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London Resort to make no 'material' changes to plans as CPRE Kent joins other conservation groups in pushing for rethink

Elementary Admin
By Elementary Admin &
19th May 2021

The Swanscombe peninsula has a superb array of natural habitats… CPRE Kent would like it to stay that way (pic Paul Buckley)

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
  • For more on this story, click here
  • To learn more about the Save Swanscombe Marshes campaign, see here

Wednesday, May 19, 2021


  • A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
  • There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
  • There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.

The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:

  • There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
  • A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
  • Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
  • Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.

Concerns about the rush to submit the plan

The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.

As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.

Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.

Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.

The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.

Further information