One of the many things coming down the tracks (this time as part of the Housing Bill) is a new requirement for councils to hold a register of brownfield land. This register is hoped to make sites easy to find and build houses on. It will also be used to measure progress towards a new target for councils to have a planning permission or local development order on 90% of these sites by 2020.
What does this mean ?
We don’t know. As is quite often the case we’ve been doing a bit of thinking about how to reduce the burden on councils but without knowing any of the details about how this will work. As you might imagine we’re wondering whether some standards or templates designed at the outset might make everyone’s lives a bit easier.
It is the case that lots of thinking about brownfield sites happens already in councils (as part of the SHLAA and plan monitoring activity) but it’s fair to say it is not done in the spotlight. It is easy to imagine that a public interest in land supply can lead to lots of questions – both of the “how dare you allocate our proposed village green for housing !” and the “can you explain why this plot is *not* suitable for housing because we think it is” variety.
A question I’ve been asking myself is quite how much of a “thing” this is all going to be. It is quite easy to imagine an automated register that monitors land supply and keeps everything up to date. It’s also easy to imagine an A4 folder with bits of paper in it kept on reception and updated by a student once a year. Some places have lots of brownfield, others hardly any. What sort of response do we need ?
A minimal response
The least councils will need to do is
- Ensure they understand and can explain the assessment process for understanding (A) What land is brownfield and (B) Whether it is suitable for housing
- Assess their land using a “call for sites” and by revisiting the sites they already know about through the plan-making process. Let’s call these sites ‘brownfield_housing’ and count them ‘X’
- For the brownfield_housing sites go through the planning registers and see which of them have a consent for housing. Count them ‘Y’
- You now know your measure against target Y/X
- You can now publish your register. Hint: you may want to expose your assessment process or be prepared to answer FOI all day long.
- You now need to think about those sites that do not presently have a permission. Will the market come forward ? Where you judge the market is unlikely to come forward, you need a plan ‘B’. This can range from doing something to make the site more attractive, to meeting the target by applying for permission yourself.
- Next year repeat this process. You will need to understand how to account for the fact that some of the old brownfield has disappeared (because it’s been built on) and some new sites have become available. You will need to track progress using your original baseline.
A more creative approach ?
I think the approach outlined above will deliver the requirement from DCLG. But I can’t help feeling that for a very marginal extra effort we could make something much more interesting and useful. A register of brownfield land is a subset of a very interesting dataset – the pipeline of housing land supply. We (collectively) have done a bad job of explaining how the pipeline works and the factors that act on whether or not consents lead to starts.
And, rather than focusing on the 90% target as if that were the important end of the telescope actually we all have an interest in boosting delivery. On brownfield *and* greenfield. Being a bit geeky, I feel confident that better visibility of the inputs (land, consents) will lead to better understanding of the environment (capital, confidence) and therefore policy interventions will work better.
But, in order to “get going” we need, as a sector, to understand whether we are simply going to comply with whatever is in the housing bill or actually do some quite difficult work exposing land supply and the judgements made by planning authorities. Where might the leadership be on this issue ? I honestly don’t know.