Swanscombe peninsula: the last resort?

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
• To read about the work of the Swanscombe Marsh Protection Campaign, see swanscombemarshes.co.uk      
• For more on the Swanscombe peninsula, see here

Monday, June 21, 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

• Read more on the Swale Local Plan
• Read CPRE Kent’s detailed comments on the plan
• View the council’s consultation document