Two Contrasting Inspectors Reports on ‘Brownfield First’

This week

Reigate and Banstead

The Council’s approach in the Submission [plan] was that urban extensions would only be required after 2022 when most of the supply from existing urban areas (plus Horley North East and North West sectors) was built out and no longer available. …
Many house-builder representatives argue that the urban land supply is so restricted that greenfield sites will be required throughout the plan period and should be released in tandem with urban development. However, introducing the often easier-to-develop greenfield sites at an early stage risks undermining the “urban areas first” strategy which lies at the heart of the [plan]. Consequently an approach which allows greenfield sites only when necessary to maintain a five year supply is sound.


Policy CS3 seeks to prioritise the development of the most sustainable sites. This appears to me to be a phasing policy and, even though you consider that it would apply to no more than a handful of sites, I do not consider that it accords with the Framework. Development which is sustainable, it says, should go ahead without delay. The Sites and Policies DPD should identify sustainable sites in accordance with the strategy set out in the Core Strategy and the Council should encourage their suitable development straightaway. I therefore ask you to re-draft this

Policy CS3 says

Policy CS 3
Location of New Development
In allocating and determining which sites are the most sustainable, for the purposes of phasing
in the Sites and Policies DPD, regard shall be given to the following considerations:
a. The need to prioritise the development of the most sustainable sites
b. The need to encourage the re-use of previously developed land
c. Maximising the proximity and accessibility of housing to service and employment centres
d. Maximising accessibility to public and private transport networks
e. Maximising the opportunities to meet the needs of Rotherham’s areas of highest deprivation

Clear as mud then.   Providing you can have phasing and still achive trajectory I see nothing wrong with policy CS3 above.   Requires an #NPPF clarification about whether unnecessary loss of less sustainable sites is ‘sustainable’ or not.  For my penneth I think the inspector at Rotheram got it wrong as consideration of nteh plan is one of the factors which makes a site sustinable.  An overly narrow reading of the NPPF.