This article was first published in the November edition of the Housebuilder Magazine.
It may be no bad thing that the Government has decided to extend its consultation on changes to the NPPF. My previous article praised the speed with which Labour is setting about planning reform, but it's comforting that no hasty changes will be taken forward without listening to the industry. As former housing secretary Michael Gove has recently accepted, getting the messaging right is key and housing delivery cannot afford any of the 'bad vibes' created by previous tweaks to national policy.
Whilst housing delivery on 'Grey Belt' might be a focus of the current consultation, the Government remains as committed as the previous administration to harnessing the development potential of 'brownfield land'. On 22nd September MHCLG published a paper inviting views on how the planning system could further support development of brownfield sites in urban areas.
The concept of 'Brownfield Passports' is intended to reinforce a brownfield first approach, where the default answer to suitable schemes should be a simple 'Yes'. A passport system could also be combined with the existing (and widely under-utilised) model of Local Development Orders so as to provide upfront consent for qualifying proposals.
When set against an already favourable national policy for brownfield redevelopment this begs the question, why have urban brownfield sites been so challenged by the planning system and what would passports do to resolve that?
Certainty has always been a limiting factor to delivery. If the principle and quantum of development could be de-risked then brownfield sites would be opened up to a wider variety of SME house-builders – as finance should be more readily available. Again, policy messaging is crucial and the Government's proposal is to use national policy to create an even clearer expectation that LPAs should approve development if certain parameters are met. It is recognised that scale, density and height of development are subjective matters to be established at a local level – so LPAs would be responsible for setting those passport parameters through development plan documents - in similar fashion to the use of 'Area Action Plans'. This is however where the speed of local plan-making could deprive the national policy of its momentum.
The immediate benefit of urban sites is their ability to rely upon surrounding social infrastructure and amenities, removing the costly barriers of funding enabling development, such as highway schemes. However, the Government is not indicating that passport sites will be given any preferential treatment in terms of CIL and planning obligations, so negotiation of viability could be another delaying factor. Hopefully, the thrust of a national policy would empower LPAs to support schemes of a sufficient scale and density so as to avoid protracted planning gain negotiations - but there will always be a planning balance to be struck to ensure that the benefits of housing are not outweighed by the harm of tall buildings, even if 'upzoning' is the message.
