Representation by Stephen Lings
- Date submitted
- 27 March 2021
- Submitted by
- Members of the public/businesses
For the attention of the Planning Inspectorate Dear Sir(s), I wish to lodge an objection and to strongly oppose this ill thought out proposal and ask the Planning Inspectorate (PINS) to refuse and reject the proposed application plans by London Resort Company Holdings (LRCH) for development of a London Resort Theme Park at: Swanscombe Peninsula SSSI between Gravesend and Dartford. The application should ‘NOT’ be granted a Development Consent Order (DOC). The development is completely disproportionate to the site and its scale would be catastrophic for this valuable Site of Special Scientific Interest (SSSI) of National importance. The wildlife riches of the site would not survive this development. The UK is already one of the most nature depleted countries in the world and there has been a sudden and continued sharp decline in the UK’s biological diversity. The theme park will permanently destroy 1,245 Acres (504 hectares) of priority habitat which forms a vital part of the ecological network of the Thames Estuary. LRCH has used outdated environmental assessments and has misrepresented the description of the site, referring to it as mainly post-industrial and largely derelict. This is not the case anymore, in just 20 years, the site has been utterly transformed into one of the most important sites for wildlife in the UK, and apart from the unique and nationally important flora and fauna; there are around 280 existing parties including businesses and landowners who would be affected. We need to start putting nature at the heart of all our decisions, before the losses are fundamentally irreversible. Swanscombe peninsula is more than a brownfield site it is a Nationally Significant Wildlife Infrastructure; a sanctuary that is a symbol of hope: a former industrial site that is now a world-famous natural rewilding, home to some of the rarest and most endangered birds and invertebrates in the UK, a place from which we may actually start to make a big difference to the recovery of the UK’s biological diversity, instead of paying lip-service to our promises. The Open mosaic habitats on previously developed land (OMHPDL) are now a priority habitat themselves [UK Biodiversity Action Plan (UK BAP) as a Priority Habitat listed on Section 41 of the National Environment and Rural Communities Act 2006 (NERC Act) ] and consist of a patchwork of bare, previously disturbed ground and stands of vegetation. Although OMHPDL is associated with brownfield sites, only a small proportion of brownfield sites actually support good examples of this priority habitat. Swanscombe Peninsula is such a place and why Natural England recently designated it a SSSI. This biodiversity hotspot one of the new “urban rainforests” has for a long-time been greatly underestimated. With all that we now know about Swanscombe Peninsula this really is a test case that will reveal how seriously the government is taking landscape and biodiversity recovery. We’ve got to act now to save the last little remnants of established unique priority habitats, that can actually rebuild our network of nature again, or it’s gone forever. To allow this blatant land grab by LRHC would be totally unacceptable and nothing less than the UK Government being complicit in allowing LRCH to commit ecocide through the destruction of the Swanscombe Peninsula’s open mosaic habitats by deliberate and negligent human action. We must stop destroying valuable biodiversity and their habitats and value its very existence over impactful monetary pursuits and its long-term consequences. Intergenerational environmental impacts including pollution and loss of biodiversity will burden future generations. Surely the UK Government is committed to the overarching aim of the National Planning Policy Framework (NPPF) policy on biodiversity to: minimise impacts on and provide net gains for biodiversity, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures. Or, the Governments; 25 Year Environment Plan committing to: creating or restoring 500,000 hectares of wildlife-rich habitat outside the protected site network; focusing on priority habitats and developing a Nature Recovery Network (NRN). The Swanscombe Peninsula surely lies at the heart of such a network within the Thames Estuary. There are numerous objections to this proposal, even the surveys conducted for and on behalf of the proposing developer LRCH recognised that the proposed site was of National importance for its invertebrate populations identifying 1,992 terrestrial species, plus a further 200 aquatic macro-invertebrates of which 250 are of conservation concern, i.e. Red Data Book or Nationally Scarce. Also of note is a marine invertebrate, the scarce lagoon worm (Alkmaria romijni) found in very few places and a protected species under the Marine Conservation Zone approval granted for the area in 2019. As an experienced field naturalist I believe that this is an underestimate of the invertebrate assemblage that is yet to be discovered on the site. The most obvious objection to this development relates to the build and the threat that would bring: the building of two theme park gates and a water park, a conference & convention centre and e-Sports facility; a hotel with 3,500 rooms, two ferry terminals (exactly where the lagoon worm lives) – one each side of the River Thames along with back-of-house facilities, a visitor centre and a new road from the A2. It also claims to be a world-leading sustainable development – this in itself would make a mockery to the meaning as it would put hundreds of at risk and critically endangered species at threat of local and national extinction. Threats to Swanscombe Peninsula 1. This development has the potential to cause direct damage to the natural environment from the impact of development practices through the removal of habitat, fragmentation of habitats and loss of wildlife corridors. Even relatively minor development practices, will impact on protected species which may occupy those spaces. 