Nick Taylor, partner in Carter Jonas’ planning and development team, questions the policy of developing brownfield sites before greenfield.
The long-held belief that we should prioritise brownfield over greenfield development has challenged housebuilding for decades, leading to a less effective, slower and more politically toxic system.
It has fuelled a housing delivery crisis and an even greater crisis in the delivery of affordable housing, thereby exacerbating social problems in an increasingly unequal society.
A potted history of the evolution of this policy takes us back to the 1990s when it was proposed that 60 per cent of all new homes should be built on brownfield land.
Planning Policy Guidance Note 3 (PPG3) enshrined the sequential approach of selecting brownfield sites over greenfield. This was, and remains, a laudable ambition, but within three years it was clearly failing: the Barker Review of Housing Supply Interim Report (2003) highlighted in relation to PPG3 that, ‘It is not the intention of the policy to restrict land supply…some local authorities appear to have overinterpreted it to the detriment of housing being delivered’.
Although the target was removed, the ambition lives on in the current NPPF which states that: “Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land.”
In the last 20 years, the situation has worsened and we need to revisit the resistance to greenfield housing.
Why? Because of the failure for planning policy today to incorporate the fundamental principle that the planning system should be plan-led. Without up-to-date plans and a commitment to plan-making by all local planning authorities, the system is doomed to fail.
This has been a failure of all governments – that is not a dig at any particular political party – although it is fair to say that matters have clearly taken a turn for the worse in the last few years. All the evidence shows housing delivery is stalling and the focus needs to be reset, with greenfield housing development integral to delivery.
There is also general increased opposition to greenfield housing development which has intensified with disastrous consequences for housing delivery and in particular, the delivery of affordable housing. A number of factors are at play here.
First, NIMBYism generally.
Second, concern about greenfield developments that are not seen to be paying their way as a result of late or under-delivery of social, community and physical infrastructure.
Third, a naïve understanding of the economics of brownfield housing development. The costs, relative to those for greenfield land, are enormous and increasing. Together with CIL, Section 106 costs and Vacant Building Credits costs, the quantum of social / affordable housing on such developments is compromised.
Fourth, the assumption that there is enough brownfield land. The annual target housebuilding target is supposedly 300,000 homes, but in reality there is only enough brownfield land to deliver 90,000 homes per year. This leaves a requirement for 210,000 homes from greenfield.
In my view, four policy changes would make a difference. These must come from the top-down because bottom-up has proven to be too big an ask as a means of delivering substantial numbers of new homes.
First, the NPPF proposal to allow land to be bought at existing use value for schemes delivering large levels of affordable housing. There are so many questions on this, but my hunch is it will be slow and not many will be delivered – but it might be worth a try.
Second, the NPPF must revert to allowing reviews of Green Belt boundaries as part of plan-making. Should Labour win the next general election, there is potentially good news on this, as it looks as though a Labour government will implement this early on.
There will be an inevitable lag but if the political commentators are right and Labour is in power for at least a single term, this could make a real difference to supply.
Third, dates must be set for Local Plan reviews and adhered to. The current stick/carrot approach is a planning free-for-all because unmet deadlines simply become Groundhog days which persist indefinitely. Whatever this mechanism is, it must force local planning authorities to bring forward development plans or allow automatic consents.
Fourth and finally, we need a more nuanced approach to the respective roles of greenfield and brownfield land in housing supply. Local authorities must be encouraged to use brownfield if they can, but if greenfield is the best way forward, they should be allowed to pursue this option within a policy framework that maximises the delivery of affordable housing and contributions to social and community infrastructure – because in the long run, this is the only way that development will pay for itself and be accepted by communities.
With these changes, there is a chance that the inertia that has restricted housing delivery through plan-making over the last 20 years or so could draw to a close.
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