Brownfield-first just won’t go away
If vested interests are still attacking an environmental policy 10 years after it was abolished, you can be fairly sure it’s on the way back, whether they like it or not.
I was struck by this thought when I read the new report from the Land Promoters and Developers Federation entitled Banking on Brownfield. And in case you’d like to do that, it adds: “Can previously developed land supply enough homes where they are needed?”
Despite the prime minister’s assertion at last year’s party conference that: “You can also see how much room there is to build the homes that young families need in this country, not on green fields, not just jammed in the South East, but beautiful homes on brownfield sites in places where homes make sense”, Government policy remains steadfastly resistant to brownfield-first.
But despite a Daily Telegraph headline claiming: “PM pledges no homes on green fields”, subsequent robust denials showed the Government is still firmly opposed to brownfield-first. As greenfield is usually more profitable, this is effectively a greenfield-first policy.
So why should such a head of steam be building to bring back brownfield-first, despite it now being more than 10 years since it was brutally excised from English national planning policy?
Well, a decade on, the complex set of threats to our well-being which dictated brownfield-first remain. Unless, that is, you think a decade ago it suddenly became less important to protect our precious farmland, to recognise there are limits to the water environment’s ability to sustain growth everywhere, to put serious limits on soil-sealing and to facilitate drainage, flood protection, carbon sequestration, biodiversity and water infiltration.
Given the continuing opposition to brownfield-first from the development industry and its hangers-on, you might be tempted to think these things have become less pressing.
But even 10 years ago, it was clear that a heavily indebted country producing only two-thirds of its food in an increasingly unstable world with a growing population was a dangerous place to be. Yet England’s National Planning Policy Framework, first imposed in March 2012, effectively prioritised squandering our farmland on low-density, car-dependent sprawl
Since 2012, the world has become more unstable, the UK has grown more indebted, we are 10 years nearer climate Armageddon, we’ve squandered vast areas of farmland on sprawl and the country has turned its back on free trade.
All those challenges have become even more serious and pressing since 24 February. Now, with climate-change growing ever more dangerous, a military superpower launching a massive invasion of Europe and seizing control of a huge percentage of the world’s food supplies, we really can’t go on acting as if building large market homes on huge greenfield sites is a political and economic priority.
Having got those reminders out of the way for the umpteenth time in the last decade, let’s look at the LPDF report.
Right from the start it makes clear it aims at: “unpacking some of the data on brownfield land availability from local authority prepared brownfield registers to help shape a better understanding of this important policy area”.
Sadly, council brownfield registers aren’t going to give anyone a comprehensive understanding of brownfield availability. It’s all downhill from there.
From its imposition in 2012, the NPPF began to seriously undermine brownfield house building and the total houses built, despite the greenfield bonanza it handed developers, began to climb only slowly. But it took a couple of years for HM Treasury, which had seized control of English planning policy, to realise its fantasy that building huge numbers of houses would solve Britain’s economic ups and downs was actually being hurt by the damage it had done to brownfield construction.
From 2014 onwards, the Government examined a series of measures of varying credibility which were supposed to increase brownfield house building. The Housing and Planning Act of 2016 required councils to publish and maintain brownfield registers and further measures were included in a 2017 white paper. The upshot was a cumbersome brownfield register scheme and other measures which, though some were welcome in themselves, didn’t do very much for brownfield development.
A series of CPRE reports identified that many sites were being left off the registers and, although things have gradually improved, it still concluded last year that the amount of land on registers was not exhaustive. Despite this, it concluded the registers included land which could accommodate up to 1.3 million homes.
The LPDF report sets about attacking the idea that brownfield land in England could accommodate the 4.5 million homes it claims England needs over the next 15 years (presumably based on extending the Government’s flaky 300,000/y target, itself based on thin air, to the long-term).
Yet although the Federation agrees the registers are: “lacking in the comprehensiveness, accuracy and detail to make effective policy decisions”, it still uses their data to claim there’s inadequate capacity to build all the Government’s fantasy house building targets.
“To answer the question: ‘is there enough brownfield land to justify a brownfield only approach to development’, we have considered a suite of questions,” says the report.
