Representation by Kent Wildlife Trust (Kent Wildlife Trust)
- Date submitted
- 23 February 2023
- Submitted by
- Members of the public/businesses
Kent Wildlife Trust (KWT) engaged with Highways England (“the Applicant”) prior to DCO submission, with a focus on reducing the impacts upon the internationally important habitats of the North Kent Marshes and Thames Estuary, which resulted in successfully reducing some of the impacts of the scheme through design changes. However, whilst efforts were made to address some of our concerns, the scheme still poses a significant threat to biodiversity. We wish to register as an interested party for the examination of Lower Thames Crossing, hereinafter referred to as “the Project”. KWT’s main concerns are listed below. ASSESSMENT OF ALTERNATIVES • Since the start of LTC there has been progress in policy around the climate and biodiversity crisis. It is our overall feeling the Project should be part of a sustainable transport strategy that aligns with the UK’s climate and environmental policies IMPACTS TO BIODIVERSITY • During the construction phase, the Project will result in habitat loss within statutory and non-statutory designated sites, including the irreversible loss of ancient woodland (there are discrepancies within the DCO about how much ancient woodland is being lost.) We would expect to see new woodland creation at a minimum of 30ha created for every one hectare of ancient woodland lost (30:1), however the proposed mitigation currently falls below this. • The widening of the A2 and construction of green bridges will see the direct and permanent loss of habitat within Shorne and Ashenbank Wood SSSI, including ancient woodland. • The Project would also result in the permanent removal of semi-natural broadleaved and plantation woodland, hedgerows, scrub habitats of County Importance, calcareous, species-poor semi-improved and improved grasslands, open mosaic habitat, swamp and marginal vegetation, arable land, ponds and streams and temporary loss of coastal and floodplain grazing marsh. • Contrary to the Applicant’s assessment that there will be no significant impacts to South Thames Estuary and Marshes SSSI, we are concerned that the significant risk of habitat degradation due to dust deposition and changes in water quality and quantity, which would result in the negative effect on the grazing marsh, saltmarsh, dykes and mudflats for which the SSSI is designated. The construction of the tunnels also has the potential to lead to reduced water levels within the ditch system associated with South Thames Estuary and Marshes SSSI, which would negatively impact flora and fauna through loss of wetland habitat, and therefore would cause direct habitat loss, which currently the application has not mitigated for. • Statutory designated sites, including SACs, SPAs, Ramsar sites, SSSIs and LNRs were only assessed up to 2km of the Order Limits. Likewise, non-designated sites such as LWS and ancient woodlands were only assessed up to 500m of the Order Limits. • The Project will see the permanent and temporary loss of functionally linked land (FLL) to the Thames Estuary and Marshes SPA and Ramsar. The proposed mitigation for the loss of FLL includes enhancements at Coalhouse Fort and Metropolitan Police firing range, however the firing range will be used as a construction compound during the works and will be reinstated for habitat enhancements post construction. Therefore, we have concerns regarding the lack of suitable FLL during the construction phase, which may have a significant negative effect to the bird populations the SPA is designated for. • Canal and Grazing Marsh Higham LWS will be reduced by 7% for the construction of a temporary compound. This includes altering the hydrology by diverting a watercourse, which has not taken into consideration the negative impacts this will have on surrounding habitats and species. • We are concerned about the potential for impacts to designated and non-designated wildlife sites from changes to the wider road network. BIODIVERSITY NET GAIN • An amendment secured within the Environment Act 2021 makes biodiversity net gain (BNG) a requirement for Nationally Significant Infrastructure Projects (NSIPs) with a minimum of a 10% BNG required. The Project currently has a 7% net gain in habitat units, -11% in hedgerow units and -7% in river units and therefore don’t meet the minimum targets. It is also essential for applicants to show how they have followed the ten Biodiversity Net Gain Good Practice Principles. • The Project has not yet been designed in detail; therefore, the application might not represent the total amount of habitat and biodiversity loss and the proposed mitigation may underrepresent what is required. • The loss of irreplaceable habitats, such as ancient woodland, would prevent any overall claim of BNG. MITIGATION, COMPENSATION AND PROTECTED SPECIES • We continue to have concerns regarding the suitability of proposed mitigation and believe that the mitigation hierarchy has not been appropriately applied and the proposed mitigation will not have an overarching positive impact to wildlife, biodiversity, and climate change. • We have concerns over the proposed seven mixed-use bridges as we believe they have not been designed for wildlife as they provide limited level of mitigation and are for the functionality and permeability of the Project’s infrastructure. • The Project will see the displacement of species through direct habitat loss and fragmentation and increase wildlife roadside mortalities, including the direct mortality and loss of habitat containing county-level important macro-invertebrates. • Barbastelle, one of the UK’s rarest species of bat, was recorded during a bat transect in Brewers Wood. Barbastelle have never been confirmed in Kent, therefore any passes and potential roost sites in Kent are a significant find. • Best practice guidelines were not followed during ecological surveys, resulting in inadequate data collection. CLIMATE CHANGE • The Project will undermine the Government’s commitments to addressing the climate and biodiversity crisis with total net greenhouse gas emissions of approximately 6.596 million tonnes of carbon dioxide equivalent (tCO2e). • We have concerns regarding the impacts during the operational phase on ecological receptors and statutory and non-statutory designated sites, including nitrogen deposition resulting in degradation of habitats. • The Project hopes to deliver economic growth, which will result in further greenhouse gas emissions through new developments and further loss of carbon storage and sequestration habitats. • We are concerned about the cumulative impacts of the Project, and the risk of an increase in development encroachment on protected wildlife sites and mitigation areas.