Following on from our 2018 blog highlighting the challenges of building homes on small brownfield sites, we thought it would be useful to take another look to see if the situation is any better than it was. Current planning policy promotes urban living, building more densely/higher to achieve the most efficient use of land, and more brownfield development. The NPPF specifically encourages the greater use of small sites to help diversify opportunities for builders and to increase the number of schemes that can be built out quickly. Plus in our neck of the woods, the Bristol Local Plan Review requires 12,000 new homes to be built across the city by 2025, with at least 33,500 by 2035.
So has the challenge of developing smaller brownfield sites got any easier over the past few years? Well, to be honest the short answer, in our experience, is no.
Small brownfield sites are still just as important as the larger sites for delivering homes. And so you’d hope for a relatively smooth application process to get a consent in your hand and spade in the ground quickly. Yet these continue to be some of our most challenging projects. They come with a multitude of developability issues and constraints (which appear to have actually increased), and are often more stressful than our larger schemes.
New permitted development rights since 2018 have enabled the change of use of various land uses and buildings to residential use under the Prior Approval Notification process. However, whilst the issues that need to be addressed as part of these applications are more limited than a full planning application, these can, at times, be just as challenging as a full planning application. But that’s a blog for another day.
Bristol can’t meet its 5 Year Housing Land Supply and so bringing smaller sites forward is vital. If you have a small brownfield site that you think might be suitable for homes then here’s a heads-up on some of the challenges we’ve been up against recently, just so you get an idea of the issues that you will need to consider:
- LPA timescales – due to a perfect storm of Central Government cuts to LPA resources, subsequent staff shortages, pandemic working practices and an increasingly large workload our LPA colleagues are really struggling at the moment. Applications are not being dealt with in statutory time periods, communication is more challenging and onsite visits have been curtailed. As a result of this officer engagement in discussions on smaller sites are being limited and the opportunity to make changes are being limited. We don’t envisage this changing any time soon, so prepare wisely. A pre application process is always worthwhile if the site is considered to be in any way contentious or difficult, this enables you to bottom out as many issues as possible prior to submission of an application. Ensure your application submission is as robust as it can be, check the LPAs validation checklist and comply with it. And remember persistence overcomes resistance, keep on trying to make and maintain contact with your case officer, but always be nice, even in the most difficult of circumstances. It pays off in the long run;
- Principle of development – whilst you would reasonably expect residential development to be acceptable in principle in most urban areas, many sites still host existing uses that can prove hard to displace, even though they are far less compatible e.g historic garages, industrial premises. You might well struggle to justify the loss of these against employment retention policies, so think ahead – check out whether you need to provide marketing evidence to demonstrate local supply/demand for such uses, and get this underway well before submitting your application;
- Density – small urban sites will by their very nature produce tighter, denser development, but this doesn’t automatically mean they are cramped or inappropriate, it just demands more sensitive design. If we’re going to achieve the new housing we all recognise is needed, we need to be imaginative and embrace more concentrated forms of development that will unlock smaller sites. The Local Plan Review for Bristol has identified focal areas for higher density in the city as well as re-introducing minimum densities for development – we’re welcoming these moves and hope to see them translated all the way down to the pocket garden plots;
- Context, Form and Layout – infill or backland sites can often straddle or be bounded by different types and arrangements of housing. In the absence of a strong architectural context (or Conservation Area), we don’t believe there is anything wrong with a well-conceived contemporary scheme, yet we’re often obliged to replicate the existing local vernacular, however inconsistent and lacking in quality. Disappointing, but don’t be deterred – just make sure you fully understand your context and be ready with a robust design rationale, should you choose to go modern. The same goes for layout, we’ve come up against a slavish adherence to building lines that will often sterilise an entire site, and believe there is a case for relaxing such constraints in dense situations unless there is a very strong urban grain or heritage impetus to consider – again, we’re hoping the increased drive for density will encourage LPA’s to take a more relaxed approach to layout and will continue to challenge for pragmatism on these issues;
- Residential Amenity – slotting a further dwelling into an established residential area will inevitably raise issues of amenity, much more challenging than if embarking on a greenfield site. However, these shouldn’t be insurmountable or dictate an instant refusal, but will require some creativity and willingness from both sides – be it the orientation of buildings, clever placing of windows, or the relaxation of privacy distances and daylight standards in some instances. Whilst we’re always striving for the best possible design solution for every site, we also recognise that not all schemes are perfect and that it’s ok for some to be just good enough. If we let one compromised amenity standard stymie an entire development, we’ll never bring enough small sites forward;
- Sustainability – we’re in the midst of a climate emergency, there’s just no getting away from it. It’s up to all of us to play our part in addressing this and small scale residential developments are not immune from having to adapt to this. Whether you like it or not, and we are seeing a more progessive approach from developers on this issue, planning policy requires new development to be highly sustainable, energy efficient, to incorporate renewables technology, to improve accessibility, reduce reliance on the car and improve biodiversity. It might not be cheap in the short term but it’s fundamental for the long term. So ensure a sustainable approach to development is integral from the outset. As a heads up, whilst we are noticing some tension between the use of renewables and the impact on residential amenity, a pragmatic approach and good noise mitigation seems to do the trick;
- Parking – many urban sites need no car parking, there is simply no justification for requiring it. Admittedly we’ve not hit this issue negatively with LPA’s very often (more often it’s our clients who press for it), but it should be a given. If the site isn’t large enough to accommodate parking and is located in a sustainable, well connected area, then standards should be relaxed without justification – it must become intrinsic to the urban living mindset;
- Environmental Constraints – brownfield land can throw up all number of developability issues, and we’ll willingly acknowledge that matters such as contamination and coal mining must be investigated to ensure any future residential development is safe. However, we’ve also encountered a desire to protect absolutely everything on site, irrespective of its environmental or aesthetic value, and this can make life difficult. The retention of garden trees or boundary walls for instance, of possibly limited lifespan or value to the street scene, can compromise the area of developable land available or worse still sterilise a site altogether. We’ll keep pushing for balanced development that keeps these sorts of constraints in check;
- Neighbours – any urban development with near neighbours will inevitably throw-up objections, it’s human nature to resist change. Long-standing residents will have become accustomed to living with the openness of large gardens/underused business yards in their area, and will be reluctant to embrace the loss of these to additional housing. Be prepared for this and do your homework – carry out appropriate pre-application consultations, be mindful and considerate of local concerns, but accept that you won’t garner everyone’s support. Remember, neighbour objections don’t always mean that development is inappropriate, and LPA’s will need to be equally robust on this issue if they are to foster the small site revolution that the NPPF envisages.
Well, if that’s not enough to put you off, we hope it’s braced you for the continued ‘small brownfield site’ challenge. We’ve come out of the application process with some projects feeling like consent has been ‘wrought’ out of the ground – we resolve one issue and another of equal thorniness takes its place. But don’t let that put you off – urban living and brownfield sites are a critical element of the strategy for national housing delivery.