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Representation by R. J. Heckford

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

I object to the planning application. We do not need another leisure and entertainment resort for humans. We need to preserve habitats for other species as it is their home. In the case of the site of the planning application it is the home of 250 invertebrate species of Conservation concern as well as many other species of Conservation concern, such as various birds and plants. Such a high number of species of Conservation concern make it an outstanding habitat. Of the invertebrates there are three species of RDB 1 Status, one of RDB 2 Status and 17 of RDB3 Status. These three statuses are defined as follows: Red Data Book category 1 (RDB 1) – Endangered species whose numbers have been reduced to a critical level or whose habitats have been so dramatically reduced that they are deemed to be in immediate danger of extinction. Red Data Book category 2 (RDB 2) – Vulnerable species likely to move into the endangered category in the near future if the causal factors continue operating. Red Data Book category 3 (RDB 3) – Rare species with small populations in Great Britain that are not at present endangered or vulnerable but are at risk. To these I can add a moth (Lepidoptera) that has no vernacular name, only a scientific name: Bryotropha dryadella. I found this at Swanscombe in 2001. It has a pRDB2 Status meaning that for the period 1980 – 2011 it was only known to occur in 6 – 10 10km squares in Great Britain. The record from Swanscombe in 2001 is the first and as far as I am aware the only Kent record. I also found the species at Grays, Essex in the same year in a very similar habitat. Again, as far as I am aware that is the only Essex record. The species is otherwise only known in Great Britain from a few sites in Cornwall and Devon. I am not aware of any records after 2011 that would increase the number of 10km squares from which it is known. In a European context it is at its most northern edge of its range in Cornwall, Devon, Kent and Essex. Otherwise it has a central and southern European distribution. The recent notification of the Swanscombe Peninsula as a Site of Special Scientific Interest shows what an exceptionally important area this is for wildlife. Their interests should prevail over human leisure activities. I urge that this and all the other species that live in the Swanscombe Peninsula be allowed to continue their existence there by the rejection of this planning application. To have such a special habitat should be something to celebrate and be proud of, not something to destroy. In any event, I cannot see how this application can proceed as a result of SSSI notification, which took immediate effect on 11 March 2021. Surely this application should either be withdrawn or dismissed now?