Representation by Friends of Crossness Nature Reserve (Friends of Crossness Nature Reserve)
- Date submitted
- 14 June 2024
- Submitted by
- Members of the public/businesses
I, Marc Lindsay Tuft, submit this objection on behalf of the Friends of Crossness Nature Reserve. I have also submited an objection in my own name, as a local resident. Land protection The land is designated as a s106 Local Nature Reserve, Metropolitan Open Land, and a Site of Metropolitan Importance for Nature Conservation. Location The location is wrong. The very concept of building on a nature reserve to offset one’s carbon footprint is ludicrous and makes a mockery of Cory’s green credentials. The Belvedere Industrial Estate is right next to Cory’s waste incinerators. This is the location for large infrastructure – so large that it is considered Nationally Significant – not on land that functions to support wildlife and people. The very notion is absurd. Cory’s preferred South Zone 1 location does not meet their own optioneering principles. Only two principles are met: reduced cost and complexity. Their site selection doesn’t meet the remaining principles regarding species, biodiversity and MOL. Other location options, particularly in the East Zone – an area purposely designed for infrastructure – has not been robustly explored and seems to have been dismissed early because of the increased cost. We would urge the inspectorate to ensure that a Nationally Significant Infrastructure Project is built on land designed for such, not on a nature reserve. An ‘extended nature reserve’ Cory are greenwashing. This development results in net loss of habitat whichever way they spin it. Their mitigation is making enhancements to habitat that already exists for nature. It doesn’t make for a larger nature reserve because it is already there! Norman Road Field (then known as Area 5) was created as wildlife habitat by Tilfen Land (now Peabody Estates) to mitigate their own development impacts. Peabody already have a duty to manage it for nature conservation to offset habitat loss, so Cory’s use of this area would be double-counting. We are concerned that Norman Road Field has been selected as the closest and cheapest option to provide a ‘sink’ for the decarbonisation impacts, so that the increased run-off and flood risk from the decarbonisation plant can be diverted to Norman Road Field and termed a ‘new wetland area.’ So that the displaced water voles and reptiles can be simply relocated to Norman Road Field. This is all about reduction of cost and effort. Measuring of impacts We don’t understand why the whole of Crossness Nature Reserve hasn’t been surveyed. Why has the Protected Area – a part of the formal LNR – been excluded from the red line boundary? Access is for members of the FoCNR (It is free and simple to become a member) and all wildlife is welcome, and its exclusion from the surveys results in skewed baseline wildlife data. We think that Island Field and Island Field Lagoons have been excluded from wildlife surveys, even though they are within the red line boundary to the south-west. We can find no evidence in Cory’s survey results of breeding and wintering birds from these areas, despite their importance for breeding Pochard (a red listed Birds of Conservation Concern) for example, and providing habitat for breeding reed warbler, sedge warbler, Cetti’s warbler, water vole and other species. These exclusions skew the baseline data, making it appear that the nature reserve’s biodiversity function is reduced. We are also concerned about the lack of survey effort on the wider nature reserve. The East Paddock and Stable Paddocks appear to have been surveyed from the margins due to the presence of grazing horses. This could have been overcome if they had liaised with the site warden who could have organised safe access. The result is that there hasn’t been a proper assessment of the development impacts on the very land that will be lost. The RS2 construction works are significantly affecting habitats and wildlife, which is affecting the baseline so the assessment of overall impact needs to bear that in mind. Cory also haven’t carried out comprehensive surveys of the adjoining habitat that will be impacted by noise, shading, dust, run-off. No reptile surveys were carried out on the actual nature reserve. Figure 7.17 (ES 6.2 Figures Part 1) shows that in addition to Riverside 1 grassland, only Norman Road Field (Peabody land) was surveyed and the very eastern edge of East Paddock along Norman Road where just 4 refugia mats were placed. This isn’t good enough. Crossness was a receptor site for over 1200 reptiles (slow worms and lizards) and holds breeding grass snake. This in fact provides a good example of how survey findings can underrepresent what is actually on site, because when it was agreed that Crossness would be a receptor for displaced reptiles from a development in Erith, we were told to expect a small number of reptiles based on ecological surveys, but the translocation resulted in 854 slow worms and 390 common lizards being released at