Representation by The Royal Society for the Protection of Birds (RSPB) (The Royal Society for the Protection of Birds (RSPB))
- Date submitted
- 13 June 2024
- Submitted by
- Members of the public/businesses
INTRODUCTION The RSPB is grateful for the opportunity to comment on the Cory Decarbonisation Project and its impacts on the Crossness Nature Reserve. The RSPB is concerned about the proposals, which due to a combination of direct and permanent loss and indirect effects would damage and destroy part of this important component of the Erith Marshes Site of Metropolitan Importance for Nature Conservation. The RSPB recognises climate breakdown as a very serious issue, and we support efforts to address it. However, the ecological crisis is also very serious and efforts to address climate change should not come at a cost to declining wildlife and rare habitats, as would happen if the proposals for Crossness went ahead. Accordingly, we support community efforts to save this site. RSPB CONCERNS The RSPB raised concerns with the Applicant in November 2023 due to our concerns about damage to this rare fragment of the former Thames Marshes. We share concerns with the Save Crossness Nature Reserve community group around wildlife losses and significant deterioration of the site should the project be consented, and we support the group’s efforts to protect the site from damage. In summary, our reasons for this view are: • It is part of Erith Marshes Site of Metropolitan Importance for Nature Conservation, classed as Metropolitan Open Land, and is a valuable, rare and biodiverse remaining fragment of the once extensive Thames Marshes. • Notable species using the site include breeding Lapwing, Barn Owl and Skylark. Marsh Harrier and Bearded Reedling also occur. • Lapwing and Skylark are Red Listed Birds of Conservation Concern and have undergone significant declines in the London area. Marsh Harrier is Amber Listed. The list of birds that have occurred at Crossness Nature Reserve is remarkable, and includes numerous passage migrants, with scarcer visitors at times. • Shrill Carder Bee, a rarity now restricted in the UK to a few mainly Thames Estuary locations, is another important species found on site and its habitat is threatened by the Application. • Scarce invertebrates are a key feature of the site, and there is an important mosaic of invertebrate habitats at Crossness. The site is also within Buglife’s Thames Estuary South Important Invertebrate Area. • The Norman Road Field, proposed as compensation by the Applicant, is already wildlife-rich and cannot be treated as compensation for land lost to the development without net loss of biodiversity. • Crossness Nature Reserve is a precious London natural resource for people and wildlife, with much volunteer effort and scientific study invested in the site and excellent work involving the local community. • We consider that this site is too valuable for biodiversity to allow it to be harmed, and that an alternative site must be found for this proposed development. The RSPB is aware that other environmental organisations will be participating in the Examination as it progresses, and we have confidence that their thorough understanding of the site and its wildlife will help the Examining Authority understand the damaging implications of the Application for the Crossness Nature Reserve and Erith Marshes Site of Metropolitan Importance for Nature Conservation. Due to limits with capacity and resource, the RSPB will be unable to take further part in the Examination and therefore this will be the RSPB’s only submission to the Examination.