Representation by Calum F Kerr
- Date submitted
- 16 June 2024
- Submitted by
- Members of the public/businesses
I am a resident living within two miles of the site and a member of Friends of Crossness Nature Reserve, these comments are my own. I experience the reserve very regularly and it is valued for my health and interest in wildlife. Below are my comments after reading the documentation, I also objected at the consultation. Cory’s submission shows even more how negatively impactful it is on the Nature Reserve. Quotes from the application are in "quotations" Land Definitions - Examples in EN010128-000145-6.1 Environmental Statement - Chapter 10 - Townscape and Visual - Cory has used the definition "Accessible Open Land" and "Non-Accessible Open-Land" throughout the ES. Obviously, most of the site is what they call "Non-Accessible Open-Land", it is a nature reserve not a park. Cory is using this definition to justify building on Crossness LNR because the areas are fenced off. Ignoring that it is for a variety of wildlife and the grazing horses that need to exist without human footfall. The nature reserve is currently accessible, people use the public paths and binoculars or cameras to view the wildlife, Cory’s definitions devalue this. Also acquiring the nature reserve land from Thames Water contravenes a 99 year 106 agreement and that should be retained. EN010128-000118-5.9 - Statutory Nuisance Statement mentions the direct, permanent, long term Significant effect on the users of the Accessible Open Land at Year 1 and at Year 15. This is too significant a 'nuisance' over a long time to justify building on Crossness LNR. EN010128-000109-5.2 - Planning Statement.pdf PP75. 5.4.1 says “This calculation does not include either replacing the stable block or potential diversion of the Thames Water Access Road as these would be like for like replacements of existing features within the MOL.” This shows that Lagoon Field will not only have a relocated stable block built on it but a diverted public path F2 through it, damaging the no-footfall nature of the nature reserve paddocks, it is not "like for like". Proposed Mitigation - EN010128-000097-5.1 Consultation Report Appendices Volume 4.pdf - Not an Enhanced Nature Reserve - There is little evident enhancement of the MOL in this application, losing 11.7% of Crossness LNR is not "small", the mitigation in Norman Road Field does equate to the loss. For mitigation Cory are just renaming Norman Field, the birds do not know the difference, wildlife will be experiencing the loss of grassland, verges, and waterways from the removal of the Stables and East Paddock. Cory say the paddocks are “found to be in ‘poor’ condition’ due to low water table levels and pressure from grazing” (EN010128-000113-5.6 - Design Approach Document - Part 1 of 3 Page 61) Grazing is crucial to the reserve, and the "pressure" on other paddocks will only increase if these fields are lost. Biodiversity Net Gain - Re EN010128-000177-6.3 Environmental Statement - Appendix 7-1 – Biodiversity Net Gain Report - "Thamesmead Golf Course, amongst other offsetting options, has been identified as a possible opportunity to deliver Biodiversity Net Gain (BNG) equating to 10%” - Thamesmead Golf Course is a place that I am familiar with, it has already been reclaimed wonderfully by nature. Local naturalists have suggested Peabody the current owners turn-it into a nature reserve, this environment is robust for birds and other wildlife. The Golf course already has consultation docs from Sustrans in relation a Peabody plan to increase accessibility. Any financial input from Cory to Peabody to make changes does not justify removing part of Crossness Nature reserve for 'net gain'. Also what are the "other offsetting options", where are the details? From: EN010128-000215-7.9 - Outline LaBARDS) 12.1.6. “It is proposed that the management plan is replicated and updated for the expanded LNR in consultation with Thames Water, Peabody Trust, and the Friends of Crossness LNR and this will be provided as part of the full LaBARDS for approval..” I am aware many Friends of Crossness do not consider this plan as extending the reserve, any consultation has been to prepare for the absolute worst case scenario for Crossness LNR which is the acceptance of Cory’s preferred plan. Ecological Surveys - Ref: ES Chapter 7: Terrestrial Biodiversity Report The ecological surveys are inadequate in assessing the East Paddock, Stables Paddock and the mitigation area. The effect of building the CCS on the reserve is greatly underplayed. The proposed mitigation area Norman Field is rated as ‘poor’ when there are nesting barn owls, raptor perches and many migrant birds yearly. Reptile survey (EN010128-000183-6.3 Environmental Statement - Appendix 7-7 - Reptile Survey Report.pdf) Pg4. 2.4.2. - East Paddock not sufficiently surveyed for reptiles, did not survey “due to presence of horses”. Acknowledges (pg8 4.4.3) that there is potential for adverse effects on reptiles and that they ‘may’ be in the proposed area. Similarly for EN010128-000182-6.3 Environmental Statement - Appendix 7-6 - Botanical Survey Report.pdf - 2.4.3. “No safe access was available to the East Paddock (as detailed in Figure 7-10: Ecological Survey Areas (Volume 2) due to the presence of horses”. Access could have been sought with co-operation with the Grazier. 