Object

Representation ID: 29131

Received: 24/03/2021

Respondent: Environment Agency

We support the promotion of sustainable development – which applies to economic, social and environmental aspects. However when it comes to new development we do not necessarily fully agree with the approach of site selection that, “wherever possible maximises the use of previously developed land”.

There are circumstances where this may not be the environmentally optimal solution. Previously developed land in an urban area can (or perhaps should) support a diversity of wildlife, (sometimes) more so than intensely managed countryside sites.

For example, a brownfield site can also be important stepping stone within an existing wildlife corridor, and therefore can be valuable in providing connectivity within ecological networks. This is particularly relevant where previously developed land lies next to rivers and streams – as these are the only location where the river environment can be improved to provide the blue infrastructure that is valuable (for health, wellbeing, biodiversity and climate change mitigation etc.).

As such, we recommend that where brownfield sites exist alongside watercourses, there should be a presumption for new development to be set-back, to include an undeveloped buffer zone or, in some cases, for the site to not be developed. This is to allow for natural recovery of green-blue infrastructure, the provision and enhancement of ecological networks and to increase climate change resilience.