Representation by Essex Wildlife Trust (Essex Wildlife Trust)
- Date submitted
- 10 January 2023
- Submitted by
- Members of the public/businesses
In respect of this development environmental sustainability is a paramount concern. An additional road based crossing of the Lower Thames is not, in our view, environmentally sustainable. We believe that new large infrastructure projects such as this should capitalise on the opportunity to encourage a shift towards low emission forms of transport such as public transport, rail and cycling. Notwithstanding these concerns, it is our aim to ensure that the delivery of this project has the minimum impact on the natural environment. In responding to this consultation we aim to ensure: • appropriate recognition is afforded to the internationally and nationally important habitats and the species they support within and adjacent to the development area; • a clear understanding of the impacts of the development on habitat connectivity; • a full understanding of the impacts of the development on nature conservation interests, including priority habitats and species; and • appropriate measures are identified to avoid, mitigate or, where necessary, compensate for those impacts. Essex Wildlife Trust objects to the plans for the Lower Thames Crossing. We have serious concerns about the impact of these proposals on the wildlife and habitats of Essex. We accept that the choice of a bored tunnel avoids direct impacts on the internationally important wetland and coastal habitats of the Thames Estuary Ramsar/Special Protection Area. However, the location of the tunnel portal to the north of the crossing (and the potential works area associated with the tunnel portal) will destroy habitats of importance for protected water voles, reptiles and rare invertebrates. The new road will also result in impacts on designated Local Wildlife Sites and priority habitats, including ancient woodland. Overall, the new road will have a serious detrimental impact on the south Essex landscape. It will result in loss or damage to important habitats and fragmentation of the habitats that remain, with accompanying impacts on protected and priority species, including biodiversity loss, habitat damage, pollution, noise, road lighting and the visual intrusion of ‘man-made’ infrastructure. New roads should be considered only as a last resort and as part of a sustainable transport strategy, which should be strategically planned and fully integrated with conservation objectives and the land use planning process. This should: • prioritise environmentally sensitive maintenance and improvement of the current road network over new road schemes; • reduce the need to travel, for example through well designed towns, cities and neighbourhoods, and improved transport technology; • promote less carbon intensive forms of transport; • promote reductions in private vehicle use in order to reduce traffic levels, fuel consumption and vehicle emissions, including fiscal measures and car share schemes; • minimise dependency on private vehicle use by increasing and improving public transport and active travel routes, which are well connected to essential services; • promote walking, cycling and other forms of active travel and promote active travel routes which are easy, safe and attractive to use; and • ensure biodiversity is protected and enhanced through the creation of new habitat networks. We have major concerns that the LTC will encourage increased car dependency and generate induced traffic. At the same time it will cause serious environmental damage, adversely impacting on biodiversity and increasing CO2 emissions which contribute to climate breakdown. This contradicts the Government’s own target set in the Environment Act 2021 to halt the decline in species abundance by 2030, and the commitment to reach net zero by 2050, including a pathway that requires 78% reduction in emissions by 2035. We will be rigorously seeking appropriate mitigation and compensation for the lost or damaged habitats, impacts on protected and priority species and opportunities to enhance, restore or create new habitats as part of the local ecological network. Our aim will be to ensure that if the scheme goes ahead there will be a significant net biodiversity gain as a result of this project. The areas of concern we wish to address through the DCO consultation process are: • Impacts on birds and the scheme’s proposed mitigation and compensation • Impacts on mammals and the scheme’s proposed mitigation and compensation • Impacts on reptiles and amphibians and the scheme’s proposed mitigation and compensation • Impacts on freshwater habitats and the scheme’s proposed mitigation and compensation • Impacts on terrestrial habitats (plants, grasslands, hedgerows, woodlands, veteran trees, etc) and the scheme’s proposed mitigation and compensation • Impacts on invertebrates and the scheme’s proposed mitigation and compensation • Impacts on marine habitats and the scheme’s proposed mitigation and compensation • The veracity of the Environmental Impact Assessment • The suitability of the Landscape and Environmental Management Plan • The veracity of the Biodiversity Net Gain assessment • The reduction of environmental damage through good design • The creation, enhancement and management of functioning ecological networks, associated wildlife habitats and key species populations • Ensuring that all proposed landscaping is appropriate to the natural character and ecological functionality of the area.