Supplementary memorandum by the South
Yorkshire Coalfield Partnership Board (COA 08(a))
1. REASON FOR
THE FURTHER
SUPPLEMENTARY SUBMISSION
1.1 The further submission aims to clarify
the key issues for coalfield communities arising from the current
guidance on the greenfield/brownfield status of former colliery
sites and its interpretation, following the debate during the
Committee's visit to Yorkshire.
2. FORMER COLLIERIES
AND THE
DEFINITION OF
PREVIOUSLY DEVELOPED
LAND
2.1 From a common sense point of view, it
would seem difficult to argue that a site whose last productive
use was for deep coal mining has not been "previously developed".
The built structures on site (including pit head gear, ancilliary
buildings and related industrial processes), the numbers of people
employed, the diversity of the jobs they did and the longevity
of the land use would make it very difficult to argue that such
a site has not been previously developed. There might be factors
which would over-ride this historical legacy, when classifying
the land as brownfield or greenfield, but the status of such land
as having been previously developed should be incontrovertible.
2.2 In our first supplementary statement
we demonstrated how the existing PPG3 should be interpreted in
a different way, such that if the site has been reclaimed in such
a way as to prepare it for hard after-uses or has unimplemented
conditions to reclaim it to such a state, then it should be considered
to be brownfield. We suggest this because it requires no change
to the guidance—just a quick reinterpretation.
2.3 This proposal stands, but to clarify
the underlying argument, it is a device to correct an approach
within the guidance which does not match with "common sense".
How, in "common sense" terms can anyone suggest that
a former deep mine coal site has not been previously developed?
3. IMPLICATIONS
OF THE
CURRENT GUIDANCE
3.1 In and amongst former coal mining settlements
in South Yorkshire, most of the land available for development
which has previously been developed is on former colliery sites.
If, as is implied by the current ODPM interpretation of PPG3,
most of this land is greenfield, there is very little brownfield
land at all in these areas. This means that development is automatically
prioritised elsewhere, where is there is land accepted within
the interpretation of the guidance as being brownfield. This places
a straightjacket upon local planning policies on the allocation
of land for industry and commerce and for housing.
3.2 We think it likely that many other former
coal-mining areas would be in a similar situation.
3.3 Reinterpreting PPG3 as suggested in
our previous supplementary evidence provides an approach which
is consistent with the underlying objectives of Government policy
and allows for local decision-making within that framework to
reflect the circumstances of local areas.
Richard Breese
Strategic Co-ordinator, South Yorkshire Coalfield
Partnership
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