Representation by Buglife- The Invertebrate Conservation Trust (Buglife- The Invertebrate Conservation Trust)
- Date submitted
- 24 February 2023
- Submitted by
- Members of the public/businesses
Buglife has engaged with Highways England prior to the submission of the Lower Thames Crossing application over a number of years, with a focus on ensuring that the proposed mitigation and compensation schemes are designed to minimise the impacts of the proposals on invertebrates and their habitats. Buglife’s input was particularly focused on the north side of the crossing and encouraging low nutrient, free draining, wildflower-rich habitats that utilise the significant material been generated by the proposed project. However, while the incorporation of much of this advice into the scheme by Highways England is welcomed, the proposals still represent a significant threat to biodiversity. Buglife wishes to register as an Interested Party for the examination, based on the main concerns listed below. IMPACT ON THE THAMES ESTUARY IMPORTANT INVERTEBRATE AREA AND ITS NATIONALLY IMPORTANT POPULATION OF RARE AND SCARCE INVERTEBRATES: The proposed Lower Thames Crossing covers a large extent of habitat mapped in the Thames Estuary Important Invertebrate Area (IIA) which spans both the Essex and Kent side of the Thames. The IIA was identified using the data from 85 national invertebrate recording schemes and fine-scale mapped using data sourced from local experts and both the Essex Field Club and Kent & Medway Biological Records Centre. IIAs are nationally or internationally significant places for the conservation of invertebrates and the habitats upon which they rely. The proposed work would lead to the loss and further fragmentation of the valuable invertebrate habitats that support nationally important invertebrate populations. This includes the network of flower-rich, open habitats in South Essex supporting remnant Thames Terrace Grasslands invertebrate assemblages, ancient woodlands in Kent and invertebrates associated with freshwater habitat features in both Essex and Kent. This includes both Habitats and Species of Principal Importance under Section 41 of the Natural Environment and Rural Communities (NERC) Act 2006, including Hornet Robberfly (Asilus crabroniformis), Brown-banded Carder Bee (Bombus humilis), Red-shanked Carder Bee (Bombus ruderarius), Shrill Carder Bee (Bombus sylvarum), Five-banded Weevil-wasp (Cerceris quinquefasciata), Small Heath (Coenonympha pamphilus), Sea Aster Mining Bee (Colletes halophilus), Phoenix Fly (Dorycera graminum) and White-letter Hairstreak (Satyrium w-album). LOSS OF AND IMPACT ON LOCAL WILDLIFE SITES: The proposed Lower Thames Crossing would lead to the complete or partial loss of a number of Local Wildlife Sites (LoWS) in Essex that support Thurrock’s rare and scarce invertebrates, including Low Street Pit, Blackshots Nature Area, Mucking Heath and Rainbow Shaw. The proposals also include a temporary land take and alteration of hydrology at the Canal and Grazing Marsh Higham Local Wildlife Site (LWS) which could severely impact the site’s habitats and invertebrate interest. Several other Local Wildlife Sites with important invertebrate populations are within the order limits and may be negatively affected by the development proposals. IMPACTS ON THE SHORNE AND ASHENBANK WOODS SITE OF SPECIAL SCIENTIFIC INTEREST AND LOSS OF ANCIENT WOODLAND, VETERAN TREES AND WOODLAND HABITATS: The proposals would lead to unacceptable impacts on the Shorne and Ashenbank Woods Site of Special Scientific Interest (SSSI) and the loss of irreplaceable ancient woodland and veteran tree habitats in Kent. The habitats affected support important populations of nationally rare and scarce invertebrates. CUMULATIVE IMPACT OF DEVELOPMENTS IN THE THAMES ESTUARY AND FRAGMENTATION OF HABITATS: The Thames Estuary has suffered from a series of large-scale developments in recent years, with numerous extensive and important wildlife sites lost to development. This includes the brownfields and Open Mosaic Habitats on Previously Developed Land (OMHPDL) that support much of the nationally important invertebrate interest in the Thames Estuary . Buglife has previously highlighted the extent of losses of these habitats in its ‘State of Brownfields in the Thames Gateway’ report in 2013. The report revealed that over half of the wildlife-rich brownfield sites in the Thames Gateway that had been identified by Buglife between 2005 and 2008 had been either destroyed or had an outstanding planning permission in this short period of time. The continued loss of wildlife-rich sites in the Thames Estuary threatens the long-term future of the estuary’s nationally important invertebrate populations. It is essential that the impacts of the Lower Thames Crossing are considered cumulatively alongside other ongoing developments and pipeline proposals to properly understand the potential impacts on invertebrate populations. INDIRECT IMPACTS OF INCREASED NITROGEN DEPOSITION ON LOW NUTRIENT HABITATS: There remain significant concerns about how the increase in road use in the area could affect wildlife through increased nitrogen deposition, the impacts of which currently remain unclear. This could lead to vegetational changes on vulnerable low nutrient habitats as a result of soil enrichment and lead to loss of early successional features, reduce floral diversity and impact on bare ground habitats upon which many rare and scarce invertebrates. Nitrogen deposition could also reduce the long-term predicted biodiversity opportunities provided by the low nutrient substrate habitats detailed in the project’s mitigation and compensation schemes. SUMMARY: The proposals threaten sites supporting nationally important invertebrate populations in the Thames Estuary IIA and the long-term viability of populations in the region through further habitat loss and fragmentation. The proposals undermine the Government’s commitment to protect 30% of the UK’s land for nature by 30% and its commitment to Nature Recovery Networks and the 25 Year Environment Plan’s commitment to “effectively linking existing protected sites and landscapes”. Buglife reserves the right to add to/amend its position should new information be made available by the applicant or other Interested Parties related to these points.