We have received the following summary from the RSPB, detailing their response to the public consultation on the plans for development at Swanscombe.
“The Swanscombe Peninsula is an outstanding mosaic of mostly undesignated grasslands, wetlands, scrub, inter-tidal habitats and brownfield features supporting a nationally important assemblage of invertebrates and a rich birdlife. The range and breadth of surveys conducted to date, demonstrate that the Swanscombe Peninsula’s rich wildlife assemblage and supporting priority habitats are in urgent need of designating as a Site of Special Scientific Interest (SSSI).
Summary of RSPB concerns
25 Year Environment Plan
The government’s 25 Year Environment Plan commits to “creating or restoring 500,000 hectares of wildlife-rich habitat outside the protected site network focusing on priority habitats” and developing a Nature Recovery Network (NRN). The Swanscombe Peninsula should lie at the heart of such a network within the Thames Estuary.
Nationally important invertebrate assemblage
Surveys conducted for and on behalf of the developer recognise that the project site is of national importance for its invertebrate populations. The 2012 and 2015 surveys identified 1,992 terrestrial species, plus a further 200 aquatic macroinvertebrate species. 250 of these species are of conservation concern, i.e. Red Data Book or Nationally Scarce based on status reviews at the time. Additional surveys this year, not yet available, may add to the assemblage.
The RSPB’s Canvey Wick reserve in Essex was designated as a SSSI for its invertebrate interest (under 1,500 species).
Assessment of alternative sites
Appendix 4.1 of the Environmental Impact Assessment (EIA) Scoping Report provides an assessment of eleven reasonable alternative site options in accordance with the requirements of the EIA Directive. This assessment should also provide an accurate comparison of the environmental effects. This should be updated and re-assessed to consider the following:
- the Swanscombe Marine Conservation Zone (MCZ).
- the functional-linkage to the Special Protection Area network,
- the nationally important invertebrate assemblage.
- the priority habitats on site.
Breeding bird assemblage
We commend the quality of the ornithological surveys conducted to date which demonstrate the site’s significant importance – recognised as “regionally important” within the Ecological Appraisal (paragraph 1.7, page 508). Surveys undertaken in 2015 recorded 54 breeding species, eleven of these species are on the red list of Birds of Conservation Concern/species of principal importance, seven are recognised as rare breeding birds and three are Schedule 1 species. To further emphasise the importance of the site, the 10-year mean (2010-2019) for breeding bird species at RSPB Rainham Marshes is 51 species.
The 2016 breeding bird report sets out that records from the Kent Biological Records Centre show that 89 species have bred at least once at the project site. Paragraph 2.3.4 (page 512) indicates that such an assemblage could be considered as nationally important as it exceeds the threshold of 85 species. We recommend that these figures are clarified.”
If you haven’t done so already the RSPB ask us to sign the Petition set up by Buglife, urging the Secretary of State to reconsider the development.