The next round of public consultation on the Lower Thames Crossing begins on Wednesday, July 14, and runs for eight weeks until Wednesday, September 8. Highways England says: “This Community Impacts Consultation will give people the opportunity to review and comment on our plans to build and operate the Lower Thames Crossing, and how we propose to reduce our impact on the local community and environment. “Topics include changes to traffic, air quality, noise and vibration, as well as the impact of the new crossing on the environment and landscape. “The consultation will also include some changes made to the project since the previous consultation in 2020. This includes a reduction in the area needed to build and operate the scheme, a smaller impact on local properties and woodland, and new public spaces on both sides of the River Thames. “We have also summarised how the feedback provided during earlier consultations has been used in the development of the project.” CPRE Kent believes a new crossing is not an acceptable option. Speaking before a previous round of consultation on the project, Alex Hills, CPRE Kent’s Gravesham district chairman, said: “Cities in this country and around the world have become aware that, due to the dreadful Covid-19 disease, more needs to be done to boost active travel (walking and cycling). “This is partly to enable social distancing and partly to reduce air pollution. The Climate Change Committee has called for proposed spending on roads to be spent on measures that offer better value for money and at the same time reduce congestion and air pollution. “Increasing investment in active travel, sustainable transport and broadband all offer better value for money. The KenEx tramline (see here) could take up to 10 per cent of traffic using the Dartford crossing for £600 million as opposed to a new crossing costing at least £6.8 billion and increasing congestion.” Highways England plans to submit a new application for a Development Consent Order this year, starting an 18-month examination process. If it wins consent, HE aims to begin construction in 2024, with the new road opening in 2029 or 2030.
The consultation materials are due to be released at one minute past midnight on July 14; they will be available here
The deadline for supporting the designation of the Swanscombe peninsula as a Site of Special Scientific Interest (SSSI) is Monday, July 12, 2021. Can you spare 10 minutes to tell Natural England you agree that this nationally important wildlife site should be protected? The importance of the Swanscombe peninsula for nature was recognised by Natural England in March, when it notified this wildlife haven in north Kent as an SSSI. This means it is an area of particularly high interest for its wildlife and significance for our natural heritage. Although this legal protection took effect immediately, there is currently a consultation on this designation. Will you help us make sure that one of the country’s most threatened wildlife sites receives the protection that it deserves by taking part in the online consultation and letting Natural England know that you want its SSSI designation to stay? The consultation portal is currently live here, where you can find all of the information on the proposed SSSI, including the detailed analysis of its precious flora and fauna, together with a map of the proposed SSSI. You can respond to the consultation online following the guidance below, but if you would rather, you can simply compose your own email, outlining your support for the SSSI designation and sending it to firstname.lastname@example.org. You can find guidance on what to say in our answer to question B6 below. When you are ready to take part in the online consultation, make sure that you have five or 10 minutes free, then click on ‘Click here to submit an online response’ near the bottom of the page. The first page asks you to say who you are and asks if you have any legal interests in the land or own any land in the SSSI. It is important that, even if you have been made aware of the consultation by any of Buglife, CPRE Kent, Kent Wildlife Trust or RSPB, you make it clear you are answering on behalf of yourself and not for an organisation in question A4. The second page is for ‘Your views on the Swanscombe Peninsula SSSI notification’. Most of these questions simply require you to select ‘Yes’, as the text boxes are reserved for explaining any objections. However, the following should help guide you through this section easily:
B1. Do you accept the scientific rationale behind the notification of this site for its special interest? Please select ‘Yes’ and move on to the next question, leaving the text box blank
B2. Do you agree that the boundary of the SSSI appropriately encompasses the features of special interest? Please select ‘Yes’ and move on to the next question, leaving the text box blank
B3. Do you agree with the views about management? Please select ‘Yes’ and move on to the next question, leaving the text box blank
B4. Do you agree that the operations requiring Natural England’s consent are appropriate? Please select ‘Yes’ and move on to the next question, leaving the text box blank
B5. Do you have any additional evidence or further comments that you wish to submit in relation to the SSSI? If you don’t have any additional information or thoughts that would further support the SSSI notification, please select ‘No’ and move on to the next question, leaving the text box blank. However, if you have any additional evidence such as your own survey data or observations of wildlife using Swanscombe peninsula, then select ‘Yes’ and either explain your evidence in the text box or choose to upload a file by selecting ‘Choose file’.
