Representation by Mr Robert Samuel, Sheerness Recycling Ltd (Mr Robert Samuel, Sheerness Recycling Ltd)
- Date submitted
- 31 March 2021
- Submitted by
- Non-statutory organisations
BC080001 Outline Objections of Robert Samuel on behalf of Sheerness Recycling Ltd. Introduction 1. I am the Company Secretary of Sheerness Recycling Ltd. of Borough Green Sandpits, Platt Industrial Estate, St Mary’s Platt, Borough Green, Kent TN15 8JL. SRL has a lease at the former Swanscombe Works, London Road, Swanscombe, Kent. Nature of the SRL Business 2. SRL was founded in 2009 and has depots in Borough Green, Tunbridge, Sittingbourne, West Hythe, Ashford, Bexley and Swanscombe. SRL’s main activity is recycling inert waste into products which include aggregates, crushed concrete, asphalt planings and soils. 3. SRL which is part of the Borough Green Group has approximately 50 employees. The Group employ approximately 120 staff. SRL at Swanscombe is strategically placed being very close to London with connections to Kent, and Essex. 4. I consider it will be extremely difficult, if not impossible, for SRL to find alternative suitable premise. We currently occupy approximately 7 acres of land. If premises are found, which is doubtful, it is likely to need full environmental assessment, where an ecologist will check the site to ensure there are no protected species e.g. newts. Once we obtain planning permission, we have to obtain a Environmental Permit before we can commence any operations and accept any waste products. There will also be costs associate with the surrender of our existing Permit. The cost of obtaining planning and a permit could be £120-160k. 5. All recycling centres must be accredited before any waste can be received. For this reason, we require an industriall site, which is virtually non-existent in . The brownfield sites in Kent are nearly all being used for housing developments. From acquiring the site, applying for planning permission and obtaining a permit, this takes approximately 18 months and possibly longer because of the COVID-19 pandemic. If we cannot operate for 12 months we will incur significant loss of earnings. Swanscombe is a very profitable site with a reasonable rent which I do not consider can be replicated elsewhere. We also have very substantial machinery at Swanscombe which will be expensive to move. 6. Furthermore, SRL is a family run business and it is envisaged that all the Directors’ children and grandchildren will inherit and continue to run and expand the business. Consequently, the effects of compulsory purchase will not only be felt immediately on a business-level but also on a personal and family level for generations to come. 7. Compulsorily purchasing one of our major bases is not in the public interest and would unreasonably interfere with our human rights. 8. I also object on the basis of the woefully inadequate consultation carried out by LRCH. There were numerous breaches and failures to provide consulation packs, as highlighted by the Peninsula Management Group. Not all of the leaseholders of Swanscombe Developments LLP have been approached by Savills. SRL has never been approached by Savills or LRCH. This is contrary to the developer’s obligation to enter into negotiations with those affected by the DCO and find them alternative premises without using compulsory purchase powers. In any event, we have made our own enquiries and suitable industrial sites which we would require just does not exist. Policy Position and Funding 9. I note that there is no National Policy Statement that covers the nature of the London Resort development proposal. Whilst other policies may apply to certain elements of the scheme (e.g. transport), there is no government drive to bring forward this development. It appears to be not a project of national significance, but rather a highly speculative private commercial development. 10. The funding position is opaque. The corporate structures and accountability should be examined in detail and I am continuing to research this position and understand that the group company, M S Al Humaidi Ltd. is now offshore in the Isle of Man after accepting a £5m government loan. Furthermore, it is understood that Mr Al Humaidi has only committed to funding the project until planning permission is granted (if it is). Once that is achieved he will seek other investors to cover the estimated £3.5billion needed to build the park. Where my business is due to be compulsorily acquired, it is essential to know that the ultimate project will be deliverable to the quality claimed and with appropriate environmental mitigation & compensation, as well as financial compensation to dispossessed landowners and occupiers. This is far from clear at present. I am also concerned that no adequate reassessment of the viability of the project has been carried out following the COVID19 pandemic. Environmental Effects 11. I also object on the basis of the environmental effects of the proposal. The site selection process appears to have proceeded on the basis that land use proximity, connectivity to Central London, transport and accessibility, environmental constraints, planning constraints, regeneration, economic benefit and micro-climate. Swanscombe should never have been selected based on these criteria. 12. I will object in detail in respect of the traffic impacts in the locality. The Swanscombe Peninsula already has hundreds of businesses (some operating 24/7) and 1,000s of employees. It is always busy along London Road, Manor Way Business Park, Northfleet Business Park and Kent Kraft Business Park, especially with lorries going to and from their depots. The recycling units and demolition companies are always busy. The highway network simply cannot support the expected vehicle numbers for such a vast scheme. The infrastructure proposed will not be able to cope with the sheer weight of traffic from the Dartford Tunnel, Ebbsfleet Garden City and the resort. 13. I also support the position of Kent Wildlife Trust, Buglife and the RSPB that this theme park is expected to destroy 76ha of priority habitat which is a vital part of the ecological network of the Thames Estuary. The Estuary has a unique climate which is more continental than the rest of the UK and the 620 acres of marshes is very tranquil. Building over this area of natural habitat will unacceptably destroy many habitats and species of importance. Reference is made in the site selection to the fact that Swanscombe Peninsular was chosen because of it is a ‘derelict brownfield site and unused wasteland’. This is simply incorrect. I do not consider there has been a proper HRA/environmental assessment. I also have concerns about how construction will be carried out including how workers will be accommodated and traffic issues. Conclusion 14. I object on four principal grounds: (I) compulsory purchase of SRL’s Swanscombe base is not in the public interest and inadequate negotiations and public consultation have taken place; (ii) the London Resort lacks government policy support and does not appear deliverable; (iii) if built, the effects on traffic congestion and pollution would be severe and (iv) the ecological harm including (during construction) would be unacceptable and in any event has not been properly assessed. I reserve the right to expand on these objections at a later stage and revise them as appropriate. DATED: 31 March 2021