5
Suggested comments;
1) English Nature defines SSSIs as 'irreplaceable...critical natural capital'. Making the
application all-industrial doesn't alter the principle that SSSIs should be permanently
protected if UK biodiversity is to survive.
.2) The proposal is not of 'significant regional or national importance' and would not
facilitate that objective as the initial phase of a scheme extending over 51% of the SSSI
as envisaged in UDP strategies and policies indicated in item (8) below. No market for
the proposed 100 acre unit has been demonstrated. The proposed uses would not
contribute the Thames Gateway Partnership priority of raising the 30% higher grade skills
level of local residents to at least the general London level of 40%. Rainham residents
have repeatedly objected to the cunent proposals.
3) This site is not 'derelict wasteland' as the Council claims. It should not seek derelict
land grant to assist development. English Partnerships should not use public funds to
finance destruction of nationally designated wildlife habitat but should be facilitating
investment in vacant industrial, brownfield or other non-sensitive sites in the area.
.4) No evidence has been produced to support official statements that 'these proposals
will provide for nature conservation more than twice the area which is being taken for
development' nor is there any guarantee of SSSI quality in any land acquisition. A
separate UDP policy allows development of a further 31% of the SSSI. To match the
above statement the total area zoned for development should be replaced by one high
quality site not already covered by a wildlife designation.
.5) The need to include extensive on-site mitigation contradicts the application claim that
the existing wildlife value is low. The need to de-water the site and the proximity of
buildings and vehicles to retained watercourses on site means that sensitive invertebrates,
birds and mammals, (including fully protected Water Voles not identified during
Environmental Impact Assessments), will be disturbed or disappear despite proposed
landscaping.
.6) Government habitat protection plans require all remaining grazing marsh to be
preserved plus the rehabilitation of another 10,000 hectares for ecological sustainability.
The Thames has already suffered near total loss. In this particular case no further
compromise can be considered reasonable.
.7) Following over 20 years failure to attract commercial development, and recent
changes in planning guidance favouring greater protection of the natural environment,
Havering UDP strategies STR8 and 15, together with policies EMP2 and 3, ENV7, 24
(a), (b), (3), (4), (5), and 25, TRN5, and 28 relating to the SSSI are no longer reasonable.
The application does not conform to the proposed environmental strategies of the Thames
Estuary Management Plan, SERPLAN, LPAC, or the LA21 objectives adopted by the
Association of London Government and LB Havering, nor does it match the
precautionary principle of sustainable development; to meet present needs without
compromising resources needed to meet future needs.
.8) Consideration of the value of the SSSI as an eco-tourism investment of regional
significance is now more appropriate. Tourism is the largest, fastest growing industry in
Greater London and is an objective of the Thames Gateway Partnership. An intact SSSI is
a major asset in a key location for such investment. This would match far more of the
stated objectives of:- the Thames Gateway Partnership, the Thames Estuary Management
Plan, the UK and Greater London Biodiversity Plans, the UK habitat and Species
Protection Plans, cunent national and regional planning guidance and LB Havering's own
UDP environmental strategy for the rest of the borough.
The Friends of Rainham Marsh c/o Phil Butler TEL: 01708 754391
Essex Field Club Newsletter No. 26, August 1998-