Representation by Amateur Entomologists' Society (Amateur Entomologists' Society)
- Date submitted
- 31 March 2021
- Submitted by
- Non-statutory organisations
We wish to object to the proposal to locate the proposed “London Resort” on the Swanscombe Peninsula. A large part of the Peninsula is categorised as Open Mosaic Habitat on Previously Developed Land (OMHPDL). From our perspective as an entomological organisation, we regard this habitat type as extremely important, given that it supports many vulnerable or endangered invertebrates. OMHPDL has developed on a number of other sites in the Thames Estuary but some of the most important of these have been lost or have come under threat from recent changes in land use. Owing to the microclimate and the flower-rich characteristics of OMHPDL, together with the relatively warm and sunny climate of the Thames Estuary, the site sustains various invertebrates that have a mainly Mediterranean or southern European distribution and are therefore very localised in the UK. Many of the site’s terrestrial invertebrates, a total of 250, are listed as species of conservation concern. These include Attulus distinguendus (the Distinguished jumping spider), which is Critically Endangered according to IUCN criteria. There are also aquatic invertebrates of high conservation value, including Alkmaria romijni (the Tentacled lagoon-worm), the habitat of which is protected under the Wildlife & Countryside Act (1981). Additionally the site supports many plants and vertebrates of conservation concern. While appreciating that the development of a resort on a suitable site could provide an important economic stimulus, we strongly believe that this particular site warrants protection because of its outstanding importance for overall biodiversity and for particular endangered and other vulnerable species. We therefore support its designation, as of 11th March 2021, subject to confirmation, as a Site of Special Scientific Interest (SSSI), incorporating the existing Baker’s Hole SSSI. Taking account of available evidence, we do not believe the effects of site development could realistically be mitigated by attempting to translocate any of the invertebrate species that it supports.