B6. Do you wish to submit a representation to the notification of Swanscombe Peninsula SSSI? Please select ‘Yes, I support the notification’. This is your opportunity to say clearly why you believe that the Swanscombe peninsula should be notified as an SSSI in your own words. Some ideas of what you can write are included below, but take any opportunity to personalise your response with your own views on the site and your own experiences of Swanscombe if you live locally. Explain why you think that the notification is justified based on the important wildlife and habitats that the Swanscombe peninsula supports. This could include highlighting: • The supporting information compiled by Natural England provides a detailed picture of the rich wildlife on the Swanscombe peninsula. • The Swanscombe peninsula clearly meets the criteria for qualifying as a Site of Special Scientific Interest. • Swanscombe supports a unique complex of open mosaic habitat on previously developed land and estuarine habitats, including grasslands, scrub, wetlands, grazing marsh and saltmarsh. • The nationally important assemblage of rare and threatened invertebrates, rich breeding bird assemblages and populations of nationally scarce vascular plants make it essential that the site is protected as an SSSI. • Swanscombe peninsula is also a vital greenspace for the local community, a place where they can escape and reconnect with nature. • Highlight your concerns that wildlife across the country is in catastrophic decline and that it is more important than ever to make sure that places like Swanscombe peninsula are protected for future generations and for perpetuity.
The third page is then simply answering if you are happy with the online consultation process – your chance to give feedback on the consultation itself. The fourth page will then ask you to click ‘Submit Response’, which will then give Natural England permission to include and analyse your submission. You will then be emailed a copy of your final submission. Thank you for your continued support for our efforts to Save Swanscombe. If you haven’t already done so, please sign and share our petition, which has already been signed by more than 24,300 people.
For more on the threat to the Swanscombe peninsula, click here
The future of the proposed Lower Thames Crossing was highlighted this week (Tuesday and Wednesday, June 29-30) when a legal challenge against the government’s roadbuilding programme was heard in the High Court. The challenge was brought by the Transport Action Network and targeted the Department for Transport’s £27.4 billion roadbuilding scheme (labelled Road Investment Strategy 2, or RIS2), saying it breached climate and air quality laws. TAN claims the government has failing to consider fully the Paris Agreement, which commits the UK to tackling climate change by limiting global warming to less than 2°C. Indeed, the group says the transport secretary pulled plans to cut CO2 emissions for a tranche of upgrades and new schemes. RIS2 includes 50 schemes, the largest of which is the £8.2bn Lower Thames Crossing. TAN said it expected the DfT to contest its challenge, saying commitments to climate change were not “obviously material” to roadbuilding schemes. However, Chris Todd, TAN director, said: “Trying to argue climate change isn’t ‘obviously material’ to approving the largest-ever roads programme is like saying public health is not relevant to reform of smoking rules. “In an audacious attempt to protect his addiction to asphalt, [Transport Secretary Grant ] Shapps is now seeking a legal precedent that decision-makers can ignore climate targets. “This puts ministers on a collision course with the Climate Change Committee, which [has] called on the government to adopt a Net Zero Test for all policy decisions.” Laura Blake, chairman of the Thames Crossing Action Group, said: “We know that the proposed Lower Thames Crossing would create over five million tonnes of carbon emissions, along with all the other negative impacts which we would suffer if the LTC were to go ahead. “We have many serious concerns about the impacts of the proposed Lower Thames Crossing and feel it is essential that all the negative impacts of the scheme should be taken into account. “We are grateful to TAN for bringing this legal challenge on climate grounds against the government’s £27bn roadbuilding programme, which of course includes the £8.2bn Lower Thames Crossing. “We wholeheartedly support this legal challenge and appreciate all the hard work by TAN and the legal team.”
CPRE Kent will be joining 30 other conservation groups in signing an open letter opposing a review of the Wildlife and Countryside Act 1981 that could undermine decades of work to restore and protect threatened species. Every five years, species listed in Schedules 5 and 8 of the Act are reviewed through a process called the Quinquennial Review (QQR), coordinated by the UK Joint Nature Conservation Committee (JNCC). Many species are listed because conservation experts have recommended their inclusion due to either persecution, population decline or other threats. This year, in a change to the normal process, the Review Group (JNCC, Natural England, Natural Resources Wales, NatureScot and representatives of the non-governmental sector) has changed the eligibility criteria of species currently (and in future times) listed and afforded protection by the Act. This change means that an animal or plant species will only be protected when it is in imminent danger of extinction as defined by the highest categories in the IUCN Red Listing process, or those identified as European Protected Species. This decision has been made without due consultation and, to date, has not considered concerns raised by conservation groups. Large numbers of species will now no longer be protected against killing and sale by law, including previously persecuted species such as mountain hares and adders. Now, 30 conservation non-governmental organisations (NGOs), including Froglife, RSPCA, RSPB, People’s Trust for Endangered Species, The Wildlife Trusts, Zoological Society of London and the Amphibian and Reptile Groups of UK, have written an open letter to the Review Group in opposition to this proposed change, as many endangered species, from red squirrels to water voles, could be at serious risk if the proposed changes are granted. Removal of protection means it would no longer be illegal to kill these species. Building developments could take place with no consideration of the impacts on formerly protected species such as slow-worms and water voles (if a case cannot be made to keep the latter listed). It also means that it will once again be legal to persecute adders, pine martens and mountain hares – despite all the costly efforts to conserve these vulnerable species. It would become legal to trade wild-caught British species including amphibians and butterflies, directly impacting populations and posing a huge biosecurity risk. This is of particular concern for widespread amphibians already at serious risk from Chytrid and Severe Perkinsea Infection, which have wiped out populations worldwide and have both been found in captive