Grey Area: What is the New Grey Belt?

If you’ve never encountered the phrase Grey Belt before, we attempt to explain it – along with other definitions of land designation such as Green Belt, Greenfield and Brownfield…

The Newly Assigned Grey Belt

If you read last month’s blog, you might be wondering where the term ‘Grey Belt’ came from. If you’ve not encountered it before, you’re not the only one! It’s a very new term, coined by the new Labour government – and one of a number of targeted changes concerning the Green Belt listed in the proposed 2024 revision of the National Planning Policy Framework (NPPF).

The Grey Belt concept has been suggested in an attempt to bridge the gap between the requirement for more housing, and the restrictions on available land that could be built on.

When deputy prime minister Angela Rayner outlined changes to the NPPF, in a bid to help the government achieve its housing target of 1.5 million homes over the next parliament, it included a requirement for local authorities to review their Green Belt, if needed, to meet housing targets and prioritise local quality Grey Belt land, ie, land with high sustainable development potential.

Freeing up some Green Belt land, by redefining it as Grey Belt is part of the plan. So what is Grey Belt land? In essence, it’s land that doesn’t really contribute to the purpose of Green Belt, and so far has been described as:

• Previously-developed land (PDL) within the Green Belt, and
• Green Belt parcels that contribute minimally to its five primary purposes, excluding environmentally valuable lands or those of significant importance, such as national parks and sites of special scientific interest (SSSI).

The final definition has yet to be made concrete, as the government seeks the views of those involved with planning and development, amongst others, to assess if more criteria need to be added. We will see that in the revised National Planning Policy Framework, due at the end of this year, or beginning of 2025.

However, within the planning industry, it is said that this is just the first step towards rethinking the purpose of the Green Belt and the restrictions on development. As far as we know, though, Grey Belt land will not become a free-for-all but will still be subject to restrictions and hurdles when it comes to development.

Some Grey Belt development might happen where a new local plan cannot identify sufficient non-Green Belt land to deliver sufficient homes to meet identified need, in those cases Grey Belt sites should be prioritised. It is also believed that councils that are not delivering on housing supply, or that have out-of-date local plans, will have more pressure on them to approve housing development on Grey Belt land. That means that either they have delivered less than 75% of the new homes they should have over the previous three years (the ‘Housing Delivery Test’), or they don’t have enough deliverable housing sites available to meet their needs for the next five years.

As a result, the CPRE (the countryside charity) is concerned that “developers will see these changes as a green light to proceed with big new speculative development proposals for lots of market-based or ‘executive homes’ in inappropriate locations in the countryside such as prime agricultural land and highly valued local landscape.” CPRE Hertfordshire 12/9/24.

However, the government is fanfaring its ‘golden rules’ that must be met by developments to secure planning permission, as a way to justify its proposal and allay some fears:

1. At least half of the new homes should be affordable housing,
2. Infrastructure – like roads, schools and healthcare provision – should be improved where necessary, and
3. New residents should be able to easily walk to a good quality green space – which could mean providing a new one or upgrading an existing space.

Land Designations

While we’re here, let’s take a look at the other designations of land when it comes to planning:

Green Belt

Green Belt is land protected from most development apart from government-stated exceptions. This land tends to be around the metropolitan towns and cities – the most famous being that around London – however, Green Belt land exists in the north too. There are five purposes although the most well-known is to prevent the coalescence of settlements – cities creeping out into the surrounding villages and countryside. In all, the National Planning Policy states the five purposes are:

1. to check the unrestricted sprawl of large built-up areas,
2. to prevent neighbouring towns merging into one another,
3. to assist in safeguarding the countryside from encroachment,
4. to preserve the setting and special character of historic towns, and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

However, many of those who work in the planning world believe that its original purpose needs serious review, especially when you consider that it came into effect about 80 years ago (1947 Town and Country Planning Act) and has been followed by huge population growth and a continuing demand for housing, employment and so on.

Greenfield Land

Not to be confused with Green Belt, is Greenfield land. This is typically undeveloped land and can be found inside and beyond urban locations. It’s more often referred to as the ‘countryside’. However, it can also relate to amenity land within urban areas. Those who wish to develop Greenfield land will still have hurdles to overcome, but they’ll be different from those encountered when trying to build on Green Belt land.

Brownfield Land

Brownfield is also known as ‘previously developed land’ meaning just that, it’s land that has been developed upon. It may still be in active use, or it could be vacant or derelict. Brownfield is where governments in general have wanted developers to focus on, before they look at other kinds of sites. This will remain the case irrespective of the potential introduction of Grey Belt land.

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