Representation by CPRE Kent (CPRE Kent)
- Date submitted
- 31 March 2021
- Submitted by
- Non-statutory organisations
CPRE Kent registers its objection to this scheme. We acknowledge the importance of employment provision within the Thames Gateway but consider the negative impacts of this scheme unacceptable. While this Representation outlines the issues with which we are principally concerned, we reserve the right to respond to any additional relevant matters raised. • Environment/Biodiversity o The recent notification of the site as a SSSI is a significant change which reflects the importance of the site’s biodiversity. The application should be re-considered in the light of this notification. o We concur with the concerns expressed by Buglife, KWT and the RSPB over the threat to the terrestrial and aquatic habitats of the peninsula, as well as the deficiencies of the proposal in delivering BNG. We will work alongside these partners during the Examination of this DCO application. o CPRE has mapped light intrusion and tranquillity. The proposed site benefits from a level of tranquillity and dark skies that are unusual for the area, and these features would be destroyed by the proposed project. o Dartford and Gravesham already suffer from some of the worst air quality in the SE. o We are concerned at the hydrogeological implications, including those of raising the formal flood defences at Black Duck Marsh and the introduction of new secondary flood defences and new raised ground on adjoining areas. • Transport o Visitors and staff will place significant strains on the transport network. It is not clear that the impact of peak travel (at weekends and school holidays) has been adequately assessed. It is also uncertain that the consequences of visitors and staff choosing not to use public transport as projected, and failing to meet the proposed modal split, has been assessed. o There remains uncertainty over the delivery of the Lower Thames Crossing, not least in the light of the pending legal challenge of the Government’s current Road Investment Strategy. It is uncertain how this will affect the transport modelling undertaken by the applicant. • Sustainability o The applicant acknowledges that water availability will be an issue. The wider south east region is categorised by the Environment Agency as an area of serious water stress, a situation that will be exacerbated as the projected levels of housing development are delivered. • Visual impact o The proposal will result in the loss of the long, wide views across the marsh, and views towards Galley Hill Church (Grade II* listed) and change the character of the location from rural to urban. • Economy and community impacts o The proposal site currently hosts companies which provide significant levels of employment and provide much-needed services locally. Some of these businesses are ‘bad neighbours’ and, even where financial support is proposed, would likely find it difficult to find appropriate alternative sites. o We are concerned at noise pollution visual and intrusion of the proposals on adjoining residential communities. o We question whether the cumulative impacts of the major developments already taking place at Ebbsfleet and elsewhere are adequately considered.