collections in the UK. While very valuable, the GB IUCN Red Listing process is not suitable for this purpose. It is complex and requires high levels of evidence of population trends. This in turn requires high-level species surveys and analysis of data to determine population trends at a national scale. There has been no provision made as to how this will be resourced and an assumption that NGOs will take on the burden of the work. The changes that have been decided by the QQR Review Group remove the opportunity to prevent species decline. Under the changes outlined we will only be reacting to catastrophic species declines. In their letter to the Review Group, the 30 wildlife NGOs are calling for a public consultation on the decision to change the eligibility criteria. Dr Angela Julian, of Amphibian and Reptile Groups of the UK, said: “We are shocked to discover these proposed changes, which will effectively remove any form of protection from many of our well-loved widespread species including slow-worms, grass snakes and viviparous lizards. Our native wildlife deserves a fair hearing.” Froglife’s Jenny Tse-Leon added: “Froglife is really worried about how these changes will particularly affect amphibians and reptiles, many of which have faced serious declines in recent years but do not qualify as threatened enough under IUCN definitions. “Our research has shown that common toad numbers have plummeted by 68 per cent in the last 30 years, but these plans mean they no longer qualify for protection.” And Nida Al-Fulaij, from the People’s Trust for Endangered Species, said: “The State of Nature report 2019 confirmed that 41 per cent of 700 species assessed have decreased in abundance since the 1970s. “We know that many of our most well-loved species, such as hedgehogs, are suffering huge declines. This is not the time to be reducing protection for them.”
You can read the letter calling for a public consultation on the proposals here
The decision to refuse a revised planning application for 450 new houses on farmland at Margate has been warmly welcomed by CPRE Kent’s Thanet committee. The scheme from Gladman Developments had first been refused by Thanet District Council’s planning committee on Wednesday, April 21, with seven members voting against it, four voting in favour and two abstaining. Loss of farmland, flooding, challenging topography and impact on wildlife were all noted as reasons for refusal, but the main concern was the proposed cut in affordable housing from 30 per cent (as set in TDC Local Plan policy) to 10 per cent. Gladman came back with the level of affordable housing increased from 10 per cent to 15 per cent – a rise described as pathetic by David Morrish, chairman of Thanet CPRE – and on Wednesday, June 23, this was also refused by the planning committee, this time by an overwhelming vote of 11-1. Thanet CPRE had objected to both Gladman applications for the Shottendane Road site. This was despite council officers saying the 15 per cent figure was acceptable as Gladman had claimed a higher level would not be financially viable. They recommended the decision be deferred to officers for approval. “Thanet CPRE is delighted that Thanet council’s planning committee is sticking to its guns and defending its Local Plan policy to ensure that 30 per cent of all housing-zone major developments is genuinely affordable,” said Mr Morrish. “It has resisted attempts by a land promoter to chew into the countryside, resisting paying minimal costs to the community and placing profit above people. “It is great that councillors have not been cowed by ‘advice’ from planning officers threatening dire problems if the council turned down this application. “A CPRE national report showed that experienced land promoters, such as Gladman, which can afford expensive lawyers and multiple appeals, often win against local authorities at appeal, leaving them confident in their ability to gain planning permission that goes against local wishes. “For example, the Gladman website states: ‘Whilst we try to achieve planning permission locally, sometimes for a variety of reasons this is not possible and the site is refused permission at planning committee. This is nothing to worry about; on average around two thirds of our sites go through the appeal process.’. “Meanwhile, councils are retreating from the appeals process due to high expenses and the perceived low chance of winning – standing up for their own policies is seen as an unmerited expense. “Let us all hope that Thanet councillors will have the courage to not retreat on this important matter and follow their own consciences rather than the diktats of council officers and threats of greedy land promoters.”
A scheme from land agent Gladman Developments for 450 new houses on farmland on the edge of Margate will be reconsidered by Thanet councillors this evening (Wednesday, June 23). The plans were narrowly refused by the planning committee on Wednesday, April 21, with seven voting against them, four in favour and two abstaining. Loss of farmland, flooding, challenging topography and impact on wildlife were all cited as reasons for refusal, but the primary concern to councillors was the proposed cut in affordable housing from 30 per cent to 10 per cent. Planning officers had argued that potential infrastructure funding made the cut in affordable housing acceptable. Now Gladman has come back with the level of affordable housing increased from 10 per cent to 15 per cent – still half the target figure set by Thanet District Council planning policy. Thanet CPRE has lodged an objection to the revised proposal, referring to several issues. Of course, it is difficult to see how the plan could now be deemed acceptable simply because of the risible increase in affordable housing. David Morrish, Thanet CPRE chairman, said: “It’s an outrage that one part of Thanet council is producing a plan for 30 per cent affordable housing while another part appears to be negotiating that figure down to 15 per cent. “Of course, if this scheme is approved, it will set the benchmark for every other developer here to push for lower levels of affordable housing – eventually, no affordable housing will be built. “These apparent negotiations appear to have been done behind closed doors, with no community involvement. This pathetic increase from 10 per cent to 15 per cent is insulting to the wider local authority and the people it represents. “A further concern is that councillors, or at least some of them, did not appear to have been given the information that the local authority is likely to benefit to the tune of £2-3 million should the development proceed. This is due to a covenant involving Margate Town Council, which formerly owned the land. “There are many issues with this scheme – for example, there is no clear strategy for disposal of foul-water, which will have to be pumped to another system, while the effect on surface drainage is certain to be detrimental. “Long-running problems with water quality where Tivoli Brook meets the sea will only be exacerbated by this development if it goes ahead. As if the beaches of Margate haven’t had enough of such problems in recent years!”
