Greenfield
versus brownfield development
57. The Government has set a target for at least
60% of new housing to be built on brownfield land. This has so
far been very successful, with around 75% of new housing currently
being built on brownfield sites. The Prime Minister confirmed
in May that: "The vast majority of housing built in the past
few years has been built on brownfield land, and that is how we
intend to continue."[90]
The memo we received from Defra and CLG conceded that, as the
pressure to deliver greater numbers of new homes increased, it
would be more difficult to maintain this proportion of brownfield
development:
With an increasing level of new house building, there
may be increasing pressure to bring forward some suitable greenfield
sites for housing, although PPS3 has maintained the national target
of at least 60% on brownfield land. Local planning authorities
should take a strategic view and develop brownfield wherever possible,
but recognising that other land may be more appropriate for development
at a particular time.[91]
58. Witnesses differed on how much remaining
capacity there was on brownfield sites for new housing. The Environment
Agency told us that:
Government has ambitious plans to build three million
new homes by 2020. Its policy is to direct this development towards
brownfield land, but the current stock is about 66,000ha, enough
for about one million homes. Furthermore, much of this land is
unsuitable for development as many sites lie within the floodplain,
and/or are important for wildlife and recreation. […] This
means that more development will have to take place on greenfield
sites in the future.[92]
Jane Forshaw, of English Partnerships, stressed that
the Environment Agency were overestimating the number of homes
that could be accommodated on brownfield land, meaning that even
more would need to be built on greenfield land:
[…] when you heard the Agency speak earlier
they were quoting the figure of possibly up to one million homes
on brownfield. That does not take account of the many filters
you might need to apply to a brownfield site, and indeed some
of that land from where they are taking the figure is actually
in use and it is called "latent brownfield". So it might
be that the local authority in classifying it as a brownfield
has a more ambitious outcome for it. So it might be a scrap yard
at the moment—it is functioning, it is recycling metal—but
the local authority might want it to be housing. So those figures
reflect a different picture. The more realistic figure, based
on EP's calculations, would be something closer to 360,000 homes
possible on the brownfield land bank at the moment […][93]
But Kate Gordon of CPRE took issue with English Partnerships'
figure:
My understanding is that the 360,000 figure refers
to the land that is vacant and available now, but it does not
include land which is in use. When you start including land that
is in use and also land which needs some remediation, the figure
goes up substantially and, to us, it just does not make sense
to exclude the land that is in use. […] We are also aware
that […] a lot of local authorities do not send information
on sites smaller than 0.25 hectares […] so we would say that
that 360,000 figure is way too low. We are pretty confident that
there is brownfield land which has been identified now capable
of accommodating around one million homes and, if you factor in
the small sites, the sites that do not get identified and picked
up, then that figure rises substantially.[94]
We recommend the Government clarifies
how much capacity it has identified on brownfield land for new
homes, and whether its target for 60% of new housing to be built
on brownfield land will be applied to the 3 million new homes
to be built by 2020.
59. Aside from how much brownfield land is available,
another issue we considered was to what extent it is always desirable
to prioritise brownfield land over greenfield land for development.
We received several memos that stressed that "greenfield"
and "brownfield" designations were often quite crude,
and that the environmental qualities of each could vary enormously.
Natural England, for example, argued that some brownfield sites
were very high in biodiversity, while some greenfield sites, especially
if they had been subject to industrial agriculture, could be low
in biodiversity. But this argument was in turn criticised by RSPB,
who argued that the biodiversity of much greenfield land could
be improved by changes to agricultural practices, while biodiversity
on brownfield land was equally important but for different species.
They concluded that in neither case should the need to improve
the biodiversity of an area be used to justify building new houses
on it.[95]
60. Irrespective of the environmental qualities
of land classified as greenfield and brownfield, building additional
homes on sites within existing communities should minimise the
environmental impacts of new housing developments, simply by reducing
the need for new infrastructure and private and commercial road
journeys. We therefore welcome the good performance in bettering
the Government target for prioritising brownfield sites for new
housing. However, we are concerned that this will be reversed
as the brownfield sites that are more easily developed become
more scarce. Indeed, a number of witnesses expressed concern that
the pressure from central government to make land available would
lead to greenfield development at the expense of urban brownfield
development, and that this would lead to "the twin problem
of greenfield sprawl and urban decline".[96]
61. We are also concerned that existing planning
policy (PPS3) provides councils with no adequate means of defending
green spaces against development as the previous 'sequential test'
introduced by this Government has been removed and councils are
expected to demonstrate five years' supply of housing 'available
now' on brownfield sites in contrast to developers who can call
on virtually limitless supplies of greenfield and green belt land.
