The phrase ‘brownfield passport’ sounds like a policy for difficult urban plots: former depots, obsolete employment land and small sites caught between existing buildings, but its potential use is much broader.
By turning suitable development from a question to be argued into a presumption to be rebutted, the idea could change how we view well-connected land on a whole variety of sites.
That matters particularly for BTR, which needs sites with enough scale to support professional management, amenities and a balanced mix of homes. A rules-based approach could widen the field to sustainable settlement-edge locations that have often been treated as politically difficult even where their planning merits are strong.
From urban exception to locational rule: The policy journey is revealing. The December 2024 National Planning Policy Framework required suitable brownfield development within settlements to be approved unless substantial harm would result.
The Government’s brownfield passport working paper then explored clearer parameters for the principle, scale and form of development, so that proposals meeting them would start with a straightforward ‘yes’.
The draft NPPF now goes further. Policy S4 supports development in principle within settlements as a whole, subject to specified exceptions. Policy S5 remains more selective outside settlements, but supports development meeting an evidenced unmet need where it is well related to an existing settlement and housing or mixed-use schemes around stations with a high level of connectivity. Together with minimum density expectations, the proposed default ‘yes’ around well-connected stations turns a brownfield initiative into a broader locational rule.
Rather than being an invitation to build indiscriminately across the countryside, the revised NPPF seeks to prevent unsustainable growth and protect land with environmental or landscape value. Furthermore, it suggests that rather than starting by asking whether a site sits inside an historic line on a plan, decision-makers would give more weight to whether a site is accessible, connected and capable of becoming part of a coherent place.
Why certainty matters to BTR: For BTR developers and investors, that shift is commercially significant. Real Estate:UK research found that BTR supplied 8% of the 210,000 new homes delivered in Great Britain in 2025. Yet applications for BTR schemes can take 14 months outside London and average 15 months in the capital. The average scheme in planning now contains 295 homes.
These projects require land, capital and an operating model to be aligned over a long period. A prolonged argument about the principle of development affects acquisition terms, funding assumptions and the point at which an operator can commit. Clearer national policy will not remove every planning risk, but it can prevent time and money being spent proving that housing belongs in a location that is plainly sustainable.
The limitations of a brownfield-only strategy are also well established. The National Audit Office notes that suitable land can remain undeveloped because remediation, infrastructure or fragmented ownership makes it insufficiently profitable or attractive. The Government’s dataset lists 37,844 brownfield sites while warning that coverage remains incomplete. A register identifies land; it does not make that land viable.
The settlement-edge opportunity
Well-chosen settlement-edge sites can offer what the BTR market increasingly needs: land for family houses as well as apartments, coherent phasing, space for landscape and play and access to schools, shops and transport.
They may have simpler ground conditions and fewer abnormal costs than a constrained urban site. They can also support mixed-tenure delivery, with BTR providing an additional source of demand rather than competing solely with homes for sale.
This is especially relevant as BTR houses spread into new markets. Real Estate:UK Q1 2026 analysis shows that the sector has 36,146 houses completed or in its development pipeline, and BTR is present in the residential pipelines of 220 local authorities. Settlement-edge schemes can add a form of rental supply that city-centre apartment models cannot provide: professionally managed homes for households that need more bedrooms, gardens and longer-term roots in a community.
But schemes will still need to qualify for the presumption. I would expect the strongest proposals to show that a site completes a settlement rather than merely adjoining it. That means credible walking and cycling links, a transport strategy that does not depend entirely on the car, a clear relationship with existing streets and services and infrastructure timed to support occupation. BTR’s long-term ownership model can strengthen that case through consistent estate management, maintained public realm and an operator with a continuing interest in how the place functions.
The practical task begins before the final policy is adopted. Developers should test settlement boundaries, station accessibility, landscape capacity and infrastructure constraints now. Local authorities should be precise about what ‘well related’ and ‘well connected’ mean locally. Ambiguity will simply move the argument into applications and appeals.
The brownfield passport may prove most valuable not as a special permit for old industrial land, but as the origin of a more rational planning default. For BTR, the opportunity is to identify settlement-edge sites that can meet that test and assemble the planning, design and operational evidence needed to bring them forward.