It is all too familiar a scenario: a local authority proposing to build thousands of houses in areas wholly unsuitable for such levels of development. When one council in north Kent targeted sites in the Green Belt, an impressive operation to challenge the potential environmental destruction was launched. Here, Alex Hills, chairman of CPRE Kent’s Gravesham committee, gathers some of the leading players to explain how they rallied residents to the cause.
At the end of last year without warning, and with rising numbers of Covid-19 cases making people worry whether they were going to have a Christmas or a job, Gravesham Borough Council began a Regulation 18 Stage 2 consultation. The proposal was for 3,790 houses within the Green Belt envelope over 21 sites, all being highly damaging to the rural area. The consultation was a perfect example of how not to run a such a process during pandemic restrictions and in the run-up to Christmas. GBC appeared to put every possible barrier in the way of people responding – the irony of it complaining about the way Highways England carried out the Lower Thames Crossing consultation was not lost on residents. As chairman of the CPRE Kent’s Gravesham committee, I am blessed to have an experienced hard-working committee who make me look good – they of course rose to this massive challenge. At the start of the campaign, we held a large Zoom meeting. The campaign slogan Stop the Green Belt Grab was created by local resident Peers MS Carter. Peers was a creative director at Saatchi & Saatchi, so we really have drawn on excellence from the talent in our borough. If you can inspire people to act, it is amazing the talents you find and we were lucky to find many such people during the campaign. I will let the committee members say in their own words what they did during the consultation process…
Pat Luxford: We were able to bring together all our contacts and residents’ groups from previous campaigns. This enabled CPRE Kent to ensure the campaigners worked together with one message. It could so easily have become various groups saying ‘Not in my backyard’ as the proposed sites were spread over various Green Belt areas of Gravesham. Despite our inability to sit around a table to make decisions or to hold public meetings, the residents’ response was extraordinary. By pulling together a group of dedicated volunteers whom we called foot soldiers, we were able to get door to door with updated information and easy-to-follow draft objection letters to GBC, making us so much more effective. By reaching out and working with like-minded groups and individuals, we were able to beat lockdown.
James Ferrin: My input into the campaign was dealing with social media. We used two main avenues, organic posting and sharing, and then paid for advertising. We used the CPRE Kent page as the main vehicle for this. We wrote the posts and then David Mairs posted them. The organic side was simple. Once the posts were up, we shared them across all the community groups in the area. There are some 30 or so that cover Gravesham. Comments were monitored and those asking for more information were helped. The paid-for element helped us reach those harder-to-reach people who were not members of groups. We set the targeting of location, interests and age and then put £50 behind the activity and set it live. We did a couple of posts, the first giving general information and the second providing wording for a standard letter that GBC had agreed would count. The results from the paid activity were a total reach of 18,315 people and a total of 3,029 engagements that equated to £0.016 per engagement. Pretty good-going!
Noel Clark: The committee decided we needed a website to quickly post reactions to the changing consultation as GBC changed the consultation documentation during the process. We used a website as the central repository of information to avoid having to walk revised notes around to our supporters. We used justgiving.com for fundraising as our costs were relatively small and several locals had expressed interest in contributing. Over the course of the campaign, we raised £570, which was used largely on printing and banners. We found the need to be local and reflect issues that affected us directly was important, but ultimately the outcome will be determined by national policy.
Jackie Luckhurst and Sue Gofton: During the first phase, thousands of leaflets informing communities of the threat to the Green Belt were delivered. The second phase entailed the delivery of printed objection letters; these had to be distributed in the shortest time possible to meet the GBC deadline of December 31, 2020. This was coupled with banners and placards placed in prime locations and attached to householders’ properties. The volunteers had been sourced through social media and community associations and support groups. Time was of the essence as we were in lockdown and the deadline was looming. The postal service was under pressure as it was the Christmas period and Covid-19 had taken its toll, so help was given by shops that were happy to have sealed drop-boxes where people could post their objection letters for free with their personal data secured. This worked incredibly well. Frequent updates were given on social media until the deadline was met and the letters from the drop-boxes were hand-delivered before the deadline. In terms of the Covid-19 difficulties and the deadline, it was deemed a success, based on communities pulling together and forging great camaraderie.
