Parliamentary push for Brownfield First is good news for land remediators
MPs fighting to enshrine in law the convention that brownfield sites should be developed before virgin land are ensuring a steady stream of work for those who clean up contaminated land. David Drew, Labour/Co-operative MP for Stroud, put forward the Early Day Motion which could persuade the Government to take note. Here he outlines the case for Brownfield First.
The Early Day Motion (EDM)1770 – ‘Brownfield First Approach for New Housing’ – notes the positive role of planning policy in the housing market with particular reference to the sequential ‘brownfield first’ approach in Policy Planning Guidance (PPG)3.
However, the motion questions the Government’s seemingly different approach in its draft planning policy on housing, which emphasises meeting market demand where it arises rather than where capacity for development exists.
In response the EDM calls upon the Government to instead retain the prominence of the sequential brownfields first approach in the new planning policy on housing due later this year.
Changes to the draft proposal have also been called for in the recent report from what was the Select Committee for the Office of the Deputy Prime Minister (ODPM) but is now the Department for Communities and Local Government.
In this report, entitled ‘Affordability and the Supply of Housing’, MPs conclude that “a simple supply and demand model cannot be applied to the housing market” with concern directed at “the relaxation in planning controls proposed in the new draft Planning Policy Statement (PPS) 3, which could result in urban sprawl and undermine regeneration efforts in established urban centres.”
They recommend local authority powers to prioritise brownfield sites are not eroded.
In recent years the Government has initiated a substantial swing towards reusing previously developed land and buildings rather than greenfield sites. The current sequential approach gives priority to development on urban brownfield sites over greenfields.
The draft proposal, if not amended, will encourage the sprawl into the countryside that had been impressively abated over recent years.
This will harm prospects for urban regeneration and will not provide the significant number of affordable homes that are so desperately needed throughout the country particularly in rural areas.
The draft proposal will designate areas as ‘high, medium or low growth’ with the key objective being “a better balance between demand and supply in every housing market.”
This assumes demand for housing should be met wherever it arises. This approach to housing could be at the expense of the countryside. The problem of the wrong type of housing being built in the wrong place, leading to the greenfield sprawl and urban decline, was being effectively addressed by the Government’s Planning Policy Guidance 3 in the year 2000.
The proposed changes are aimed at increasing the amount of land allocated for housing, make the planning system more responsive and improve affordability.
Evidence from the UK and abroad suggests that the price of borrowing may be as important as supply in determining the price of housing, or even more so. Furthermore, the Government’s National Land Use Database lists approximately 64,000 hectares of brownfield land available for development, with 28,650 hectares considered suitable for housing. Using a density of 40 homes per hectare this equals more than 1 million homes.
The proposed approach could stoke demand where the capacity to absorb it does not exist. This will damage the qualities that made the area desirable and place unsustainable burdens on the infrastructure and environment.
A framework for renewal can transform the prospects of run-down areas providing the homes we need from the best use of resources.
By prioritising brownfield sites and only using greenfields where absolutely necessary, the sequential approach provides a catalyst for urban regeneration whilst protecting the countryside.
More than 70 per cent of homes are currently being built on brownfield sites. This is a significant achievement by the Government.
A ‘brownfields first, greenfields last’ approach is a more environmentally friendly way of development which can boast being sustainable, energy and resource efficient and less car dependent. By regenerating disused land in town and city centres the infrastructure of jobs, homes and services are provided on the door step.
Public transport is accessible and journeys can be made on foot or by bicycle. It is important not just to minimise the environmental impact of building the structure but also of its future use.
Development should take place on urban sites which reduce the need to travel. Fulfilling these criteria alone, however, does not mean the site is inevitably suitable for development.
A variety of factors such as traffic generation and local character must be taken into account. Large areas of open land surrounding built up areas would not normally be considered suitable for development. This would also apply to brownfield land important for wildlife, recreation or with historical significance where development would not be able to retain the site’s intrinsic qualities. It is simplistic to believe that brownfield land always has intrinsic value as a site for redevelopment.
Communal green spaces and private gardens in town and cities are as important to people as open countryside. Whilst the re-use of brownfield land is an essential measure to protect the beauty of rural England this should not be at the expense of precious urban greenery.
The Government has not defined parks, playing fields, allotments and public gardens as brownfield land and it is essential that this lack of definition is not the cause of development abuses.
The decisions necessary to develop an area should be primarily the responsibility for local councils and communities.
Priority must be given to meeting identified local housing needs rather than crude market demand. This includes providing affordable, subsidised homes for rent or part ownership and cheaper homes for sale for key workers and first-time buyers. Improvements need to be made in the use of existing buildings.
There are around 700,000 empty homes in England and many more partly empty and empty properties of all types. In general it requires less energy and fewer resources to refurbish an existing building than to demolish and rebuild it though the tax regime may point in a different direction.
With the enormous pressure for new housing, land must be used wisely. Where a site is to be developed there may be the opportunity to provide more floor space, known as intensification.
Badly done, this raises criticisms of over-development but intensification can be done sympathetically whilst ensuring an efficient use of land. Intensification may not mean extending beyond the blueprint of the previous building – a large house can be converted into flats whilst retaining the garden.
Intensification can also involve a mixed use development extending the range of uses on a site, keeping jobs local as well as housing.
The Government has stated that a key test of development should be whether it positively improves the character and environmental quality of an area and the way it functions. This should be a cornerstone of all development.
It is essential that this principle is set out clearly, enshrining the Government’s aspirations for the places we live, particularly concerning traffic management, parking controls and sustaining a high quality public realm.
It is not good enough to simply ‘plan for appropriate levels of car ownership.’ New housing should be built where inhabitants do not need to travel by car.
The random speculative development of private gardens is not an acceptable form of urban development either and such designs for residential areas should be planned for and serve the overall public interest.
It is not known how much development takes place in gardens. In 2005 20 per cent of all new homes were built on residential land; however, this figure is misleading as much of this development would have remained within the footprint of the original building.
Though local planning authorities have the powers to control and prevent inappropriate development they do not always make full use of them.
The reasons why brownfield sites are not always a developer’s first choice include contaminated land and multiple ownership. The local environment and schools may be poor and deter prospective investors and buyers.
Addressing such issues requires a brownfield first approach in planning policy, resources for remediating contaminated land, selective compulsory purchase powers and changes to VAT. Currently VAT is zero rated on new builds and 17.5 per cent on repairs and renovations. The extra cost of VAT makes greenfields more profitable and contributes to a cycle of neglect and decline.
Overall, this EDM re-states the principles the Government should adhere to, criticises any change in that approach and demonstrates that good practice is possible but must achieve public consent if the different and difficult pressures facing Government in this area are to be overcome.
David Drew is Labour/Co-operative MP for Stroud.
The Early Day Motion 1770 “Brownfield first approach for new housing” can be accessed here.
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