Once released for development, however, this land will be lost
forever.
62. Given existing planning
policy, we are concerned that by continuing to impose high national
house-building targets and regional plans during a market downturn,
the effect of Government policy is to make it impossible for local
authorities to prevent planning permission being granted for development
on land that is not currently needed and that would not otherwise
be granted. Presented with an excess of available land, it is
likely developers will build new developments on greenfield sites
in preference to developing brownfield sites within the boundaries
of existing settlements. We recommend that Government ensures
this does not happen by revising urgently its targets and regional
plans in the light of current market conditions, and by reintroducing
a clear sequential test in favour of brownfield sites into planning
policy.
63. According to the Empty Homes Agency, the
focus on building new homes is overlooking the potential for vacant
buildings to provide up to 1.2 million new homes across the UK.[97]
We recommend that the Government
investigates the potential for the redevelopment of vacant buildings
to provide new homes, with an emphasis on examining how many homes
this could provide, and what savings in environmental impacts
this would lead to over building the same number of new homes.
64. In our last report on housing,
we expressed concern "that current rates of VAT are heavily
stacked in favour of demolition, as opposed to refurbishment",
and recommended that HM Treasury revises the current VAT rules
concerning both new build and refurbished homes built to high
environmental standards. We recommend that the Government renews
its efforts at overcoming the obstacles to reforming VAT in this
way.[98]
Green belt reviews
65. The green belt plays a key role in encouraging
development to take place within the boundaries of existing settlements,
which can thus reduce the environmental impacts associated with
new housing. The Government has consistently maintained its commitment
to protecting the green belt.[99]
But national house-building targets have led to pressures on local
authorities to weaken protection of the green belt, in order to
find land for the extra developments. CPRE told us:
Regional planning bodies and local planning authorities
face growing pressure from Ministers and government regional offices
to review Green Belt boundaries […] We are concerned by growing
evidence which suggests that housing demand is being seen as an
'exceptional circumstance' justifying Green Belt boundary reviews.
CPRE is aware of at least 37 separate reviews either currently
in progress or envisaged in draft regional plans across the country.
[…] In these and most cases, the main reason for the reviews
is to accommodate increased levels of housing development.[100]
66. The Housing Minister stressed to us that
it was "only in exceptional circumstances that green belt
boundaries can be amended through the development plan process
and only after there has been robust public consultation, an independent
examination and the independent examination of the draft proposal."[101]
Indeed, the Government has repeatedly argued that it is the responsibility
of local authorities both to decide on the location of new housing
and to decide on the boundaries of green belt land.[102]
While the decision on green belt boundaries may rest with local
authorities, they are being put under pressure to meet housing
targets set at a national level by central Government; and then
at a local level via regional spatial strategies.[103]
The 2007 Housing Green Paper presented a range of measures designed
to push through planning approvals where councils do not themselves
make enough land available.[104]
The Local Government Association (LGA) said: "local councils
should retain scope to review green belt boundaries and that changes
should not be imposed on them. […] Green belt land should
not be regarded as a potential land bank and should not be subject
to review simply when additional housing is needed."[105]
67. The Housing Minister argued that any encroachments
on green belt land could be "offset by creating green belt
elsewhere".[106]
We would argue, however, that if the point of the green belt is
to contain the development of towns within certain boundaries
and prevent urban sprawl, then it is not only the amount of land
designated as green belt that is important, but crucially where
those specific areas of land are situated. National aggregate
figures for green belt area do not in themselves reveal the extent
to which existing green belt boundaries are being encroached on.
We recommend
that the Government specifies how much existing green belt land
has been lost since 1997, separately from the amount that has
been offset by new green belt land elsewhere, and amends planning
policy and guidance to strengthen the "exceptional"
test and emphasise the importance of protecting and where possible
extending existing green belt boundaries.
90 HC Deb, 14 May 2008, col 1380 Back
91
Ev 87-8 Back
92
Ev 7 Back
93
Q78 Back
94
Q123 Back
95
Ev 131-4 Back
96
Ev 65 Back
97
Ev 57 Back
98
Environmental Audit Committee, Sustainable Housing: A Follow-up
Report, paras 13, 61 Back
99
HC Deb, 5 February 2003, col 275; HC Deb, 11 July 2007, col 1450 Back
100
Ev 65 Back
101
Q203 Back
102
For example, HC Deb, 7 May 2008, col 307WH Back
103
Qq 137-8 Back
104
Cm 7191, p 8 Back
105
Ev 73 Back
106
Q200 Back
