Shorne Woods Country Park © Greg Hitchcock
Highways England have proposed a ‘Lower Thames Crossing’ taking the form of a tunnel east of Gravesend, connecting with Thurrock, Essex. Two link road options have been proposed, with the ‘Eastern Southern Link Road’ the preferred option. Kent Wildlife Trust is opposed to the proposals for a Thames Crossing at this location (‘Option C’).
The Trust recognises that the proposed tunnel, quite rightly, avoids direct impacts upon the internationally important habitats of the North Kent Marshes and Thames Estuary. Unfortunately the same cannot be said of either of the proposed link road options, which will destroy nationally important areas of irreplaceable ancient woodland.
Both link road options will result in the loss of ancient woodland designated as nationally important Sites of Special Scientific Interest and/or Local Wildlife Site (LWS):
- The Eastern Southern Link Road (Highways England’s preferred option) will destroy parts of Great Crabbles Wood SSSI and Court Wood LWS.
- The Western Southern Link Road will destroy parts of Shorne & Ashenbank Woods SSSI and Claylane Woods.
The remaining areas of habitat will be smaller and fragmented, putting the species that rely on these habitats at greater risk of being lost. Surveys have yet to be undertaken, so the full impact of the proposals on the environment has not yet been assessed, and thus the decision process undertaken by Highways England is flawed.
While the economic benefits have been weighed against the financial costs, they have not assessed the economic costs, for example the impact on community health, ecosystem services, or tourism. Kent Wildlife Trust believes that the only sustainable way to reduce congestion is to reduce demand. This has the additional benefit of reducing air pollution and the greenhouse gasses that result in climate change. Air pollution is the leading environmental health risk factor in the UK, and climate change is one of the greatest threats to our environment and the ‘ecosystem services’ which we depend upon.
We believe that road developments should only be considered as a last resort within a sustainable transport strategy, which must be planned and fully integrated with conservation objectives and the land use planning process. This should:
- prioritise environmentally sensitive maintenance and improvement of the current road network over new road schemes
- reduce the need to travel, for example through: well-designed towns, cities and neighbourhoods; and improved transport technology
- promote reductions in private vehicle use in order to reduce traffic levels, fuel consumption and vehicle emissions, including fiscal measures and car share schemes
- minimise dependency on private vehicle use by increasing and improving public transport and active travel routes, which are well connected to essential services
A public consultation on the Lower Thames Crossing proposals ran from the 26th January to the 24th March.
Kent Wildlife Trust's full response to the consultation can be downloaded below, but in summary we have called upon Highways England to:
- Undertake a proper analysis of the economic case for a Lower Thames Crossing that takes into account wider economic impacts, including environmental economic impacts
- Demonstrate that alternatives to further unsustainable road construction are not a better fit to the stated objectives of the scheme, given due regard to those objectives
- Reject the Eastern Southern Link Road, owing to an unacceptable environmental impact
- Reconsider the Western Southern Link Road, with the aim to avoid environmental impacts
- If Option C is chosen, rule out all crossing types apart from a bored tunnel
Undertake a full analysis of the direct and indirect impacts of any chosen scheme, with an aim to have regard to the avoid-mitigate-compensate hierarchy, ensuring any mitigation or compensation is properly planned within a strategic ecological network, managed in perpetuity, and properly funded.
About the Sites
Site of Special Scientific Interest (SSSI) is a national designation intended to provide statutory protection for the best examples of the UK's flora, fauna, or geological features. Local Wildlife Site (LWS) is a non-statutory designation and provides no legal protection (though species supported by LWS may have legal protection). It is given to sites that are important for wildlife at a county level and above. More information on Kent’s Local Wildlife Sites can be found here. An ancient woodland is one which has been present since 1600, and are often best identified by the suite of ‘indicator species’ that they support. Ancient woodlands now only cover about 2% of the country, and are irreplaceable.
Great Crabbles Wood SSSI
Most of Great Crabbles Wood SSSI is mixed coppice under oak standards, with sweet chestnut dominant. A number of scarce plants occur, including lady orchid, man orchid, white helleborine, bird’s nest orchid, wild liquorice and spurge laurel.
Open oak-birch woodland with a ground flora of bracken and bramble merges with sweet chestnut coppice under oak standards as the soils grade from gravels to loam. Coppice species include hornbeam, ash, field maple and hazel. Dog’s mercury and bramble dominate the ground flora. The shrub layer is varied and includes spindle, wayfaring tree and traveller’s joy.
Shorne and Ashenbank Woods SSSI
Shorne and Ashenbank Woods SSSI includes both Shorne Woods Country Park and the Woodland Trust’s Ashenbank Woods on the other side of the A2. Part of the former may be lost to the widening of the A2 should the western link road be built.
The site supports an important and diverse invertebrate fauna, especially beetles, true bugs and dragonflies. The woodland varies from sweet chestnut coppice to a more mixed broadleaved woodland of mature oak, sweet chestnut, and hornbeam, and holly and yew are frequent in the understorey. Bramble, bluebell, dog’s mercury, and bracken dominate the ground flora, together with ancient woodland indicators such as wood spurge, wood sedge and wood anemone. The woodland breeding bird community includes hawfinch, marsh tit and all three British woodpeckers.
Court Wood LWS
Court Wood Local Wildlife Site includes Court Wood, Cole Wood, Starmore Wood and a traditional orchard to the north west. Much of the semi-natural broadleaved woodland, on a range of soil types, has been converted to sweet chestnut coppice, but still retains standard trees (mostly oak). Fine relict hornbeam coppice is present along some of the edges and sporadically within the chestnut. In places the coppice is more mixed. Ash, hazel and field maple coppice stools occur occasionally and are dominant in the valley and on the lower ground on the chalk in the north.
The LWS supports a good diversity of flowering plants, including many ancient woodland indicator species. Bluebell, wood anemone, and bramble dominate, and great wood-rush and bitter-vetch have been recorded on the more acid soils. Early-purple orchid, sanicle, primrose, nettle-leaved bellflower and moschatel are found amongst dog's mercury on the base-rich soils at the northern end. The bryophyte flora is diverse and reflects the different soil types. Over 40 species have been recorded. In total, 38 ancient woodland indicator plant species have been recorded, including large clumps of butcher's broom.
A small stream bordered by pendulous sedge and supporting aquatic flora runs through a narrow block of ancient woodland and chalk and elm scrub in the north.
Greater spotted woodpecker, nuthatch and common warblers use the woodlands, as do badgers.
Like Great Crabbles, Shorne and Court Woods, Claylane Wood is ancient woodland. We do not have much information on this woodland.
|Kent Wildlife Trust's response.pdf||236.41 KB|