Representation by Buglife- The Invertebrate Conservation Trust (Buglife- The Invertebrate Conservation Trust)
- Date submitted
- 30 May 2024
- Submitted by
- Members of the public/businesses
The current project proposals will directly impact 2ha of Crossness Local Nature Reserve (LNR), a site that falls within the Thames Estuary South Important Invertebrate Area (IIA). IIAs are nationally or internationally significant places for the conservation of invertebrates and the habitats upon which they rely. The site at Crossness is part of a network of sites that have become increasingly fragmentated due to development and Buglife is concerned of the cumulative impacts on important invertebrate sites within the Thames Gateway. Buglife have concerns regarding impacts to both terrestrial and aquatic invertebrate assemblages. Relatively recent data from Thames Water provides figures of 69 notable species of terrestrial invertebrates from the reserve which include the European Vulnerable Moss Carder Bee (Bombus muscorum) and several Priority Species under Section 41 of the Natural Environment and Rural Communities (NERC) Act 2006, including the Shrill Carder Bee (Bombus sylvarum), Brown-banded Carder Bee (Bombus humilis) and Phoenix Fly (Doyrcera graminum).Data from the Terrestrial Invertebrate Survey report 2020-21 (Colin Plant Associates, November 2021) was run through the Pantheon invertebrate analysis database and this highlighted the favourable status of six Specific Assemblage Types, those associated with: rich flower resource, scrub edge, bark and sapwood decay, reed-fen and pool, open water on disturbed mineral sediments and undisturbed fluctuating marsh. This indicates the importance of the wide variety habitats present at the reserve to the invertebrate assemblage. Of particular concern is the loss of habitat for the Shrill Carder Bee, a species which requires a network of flower-rich sites, so can suffer from the progressive loss of sites, as has been the case in the Thames Estuary. A Invertebrate Habitat Potential assessment has been undertaken to inform proposals but no terrestrial invertebrate surveys have been undertaken. The aquatic macroinvertebrate community present within the Site have been identified as being of Regional importance. Rare species that have previously recorded in a 2019 Aquatic Invertebrate Survey of the reserve (Colin Plant Associates, July 2019) include the Vulnerable Lesser Spangled Diving Beetle (Graphoderus cinereus) and two Near Threatened water scavenger beetles, Hydrochus ignicollis and Hydrophilus piceus. The scheme will result in the loss of 540m of the ditch network which will be difficult to adequately mitigate for. Crossness LNR is part of Eith Marshes Metropolitan Site of Importance to Nature Conservation (MSINC), an important remaining area of grazing marsh on the Thames, with a wildlife-rich ditch system. Belvedere Dykes MSINC and River Thames and Tidal Tributaries MSINC, also falls within the site. There will be permanent loss and impacts to these sites from the proposals. A wide range of impacts from the project on terrestrial and aquatic invertebrates has been identified during both the construction and operational phases. Some of the impacts included adverse effects from; loss of habitat, degradation and fragmentation of habitat, decrease in water quality due to pollution and Artificial Lighting at Night (ALAN). Buglife is concerned that there are multiple conflicting land use issues with the direct loss of Crossness LNR from the scheme. Firstly, Thames Water highlight in their consultation response that Crossness LNR was secured by a Section 106 agreement for a period of 99 years from 1994 as compensation for the “Sludge Powered Generator planning permission”. In addition to this conflict of use, a key proposal to mitigate impacts is the ‘enhancement’ of Norman Field, adjacent to Crossness Nature Reserve. Norman Field already supports the HPI Coastal and Floodplain Grazing Marsh, as well as a network of ditches and scrub habitat. It is already a valuable wildlife habitat. Buglife understands that this land was already used for mitigation for the Veridian Park development in Thamesmead and it is not appropriate for it to be utilised again for another development. Buglife is therefore very concerned that Norman Field is the primary area of focus for compensation for loss of habitats, considering the habitats the Field already supports and the high likelihood that notable and/or Priority Species of invertebrates are present. In summary, Buglife are concerned that the proposals will result in an overall loss of important invertebrate habitats and potentially ongoing adverse impacts on the Thames Estuary South IIA that supports a nationally important assemblage of invertebrates.