And back to Alex Hills for the final word… The Gravesham committee is an equal partnership (as chairman I do not have a casting vote) of six very different individuals with different skills, but we all respect and trust each other, which means we can debate openly. This was a vital asset as we had to set up a campaign structure from scratch, working with the hard-working Higham, Shorne and Cobham parish councils. We also had to respond quickly as the campaign developed, so weekly Zoom meetings were important. Covid-19 prevented us from such options as public meetings, while media disinterest meant that leaflets, the website (www.cpregravesham.org) and social media were our main tools in the campaign. Seeing local groups as an asset and working with them was another key part. My role was very much that of coordinator and making sure everyone was kept informed about what was happening– this included local councillors. The fact we were able to keep the campaign non-political and have so many saying very clearly to GBC that the Green Belt is not for building on is a great compliment to the committee.
Proposals for the largest theme park in the country could spell a miserable time for the wildlife of the Swanscombe peninsula and the people who live and work in the area. David Mairs reports on a scheme that really is no fun for nature.
It could almost be the standard definition of brownfield. Dominated by the excesses of our urban and industrial assault on the Thames estuary, the Swanscombe peninsula is flanked on its southern and eastern fringes by warehouses, breakers’ yards, deepwater docks and used-car dealerships and to the north by the river and the ugly sprawl of south Essex. It is cut through by HS1 and glowered over by the tallest electricity pylon in the country. It has been abused through the widespread dumping of fly ash – a legacy of the cement industry that was once such a feature of this area – and targeted for landfill. In short, Swanscombe Marshes have not been loved. However, such intricacies do not trouble the extraordinary wildlife that makes its home on the peninsula, which juts into the Thames between Greenhithe and Northfleet. It is the numbers of invertebrates that highlight how important a site this is. Almost 2,000 species have been recorded, more than 250 of them classified as of conservation concern. In total, there are 49 Red-listed species, meaning they are accorded highest conservation priority. The star of the show is the distinguished jumping spider (surely the name alone warrants respect!), which is found at only one other site in the UK, but there is also an array of scarce bees, beetles, butterflies and moths among a wider fauna that makes this the most important brownfield site for invertebrates in the land. Swanscombe represents an uplifting tale of nature coming back against man’s abuse of our natural environment. The combination of natural features and human activity has formed what charity Buglife _ “the only organisation in Europe devoted to the conservation of all invertebrates” – describes as “a remarkable mosaic of grasslands, coastal habitats, brownfield features, scrub and intricate wetlands”. The peninsula is home to more rare and threatened species than any other brownfield site in the country. They include the endangered Duffey’s bell-head spider, brown-banded carder bee, saltmarsh shortspur beetle and orange-striped water beetle. Surveys have shown the presence of water voles, harvest mice and dormouse; cuckoos, nightingales and black redstarts breed; there are exceptional reptile populations; and scarce plants include the man orchid. The estuary’s most comparable brownfield for natural wealth lies on the other side of the river at Canvey Wick and has been designated a Site of Special Scientific Interest (SSSI). As important as its wild inhabitants, of course, the peninsula provides space for people living in a desperately overcrowded part of the country to walk, birdwatch, go fishing or simply take an increasingly precious breather from their more regular surroundings… Cue proposals for the “UK’s Disneyland” – or the London Resort theme park. Or to put it yet another way: developers intend to build the largest theme park in the country on the peninsula. London Resort Company Holdings submitted its 25,000-page application for a Development Consent Order to the Planning Inspectorate on New Year’s Eve last year – and in a letter dated Thursday, January 28, the inspectorate announced it had accepted the application, which is now proceeding towards a six-month examination. The final verdict will lie with the Secretary of State for Housing, Communities and Local Government, a post held at the time of writing by Robert Jenrick. The scheme has been designated a Nationally Significant Infrastructure Project (NSIP), the first ‘business or commercial project’ to be accepted as such by the government under the Planning Act 2008. Covering more than 1,000 acres (958 acres at Swanscombe and 63 in Essex), London Resort is anticipated by its backers to open in 2024 should work begin next year. The project is predicted to create 8,810 jobs on site by 2025, of which 3,590 will be full-time, 1,990 part-time and 3,230 seasonal. From 2038, we are told there will be 17,000 jobs on site, of which 6,535 will be full-time, 3,690 part-time and 7,080 seasonal. An access road to the A2 is planned, along with “easy access” from Ebbsfleet International station. On the other side of the river, in Essex, linked infrastructure would take up more than 60 acres east of Tilbury, with an “access corridor” around the A1089. This would all enable a “park-and-glide” system to ferry people across the river. The project website states: “Sustainability is at the core of our vision. We are exploring new and innovative ways of integrating sustainable and low-carbon principles into every area of design and operation of the London Resort. Our aim is to create one of the most sustainable theme park destinations in the world.” It