Greg Clark tonight on C4 news debating with Ben Plowden of the NT said that it did include a ‘bropwnfield first’ policy. Which puzzled us in the past, such as on Newsnight, because nowhere does the NPPF give any policy relevance to ‘previously developed land’ and the impact assessment quite expressly says this policy is being dropped (page 49)
A rigid focus on brownfield development over other sites has contributed to a rise in land prices by focussing development on previously developed sites even where more sustainable options may be available. This is demonstrated by the land value differentials between brownfield and greenfield land (highlighted below). This has led to a focus on higher density developments and has potentially constrained growth in some areas…Government wants to move away from a prescriptive designation of land towards a concept of “developable” land where local areas decide the most suitable locations for housing growth based on their local circumstances….brownfielddevelopments often involve greater risk and uncertainty and are generally more complex
than greenfield development….
It goes on to say the government is “removing the national priority for brownfield development” And that one of the benefits is that “regulation can constrain city growth, such as in the form of greenfield development”.
there is a risk that derelict urban sites could be left undeveloped in favour of greenfield land, where there are lower remedial costs. However, these sites can be used for other uses such as economic uses including industry and retail, as well as leisure and community uses…[and] there is a risk that by removing the target and the priority for brownfield development, Government may be seen to be encouraging development on greenfield land.
Lets look at paragraph that he quoted (165) as meaning that Brownfield sites should be developed first.
Plans should allocate land with the least environmental or amenity value where practical, having regard to other policies in the Framework including the presumption in favour of sustainable development.
Three things, firstly it needs to be read in conjunction with a following para 167 – which narrowly defines which land is considered of value – and excludes 54% of the UK
Secondly it only applies to plan making not development management decisions. With 95% of plans likely to be out of date when the NPPF is agreed para 165 wont apply.
Finally para 110 says that in these circumstances applications ‘should be approved’ no ifs, no buts, no consideration of alternative ‘brownfield first’ sites.
What is outrageous is the minister claiming a policy was being kept when the impact assessment says it is being dropped. It is clear his spad was desperately casting around the document to find something top throw into the debat. One hopes that the NT issues a rebuttal press release (nicely of course).