Representation by Dorian Osmani (Dorian Osmani)
- Date submitted
- 31 March 2021
- Submitted by
- Members of the public/businesses
BC080001 Outline Objections of DMJ Group Ltd and Mr Dorian Osmani Introduction 1. I am the Director of DMJ Group Ltd of Yard 6 and Unit 3 of B5/B6, Manor Way Business Park, Manor Way, Swanscombe, Kent DA10 0PP. Nature of DMJ Group Ltd 2. DMJ Group Ltd is a construction company dealing with the removal of asbestos and other commercial waste. I have a licence to occupy from 1 December 2020 for 3 years. (expiry 30/11/23). 3. DMJ Group was incorporated on 14th September 2016. It is a relatively new business but the plan is to expand with more units at Manor Way Business Park. 4. DMJ has 40 employees and is strategically placed as it is very close to London with connections to Kent, Essex and the North and importantly our principal client, based in Longfield, Dartford. 5. I consider it will be extremely difficult, if not impossible, for DMJ Group to find brownfield site. There has to be an environmental assessment where an ecologist will check the site to ensure there are no protected species. Once we obtain planning permission, we have to obtain a permit before we can accept any waste products. The cost of obtaining a permit is approximately £10,000. 6. Because asbestos is a hazardous waste we have to be accredited. For this reason, we require a brownfield site, which is virtually non-existent in London. The brownfield sites in Kent are being used for housing developments. From acquiring the site, applying for planning permission and obtaining a permit, this takes approximately 9 months and possibly longer because of the COVID-19 pandemic. If we cannot operate for 9 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 and there is a possibility of damage. 7. Furthermore, DMJ Group Ltd 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 be felt immediately on a business-level but also on a personal and family level for generations to come. 8. Compulsorily purchasing one of our major bases is not in the public interest and would unreasonably interfere with our human rights. 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 mitigation and compensation. This is far from clear at present. Environmental Effects 11. I also object on the basis of the environmental effects of the proposal. I will object in detail in respect of the traffic impacts in the locality. Dartford and the Dartford Crossing is already heavily congested with industrial lorries and other traffic. I note that Highways England have stated that Dartford Tunnel is “one of the least reliable sections of the UK’s road network”. It is not viable for the London Resort to be so close to the Dartford Tunnel. Dartford also has, according to Public Health England, one of the highest percentage of deaths attributable to long term exposure to particulate air pollution. The introduction of the London Resort into this area will only cause increased traffic delays and increased pollution. 12. I 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 to Swanscombe Peninsula being a largely unused brownfield site. This is simply incorrect. Conclusion 13. I object on four principal grounds: (i) compulsory purchase of AGB Development Ltd’s base is not in the public interest; (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 done would be unacceptable. I reserve the right to expand on these objections at a later stage and revise them as appropriate. DATED: 31 MARCH 2021