adds: “Our designs will integrate local public rights of way and a green network, with improved access to the river for visitors and local communities. The London Resort will showcase the natural features of the site, seamlessly integrating them into our designs. A large proportion of the peninsula landscape will remain undeveloped and will be enhanced.” However, such fine words have failed to convince everyone and not only are there widespread fears for the site’s wildlife but concerns have been raised for people employed on the peninsula who might see their workplaces lost. It has been estimated that some 2,000 workers could effectively be forced out by the proposed development. The concept of sustainable communities seems to have been mislaid along the way. Further, it is unclear how many of the claimed new jobs will go to local people. With the plans including “staff accommodation, which will reduce the amount of staff travel”, it is evident that a significant element of the workforce is expected to be drawn from outside the immediate area. And would the bulk of the roles that did become available be of the calibre to really lift the north-west Kent economy? With the developer predicting up to 12.5 million visitors a year by 2038, CPRE Kent believes work needs to be done in relation to transport. Could the existing road network really cope with taking such huge numbers of people to and from the site? On top of all this, it is feared the NSIP status, usually reserved for such substantial schemes as roads, airports and power plants, might result in a largely inaccessible and not widely understood process (the 25,000 application pages come in 449 documents!) that deters people from participating. But it is the potential loss of wildlife that has perhaps struck the loudest chord, with Buglife, the RSPB and Kent Wildlife Trust calling on Natural England to protect the peninsula by declaring it an SSSI. The three groups have presented a ‘Rationale for the SSSI designation of the Swanscombe Peninsula’ to the government advisory body, together with a letter signed by 77 current and former senior staff from nature organisations and public bodies. Matt Shardlow, Buglife chief executive, said: “Biodiversity is in crisis; wildlife populations, particularly of insects, are in steep decline; many habitats and specialist species are increasingly rare and their fragmented populations are at risk of extinction. “Too few wildlife-rich brownfield sites like the Swanscombe peninsula are protected, and this is the last chance to protect a large Thames estuary brownfield site before it is too late. This is one of only two sites nationwide for the distinguished jumping spider. If the development is allowed at Swanscombe, it will push this special spider a step closer to national extinction.” Richard Bloor, of Kent Wildlife Trust, added: “Swanscombe is one of the last remaining wildlife-rich brownfield sites in the Thames estuary, with habitats ranging from dry bare earth, which is vital for invertebrates, to complex wetlands, which support a great diversity of birds, reptiles and mammals.” Swanscombe’s broader importance was emphasised by Emma Marsh, RSPB England director, who said: “In September, the Prime Minister announced the government’s ‘30 by 30 pledge’ – a commitment to protect 30 per cent of UK land for biodiversity by 2030 – calling for immediate action and avoiding dither and delay. Saving nationally important wildlife sites like Swanscombe is surely an easy win on the road to meeting that commitment.” As part of the campaign for SSSI designation, a Save Swanscombe Marshes petition has been set up by Buglife. Aimed at Mr Jenrick, it has, at the time of writing, been signed by more than 22,000 people. There is also the Swanscombe Marsh Protection Campaign, “run for and by local residents who are concerned about the loss of the marshes for current and future generations, for the difficulties it could bring to local residents, and the loss of habitat for the wildlife which lives there”. The concerns are many and varied. How high will the buildings be? How many outside events are likely? Laser shows? Fireworks? What price tranquillity? How robust was the methodology employed for the ecology reports? So many questions and so much to be done to ensure a desirable future for the Swanscombe peninsula. CPRE Kent has registered as an Interested Party for the forthcoming inquiry and submitted the necessary ‘relevant representation’. The battle is just beginning. After nature has already fought back so strongly, surely we owe it to the Swanscombe peninsula, its wildlife and its people to not betray it now.
To learn more about the Save Swanscombe Marshes campaign and sign the petition, see www.buglife.org.uk
The Kent countryside is littered with discarded single-use drinks bottles and cans. CPRE has been calling for the solution for over 10 years: a simple system that prevents the littering of drinks containers and ensures recycling rates of more than 90 per cent: an all-in Deposit Return Scheme (DRS). Yet, despite committing two years ago to making this happen, the government is seeking to delay and water down its promises once again. We’re sending a message in a bottle directly to the prime minister, telling him to commit to an all-in DRS now. Will you add your name? Public pressure has worked before. In 2018, our campaigning led to the then-environment secretary Michael Gove giving his support for an all-in DRS. Since then, even big drinks producers like Coca-Cola have agreed that the scheme is the answer to our litter problem. But now the government has released another, worrying, consultation. Not only is it delaying the scheme until the end of 2024 at the earliest but it’s also still considering a half-hearted design that will set the system up to fail. We can’t let this happen. Together we can make this a priority again with a message straight to our decision-makers: don’t dilute or delay a Deposit Return Scheme. Join us now for one last push.
