Representation by Josh Nelson
- Date submitted
- 31 March 2021
- Submitted by
- Members of the public/businesses
I am a former Member of Council and Trustee of the Amateur Entomologists Society and a former Member of the Committee of the UK Bees, Wasps and Ants Recording Society. I have been visiting the Thames Gateway area, in particular so called brownfield sites (previously developed land) to record and study the habitats and species found there, for over thirty years. I have no doubt that the Swanscombe Peninsula - as a whole, is of exceptional value to biodiversity; both in itself and in its likely functioning as what could be considered as a meta population hub for mobile species such as birds and invertebrates. It is a key site for biodiversity both in the context of the Thames Gateway - itself a biodiversity rich but increasingly threatened area for wildlife and habitats, but also as a site itself of what must be considered national importance for its habitats and species assemblages. There is no way that the development proposed could in any meaningful way preserve or effectively mitigate the very substantial biodiversity loss that would be brought about if it were to be imposed here. Nor is it acceptable to suggest some preservation of wetlands can compensate for the unmitigatable loss of some of the much rarer habitat types. For instance, the open, drought prone historic aggregate rich sites are vital to many thermophilic species that are particularly scarce and in need of protection from development. Others will make the point more fully and helpfully I am sure but, suffice it to say, the now famous Distinguished Jumping Spider Attulus distinguendus is a denizen of the drylands and not an aquatic arachnid. I therefore wholeheartedly support Natural England's clear position on SSSI status, including geographical extent; indeed, I would suggest that the site should be made a national nature reserve. Seeking to rely on status of the proposed development as a nationally significant infrastructure project - in this location, would drive a coach and horses through the national imperative and fundamental planning policy framework underpinning of sustainability. If such a project were to be deemed necessary near to London (which I do not comment upon here), then there must be a great number of potential candidate sites that do not involve what would be the unconscionable loss and destruction of such a nationally important biodiversity resource, which already helps so many and has the potential to improve the lives and well being of so many more people. The candidate development could be constructed elsewhere but the biodiversity on this site cannot be mitigated; further, as this site provides a vital link to an abundant natural world for people to visit and spend time in, the development would lead not only to a significant loss to biodiversity but also to the well being potential that the planning system should also seek to maintain and promote. Development here would be a double failure on planning grounds. Josh Nelson