Representation by Wildlife and Countryside Link (Wildlife and Countryside Link)
- Date submitted
- 31 March 2021
- Submitted by
- Non-statutory organisations
London Resort Nationally Significant Infrastructure (NSIP) application - Wildlife and Countryside Link Relevant Representations Wildlife and Countryside Link (Link) welcomes the opportunity to make representations on proposals for the London Resort NSIP application. Link is the largest environment and wildlife coalition in England, bringing together 57 organisations to use their strong joint voice for the protection of nature. Our members campaign to conserve, enhance and access our landscapes, animals, plants, habitats, rivers and seas. As a SSSI, an application for development on the Swanscombe Peninsula should be considered in the light of its own special interest and in the context of the government’s overall ambition to halt biodiversity decline. We recommend that the application for development should be withdrawn. If it is resubmitted, it should be updated to take into account the environmental importance of the site. We consider that major development on the site would be incompatible with the conservation of the important features present and that destruction of such an important ecosystem and the wildlife it supports would be incompatible with the aims of the 25 Year Environment Plan. The proposed London Resort development is located on the Swanscombe Peninsula, which supports a unique mosaic of coastal habitats, grasslands, scrub and wetlands that have developed as a result of the site’s complex human history. The site is a superb example of a wildlife-rich brownfield site that has been reclaimed by nature, supporting a nationally important example of Open Mosaic Habitat on Previously Developed Land (OMHPDL), a habitat of principle importance under Section 41 of the Natural Environment and Rural Communities (NERC) Act 2006. The Swanscombe Peninsula supports nationally important assemblages of invertebrates, including 250 invertebrate species of conservation concern, notably the Critically Endangered Distinguished jumping spider (Attulus distinguendus), which is found on only one other site in the UK. It has also been notified for its nationally scarce plant populations and its diverse assemblages of breeding birds associated with lowland open waters and their margins, lowland fen and lowland damp grassland, and also with lowland scrub. The value of the site is such that Natural England has recently notified the Swanscombe Peninsula as a Site of Special Scientific Interest (SSSI) under section 28C (Enlargement) of the Wildlife and Countryside Act 1981. The enlargement of the SSSI has taken effect immediately, while a consultation on the site’s notification is ongoing. The London Resort proposals would lead to the direct loss of over 100ha of the new SSSI, including the majority of the nationally important OMHPDL areas, and indirectly impact much of the remainder. The protection and enhancement of the SSSI network is central to the government’s commitment to protect 30% of the UK’s land for nature by 2030, its commitment to recover nature at scale through the Nature Recovery Network and the 25 Year Environment Plan’s ambition to “effectively link existing protected sites and landscapes.” The London Resort application and the associated Environmental Statement pre-date the SSSI notification. This notification is a significant change in the baseline and the degree of potential impacts against which the application should be considered. It is therefore essential that the application is withdrawn and re-submitted with appropriate assessments that correctly address the site’s SSSI status and the potential impacts of the proposed NSIP upon the now-recognised locally and nationally important species and habitats of Swanscombe Peninsula. For questions or information, please contact: Emma Clarke, Policy and Information Coordinator, Wildlife and Countryside Link T: [] E: [] This response is supported by the following Link members: Bat Conservation Trust Buglife Butterfly Conservation Plantlife People’s Trust for Endangered Species Zoological Society of London