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CPRE calls for brownfield first – a great answer, but the right question?

The premise of CPRE’s report is to underpin their aspired brownfield first approach and comes at a time when speculation around the revised NPPF is cranking up.

A recent article published in The Times ‘Brownfield sites have room for 1m homes, says charity’ follows the publication by CPRE of a report entitled ‘State of Brownfield 2018: An analysis demonstrating the potential of brownfield land for housing’.

The claim is that councils have identified capacity for more than a million homes on ‘brownfield land’, whilst the Green Belt is being sacrificed.  In fact, the CPRE claims that “When considering all suitable sites (that is, not just those that are ‘deliverable’ in the next five years), there is enough space for at least 4.1 years housing land supply countrywide”.

In support of this approach, CPRE refers to twelve authorities, including South Oxfordshire and Waverley which have, alongside ten others, identified capacity for more than 100,000 homes but which have (or propose to) allocated Green Belt sites for 100,000 homes.

There should be no dispute that these brownfield sites do exist and it is right that these should be promoted as one element of providing the homes which are needed to help address the housing crisis. However it would be wrong to assume that that this source of housing, including the mooted brownfield first approach will represent a silver bullet that should be relied upon.

In this short commentary, we explore the issue from several perspectives: that of delivery; employment provision; and place-making.

Delivery

If any source of housing is to be a capable of making a contribution towards solving the grim availability of housing then it clearly has to be deliverable. It is well acknowledged that developing previously developed land is more costly and complex than other sources, often involving abnormal remediation costs not encountered on other sites and ultimately if a scheme is not viable then the prospects of housing being delivered are severely compromised. There is a greater likelihood that such sites will have complex ownership issues and leasehold arrangements for example which will also have a bearing on their immediate delivery.

Simply put, the demographics require deliverable supply and in order to achieve that supply will be required from all sources.

Employment Provision

The claims regarding the high quantum of housing which could be delivered on brownfield land risks overlooking a key component of spatial planning – providing space for employment opportunities. In many cases the brownfield land will have, or still does, accommodate those uses and therefore raises the question as to how displaced businesses will be accommodated and where land for new employment opportunities will be found. Is the prospect of greenfield sites being redeveloped for employment uses more palatable than housing?

Place-making

Not only is the quantum of delivery a relevant consideration but so also is the form. Our major urban areas are often short on space and when that is twinned with the level of housing need, the outcome is generally the provision of smaller units.  For example, Slough has an extraordinarily tight administrative boundary, high housing need (with a significant requirement for family housing) but a historic pattern of smaller units being delivered (as a symptom of accommodating a large number of dwellings in a smaller area). 

The recent report from CPRE follows an earlier call from the Oxfordshire branch in that increasing housing density could mean that countryside and Green Belt sites were spared development. In order to achieve this, the CPRE branch claimed that development should take place at the density of Barcelona, Paris or historic parts of Oxford itself. Notwithstanding that the City Council refuted the claims, the approach would have required swathes of the City to be demolished, the likely displacement of jobs and significant change to the fabric of the historic City. A City of Spires perhaps, but probably not that which the Victorian poet Matthew Arnold had in mind when writing ‘Thyrsis’.

Summary

The complex nature of delivering such sites was demonstrated in the Government’s own announcement (16 February 2018) that £45 million was being made available to support the delivery of 7, 280 homes on council owned land. The associated press release reveals that the Land Release Fund will be able to “combat barriers which would otherwise make land unusable for development”. This highlights the scale of the issue, the costs associated and the complexities of making brownfield land suitable for new housing.

In short, brownfield, or previously developed land does offer an opportunity to make an important contribution towards housing delivery and there is no doubt that such sites do exist and in locations where people want to live. However it is just one source of supply, with the others also making an important contribution. A balance is required between providing a deliverable source of housing which meets the need for a variety of house types and sizes, is suitable for development bearing in mind the myriad of considerations (flooding, accessibility and contamination for example) maintains accessible employment opportunities and which supports positive place-making (including through redevelopment) and maintaining the valuable features of our urban environments.

If you have any queries regarding this, please contact David Murray-Cox or Tim Burden.

9 April 2018