BASE HEADER

Yes

ID sylw: 106510

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

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 field site on the edge of a town or extended village 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 in 2012 and has not
been re-introduced in any of the revisions to the NPPF since