2. Less well understood is indirect disturbance and cumulative impacts which can result from the increase in visitor numbers and intensification of recreational use of a wildlife site. Indirect disturbances can range from short-term to long-term events with permanent effects, examples include: • Impact from increased visitation to the site and threats of introduced species; • Damage to habitats through human activities: walking, cycling, fires, fly-tipping, litter, dog fouling etc; • Damage from track spreading, causing erosion or the crushing of plants and invertebrates; • Disturbance of wildlife during construction through noise and vibration; • Predation of domestic cats upon wildlife such as nesting birds and water vole; • Recreational disturbance of sensitive fauna, particularly by dog walkers; • Siltation of water bodies / courses from run-off; • Pollution of water from new commercial and industrial discharges; • Air pollution from additional traffic, business etc for example their effect on lichens; • Threat on sensitive habitats from the escape of invasive exotic garden and aquatic plants, such as American skunk cabbage; • Disturbance of nocturnal fauna through the use of artificial lighting; • Visual disturbance and mortality from pedestrians and on-site vehicles; and • Mortality caused by increased traffic or new roads. Due to their sensitivity and importance even development located at a distance can have a negative impact on a SSSI and especially one as important as Swanscombe Peninsula. 3. The highest level of legal and policy protection should be given and afforded to Swanscombe Peninsula which forms a dramatic landscape with distinctive geology, flora and fauna which are of international and national conservation importance and support robust protection to this biological diverse asset which must be upheld in future policy from any opportunistic developments. This development goes against all National Planning Policy Framework 2018 (NPPF) Paragraphs 170 to 183, recognising wider benefits of ecosystem services, protecting and enhancing valued landscapes and minimising impacts on biodiversity. I would also state that this development would undermine the purpose of any and all of the following: 1. Natural Environment and Rural Communities Act 2006 (NERC 2006) 2. Countryside and Rights of Way Act 2000 (CRoW Act) as in the increasing measures for the management and protection of SSSI’s 3. Flood and Water Management Act 2010 4. Wildlife and Countryside Act 1981, as amended 5. Conservation of Habitats and Species Regulations 2010 (Habitat Regulations) 6. European Landscape Convention (The UK ratified this international treaty aimed at the protection of all valued landscapes and established the need to recognise this in law) 7. Convention on the Conservation of European Wildlife and Natural Habitats 8. Convention on Biological Diversity (As of 2015 the UK along with 196 other countries ratified this global agreement to achieve conservation, restoration and protection of biological diversity. The strategy is implemented by the UK biodiversity Framework 9. EU Biodiversity Strategy to 2020 (to halt the loss of biodiversity) 10. Water Framework Directive 2000/60/EC (Enhance protection for the aquatic environment) 11. Birds Directive 2009/147/EC 12. EU Habitats Directive 92/43/EEC 13. UK BAP Species and habitats of principle importance 14. UK Biodiversity Action Plan (UK BAP) as a Priority Habitat listed on Section41 of the Natural Environment and Rural Communities Act 2006 (NERC Act) Conclusion Either the UK Government believes in upholding the overall combination of local policy or legislative frame works that afford Sites of Special Scientific Interest (SSSI) a high level of protection commensurate with their status or they do not. What is the purpose of any protective legislation and signed treaties if at the end of the day Monetary Capital can always bulldoze and concrete over Natural Capital under the disguise of Sustainable development or National Infrastructure? Swanscombe Peninsula should be seen as a beacon of light. A cornerstone of the UK’s nature conservation policy and recognised as part of an important ecological network of protected areas. They should be safeguarded against ill conceived and potentially devastating developments as that proposed by LRCH. It would be a wilful violation to not protect biodiversity. Development must not come at the expense nor threaten other species’ survival. Therefore the most practicable action to safeguard our green fringes from incremental assaults from speculative development is for the Rt Hon Robert Jenrick MP Secretary of State for Housing, Communities and Local Government; to refuse and reject this planning proposal for a theme park on the Swanscombe Peninsula. I earnestly implore you to reject the London Resort Company Holdings development plan outright. Yours Faithfully Mr. Stephen Lings