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Representation by Bromley Biodiversity Partnership (Bromley Biodiversity Partnership)

Date submitted
27 March 2021
Submitted by
Non-statutory organisations

In view of the fact that the Swanscombe Peninsula has now been designated a SSSI, members of Bromley Biodiversity Partnership request that the proposed development of this site as a London Resort Theme Park Nationally Significant Infrastructure Project (NSIP) is reviewed because information previously submitted obviously does not take into account its new SSSI status: it is no longer ‘just a brownfield site’ but has now been recognised for what it really is, an important wildlife rich site important not just locally but also a nationally important asset. The drastic decline in biodiversity highlighted in the State of Nature Report 2019 makes it more than ever important that the SSSIs are protected. Concerns are as follows: • Swanscombe has now been recognised as of SSSI status because of the nationally important habitats it supports, the UK BAP Priority Habitats: Open Mosaic Habitat on Previously Developed Land, coastal habitats, grasslands, wetlands and also scrub. If these are lost to development so too are the plants and animals which currently live on the site some of which are rare and endangered. These include: o 13 nationally scarce vascular plant species, including 5 red-listed species eg,Man Orchid. Divided Sedge and Slender Hare’s Ear. o More than 1,700 invertebrate species, including over a quarter of the UK’s water beetle species and 250 invertebrate species of conservation concern o the Critically Endangered Distinguished Jumping Spider (Attulus distinguendus), only found in one other UK site. o a regionally important breeding bird assemblage including 15 red-listed Birds of Conservation Concern and 12 Species of Principal Importance,- including Marsh harriers, Bearded tit, Nightingales and Black redstart. o A population of Red Listed (Vulnerable) Water Vole & Dormouse o important populations of reptiles and Otter. o An important area for bats with 9 species recorded including the Nationally Rare Barbastelle As one of the last remaining brownfield sites in the Thames Estuary without an extant planning permission Swanscombe Peninsula is incredibly important. Its size means that it will support a many times greater diversity of wildlife than the small fragmented areas which remain when mitigation for development has previously occurred. The drastic decline in biodiversity highlighted in the State of Nature Report 2019 makes it more than ever important that areas so rich in biodiversity as this are protected not just for wildlife but also for people so that they can access nature- shown by the recent pandemic to have been so important for people. It is an inappropriate site for a Theme Park. In addition, the rich biodiversity demonstrated in Swanscombe Peninsula’s recent designation helps as a buffer against climate change through sequestering and storing carbon within plants and animals and in the soil. The destruction of this site will cause huge biodiversity and carbon losses in addition to the enormous carbon losses involved in construction and access. How can this possibly considered in an area with poor access to nature at a time of climate crisis?