2.4.4. "Access to ditches was not possible due to health and safety concerns and reeds blocking the view" - Challenge Cory's assessment as ‘Poor’. The ditches bordering the Stables / East Paddock, those hawthorn bushes and scrub described have high numbers of migrant birds such as Wheatear, Stonechat, Cetti's, Reed and Sedge warblers. The ditches / paddocks threatened support these birds and should not be built on. The surveys are inadequate. Application mentions “Direct, permanent, long term, moderate adverse (significant)” - affect on Crossness LNR within the ES assessment, how can this be acceptable for a significant new development? Alternative sites - Ref: ES - 7.5 Terrestrial Site Alternatives Report Cory have dismissed the alternative sites to the East where there is industrial land, Iron Mountain storage, Lidl Warehouse, etc. Inadequately explored these alternatives. Their reasons for not choosing are the affect on businesses and duct work over paths but all options involve some duct work over the reserve / paths. All South Zone options involve loss of Metropolitan Open Land / Crossness LNR / Erith Marshes but these are the only ones considered! Building on the nature reserve appears just the least expensive option for Cory, more investigation needed to consider the concreted land nearby, with alternative industrial sites in the borough of Bexley provided for those businesses. Planning Inspectorate - Reference: EN010128 Planning Statement Application Document Number: 5.2- 5.6.2. “In order to achieve the objectives of the Proposed Scheme, there is no reasonable option that avoids loss of MOL and all reasonable measures have been taken to minimise this impact” - There is insufficient investigation into the alternative sites, building on the reserve is the maximum impact not minimum. Grazing / Traveller Rights The grazier who run the stables is threatened with the relocation and reduction of their grazing land. I am aware they have a long family history on the land but only referred to as 1 private grazier. The stables field is there to nurture horses, vital in managing a ‘grazing marsh’ reserve. Relocation of the stables proposed will create loss of further nature reserve land. In 7.5 Terrestrial Site Alternatives Report - Pg97. 6.4.49. “The loss of grazing land is minimised and affects one private interest …”- It is not minimised considering the graziers history and that these stables were built using GLA money in the 2000's, it is a major effect to relocate. Pollution - EN010128-000087-5.1 - Consultation Report Appendices Volume 1 page 68 - The possibility of pollution and chemical disasters is increased by building the CCS on the reserve. Nitrosamines (which are carcinogenic) and Nitramines used in the CCS do not bode well for health. Potential pollution from the Solvent and Carbon Storage proposed. Air quality - Ref EN010128-000087-5.1 - Consultation Report Appendices Volume 1) - 5.8.54. "The annual mean nitrosamine 2 impacts exceed 1% of the long - term objective in the A13 Ripple Road AQFA and the Rainham Broadway AQFA. The annual mean aldehyde impacts exceed 1% of the long-term objective in the Rainham Broadway AQFA but are <2% of the EAL for NDMA.Whilst the pollutant impacts cannot be screened as negligible, increased risk to health is very low when considering the overall conservative nature of the assessment.” Long-term increase of cancer-causing chemicals is unacceptable. 5.8.63. “The air quality impact of the Proposed Scheme on NOx at Crossness LNR, which is located partly within the Proposed Scheme Site Boundary, equates to 1.2% of the critical level. However, the Critical Level (30 ? g/m 3) is not exceeded under either the Baseline or Proposed Scheme scenarios and, as such, the effects at Crossness LN can be determined to be insignificant.” Any increase over time will affect humans and wildlife visiting Crossness LNR and Rainham Marshes across the Thames. Visual Design / Construction The designs (Ref: EN010128-000126-2.10 - Engineering Plans Elevations.pdf) show huge CCS stacks which will be visible throughout the nature reserve, the Thames Path, Southmere Park and Lesnes Abbey Woods. Already with Riverside 2 there is construction until 2026, with this development until 2030, overall it is 6 years + of construction, acknowledged in the application as particularly affecting Crossness LNR. Visitors to Crossness LNR will be surrounded by Cory infrastructure, it will make it unbearable. Decommissioning - Ref EN010128-000087-5.1 - Consultation Report Appendices Volume 1) - If the CCS has a built design / structural life of 25-50 years it is not worth building on fields for nature that will last much longer. It is even acknowledged that the demolition of the scheme could improve the area! LIMITATIONS AND ASSUMPTIONS 7.13.1. “The assessment undertaken in this Chapter was limited by incomplete ecological surveys, which are ongoing during the summer and autumn of 2023. However, sufficient information was available to determine residual effects of the proposed Scheme for the majority of ecological features. Where insufficient information is available from surveys, this has been made clear” - This application does not determine effectively residual effects on the ecological features. Any ‘moderate adverse’ effects are cumulative and make for major significant effects over time. PG 892 - 14.8.20 …”This may deter some bird populations and reduce overall levels of tranquillity and enjoyment of the site.” – Crossness LNR is one of the best places to view birds all year round, this shows the development is not viable on a public nature reserve. 14.8.23 - “For the assessment of effects on terrestrial recreation, the sensitivity of Crossness LNR and Erith Marshes SINC is medium as they provide a regionally important area for recreation and tourism. The magnitude of change for those areas of the LNR and Erith Marshes SINC that will be lost is medium. Therefore, there is likely to be a direct, permanent, long term, moderate adverse (significant) effect on Crossness LNR and Erith Marshes SINC.” The application suggests there will be permanent and long-term effects for everyone who visits Crossness LNR, not “moderate” ones. I urge the Planning Inspectorate to not consider Cory’s application for the CSS if they insist it is built on 11.7% of Crossness LNR, a grazing marsh habitat that is increasingly rare in Greater London.