In the last few months a flurry of wildlife sites have been put in peril by inappropriate developments – Lodge Hill in Kent, Rampisham Down in Dorset and Radford Quarry in Plymouth. All three, and the precious life that they support, currently hang in the balance and in the hands of the planning system. All three are considered by many to fit the official definition of brownfield, yet all three are home to habitats and species that are currently heading towards extinction.
Some sites that fit the official definition of brownfield are also amongst the most important sites for endangered species. Buglife has been highlighting this problem for over a decade and has been on hand to stand up for such sites where necessary. In 2004 at Canvey Wick in Essex we halted a development on a site so rich in red listed species that it is now the first National Bug Reserve, managed jointly by Buglife, the RSPB and the Land Trust. In 2008 Buglife took Thurrock Development Corporation to court over the development of West Thurrock Marshes, in a landmark case that tested the effectiveness of the legislative framework that is supposed to protect biodiversity, and found it to be wanting.
Lodge Hill, Rampisham Down and Radford Quarry have all been subject to historical planning applications, the first as an MoD training area, the second as a BBC transmitter station and the third as a limestone quarry. Scrub and open mosaic habitats, wildflower rich meadows and a rocky limestone grassland are not what the public pictures brownfield land to be like, but unfortunately the government’s definition of brownfield includes a very wide range of places that have been subject to planning approval.
Once a site has the label ‘brownfield’ it is much easier to get a new planning application approved; thereby army ranges full of wildlife can be converted into a dense housing estate; and thereby two Sites of Special Scientific Interest (SSSIs) and a Local Wildlife Site – that may be the last home on this planet for an endangered spider, the Horrid ground-weaver – are currently at risk of being replaced by a solar farm and two housing estates.
There is clearly a problem with the definition that the planners are using for ‘brownfield’ and the caveat in the National Planning Policy Framework:-
“policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value.”
does not always appear to be being applied. Perhaps in part because there is no clear definition of ‘high environmental value’ for planners to apply.
The current situation could get worse, the Government is currently consulting on new measures ‘Building More Homes on Brownfield Land’ that would hold local authorities to account for developing brownfield land. This is part of a thrust to see “local development orders in place for homes on more than 90% of brownfield land suitable for new housing by 2020” and the Government’s intentions with the proposed measures are clear:-
“The Government wants to go further to deliver more new homes. Brownfield land suitable for housing has a vital role to play in meeting the country’s need for new homes while protecting the countryside, and for this reason the Government wants to maximise the number of new homes on suitable brownfield land.”
The consultation goes on to state that “Inappropriate development on brownfield land in the Green Belt should not be approved except in very special circumstances.” or in other words – even in the green belt ‘brownfield’ land can be subjected to ‘inappropriate’ development in some circumstances!
The big bold simple headline is BUILD ON BROWNFIELD, the small print warns developers and planners away from land of ‘high environmental value’ and encourages them to only target ‘suitable’ land for development, but is clearly inadequate to prevent outrageous decisions that fail to adequately consider the nationally important biodiversity that is being put in jeopardy.
The failure of the current definition of ‘Brownfield’ will get worse over time. More and more of our countryside will be subject to planning approvals for wind turbines, solar farms and other uses and the MoD will continue to dispose of land holdings. This is a concern not just for wildlife charities, it is also worrying the Campaign for the Protection of the Rural Environment (CPRE) who can see the opportunity for development creep and the erosion of green belts that the current definition of brownfield encourages.
So what is the solution? Clearly, Buglife, the RSPB and Wildlife Trusts can fight a certain number of fires, and, as the three sites mentioned above demonstrate, the public will come on board and support efforts to save the wildlife. But surely it would be better is we had a system that we could trust not to make environmentally flagrant decisions. Buglife thinks that the following actions are required to ensure that wildlife on previously developed land is not exposed to development associated destruction:-
1) Change the definition of brownfield.
2) Protect all sites of SSSI quality.
3) Legally protect the homes of endangered species.
4) Give third parties the ability to appeal planning decisions on environmental grounds.
Taking those one by one:-
1) Change the definition of brownfield.
What must happen?
The direct link between ‘previous development’ and brownfield should be broken. Brownfield should mean what the public think it means – places heavily altered by human activity, that are empty of uses and wildlife and are wholly suitable for redevelopment. In addition there needs to be a universally accepted definition of ‘high environmental value’ so that planners and developers are able to clearly interpret when a site should not be considered for redevelopment, or if it is considered then there also needs to be security for the wildlife as part of the package.
What is Buglife doing?
Buglife has been leading on the development of a definition of ‘high environmental value’, that is currently circulating around environmental NGOs for approval, once this is achieved we hope to bring on board other bodies such as Natural England and the Town and Country Planning Association to give the definition wider authority.