No-one has actually said there should be no greenfield building of course, so this is a straw-man argument. What we want is to ensure suitable brownfield sites are used before greenfield which are almost always far less sustainable, as was the case until 2012.
Inevitably the report’s first question – whether there’s “enough” brownfield land – is answered in the negative.
No, there isn’t enough brownfield land on incomplete registers to meet impossibly high house building targets, especially at the ultra-low densities developers find most profitable. Who knew?
Its second question, whether the land is in the “right” places is again answered in the negative.
As you might expect, it argues that most land is needed in the South East and South West and it isn’t at all impressed by the Government’s ideas on levelling-up.
“Attempts to direct new housing to brownfield sites in more affordable regions will not address the availability of housing – including affordable housing – in the housing markets of the South East and South West where many communities struggle to attract and retain young families,” it says. “Brownfield land in different areas of the country may also require different development models and policy support.”
Whether developers’ preferred model – building large, market homes at low-densities on car-dependent, greenfield sites – would do much to address availability, particularly availability of genuinely affordable homes, is not an issue it covers of course.
Its third question – what types of home might be built on brownfield sites – reveals some interesting perspectives on this.
It’s interesting that the report cites the Building Better, Building Beautiful Commission’s belief that “’small flats in big blocks’ (on brownfield sites) are an example of ‘the wrong development in the wrong place’”.
The right home and the right place, it says – rightly indeed! – should be a matter of planning judgement. But anyone with long memories of the era of brownfield-first and (fairly undemanding) residential density standards will remember that developers responded to those policies on brownfield-sites with what were called “rabbit-hutch flats”. Now, there’s a need for small flats as part of the mix, but the reason developers did this wasn’t because of planning judgement, but commercial pressures assumed primacy over it.
Whether local planning authorities in the 2000s could have stood up to Whitehall’s pressure to build as many homes as possible, coupled with the building industry’s commercial imperatives, is extremely doubtful. Given that some of them would surely have wanted to do so, we can discount this possibility. The rabbit-hutch flat response to sustainable building policies came from the industry.
Certainly, people at the time pointed out there were ways of achieving higher densities without high-rise or tiny flats. Our Victorian and Edwardian forebears produced wonderfully functional cities at pretty high densities using terraces and mansion blocks. There was nothing to stop the industry building these on brownfield sites but, by and large, they haven’t, even given the huge power they’ve been handed over the past 10 years.
“We use a threshold of 100dph to estimate whether a development proposed on the brownfield register is likely to be mainly houses (densities of up to 100dph) or more likely to be mainly flats or apartments (over 100dph),” says the report.
Given the industry’s penchant for building flats on brownfield sites at relatively low densities and its desire to build houses anywhere at even lower densities, this is plainly misleading. Throughout the years of (fairly feeble, <30dph net) residential density standards abolished in 2010 (let alone at any density approaching 100dph), the industry managed to ignore the standard on greenfield sites. But it’s not quite as misleading as what it concludes from this.
Using its 100dph standard, it claims 48% of homes on proposed register sites would be flats, though only 17% of households currently live in flats.
“This suggests the brownfield land capacity is associated with a form of development that is not aligned to current demand,” is its bizarre claim. “Effectively, there is a ratio of one apartment on the brownfield register for every six households likely to live in apartments but one house for every 27 households likely to live in houses. At a national level, the latest English Housing Survey found that just 19% of the existing housing stock is made up by purpose-built flats This suggests the type of home coming through the brownfield registers is much more likely to be an apartment or flat than for the current market.”
This is just worng. It suggests everyone can live in the kind of property – apartment or house – that they choose. If that’s so, can I have an 18-bedroom mansion please? With an income to match of course.
“The capacity of land on the brownfield register is expected to deliver many sites at high densities, leaving little space for new family homes with gardens,” it says and concludes there is: “a mismatch between the type of homes that can be delivered on brownfield sites compared with household needs and demands in their respective market areas.”
So, could people with the power to change this – say, land promoters and developers – deliver what people are “demanding”? Or, in reality, should the main issue be that of need rather than demand? And the principal need has little to do with what is most profitable, which is currently the real driver of what gets built.
