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Brownfield priorities for a new Government

The Conservative election manifesto promised to prioritize brownfield development in England. We asked leading figures what the new Government’s priorities for brownfield policy should be.

British Land Reclamation Society chair Andy Moffat

Future policy which relates to brownfield land should recognize both the opportunities and risks this type of land presents.

In an urban context, brownfield land often occupies significant space amidst other development, and thus provides opportunity to inject new life into the built environment.

On even moderately sized sites, this should now include space for green infrastructure and for sustainable drainage. Brownfield land development should therefore be considered in a rigorous spatial planning context, taking account of the needs of, and prospects for, enhancing the community and neighbourhood as well as providing new housing.

Brownfield policy should support high standards of development commensurate with modern interpretation of the sustainable development principle.

Brownfield regeneration must be both forward looking, whilst fully engaging with existing local community views.

The risk of chemical contamination in brownfield land is, however, significant, especially if previously used for industry.

Current legislation and regulation relating to the identification and treatment of contaminated land, particularly Part 2A of the Environmental Protection Act 1990, is inadequate and should be thoroughly revised.

Planning authorities also require more support so that they can exercise their responsibilities effectively.

The land reclamation sector has made a real contribution to the regeneration of urban landscapes and communities over many decades.

It has evolved to embrace the wide range of professions involved in regeneration and there is almost certainly a greater understanding of technical opportunities in the private rather than public sector.

Central and local government should thus provide greater leadership in promoting land reclamation. They should continue to support organisations such as the Land Trust in order that cleaned-up brownfield land is managed well after reclamation.

Campaign to Protect Rural England planning campaign manager Paul Miner

CPRE will be pressing the new Government to implement three key pledges that appeared in the Conservative manifesto: (i) to prioritize brownfield development, (ii) to protect the green belt and (iii) to require local authorities to have a register of available brownfield land.

CPRE believes that the National Planning Policy Framework will need to be changed quickly if the Conservative pledges on brownfield development and the green belt are to be realised.

Since the NPPF came into force in 2012, developers have too often been allowed to build what they like, where they like.

In places such as North East Lincolnshire and Salford, local policies to prioritise brownfield sites have been overruled by planning inspectors. Conversely, in Leeds and Newcastle, little or nothing has been done to rein in local authorities that have been keen to promote large scale releases of green belt even when plenty of brownfield sites are available.

The commitment to introduce a brownfield register indicates that the proposals consulted on in early 2015, in direct response to CPRE’s 2014 From Wasted Space to Living Spaces report, will be enacted. This is welcome.

But for a register to be successful, the Government needs to call on local authorities to provide information on an annual basis and in a consistent format.

Also, brownfield land with obstacles to development such as contamination should be identified, as well as easily developable sites.

A final area to watch will be the controversial pledge to extend the Right to Buy policy to housing association tenants.

The proceeds will be used to create a new £1bn brownfield fund.

CPRE welcomes more funding for bringing brownfield sites forward, but a key issue is whether sufficient affordable housing will be delivered to replace the homes lost in Right to Buy sales.

Chartered Institute of Environmental Health principal policy officer Howard Price

Environmental health professionals have long been involved in regeneration and it’s only natural that the CIEH believes in “brownfield first”.

It makes sense in so many ways – in making use of existing infrastructure, replacing eyesores and dereliction, showing confidence in local people and services and minimising transport needs.

In fact, it’s such common sense that minimising calls on previously undeveloped land is almost just a bonus.

It doesn’t, of course, mean “brownfield always”; brownfield sites aren’t all the same and may not be suitable for particular reuses, nor will they necessarily be in the right places.

Sometimes they will have an overriding value left undeveloped; nevertheless we think there should be good reasons not to redevelop them, and to do so preferentially and, in principle, support the application of a sequential test.

On the face of it, so does the new Government, yet things may not be all they seem; house builders’ share prices didn’t jump on the election result for nothing

Such a process needs to be genuine, and ultimately for the public good in pursuit of a more rounded understanding of sustainable development than we enjoy now.

That means it must not be set up to fail by an over-restrictive definition of “brownfield” and contaminated sites (of which there will be many) should not be excluded, in particular when other avenues to bring them back into use have been shut off.

