Brownfield Passports: Unlocking the Potential of Urban Land Use

Last week, the Ministry of Housing, Communities & Local Government unveiled a new proposal for planning reform, furthering the government’s commitment to accelerate Britain’s housing development and optimise urban land use. With a target of building 1.5 million homes over the next five years, this initiative could become a key tool in the government’s strategy to boost housing construction.

But what exactly are 'Brownfield Passports,' and how will they work? In short, they aim to simplify and speed up the redevelopment of brownfield sites by defining specific types of developments that would be automatically approved. For suitable projects, the default response would be a straightforward “yes,” cutting through the red tape that often complicates planning.

The Brownfield Passport will likely focus on four critical areas:

  • Principle of Development: The passport would confirm that development on brownfield land within urban areas is acceptable, except in cases with clear issues such as flood risks or lack of access.

  • Scale of Development: Guidelines for the scale of development, including minimum building heights or density requirements in highly accessible locations (e.g., near public transport hubs), would be outlined.

  • Form of Development: To ensure developments fit their surroundings, design codes may require developers to follow specific guidelines for building styles, layouts, or materials that reflect the area's character.

  • Local Development Orders (LDOs): Local authorities could expand the use of LDOs, which provide upfront consent for specific development types across defined areas. This would eliminate the need for individual planning applications, provided developers adhere to the rules set by both the passport and the LDO. Though LDOs already exist, they are underutilised, and the government is keen to enhance their role alongside Brownfield Passports.

By reducing the uncertainty, cost, and timescale for planning, Brownfield Passports aims to fix a key flaw in the current system, where securing planning permission is often one of the riskiest and most time-consuming parts of development.

As urban sprawl is limited by the Green Belt, meeting housing demand will require making the most of brownfield sites before considering further Green Belt expansion. With rental demand already outstripping supply in cities, Brownfield Passports could be a critical tool to meet housing needs. Around 85% of the UK population already lives in urban areas—a figure expected to rise to 90% by 2050, according to UN estimates. With most jobs also concentrated in towns and cities, this proposal comes at a pivotal time, as urban centres struggle to accommodate growing populations.

Brownfield Passports could mirror the success seen with Permitted Development Rights (PDRs), which have empowered SME developers by offering certainty. Between 2015/16 and 2022/23, 102,830 new homes were delivered via PDRs, contributing around 6% of the net additional dwellings in that period, mostly in urban areas. While PDRs focus on converting existing buildings with minimal external changes, Brownfield Passports could unlock more ambitious redevelopment projects, addressing the hesitation that currently stifles urban growth. When developers hesitate to redevelop, valuable land goes underutilised, shrinking the population base for local businesses and reducing access to jobs and services.

The proposal reassures that Brownfield Passports won't give developers carte blanche to build whatever they please. Local authorities will still need to review and approve applications to ensure they meet passport guidelines. However, the government has signalled its intent to encourage urban densification—something the UK currently lags behind on. For instance, no square kilometre in England has more than 25,000 people, while cities like Paris and Barcelona exceed twice that. Even London, by comparison, has significant potential for increased density. While the possible introduction of 'grey belt' designations may unlock low-quality Green Belt land for development, such sites may lack connectivity to jobs and transport. By contrast, urban redevelopment can revitalise local centres and improve connectivity, making the densification of cities a more attractive solution.

Of course, some questions remain. For example, how will different types of brownfield sites—like a disused car park on the outskirts of town versus a vacant shop on a struggling high street—be treated under the passport? While both qualify as brownfields, their contexts are quite different. Another concern is whether developments outside passport criteria could face increased difficulty in gaining approval, potentially stifling creativity and ambition. However, the passport offers the certainty the current system lacks, and developers could still pursue non-passport developments if they accept the greater risk involved.

Ultimately, the most significant shift this proposal brings is a change in mindset. Instead of developers submitting applications and trying to justify approval, the system would flip; developers would be told what types of projects are pre-approved, streamlining the entire process. By removing uncertainty, Brownfield Passports could speed up the delivery of much-needed homes, reduce costs, and make better use of urban infrastructure—a timely solution to the housing crisis that deserves serious consideration.

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