Representation by Mark Warnett
- Date submitted
- 31 March 2021
- Submitted by
- Members of the public/businesses
ECOLOGY & SSSI The Gravesham and Dartford area has changed beyond recognition in my lifetime due to on-going development. There are very few places locally where interesting and varied nature can be found. Within five minutes of my first visit to the Swanscombe Peninsula I had seen my first Marsh Harrier, hunting in an area which would be part of the core theme park. On this and every subsequent visit, observing the wildlife on the Peninsula has given me great and lasting pleasure. This is an important and scarce nature resource and in my opinion the environmental impact of the development would be a tragedy. Based on over-laid digital plans, I calculate London Resort would develop over 243 acres of the new SSSI. I believe the direct SSSI loss is without precedent under the NPPF. The significant change in the legal status of the development site is not accounted in the application and justifies a new round of consultation and re-evaluation of relevant Chapters of the Environmental Statement (ES), which are now obsolete. My concern is not allayed by the conclusions of the ES or the Applicant’s mitigation proposals. I cannot reconcile the scale of loss of a number of different nationally significant habitats with the ES’s conclusion that the most significant impact is ‘moderate adverse’ at regional level. Moreover I note that while the ES recognises the importance of the ‘mosaic’ of habitat, it only seems to consider species and habitat impacts individually and does not assess the significance and magnitude of the impact on habitat as a whole. I also cannot reconcile the loss of 243 acres of SSSI with the conclusion that this would result in ‘no significant’ residual impact, particularly as there is no detail provided on off-site mitigation proposals, despite this being a fundamental element of the Applicant’s mitigation proposals. LAND ASSEMBLY I am a compulsory purchase surveyor with 15 years’ experience acting for both claimants and acquiring authority. In my opinion the Applicant has not made reasonable efforts to acquire interests by agreement as required. I understand the Applicant had not acquired any interests between the NSIP designation in 2014 and the application for Development Consent being made. The Applicant should disclose how many conditional agreements had been agreed at that date. There is a known scarcity of commercial property in this location. Other CPO schemes affecting commercial property I am involved in have made pro-active efforts to support claimants re-location, including appointing site finding agents. I am unaware of any such support provided by the Applicant. The 30% premium over the compensation code is ostensibly generous and commendable. However the number of businesses affected mean rental and freehold values locally risk increasing corresponding increased demand from displaced claimants, eroding the benefit of this premium. Moreover it will not apply to businesses needing to extinguish. I would encourage the Applicant to amend its acquisition policy as follows: i. +30% applying to all compensation including extinguishment. ii. Minimum 12 months notice period prior to Applicant taking possession.