environment magazine

WHY WE STILL NEED THE BROWNFIELD FIRST APPROACH

By Paul Miner, Senior Planning Campaigner, Campaign to Protect Rural England (CPRE)

In November 2011 CPRE published a new report: Building on a small island: why we still need the brownfield first approach, produced by the planning consultancy Green Balance. The report presents evidence which demonstrates overwhelmingly that existing national planning policy on prioritising the development of ‘brownfield first’ has been successful and that it should be retained. 

The report examines the implications of moving away from an emphasis in national planning policy on prioritising the re-use of brownfield land. In the draft National Planning Policy Framework (NPPF) it is proposed to cease referring explicitly to the need to development on brownfield sites (or ‘previously developed land’) before greenfield. Instead the draft NPPF refers to using land of ‘lesser environmental value’. The report also considers the implications of other related recent Government policy changes to drop the minimum housing density range which has until recently been national policy.

Currently, Planning Policy Statement 3: Housing (PPS3) requires that local planning authorities prioritise the development of suitable brownfield land for new development before greenfield sites are considered and to promote residential densities that make efficient use of land. 

Great strides have been made over the last 15 years to secure more use of brownfield land and build at minimum residential densities of at least 30 dwellings per hectare. These have assisted in urban renewal, avoidance of countryside loss, efficiency in land use (including reduced aggregates extraction and carbon emissions) and transport, and the associated social benefits of all of these.  There is a real risk that these achievements will be reversed if the new Framework does not clearly continue the existing emphasis.

The report finds that the justifications for the proposed policy changes, set out in an Impact Assessment to the draft NPPF, do not to stand up to scrutiny.  There appears to be an underlying misconception that brownfield land will not be replenished sufficiently at the same rate as it is being built on and therefore the existing policy, if continued, constrains land supply. Our analysis, which is based on the Government’s data, demonstrates, however, that brownfield land continues to come forward as part of the process of urban land recycling in a dynamic market.  Indeed, across England as a whole replenishment has exceeded reuse since 2001.  The detailed reasons to support the change of policy in the Impact Assessment inadequately understand the land and housing markets, and at times give misleading impressions. 

Case studies examined local authority areas and regions (in particular South East England) where there might be particular difficulty in sustaining house building rates, especially if brownfield sites were no longer forthcoming.  Evidence over many years showed that these areas continued to supply large quantities of housing, almost entirely on brownfield land, often on ‘windfall’ sites that would have been difficult to predict in advance. 

With urban densities often high or very high, there is concern that ‘town-cramming’ may be taking place to the detriment of dwelling sizes, the availability of private gardens, and family life.  Half the London boroughs have recently had average housing densities in excess of 100 dwellings per hectare (dph), for instance. The evidence suggests that good design, construction and management can resolve these problems, so that urban living can be enjoyable and affordable to families and other households on modest incomes. 

Ministers have argued that the reference to using land of ‘lesser environmental value’ will help address concerns that the existing brownfield first policy led to sites of high biodiversity value being developed. While the report recognises the concerns about the biodiversity value of some sites it does not come to the same conclusion about the need to radically reword the policy. It notes that in responding to the draft NPPF, Wildlife & Countryside Link (an umbrella body of environmental NGOs) stated that this should be addressed by retaining the brownfield first approach, but removing sites of proven high biodiversity value from the definition of brownfield.

Key findings from the report, based on a statistical review of the available data on supply and use of brownfield land, include:

• 31,160 hectares of brownfield land are available and suitable for residential development: enough to deliver nearly 1.5 million new dwellings. This is higher than the corresponding figure for 2001.

• 36,680 ha of brownfield land have been redeveloped for new housing since a national brownfield target was introduced in 1995. Had this development taken place on greenfield land instead, an area of countryside at least seven times the size of Southampton would have been lost to new housing. 

• The rate of greenfield land developed for housing could increase by as much as 158% per year from current levels, based on both the scenarios produced by the Government and the possible consequences of a loss of policies over brownfield and density.

The report recommends the retention of the ‘brownfield first’ approach in the final National Planning Policy Framework (NPPF), and also that the final NPPF should:

• allow for the reasonable expectations of ‘windfall’ sites coming forward in a local authority’s five year supply of developable land for new housing;

• include policies which specifically encourage well-designed housing development at medium densities (at least 30 dwellings per hectare) or high densities consistent with other planning objectives, including the provision of family accommodation within urban areas at densities above 50dph; and

• encourage local planning authorities to set targets for the re-use of previously developed land, based on local circumstances.

 Finally, the report argues that land recycling and housing density should remain part of the suite of indicators of sustainable development produced by Defra. This involves local authorities continuing to provide annual data on the proportion of brownfield land being redeveloped, along with average densities of new housing. A concern is identified that worrying gaps in the evidence may open up in the coming years without a continued commitment to the collection of relevant data.