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ID sylw: 108169

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We broadly support the requirements to make efficient use of brownfield land. Recycling previously developed land can (though not always) achieve a series of sustainability objectives.
However, the scale of housing required in the plan area – even by the HEDNA evidence, which is significantly below the Standard Method and before adding in the duty to co-operate – is such that brownfield opportunities are insufficient to make even a small contribution to overall housing delivery in the plan area.
Furthermore, we object to any suggestion that a sequential approach should be taken to bringing forward brownfield sites ahead of green field opportunities. Setting aside that broader sustainability objectives should be applied (for example, a Green Belt site on the edge of Stratford town performs significantly better than an isolated brownfield site in National Landscape) the NPPF contains no such sequential approach to previously developed land. The sequential approach to brownfield development was founded in PPS3 and PPG3 before it and was expressly removed from the NPPF ion 2012 and has not been re-introduced in any of the revisions to the NPPF since.