On the same day that The Gracechurch Group published its review of the potential of brownfield land, the Campaign for the Protection of Rural England (“CPRE”) published, ‘Unlocking potential – Best Practice for Brownfield Land Registers’.
Unlike the Gracechurch brownfield report, the CPRE’s document is not focused on the amount of brownfield land available vs. demand for housing, but concerns itself with the idea of the brownfield registers and how they could be improved. To paraphrase the central conclusion, it is that the registers are a promising idea but need more effort put into them to make them really useful. We agree.
At the same time the CPRE put out a press release claiming that the brownfield registers were missing land for 189,000 homes. This had us scratching our heads, but the CPRE’s arithmetic goes as follows:
1. The budget announced consultation on a target of 20% of all new homes being built on small sites. Small sites were not defined in the budget and the official budget document does not include any reference to brownfield in connection with small sites – they can be greenfield.
2. The CPRE defines small sites as 10 homes or fewer. The registers exclude sites for 5 homes or fewer.
3. In a CPRE study of 43 brownfield registers, they found that 4,481 homes could be built on small brownfield sites, or 4% of the total number of houses that could be built on brownfield land in the study areas (although as we say in our report, sites for 15 homes or fewer make up over 50% of the total number of sites).
4. The CPRE then go on to speculate that if small sites made up 20% of the total rather than 4% then 24,894 homes could be built on small brownfield sites in the study areas. In our view this is logical sleight of hand, conflating the government’s proposed target to build 20% of homes on small sites with speculation about small sites making up 20% of all brownfield. As we note above small sites does not just mean brownfield and the size of small sites has not been defined by the government.
5. The CPRE has extrapolated from the 43 authorities in its sample to a national picture by multiplying up from 43 regions to 326. Since England is highly regionalised we don’t think this is a useful or accurate way of generating national statistics. However, the CPRE say this gives a total of 188,734 homes that could be built on small brownfield sites. It is wrong to say, as the CPRE does, that an extra 188,734 can be built on small brownfield sites. This is because the CPRE national estimate already records 33,972 of these homes as being on the registers, so that the number of extra homes should have been stated as 154,762.
It is possible that there is more brownfield land suitable for housing than the registers show, and, as noted above, sites suitable for under five homes are not on the registers at present. However, the CPRE analysis would mean that the registers have missed 80% of all small sites, which doesn’t seem likely. Put another way the CPRE’s missing 189,000 homes need 40 square miles of land – net of planning attrition. It’s inconceivable that this could be found from small brownfield plots alone.
One further thing that confuses the numbers is that Ministers have said we need 1 million new homes in total over five years and at the same time the government has said that 20% of housing need must come from small sites – so 200,000 crops up again. But that isn’t how the CPRE got to 200,000 (unless of course the CPRE worked backwards to come up with the number they first thought of).
The CPRE conclude from their analysis that local authorities have been incompetent in compiling the registers and have missed thousands of brownfield sites.
Our conclusion remains that housing need cannot be met from brownfield alone. Regarding the government’s target for small sites, it is our understanding that these include greenfield sites as well as brownfield and that the definition of small sites is more likely to be over 30 or over 50 homes than over 10 – if indeed the government ever spells it out.