Memorandum by the Invertebrate Conservation
Trust (PGP 31)
PLANNING GREEN PAPER
Urban brownfield sites often contain a unique
diversity of invertebrate species from variety of different habitats
that are rich in scarce and threatened species. It is essential
that adequate information on invertebrates in urban sites is available
to feed into the planning process, however the proposed legislation
will not allow sufficient time to perform necessary survey work
by which to inform the planning decision.
Under the government's brownfield development
policy many sites for rare or nationally scarce invertebrates
have been threatened with development, particularly in the Thames
valley area, where land for development is at a premium. A few
cases where sites with exceptional invertebrate faunas are threatened
by development or have been built on are detailed below.
The bumblebees Bombus sylvarum
and B. humilis are currently threatened by loss of flower
rich sites and both are listed as UK Biodiversity Action Plan
(BAP) priority species under the UK Biodiversity Action Plans.
B. sylvarum is now restricted to just seven sites in the
UK. One brownfield site in the Thames valley contains a major
population of both these species and is currently threatened with
A second brownfield site in the Thames
valley area had outline planning permission for housing, and a
survey of the site funded by the developers revealed the Species
Quality Index for invertebrates to have a value greater than that
of Salisbury Plain SSSI in Wiltshire (one of the top invertebrate
sites in the country), and therefore of national significance
for invertebrates. The site contained nearly 50 species of Endangered,
Threatened, Vulnerable, Rare and Scarce invertebrates, including
Eutolmus rufibarbis, a Robber Fly with very few recent
sites in the UK. Despite this, planning permission was granted,
and the site has now been developed as a housing estate.
A third brownfield site which has
developed on old railway sidings in the same area is currently
threatened with large scale development despite the nature conservation
importance of the site, containing as it does two BAP priority
listed insects, B. sylvarum and the Hornet Robber Fly Asilus
crabroniformis., both of which are priority species on the
UK BAP list.
In addition, the following points are noted
with regard to the Green Paper proposals:
Faster decisions for businesses
The government's proposal to speed
up the planning process will make it much harder to inform the
planning process about the value of certain urban sites for invertebrates.
Effective survey for invertebrates is often time consuming but
is necessary to better inform the planning process, to ensure
that sites of high value for invertebrates are not lost to development.
Faster decisions for business may well result in bad decisions
for biodiversity. Whilst businesses usually have the resources
to undertake the volume of work necessary to keep pace with such
a process, organisations acting on behalf of wildlife rarely have
comparable resources and hence are unable to respond effectively
to short deadlines. Hasty decisions can often be regretted at
Business planning zones
Businesses will usually perform better
in good environments. It appears likely that under the business
planning zone system that any habitats within this zone which
are capable of contributing to a quality environment will be scheduled
for development with little regard for any intrinsic wildlife
value. At least 12 per cent of all UK threatened invertebrate
species are particularly associated within urban situations, predominately
on brownfield habitats, and are likely to be severely affected
by such proposals.
Planning's contribution to the urban
Urban brownfield sites are often regarded
as unsightly and frequently targeted for "renewal" by
urban community groups. We would like the value of these sites
for invertebrates to be recognised by such groups and sustained
by planning policy.
Role of regional planning bodies
The regional planning bodies which
already exist forms an ideal platform by which to develop conservation
strategies for invertebrates within an urban framework. These
bodies need to have the flexibility to direct development funding
away from sites where there is high biodiversity value and instead,
direct it to promote development on sites where there is little
inherent biodiversity value.
Biodiversity Projects Manager
18 March, 2002