Thus the Federation’s fourth question – whether the brownfield sites are viable for development – shows pretty clearly what the fundamental concern is. “Viability” here pretty much means profitability, and not the profitability understood by small firms struggling to keep their heads above water, but the 20% guaranteed rate-of-return volume house builders demand to get out of bed.
The report actually makes clear this is really the main concern.
“Place-making investment – to create an environment where people will want to live – is often a significant cost,” it moans. “The recent extra challenge of achieving biodiversity net gain [BNG] also provides an extra variable for brownfield urban sites in comparison to greenfield sites where calculations are typically more straightforward.”
It even complains the “economics of remediation” could change over the next 10 years due to BNG, but it’s an ill-wind: “Some of these sites may become unviable for housing but could be suitable for biodiversity off-setting providing net gains for urban areas (e.g. new urban parks and nature reserves). This not only changes the equation about ‘what is developable’ but also changes the risk and cost profile for potential development. All of this tends to mean that, on a cost per square metre basis, brownfield development will typically cost more to build than on greenfield sites.”
So, as well as offering dubious benefits but lots of greenwash on greenfield sites, BNG could be used to silence us irritating folks advocating brownfield-first. And that would mean an even higher percentage of development could be forced on to the much more profitable, sorry “viable”, greenfield sites.
This leads the Federation to a conclusion which we’ve been trying to tell the world for years.
“All of this tends to mean that, on a cost per square metre basis, brownfield development will typically cost more to build than on greenfield sites,” it admits.
And so, what do these hard-pressed philanthropists need?
“Certain locations have strong markets where viability challenges are likely to be overcome, but in other locations, even small abnormal costs can render a scheme unviable without targeted government support.”
Translating this into English, it’s effectively saying that it should be allowed to build wherever it wants, and if the state or local authorities demand it concentrate its developments somewhere less profitable but more sustainable, the Government should stump up the difference. Which, indeed, the Housing Infrastructure Fund has done to some extent. (Four billion quid, if you’re interested.)
The report goes on with some predictable stuff complaining that “viability” is a greater risk in areas where demand is lower (who knew?) and it complains there are parts of the country where brownfield land is available but no commercial developer wants to build on them (again, who knew?). In such areas, it says, sites may not be “deliverable” (another NPPF boondoggle).
It even produces a map of “viability risk” around England’s local authorities. And whaddya know?
“The spatial pattern… is clear as to where viability is a greater risk. This pattern correlates with where there are larger amounts of brownfield land on the register when measured relative to local housing need.”
Let’s translate that: “Brownfield development is less profitable”.
So, what’s to be done?
Here there’s a bit of a conundrum for the Federation. It admits that, to meet the 300,000/y fantasy housing target, no source of land can be off the table. Despite this it suggests that prioritising brownfield sites for housing rather than employment should be treated with caution.
“To effectively transform the current register into a useful resource it needs to learn from the past history of the National Land Use Database (NLUD),” it says.
Well we can certainly agree with that. When NLUD showed the disastrous increase in the percentage of greenfield building land post-NPPF, it was abolished.
The report rightly calls for improvement of the data on brownfield registers, yet its call comes despite the fact it’s been using these inadequate registers as the basis for its attack on brownfield development. Perhaps such improvement could include sites which don’t make it on to registers?
So here we are, more than 10 years after brownfield-first was abolished, with land promoters and developers frantically trying to find ways of keeping it from coming back.
Or if it does, they want subsidy. Lots of it.
“The re-orientation of housing policy, and Homes England efforts towards brownfield regeneration may help support the conditions where viable and developable land can come forward, but many of these sites will also require grants to unlock them, at greater expense to the taxpayer,” it says.
Eye-watering profits have been made by the industry over the 20 years since HM Treasury got into its head that the ups and downs of the UK economy could be solved by building towards fantasy targets and creating vast unsustainable areas of greenfield sprawl. To this end, many billions of public money have been stuffed down the industry’s neck.
With a major recession looming, the industry will do what it’s always allowed to do, namely stop building and secure land at lower prices, to await the next boom.
If instead, the Government stopped listening to this self-interested pleading, stopped extending greenfield planning consent ad infinitum, stopped bunging money down the industry’s throat and addressed itself to the serious issues of housing need and levelling-up, how much better run this country would be.