Select Committee on Environmental Audit Twelfth Report

5  Where should new homes be built?

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

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