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The presence of three pairs of turtle doves – one of the fastest-declining species of bird in the country – was not enough to block permission for more than 200 new homes on the site of the former Betteshanger colliery. Quinn Estates last night (Thursday, May 27) won approval from Dover District Council’s planning committee to build 210 houses, 2,500 square metres of office space and 150 sq m of shopping space. The proposal was approved on the casting vote of the committee chairman. CPRE Kent had objected to the proposal and submitted a substantial environmental statement. Altogether, there were more than 80 objections, many relating to the loss of wildlife. A spokesman for the Friends of Betteshanger, the group formed to oppose the scheme, said: “There was some well-argued opposition, but ultimately it was agreed that Section 106 agreements to finalise mitigation and compensation were an acceptable way forward. “We hope we will see the day when environmental considerations really are centre-stage and wildlife is given the protection it deserves.” Extraordinarily, the mitigation reportedly included a pledge to relocate the site’s turtles doves – a migratory bird that winters in sub-Saharan Africa. Extraordinary… and depressing that such nonsense could be taken seriously by a planning committee.
A scheme for 165 new houses near Cranbrook in the High Weald AONB has been ‘called in’ for review by a planning inspector after Tunbridge Wells Borough Council’s planning committee resolved to approve the scheme. Berkeley Homes had been granted permission to build 36 homes at Turnden, in the Crane Valley between Cranbrook and Hartley back in February 2019. The developer then expanded its proposed scheme to add 165 more homes – which was also backed by the council. The development follows the council’s granting of outline permission for 180 dwellings at nearby Brick Kiln Farm. CPRE Kent supported Natural England in objecting to the proposal and asking Robert Jenrick, Secretary of State for Housing, Communities and Local Government, to call in the decision. This has now happened. John Wotton, chair of CPRE Kent, said: “Major developments on greenfield sites in the High Weald AONB should not be happening. Allowing the Turnden scheme would set a precedent that could lead to harm to our precious protected areas throughout the country. “This scheme will destroy a piece of medieval farming landscape, obliterate historic settlement patterns and suburbanise the rural setting of Cranbrook. Spreading spoil from the development over adjoining fields will only cause further harm to the environment and the enjoyment of the countryside by local people.” CPRE will be working with the local action group, Hartley Save our Fields, to oppose the granting of permission and will support Natural England and the High Weald AONB Unit when the case comes before a planning inspector later this year. We are also opposing the allocation of the site for development in Tunbridge Wells’s new Local Plan.
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The developer behind the proposed London Resort theme park has been accused of failing to provide enough information about the impact of increased traffic on road and rail in north Kent and London. In damning submissions from leading transport organisations to the Planning Inspectorate, it is suggested that transport infrastructure could be overwhelmed by traffic from the development, on the Swanscombe peninsula. Highways England says there has been “insufficient information” to allow conclusive statements on traffic impact, citing junctions 2 and 30 of the M25, the A13/A1089 junction and the A2/M2 east of the M25 as potential problem spots. Transport for London, meanwhile, has slammed London Resort Holding Company’s lack of an “appropriate assessment methodology”, saying it could mask “significant impacts that must be mitigated”. It said: “The failure to use appropriate modelling means that impacts on the rail and Underground network have not been assessed with any degree of certainty. “The arbitrary assumptions about the scale of traffic that will use the north Kent lines risks ignoring potential impacts at their central London termini and on interchange flows at Abbey Wood (to the Elizabeth line).” It also warned that the development could cause congestion on north Kent roads and lead to problems at east London road tunnels. For its part, Network Rail was concerned about impact on stations close to the planned development as well as the effect on the Ebbsfleet Southern Link and HS1. As if all that were not enough, the C2E Partnership feared that the scheme could take up land earmarked for a potential Crossrail extension to Ebbsfleet. A list of Relevant Representations was published on Planning Inspectorate website in April after its deadline for comments had passed.
The UK government reaffirmed its commitment to the ‘net-zero by 2050’ emissions target within the Queen’s Speech on May 11. While to many, the net-zero by 2050 target does not go far enough, to achieve even this clearly requires action now. It certainly requires action by 2028. Especially in a borough where there is a local net-zero emissions target of 2030. Therefore, CPRE Kent was extremely disappointed by the decision by Robert Jenrick, Secretary of State for Housing, Communities and Local Government, to remove measures intended to reduce carbon emissions when approving the Quinn Estates proposal for 675 houses at Wises Lane, Sittingbourne – a development that had already sparked a ‘Cash for favours’ headline. This is even more disappointing when you consider that in doing so he has overridden the planning judgment of both Swale Borough Council and the Planning Inspectorate, both of whom had the benefit of actually hearing the evidence at the inquiry. This is compounded further by the fact the full net-zero carbon emissions measures were not even being sought until 2028 at the earliest. While the proposed development at Wise Lanes has a long and complicated background, the facts regarding the carbon emissions point are as follows:
Swale Borough Council took the position that if the Wises Lane development was to be approved, it wanted to see planning conditions imposed that reduced carbon emissions. This was to be on a tapered basis, culminating in a zero-carbon requirement on any new houses where details were to be agreed after 2028. This was deemed necessary to meet the Swale 2030 carbon-neutrality target locally and the national target of 2050.
