The Environmental Industries Commission is urging government to increase the number of houses built on brownfield to 80%. Toby Uppington reports.
Towards a National Brownfield Strategy is the title of a 2003 report by English Partnerships, the UK government's key regeneration agency. The document assesses brownfield regeneration policy, including the reuse of all previously developed land, and recommends changes.
A key feature is EP's requirement to develop and maintain a national brownfield strategy. This will include a best practice guide on the assembly, remediation and development of land and buildings.
Lobby group the Environmental Industries Commission (EIC) fully supports the broad objectives of the strategy. However, to provide a voice from the remediation industry on how to achieve them, EIC's contaminated land remediation group is developing its own brownfield strategy.
EP used government statistics from the National Land Use Database to assess the UK's progress with respect to the regeneration of previously developed land, including contaminated and derelict sites.
The report highlights several weaknesses in the data and assesses trends within the regeneration field.
The target set in the Sustainable Development Strategy, for 60% of new dwellings to be built on previously developed land, has already been exceeded.
EIC published its own report, Driving Regeneration: A Report on the National Brownfield Strategy, at the end of May (GE news in brief June 05). To meet the objectives of the national brownfield strategy, the EIC suggests that continued impetus for the redevelopment of previously developed land is required and that the 60% development target should be revised upwards to 80%.
Uncertainty (perceived and/ or real) in both time and cost is the major obstacle to brownfield redevelopment. The challenge to government is to reduce this uncertainty, providing confidence to potential investors and developers.
The EIC notes that ongoing uncertainty with regards to waste regulation and classification only hinders remediation opportunities, as does the lack of clearly defined clean-up criteria. On top of this, continuing changes to legislation cloud the market's perception of environmental requirements. The issue of contaminated land liability needs to be resolved to increase investor con'dence.
Historic data suggests a 'at rate of brownfield redevelopment. While there are incentives for reuse of previously developed land, these are not well understood or inter-related and the associated requirements to qualify may discourage uptake.
In the UK there is no standard approach to the availability of assistance or to the processing of funding applications. EIC suggests a number of changes to market influences, including disincentives for greenfield developments or for the long-term retention of derelict sites.
National policy initiatives seeking to increase the uptake of previously developed land cannot be made in isolation, but must incorporate the legislation, infrastructure, dynamics and market conditions of the entire regime. The full chain of events, costs and risks must be considered together.
It is noted that the planning authority is obliged to involve a number of statutory consultees, but that these parties may not have any common guidance. The creation of uniform, clear and reliable guidance or published precedent on critical policy issues that affect cost would be a valuable step forward.
Government policy to develop a national brownfield strategy should focus on simplifying the planning regime and legislation to provide incentives for brown'eld regeneration. The strategy should be of use not only to the development community and environmental practitioners, but should also support the decision makers in the process.
By smoothing and standardising the planning requirements for brownfield redevelopment and promoting greater understanding of these requirements, the government should be able to increase the uptake of brownfield land.
The transfer of responsibility for the identification of contaminated land to local councils under Part IIA of the Environment Protection Act is not fulfilling its potential as a driver for redevelopment. It needs much greater enforcement muscle and the technical guidance required to support the regime is developing far too slowly.
One of the key problems identified by EP is the legacy of 'hardcore' sites that remain difficult to develop.
The EIC suggests up-front funding of site classification and planning studies to provide developers with greater certainty for the opportunities associated with these challenging properties. The intention of the strategy should be to limit the at-risk costs that are required to be paid up front and provide a framework for risk management of the development process.
The large number of complex, changing regulatory controls associated with the management of brownfield land and wastes present a significant challenge to redevelopment.
Better coordination with regionally standardised implementation of licensing, classification and approvals is required to increase housing built on brownfield. The national strategy should address uncertainty in time to release planning conditions and remediation costs to achieve this goal.
Toby Uppington is principal consultant, URS Corporation and a member of the EIC's contaminated land remediation group.