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Representation by Gabriel Ciudatu, AGB Cars Ltd (Gabriel Ciudatu, AGB Cars Ltd)

Date submitted
31 March 2021
Submitted by
Members of the public/businesses

BC080001 Outline Objections of Gabriel Ciudatu, Director of AGB Cars Ltd Introduction 1. I am the Director of AGB Cars Ltd, of Unit B5, Manor Way Business Park, Manor Way, Swanscombe, Kent DA10 0PP. Nature of AGB Cars Ltd 2. AGB Cars Ltd deal with second hand car sales and have a large amount of stock at Manor Way. It also sub-let to a number of tenants who specialise in car sales, salvage, MOT, recovery and repairs. We also deal with part exchange and arrange finance. I have been at Manor Way Business Park for four years. My freeholder is Vitesse Investments Ltd and Buckland Dartford Ltd. The lease is for five years. 3. AGB Cars Ltd work closely with some of its sub-tenants who are Interested Parties will be filing Written Representations. We all run similar businesses and cross-refer work. I am very concerned that if the land I lease is subject to a CPO, LRCH will not find suitable land with all the acres I require. 4. AGB Cars Ltd also leases land from Swancombe Developments Ltd at the Former Swanscombe Works, London Road Swanscombe, Kent DA10 0LL. The lease expires on 20 October 2023. There is a break clause. The lease will terminate on a date which is not less than 3 months after service of a break notice, at any time on or after 22 March 2022. 5. AGB Cars Ltd also leases Unit B4 Manor Way Business Park. The freeholder of this unit is Vitesse Investments Ltd. The lease is for 5 years. Therefore in total AGB Cars Ltd lease 14.25 acres and will require this is they are relocated. 6. Because of the nature of my work, I require a brownfield site away from residential properties. My tenants need to be at the same premises as we compliment one another. They consider that my rent is very reasonable. 7. Our location is a very good spot close to Dartford Tunnel and the rent AGB Cars Ltd pays to the freeholder is reasonable. There are no suitable premises in this location with the acres I require. 8. If AGB Cars Ltd were to move from this site, we would incur significant losses which will not be fully compensated. 9. Compulsorily purchasing our major base which provides an important service to the public is not in the public interest and would unreasonably interfere with our human rights. Policy Position and Funding 10. 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. 11. The funding position is opaque. The corporate structures and accountability must be transparent in order that they be examined in detail. They are not. 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. I understood the DCO process is “front loaded” so this information should already be available but it is not. The situation is far from clear at present. Following the COVID pandemic there has been no adequate re-assessment of whether the proposed project is viable. Environmental Effects 12. 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 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. 13. 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. I do not consider that there is an overriding public interest in this proposal going forward. I do not consider this has been properly assessed in the Environmental Statement or in the HRA. I also have concerns about how the construction works will be accommodated including impact of the securing accommodation for workers and traffic impacts. Conclusion 14. In summary object on four principal grounds: (i) compulsory purchase of AGB Car Ltd’s is not in the public interest and there has been an inadequate engagement by the applicants in securing suitable alternative accommodation for my business; (ii) the London Resort lacks government policy support and has not been demonstrated to be deliverable in funding and/or viable (iii) if built, the effects on traffic congestion and pollution would be severe and (iv) the ecological harm done would be unacceptable (including during constriction). I reserve the right to expand on these objections at a later stage and revise them as appropriate. Dated: 31 March 2021