Brownfield First Does Not Mean ‘Brownfield Only’

Posted by Carter Jonas - Building Consultancy on 10th June 2024 -

Albert Einstein famously said that the definition of insanity is doing the same thing over and over again and expecting different results. In respect of the approach to housing development in Britain, that phrase has never seemed more apt. The policy ambition that we should prioritise the development of brownfield sites over greenfield has seriously challenged everyone involved in this process, delivery has become slower and more politically toxic, and most importantly, caused serious social stress. 

 

And alongside a crisis of housebuilding delivery is an even greater crisis in the delivery of affordable housing, thereby exacerbating social problems in an increasingly unequal society. 

 

So what needs to be done? A potted history of the evolution of this policy takes us back to the 1990s and the proposition that 60% of all new homes should be built on brownfield land. In 2000 Planning Policy Guidance Note 3 (PPG3) enshrined the sequential approach of selecting brownfield sites over greenfield. This was, and remains, a laudable ambition which made sense, but it had unintended consequences. 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.” 

 

Subsequently the target was removed, but the ambition lives on in the NPPF (2023) 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.” 

 

Although, superficially, it might be hard to reach any conclusion other than that nothing has changed over the last 20 years, I believe that 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. I believe a number of factors are at play here. 

 

First, NIMBYism generally. 

 

Second, valid opposition to urban extensions on greenfield land 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, that it is always viable and that building flats, often at high rise, supplies the homes that we need. It won’t and it doesn’t. 

 

Fourth, the assumption that there is enough brownfield land. The annual target housebuilding target is supposedly is 300,000 homes, but even with the greatest optimism, the most that we can deliver on brownfield land is around 90,000 homes per year. This leaves a requirement for 210,000 homes from greenfield and other sources. 

 

So why can’t we have more on brownfield sites, in particular affordable housing? This is due to the lack of funding for public housing and the requirement for developers to deliver this despite the relatively enormous (and increasing) costs of delivering on brownfield sites, CIL and Section 106 costs, and Vacant Building Credits – all of which almost always (and inevitably) suppress the delivery of social / affordable housing.

 

Aside from all this, what policy changes need to be made to address the complex challenge that was first identified back in 2003, if we are to increase housing delivery? 

 

In my opinion, there are four policy changes that 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, it will be interesting to see whether the NPPF proposal to allow land to be bought at existing use value for schemes delivering large levels of affordable housing has any effect. 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 has to be changed back to allowing for reviews of Green Belt boundaries as part of plan-making. Should Labour win the 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, it is necessary to set the dates for local plan reviews and stick to them. 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, 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.

 

Given these changes, maybe, just maybe, in respect of housing delivery through plan-making, the inertia of the last 20 years or so could draw to a close.  

Albert Einstein famously said that the definition of insanity is doing the same thing over and over again and expecting different results. In respect of the approach to housing development in Britain, that phrase has never seemed more apt. The policy ambition that we should prioritise the development of brownfield sites over greenfield has seriously challenged everyone involved in this process, delivery has become slower and more politically toxic, and most importantly, caused serious social stress. 

 

And alongside a crisis of housebuilding delivery is an even greater crisis in the delivery of affordable housing, thereby exacerbating social problems in an increasingly unequal society. 

 

So what needs to be done? A potted history of the evolution of this policy takes us back to the 1990s and the proposition that 60% of all new homes should be built on brownfield land. In 2000 Planning Policy Guidance Note 3 (PPG3) enshrined the sequential approach of selecting brownfield sites over greenfield. This was, and remains, a laudable ambition which made sense, but it had unintended consequences. 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.” 

 

Subsequently the target was removed, but the ambition lives on in the NPPF (2023) 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.” 

 

Although, superficially, it might be hard to reach any conclusion other than that nothing has changed over the last 20 years, I believe that 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. I believe a number of factors are at play here. 

 

First, NIMBYism generally. 

 

Second, valid opposition to urban extensions on greenfield land 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, that it is always viable and that building flats, often at high rise, supplies the homes that we need. It won’t and it doesn’t. 

 

Fourth, the assumption that there is enough brownfield land. The annual target housebuilding target is supposedly is 300,000 homes, but even with the greatest optimism, the most that we can deliver on brownfield land is around 90,000 homes per year. This leaves a requirement for 210,000 homes from greenfield and other sources. 

 

So why can’t we have more on brownfield sites, in particular affordable housing? This is due to the lack of funding for public housing and the requirement for developers to deliver this despite the relatively enormous (and increasing) costs of delivering on brownfield sites, CIL and Section 106 costs, and Vacant Building Credits – all of which almost always (and inevitably) suppress the delivery of social / affordable housing.

 

Aside from all this, what policy changes need to be made to address the complex challenge that was first identified back in 2003, if we are to increase housing delivery? 

 

In my opinion, there are four policy changes that 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, it will be interesting to see whether the NPPF proposal to allow land to be bought at existing use value for schemes delivering large levels of affordable housing has any effect. 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 has to be changed back to allowing for reviews of Green Belt boundaries as part of plan-making. Should Labour win the 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, it is necessary to set the dates for local plan reviews and stick to them. 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, 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.

 

Given these changes, maybe, just maybe, in respect of housing delivery through plan-making, the inertia of the last 20 years or so could draw to a close.