Insight

Grey Belt: Just adding colour to the debate or meaningful change

18.8.24 3 Minute Read

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As a planner who believes in the real benefit to good spatial planning I have been long upset in the way the Green Belt has been used as a political tool to win (or not lose) votes and pander to those whose default position is "just say no" when it comes to development.

The Green Belt has lost its role as a well-executed strategic planning tool that can underpin sound decisions around sustainability and placemaking. 

So, is Labours' suggested tweak to the NPPF another change to gain political support and win over certain votes? Maybe, but they certainly get my vote when it comes to being pragmatic about the Green Belt. 

While the mantra of the general public is "you can't concrete over the Green Belt", it is shown time and again that the public are unclear on what the Green Belt is, what is special about it, and when it performs a useful function. Agreed, it has taken decades of polices, appeals and court decisions for even the most earnest planner to be confident for what 'openness' really means. It was vital for Labour to grasp the 'Green Belt nettle' and update guidance for the greater good of development.  

So what is Labour proposing? Here are the headlines:  

Green Belt and housing need – No longer can Planning Authorities hide behind their Green Belt when it comes to delivering housing need through their Local Plans.  Once non-Green Belt sites are optimised, Planning Authorities have to look into their Green Belt to deliver their housing needs ‘in full’, unless doing so would fundamentally undermine the function of the Green Belt ‘across the area of the Plan as a whole’.  A high bar indeed!  This will be impactful to achieve housing delivery in lagging Green Belt authorities where the Green Belt has been used as an excuse to avoid delivering much needed housing.   

Green Belt brownfield land -The restrictive limit for development on previously developed Green Belt land to have no greater impact on the openness of the Green Belt has gone and replaced with a policy bar to not cause ‘substantial harm’ to the openness of the Green Belt.  A helpful shift so that development sites can deliver more good development. 

Green Belt fundamentals – When Green Belt land is released or permitted for development it should deliver against new para 155; 50% affordable housing, necessary infrastructure and green spaces accessible to the public. 

Grey belt – The promised concept of grey belt has been set out.  It is set to open up some Green Belt sites that lay idle under the current blanket Green Belt protection, but subject to ‘para 155’ compliance.  We have a definition of grey belt: 

For the purposes of plan-making and decision-making, ‘grey belt’ is defined as land in the green belt comprising Previously Developed Land and any other parcels and/or areas of Green Belt land that make a limited contribution to the five Green Belt purposes (as defined in para 140 of this Framework), but excluding those areas or assets of particular importance listed in footnote 7 of this Framework (other than land designated as Green Belt). (My emphasis.  This will be argued over for what really is a ‘limited contribution’, so it be great for the NPPG to help define this further set against the manner in which Green Belt assessments are already undertaken)  

‘Appropriate Development’ – A major move for development on grey belt land in sustainable locations to be 'appropriate' Green Belt development, which would mean no titled-balance acting against the development and no need for those Very Special Circumstances. Subject to there being a five year supply deficit or housing delivery test failure if a housing scheme and if there is a ‘demonstrable need for land of regional, national or local importance’ for any form of development, plus meeting the new para 155. (Another policy test that will be argued about).   

The protection for the Green Belt is set to decrease, but not in a blanket 'anything goes' way

Any Green Belt land to be developed would have to be previously developed or grey belt (a parcel of Green Belt land that is assessed to perform a limited function).   

So, is this political tinkering or meaningful change?  I say it is a purposeful and meaningful change for two great reasons. 

Firstly, this sends a big message that there is a welcome shift in the culture of development and delivery.  Land of limited function, in the right location, should be used to deliver good, beneficial, high-quality development. 

Secondly, it could deliver some very helpful numbers to get closer to actually meeting the national annual housing target.  There are 177 Local Authorities with Green Belt within their jurisdiction; on average an Authority would have 36.4% Green Belt coverage, which in total equates to 1,638,420 Ha of Green Belt land in England, set against a total land coverage of 13,046,230 Ha; so 12.6% Green Belt. 

Let's say 1% of the Green Belt could be Grey Belt.  From my experience a conservative number,  1% equals 16,384 Ha, if it was all used for housing at a moderate 30 dwellings per hectare then 491,500 homes could be achieved.  If 2% of the Green Belt land was grey belt and we pushed to 40 dwellings per hectare then we could have 1,310,700 homes.  Yes there are lots of assumptions in there, but it gives a good indication that this could be a meaningful policy.
 

Final Thought 

A proposed shift in Green Belt policy is so very welcome.  Many Green Belt sites are prime for the most sustainable developments if pragmatic and positive planning can take place.  So well done to Labour for taking this difficult issue head on.  I for one am a fan. 

There will be a raft of concerned groups that will rally against this move.  It is incumbent on us all to voice our support to this policy shift and push away from any emotive suggestion of 'concreting over the Green Belt', but rather 'delivering much-needed new homes and development of the highest quality on land that has been assessed to provide no worthwhile Green Belt function'.   

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Guy Kaddish

Partner, Planning

Guy is head of one of the largest planning teams in Cambridge, and planning representative in our science and technology leaders group.

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