The Government has today published a consultation on new guidance on brownfield land in the 20 largest cities in England Strengthening planning policy for brownfield development - GOV.UK (www.gov.uk). The gist is that Councils in the 20 largest towns and cities will be subject to the presumption in favour in respect of residential proposals on brownfield sites where housing delivery has dropped below what is expected – defined as being when their Housing Delivery Test result drops to below 95%. The aim (apparently) is to address “under delivery” in these towns and cities.
This story has been trailed in papers over the weekend, and in the Planning Resource. Now, is it me, or is this new approach a little disingenuous? Mr Gove talks about “nimby” Councils blocking development on brownfield sites. I have spent many years working in Council planning departments, and a great deal of that time was in an urban authority. Without exception, all those Councils were committed to bringing forward brownfield land for development. Councils are normally doing everything they can to facilitate brownfield development and trying to persuade developers to join in. Most also have policies in Local Plans trying to prioritise brownfield ahead of greenfield. So I’m not sure where these “nimby” Councils of which Mr Gove speaks may be located. Moreover, there are usually very good reasons that brownfield land is more difficult to develop and takes longer to come forwards. For example costs and viability, multiple landownerships, contamination and need for remediation, and risk of finding unexpected problems half way through delivery (in one of my past authorities the problem tended to be finding unknown medieval graveyards and unexploded WW2 bombs!) Forcing urban Councils who are desperately trying to work out how to deliver homes through the regeneration of their communities to issue consents won’t solve these issues, nor will it boost the delivery of new homes to address the housing crisis.
Of course, using brownfield land is a good idea – but on its own this will not solve the Housing Crisis in this country. The excellent report "Banking on Brownfield" produced for the Land, Planning and Development Federation in June 2022 sets out why – but I was struck by the gap between the capacity of brownfield land to provide homes vs housing need. In the South West alone brownfield land could provide around 150,000 new homes against a need for nearly 420,000 new homes. And brownfield does not provide the answer to delivering the affordable homes we need. In 2022/23. Government figures show that Birmingham (the largest Council by population in England and, one would think, an area utilising plenty of brownfield sites), a total of 3,062 homes were completed – 616 (20%) of these were affordable housing, none were First Homes and completions just about cancelled out the number of affordable homes in the city lost to Right to Buy. So a net result of virtually no new affordable homes delivered. Difficulties in delivery mean that affordable housing is far harder to achieve on brownfield sites.
Forgive me, but the policy seems to be an attempt to shift the blame for the lack of delivery of new homes to our largest towns and cities and away from places where there are plentiful supplies of greenfield sites in sustainable locations which could be brought forward simply, quickly and with policy compliant levels of affordable housing. The policy we need is a properly thought out strategy for tackling the housing crisis, on brownfield and greenfield sites with each playing to their strengths, facing up to the need to build homes of all types and tenures. Not setting out more national policies without purpose aside from giving more tools for the real nimbys to block housing where it is needed.
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