Jon Sebbage from Savills’ planning team considers the local implications of the Government’s latest consultation on planning policy for brownfield development.

Over the last month, local authorities, representative bodies and businesses have been feeding into a consultation on its proposed approach to ‘strengthening planning policy for brownfield development’.

The consultation, which closed on March 26, includes two proposals:

  1. ‘A change to national planning policy that would expect local planning authorities to give significant weight to the benefits of delivering as many homes as possible, and to be flexible in applying policies or guidance on the internal layout of developments especially for proposals on brownfield land’; and
  2. ‘The application of the presumption in favour of sustainable development in respect of previously developed land only for those 20 towns and cities subject to the urban uplift, where their housing delivery test score falls to 95 per cent or below’.

National planning policy already includes firm support for the development of brownfield land through the updated National Planning Policy Framework (December 2023), including requiring a 35 per cent ‘uplift’ in housing in the largest towns and cities and through ‘permission in principle’ brownfield registers.

However, the current consultation appears to try to take this approach further by proposing that, across all local planning authorities, ‘significant weight’ should be applied to the benefits of brownfield development when determining applications, and that a ‘flexible approach’ should be taken to considering other matters relating to the internal layout of development (although notably not to ‘external design or layout standards’).  In addition, in the 20 largest towns and cities there would be a new presumption in favour of brownfield development.

The consultation is particularly relevant to Reading as a predominantly urban authority and one of the 20 largest towns and cities in the country which is subject to the ‘urban uplift’ for new housing supply.

Indeed in 2022-23, some 888 dwellings were delivered in the borough (in excess of its current annual housing requirement), of which 77.8 per cent were on brownfield land.  Notably, the borough has exceeded its required housing delivery over the past three years, and the council’s current housing trajectory indicates that this trend will continue for some time.

On this basis, the current proposals for a presumption in favour of brownfield development (part 1 above) would not currently apply and may not apply for some time.  The broader proposals for ‘significant weight’ to be applied to the benefits of brownfield development (part 1 above) would however be applicable, and particularly relevant, to new development in Reading.

The council’s recent consultation undertaken on the Local Plan Partial Update (November 2023) proposes an ‘even stronger focus’ on Central Reading to accommodate increasing local housing needs and the required ‘urban uplift’.

Indeed around 60 per cent of new homes are proposed to be delivered in the town centre up to 2041.  It is clear therefore that the council is already seeking to prioritise brownfield development in order to meet its increasing local housing needs.

However, the increased emphasis on brownfield development, proposed by the Government’s current consultation, and the need to apply ‘flexibility’ to other policies, may have a further impact on the type and design of new development coming forward in the borough.

The consultation is clear that the proposals would only apply to ‘internal layouts of development’ and would ‘not remove legal requirements nor the importance of other considerations relating to beauty or undermine wider considerations of character’ – although the consultation does also invite responses on whether the scope of such proposals should be widened.

There is therefore the potential that the current proposals will push local planning authorities to further relax standards relating to density, mix, affordable or amenity space for instance, in order to facilitate increased brownfield development.

Notably, the council’s recent Local Plan consultation further emphasised the need for affordable family housing in Reading and set out increased sustainable design standards.  In particular, proposals were set out to either double or triple the proportion of three-bed homes delivered at town centre sites.

Provision was also set out for all new-build housing to be net zero carbon and water neutral (to support the aim for a net zero borough by 2030) and to deliver 10 per cent biodiversity net gain (in line with new national mandatory requirements).

Despite these laudable aspirations, there is concern locally that the proposals may further exacerbate the challenges the industry faces in meeting housing need and delivering the type and design of housing required.

The Government state that they would look to implement these changes ‘as soon as possible’ through updates to national planning policy and as part of new National Development Management Policies.

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