The CPRE is working to protect the countryside and believes that brownfields should be considered for development before green field – ‘Brownfield First’ – but the charity also recognises that “Land important for wildlife, historically significant or that provides valuable open space should be safeguarded from inappropriate development.”
Therefore Buglife is working with the CPRE to consider how the definition of ‘brownfield’ can be changed to provide greater environmental safety.
2) Protect all sites of SSSI quality.
What must happen?
There should be no debate here, Natural England has a legal duty to designate sites as SSSIs if they are “of the opinion that any area of land is of special interest by reason of any of its flora, fauna, or geological or physiographical features”.
In the cases of Lodge Hill and Rampisham Down Natural England did designate the sites as SSSIs, but only after they came under threat. Inevitably this is unsatisfactory for the developer and the planning authority. In the case of Radford Quarry, despite this being potentially the only site left in the world where an endangered spider, the Horrid ground weaver, lives, the site has still not yet been designated as an SSSI by Natural England. It is clear that the 9,600 people who signed the petition felt passionately that this home for the Horrid ground weaver is very, very special.
The SSSI series was devised on the back of bird and flower data in the 1970s. Nearly half a century later there are ten million more people living in the UK, we know much more about endangered species and where they live, and the SSSI series looks woefully inadequate.
Natural England should undertake a full review of the SSSI series to ensure that it is not a museum of sites of ‘scientific interest’, but is capable of being the ark in our isles. The SSSI series should contain sufficient habitat and spread to enable the survival of all British species, this does not in any way conflict with the current SSSI policy which states that:-
“The purpose of SSSIs is to safeguard, for present and future generations, the diversity and geographic range of habitats, species, and geological and physiographical features, including the full range of natural and semi-natural ecosystems and of important geological and physiographical phenomena throughout England.”
What is Buglife doing?
Buglife is calling on Natural England to designate Radford Quarry as an SSSI.
We have also submitted a project to the Esmee Fairburn Foundation that if funded will enable Buglife to define Important Invertebrate Areas across the UK. Important Bird Areas underpin the SSSI network for birds, but there is no similar underpinning for invertebrates. Once we know where all the most important invertebrate sites there will be no excuse for not designating a comprehensive series of SSSIs.
(For more on how these cases highlight the failure of the SSSI series see Miles King’s blog on the issue)
3) Protect the homes of endangered species by adding them to the Wildlife and Countryside Act.
What must happen?
The Wildlife and Countryside Act allows the Government to add for protection “any animal or plant which, in his opinion, is in danger of extinction in Great Britain or is likely to become so endangered unless conservation measures are taken”. It is clear that there are several species whose homes (places of shelter) could be protected by the Wildlife and Countryside but which are currently exposed to developments which threaten them with extinction on their last handful of sites, as well as the Horrid ground weaver, other examples include the Distinguished jumping spider, the Four-banded weevil wasp and the Streaked bombardier beetle.
If added to the Wildlife and Countryside Act then developers would be expected to undertake surveys for the species where suitable habitat occurs on a development site, and Natural England and the Local Authority would be expected to ensure that any development does not cause significant harm to the species.
What is Buglife doing?
Buglife formally proposed the species listed above to the Government for protection in 2008, the current failure of the system to protect these species from development has been acknowledges and with Plantlife we are working with the Statutory Agencies to develop a solution.
4) Give third parties the ability to appeal planning decisions on environmental grounds.
There is an underlying bias against the environment in the planning system. While developers are able to appeal a planning decision that goes against them, environmental charities are unable to appeal a decision that goes against the environment. A re-balancing of the process would ensure that planners and councillors were aware when they made their decisions that if they get it wrong then they would be open to an environmental appeal. This should focus the mind in the first place and ensure more consistent and rational decision making.
Back to the Horrid ground-weaver
That’s the big picture and I hope I have given you a flavour of what Buglife and other charities are doing to ensure that threats to wildlife from development are minimised and that there is greater clarity for all about where the important wildlife is and where the best sites for development are. But we are currently fighting a fire at Radford Quarry and help is needed.
The Horrid ground-weaver is a UK speciality, found nowhere else in the world, it has been seen in three limestone quarries in the Plymouth area. The Horrid ground weaver is a little hammock web building predator that is thought to live amongst lime rich rocks and interstices. One of quarries has already been developed with housing so it is essential that this important wildlife site is saved.
For more on the horrid ground weaver and Radford Quarry wildlife see:- The Guardain, Daily Mail
For more on Rampisham Down see:- RSPB
For more on Lodge Hill see:- RSPB