If public subsidy is needed to remediate them, so be it, but that should come from a more realistic and equitable source than the sale of council houses.

If surplus public land must be seized by new land commissions – though better would be a renewed trust in planning - there is no reason why fallow private land should not be thrown into the mix too and local authorities must retain full control over standards in any event.

Environmental Industries Commission executive director Matthew Farrow

The Conservative manifesto was light on environmental pledges – air quality, for example was dismissed with a throw-away line about “doing even more”.

But one green issue did make a more meaningful appearance – a commitment to boost house building on brownfield sites with a £1bn fund to match.

This is welcome but, given it’s been estimated we will need to find an additional 7m hectares of useable land to meet future housing and food needs, we need a much more comprehensive brownfield strategy.

This must start with promotion of contaminated land or brownfield sites as a resource rather than a problem so recognition that clean-up is good not just for the environment but releases more building land.

This then ties into a more general “brownfield first” approach.

Fiscal incentives also need revisiting. Existing incentives such as Land Remediation Relief need to be extended, by raising the rate of relief and/or widening the eligibility.

There is also a case for targeted incentives for the more deprived areas of northern towns and cities.

In general we need smart planning and development objectives and legislation, driving development where it is needed rather than where developers can make more profit by reducing risk.

For example planning incentives to promote house building of smaller units in urban areas where people need to live to access jobs with reduced travel - this will undoubtedly mean the reuse of more brownfield sites.

Skills also matter - the construction sector quality programme (“right card for the job”) should be supported and training and qualification programmes already in place promoted. 

A last issue, not exclusive to brownfield but important nonetheless, is radon – where Public Health England’s work on radon awareness and management programme needs a boost. 

Environmental Protection UK Land Quality Committee chair David Rudland

EPUK is supportive of proposals to prioritise the development of brownfield land if it helps reduce greenfield sprawl and accelerates the management of the contamination sometimes associated with brownfield sites.

We note that the new Conservative manifesto has proposed that brownfield land would be used “as much as possible”.
The Conservatives have pledged to build 200,000 starter homes on brownfield land.

One of the temptations of having housing targets is to squeeze in as many homes as possible on a given parcel of land without any attempt at creating a sense of place.

It wasn’t long ago that housing densities were the obsession – near where I live is a new housing estate nearing completion but begun in the mid-2000s.

It is noticeable how every public space is occupied by parked cars, there is no place for refuse bins which have to live in front of houses, and weeds abound, growing between the sections of ubiquitous block paving.

Even after a short space of time the place is looking neglected and tatty. Perhaps all development master planners should be made to revisit their creations after five years and again after 10 to see how they have fared and learn from this.

The drive to provide additional housing must be mindful of the wider impacts on the environment such as deterioration in air quality through increased road vehicles, waste disposal/recycling and demands on scarce natural resources like water.

We note that some brownfield sites are contaminated and there will be instances where land condition is so poor that considerable work will be needed to bring these sites into a condition where development is feasible.

The amount of up-front investment is considerable and without a readily available programme of public funding for this aspect it’s hard to see how these sites will move forward.

Planning Officers’ Society president David Evans

Making the most effective use of previously developed land which is not of high environmental value is a core principle of national planning policy.

The Planning Officers' Society, which is the voice of public sector planners, believes that this is best achieved through local planning authorities working with their local communities in preparing local plans and determining planning applications.

This locally determined place shaping work is key to the creation of successful mixed use communities properly integrated into the locality with the necessary infrastructure.

This includes providing not just homes but also local jobs, community facilities, affordable housing, transport facilities and greenspace.

As Greg Clark said in November 2011: “When people know that they will get proper support to cope with the demands of new development, when they have a proper say over what new homes will look like and when they can influence where those homes go, they have reasons to say ‘yes to growth’”.

The Society is concerned that the proposals to introduce local development orders to relax planning controls at a national level will by-pass local community involvement and undermine the creation of sustainable mixed use places.

The Society believes that decisions on whether or not a LDO is an appropriate solution should be taken locally through the democratic process following community engagement.

The Government's desire to speed up the delivery of affordable housing is welcomed but the Society believes that local community based decision making is the right way forward.

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