Representation by Snowgoose Wildlife Trust (Snowgoose Wildlife Trust)
- Date submitted
- 31 March 2021
- Submitted by
- Non-statutory organisations
The Snowgoose Wildlife Trust is a registered environmental charity with nature reserves in Kent, Wales and Lincolnshire. I am chairman and a trustee. My knowledge of the Swanscombe marshes extends over 35 years of working locally and visiting them. We fully support the SSSI designation and consider that they should not be built on for any reason. We represent: a) That the geographic location of the Swanscombe marshes on a promontory makes it a vital stepping stone resource for wildfowl and other birds. These can pass along the estuary during the day and night on local and migration routes, for which the broadness beacon is probably a major landmark. b) That the geographic location of the Swanscombe marshes on a promontory gives it a unique climate that cannot be reproduced elsewhere. If it is destroyed it is gone. c) The Swanscombe marshes are a unique landform mosaic of interconnected open coastal and inland habitats. The marshes themselves have been developed through a unique circumstance of land formation, intertidal mud flats, large areas of industrial waste, used industrial processes, gravel dredging, fresh water and saline lagoons and tidal creek intrusions. The net result is an interconnected whole that is significantly greater than the sum of its parts for wildlife and flora of all kinds and an area that would be impossible to recreate by any compensation measures. d) The applicant has simply failed to understand what makes this a very special environmental area with the sum of the connected whole, far more than the number of individual parts. Ripping the centre out of the peninsular and ‘tidying up’ the areas by creating more pathways and human disturbance on what is left will simply destroy its very functioning. No compensation could possibly compensate. e) That the diverse mosaic of land conditions has produced not just a rich assembly of plant species but also scrub and long grass habitat. LRCH describe this as ‘untidy’ but it is today widely recognised as the ‘gold standard’ for wildlife of all kinds and the records here show it to be so. f) That the Swanscombe marshes are home to over 1,700 species of invertebrates over 250 of which are nationally of conservation concern. It supports over fifteen red list bird species and many others of principle importance. There are populations of Water Vole, Otter and nationally scarce flora and fauna. g) This is probably the most important single SSSI in the UK for invertebrate species including the rare jumping spider and as such irreplaceable by any mitigation measures. If it is the best then it means that despite efforts to do so, we have been unable to make a better one anywhere and that’s because we can’t. This is a really rare site. h) Modern approaches to nature conservation recognise that nature reserves must be substantial and connected and no more isolated pockets like many of our older nature reserves. The theme park proposes to rip the heart out of the SSSI and then fragment the rest. This is yesterday’s slash and destroy developer thinking at best and at worst it simply means that they don’t care about what or who they destroy. i) The marshes are needed as ‘green lungs’ for the thousands of new and existing homes within the area. There are ways of providing better access that will not do much harm to the SSSI but the prominent visual aspects and noise from the theme park proposals will take away even that pleasure. j) There has been no established need for a theme park k) They have not satisfied the financial ability part of the DCO application. Saying they think they can get the finance but are shy of saying where or who from is totally unacceptable when considering the destruction they propose.