Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by the Invertebrate Conservation Trust (PGP 31)


  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 development.

    —  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 leisure.

    —  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 renaissance

        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.

Alex Ramsay

Biodiversity Projects Manager

18 March, 2002

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