Comment

Representation ID: 29175

Received: 24/03/2021

Respondent: Environment Agency

In principle we support the effective and efficient re-use of previously developed land. As above, we feel that in some instances previously developed land may hold (or have the potential to hold) significant environmental / ecological value. Based on this, we support the inclusion of the qualifying statement “that is not of high environmental value” within bullet point A, 1 of Policy SP4. However, the policy wording does not explain how the environmental value of prospective, previously developed sites, will be determined. For example, previously developed land immediately adjacent to river corridors, even if currently in a poor state, has a high environmental value.

Equally, rather than solely focussing on current environmental value, we feel the policy needs to consider the future / potential environmental value when determining which previously developed site are most suitable for future re-development. For example, the potential to unlock previously lost environmental value through de-culverting rivers and streams should be given weight when determining site selection.