of extinction in Great Britain. I am especially aware of the flora, being the county recorder for the Botanical Society of Britain and Ireland, and the chair of the Kent Botanical Recording Group. It is clear from the Project’s environmental assessment that their 2020 survey was made at the wrong time of year to assess the presence of Sickle clover and (Vulnerable to the risk of extinction) Slender hare’s-ear. Vulnerable round-leaved wintergreen is also a much larger population than their survey found. The assessment as a whole underplays the value of the extraordinary floral (and indeed, wildlife generally) diversity of this site, the open mosaic habitat on previously developed land, coastal habitats, grasslands, scrub and wetlands. The wildlife value of the site is not compatible with the NSIP as proposed and it is now clear that the Swanscombe peninsula is a national wildlife asset which should be safe-guarded. This is no longer (if it ever was) the right place for a theme park. If the London Resort Project were to be regarded as ‘national’ infrastructure, it should be on non-SSSI land and would be far more appropriately cast as part of the national levelling up to benefit the north and midlands, not the already prosperous south east.