As we’ve touched upon in our previous blog posts, the new NPPF has shaken up the property industry by steering the planning system in a ‘development-positive’ direction, with a more flexible approach to tackling the housing crisis. As part of this monumental shift in planning policy, the new Labour government has gone where no other policy has gone before…you guessed it…dabbled with the ‘Green Belt’!
The Green Belt has been around since the very early days of planning legislation (since 1947!) and the policy itself hasn’t changed much since. That is until last year when the new NPPF was published and introduced a new term…drum roll please…the ‘Grey Belt!
In a nutshell, new guidance on the Grey Belt represents a once in a generation shift in planning policy which arises from the Government’s acknowledgment that there is insufficient brownfield land to meet development needs and responds to calls to look to poorly performing Green Belt sites.
The formal definition on ‘what is the Grey Belt?’ is set out below:
‘land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of the purposes (a), (b), or (d) in paragraph 143. ‘Grey belt’ excludes land where the application of the policies relating to the areas of assets in footnote 7 (other than Green Belt) would provide a strong reason for refusing or restricting development.’
However what does this mean in plain English? Let’s break it down…
Firstly, it is split into two parts: plan-making and decision-taking. The former being relevant to LPAs and the latter to the rest of us.
For plan-making, the approach is (relatively) simple; LPAs have to turn to releasing Grey Belt land first, before releasing Green Belt land.
For decision taking, it gets more complex! Hurrah! If the site can be demonstrated to meet the definition of Grey Belt as outlined above, then the scheme is no longer classed as what is termed “inappropriate development” in the Green Belt… I.e. the scheme is now appropriate development. This means that there may be no need for something called “very special circumstances” and there is no strong reason for refusal under Green Belt policy in line with the tilted balance as laid out in NPPF Paragraph 11(d). Put simply, effectively the balance now tips in favour of development.
Despite this, and unsurprisingly, application of the ‘Grey Belt’ has been…let’s say, a ‘grey area’ since its recent emergence into the realms of planning policy.. However do not fear! Further clarity has been provided in the Planning Policy Guidance (PPG) on the new Grey Belt which was published in February 2025. Here’s a breakdown of our key takeaways:
- The PPG holds the same legal status as the National Planning Policy Framework…so, it’s important!
- When assessing a sites Grey Belt potential, the focus is on the ‘site’ and its contribution to Green Belt purposes – not a wider parcel or area…a big shake-up that will make many Green Belt assessments outdated across the country.
- Not all undeveloped land contributes towards checking unrestricted sprawl, and sprawl is therefore not the same thing as development…in effect, if you have a ‘physical barrier’ (think rivers, roads, woodlands) between your site and the rest of the Green Belt, you are unlikely to contribute towards “unrestricted sprawl”
- The PPG clarifies that Green Belt policies targets the merging of towns, not villages, therefore invalidating previous Green Belt reviews which treat villages similarly (again, another big shake-up!)
- Development deemed “not inappropriate” on Grey Belt or previously developed land, isn’t harmful to the Green Belt and you get out of having to do a “very special circumstances” test.
To add to the list of changes to Green Belt policy, the NPPF sets out that where Green Belt land is released for development through plan making or review, certain “Golden Rules” should apply. These are set out below!
Crucially, when determining planning applications, LPA’s must give significant weight (yes, you heard that right!) in favour of permissions where a development complies with the Golden Rules.
Whilst further policy guidance is eagerly awaited, these changes demonstrate a huge potential for the release of a vast number of sites for development, offering a positive approach to assist in meeting the Government’s target of 1.5 million new homes.
Need help navigating these changes? Our team of planning consultants can guide you through the new Grey Belt legislation, ensuring your project has the best chance of success.
Get in touch with us today on 01344 508048 or email office@etplanning.co.uk to discuss your planning strategy.