Crossness, so Cory’s results turning up just 2 common lizards vastly underrepresents what it is actually present. This will be because they didn’t survey the nature reserve, and where they did, the density of refugia was inadequate (10 per hectare according to their own recommendation in Table 5-1 of Appendix 7-2 Preliminary Ecological Appraisal) and the survey period wasn’t long enough. Surveys should have taken place throughout the breeding season. Instead, they surveyed for just 2 weeks (13-29 September 2023 with refugia collection 3 October 2023) (2.3.2 of Appendix 7-7). The reptiles that are not directly impacted by the land loss, will be impacted by the height of the buildings and the shading it creates because cold-blooded reptiles require external heat, so the decarbonisation plant could have a significant impact on reptiles and yet they have not been properly assessed. We have the same concern regarding bat surveys. The only bat detector on the nature reserve was on the western edge of East Paddock, just 120m from Riverside 2 construction where disturbance and light pollution would have deterred bat activity because they prefer dark habitat corridors for foraging, and so skewing the baseline data. We feel that all wildlife data is skewed by the construction of Riverside 2 and so the baseline is misrepresented. Survey effort has focussed more on the habitat that will remain as mitigation in Norman Road Field, and not enough on the LNR that will be lost and most severely impacted by the decarbonisation project. Designations The Friends are concerned that Cory are trying to undermine the importance of the nature reserve by creating a new ‘Accessible Open Land’ designation. Any controlled access at Crossness is so that visitors aren’t trampling habitat and destroying the very wildlife that they come to see. All paddocks can be viewed from adjacent footpaths and dedicated wildlife viewing screens, but controlled access ensures visitor safety where livestock is present, and ensures that wildlife remains as undisturbed as possible. The Protected Area which Cory have conveniently excluded entirely, is an accessible part of the reserve where people can walk down boardwalks through reedbeds, through grassland and scrub and be fully immersed in nature. ‘Non-accessible Open Land’ does not equate to less valuable and should not be presented as such. Visitors We are concerned that visitors and members will be deterred from visiting Crossness Nature Reserve in the future. Nobody visits a nature reserve to find themselves in the middle of a construction site. This area was once an open, wildlife-rich part of Erith Marshes. Cory have already destroyed that openness by building Riverside 1 and Riverside 2 to the north and by destroying land to the east where Skylarks bred until 2023 (when construction started). With the threat of this huge decarbonisation plant and the 5 years of construction disturbance we face, it is not just wildlife that will be deterred, but people too who expect peace, tranquillity and wildlife. We worry that all this will be lost. The decarbonisation plant has no place here on a nature reserve. If it is granted, it should be on the industrial estate, not on a nature reserve doing its best, in the middle of a biodiversity crisis, to support people and wildlife. Graziers Graziers from the Gypsy community graze their horses on designated paddocks on site under licence. This is beneficial to the ecology of the marshes; horse densities and animal welfare are carefully managed by Thames Water. The grazing of horses has taken place on this and adjacent sites for generations by families who have historic ties to the land. Visitors enjoy seeing the horses and they are an integral part of the visitor experience. Section 106 When the Thames Water sludge incinerator was granted planning consent, an important planning condition was enshrined in a section 106 agreement. In 1994, Thames Water was required to create Crossness Nature Reserve and tied into a 99-year agreement to manage it for wildlife and the local community. Public funding In 2005 and then in 2014, substantial public funds were invested in the marshes and Crossness Nature reserve from the Managing the Marshes and Belvedere Green Links programmes. In this context, substantial investment went into the creation of paddocks for horse welfare, a stables block, the clearing of ditches for ecology and to reduce localised flooding, the installation of the Gypsy Cob sculpture by Andy Scott on a local roundabout to place the project firmly on the map. We are concerned that these investments could be compromised by the development. For example, it is proposed to build on several paddocks and to destroy the stables block. The new construction will inevitably transform the hydrology of the site which is carefully managed at present. And what would be the point of a large Gypsy cob sculpture if all the real life gypsy cobs have been displaced? Petition A petition started by one of our members has attracted 2,926 signatories opposing Cory's proposals (on 14.06.2024).