Although the Planning Inspectorate allowed the appeal, it agreed the conditions setting the path to net-zero emission should be applied. Specifically, it reasoned: “The planning regime has a role to play and cannot leave climate change to other regimes to deal with, particularly when those regimes have not kept pace with the requirement to take urgent and material action. “The scale and urgency of the climate change emergency is such that it would constitute a material consideration of significant weight to support the imposition of conditions to mitigate the impact of the development.”
As this was a ‘called-in’ appeal, Mr Jenrick had the last say on the matter. In very simple terms, this meant he got to review the written evidence, including the planning inspector’s report and then issue a final decision on the matter.
While Mr Jenrick agreed with the planning inspector on most issues, he directed that the conditions setting the path to net-zero emission be removed. The stated reasoning was as follows: “Notwithstanding the high-level national commitment to carbon neutrality, and the significant weight attaching to tackling climate change, these conditions also go beyond current and emerging national policy. He therefore considers that the proposed conditions cannot be said to be either reasonable or necessary.”
While the ins and the outs of such a position in technical planning law could be debated, ultimately this was a matter of planning judgment on which the Secretary of State had a clear choice. He could have accepted Swale Borough Council’s and the planning inspector’s position and let the conditions stand. These might not have been perfect, though at least would have provided a hook within the decision which could have been amended in the future by way of a variation of condition application should national policy change. Or he could have accepted the applicant’s position that, as we cannot predict which policies might apply in the future, the only option is to do nothing now. By taking the latter position, he is likely to have handed the developer huge cost savings, though without reviewing the viability evidence up-front. This is on a scheme where a much lower than policy-compliant affordable-housing provision had been agreed. While the legal agreement does allow for this to be reviewed once 400 houses have been built, the need for affordable housing in Swale is now. There is, however, no option to review the net-zero-emission conditions. There were a number of seemingly positive climate and environment soundbites within the Queen’s Speech. However, the position taken by the Secretary of State at Wises Lane raises serious questions as to just how genuine the government is about tackling these issues and indeed where priorities actually lie. Saying is the easy part, it is the doing that matters!
The developer behind the proposed London Resort theme park on the Swanscombe peninsula is ploughing on with the project, although it will be changing its plans after the location’s designation as a Site of Special Scientific Interest (SSSI). London Resort Holding Company has been granted an extra four months to submit revised documents in its bid for a Development Consent Order from the Planning Inspectorate, meaning examination of the project is now likely to begin in September. It is reported by the BBC that LRCH does not intend to make any “material” changes but will be amending almost half of its 460 submission documents. A letter to the Planning Inspectorate shows that 11 documents will be replaced or have “substantive” updates, 46 will receive “some amendments” and about 160 “minor amendments”. Some 250 documents will not be changed, says the BBC. If the report is correct, LRCH’s latest proposals fall very far short of meeting an appeal by CPRE Kent and three other conservation charities, who have said in a joint letter to the Planning Inspectorate that LRHC “should have sought to withdraw their existing application and restart the pre-application process” after the SSSI designation. The letter has been signed by CPRE Kent, Buglife, Kent Wildlife Trust and the RSPB. Jamie Robins, of Buglife, said: “There is so much change here, it is hard to argue that it doesn’t warrant resubmission and fresh consultation.” He urged LRCH to consider other locations as “you cannot replace these habitats”. Natural England, which made the SSSI designation, said some 40 per cent of the site would be lost to the theme park, while there would be probable further impact from construction and operation. Transport and river navigation assessments will also receive “substantive updates” in response to concerns from Transport for London, the Department for Transport and the Port of London Authority. The Save Swanscombe Peninsula campaign says LRHC appears to be “using the extension as an opportunity to try and address big holes in the original application and not just regards their devastating impact on biodiversity”. With the six-month examination of the DCO application due to begin in September, the final decision on the project – by Robert Jenrick, Secretary of State for Housing, Communities and Local Government – will be made next year.
To read the letter from CPRE Kent, Buglife, Kent Wildlife Trust and the RSPB, click here
The Planning Bill highlighted in last week’s Queen’s Speech (Tuesday, May 11) has been blasted by CPRE, the countryside charity. Tom Fyans, CPRE campaigns and policy director, said: “The Planning Bill looks set to prioritise developers’ needs over local communities, provide no new environmental safeguards and could slow the delivery of genuinely affordable homes in many areas. All in all, it risks creating a free-for-all for development. “We know from painful experience that without the right checks and balances in the planning process, developments can lead to a huge and unnecessary loss of countryside while doing nothing to tackle the affordable housing crisis or level up. “That’s why we urgently need more joined-up thinking from the government if we are to address the nature and climate emergencies. On the one hand, we’ve got the Environment Bill being touted as world-beating legislation to leave nature in a better state than we found it over the next 25 years. On the other hand, we have a Planning Bill that looks set to take us back to a deregulated dark age of development. “The government must urgently rethink the Planning Bill. If not, we’re facing an open season for developers on large parts of the countryside, and a fatal weakening of local communities’ right to be heard on the future of their area.”