Comment

What next for Green Belt and grey belt: implications of the NPPF

Until the updated NPPF of December 2024, Green Belt policy had hardly changed in decades. It could now be changing twice in a year. This in itself is a sign of Government intent in relation to growth and development.

The introduction of “grey belt” was a significant change. We considered its first year impact here. The draft revised NPPF proposes further changes. This latest in our NPPF series considers the potential implications in practice.

Tilting the balance

Green Belt boundaries are a product of a balance between meeting society’s need for development and protecting undeveloped land. Over the decades, when tweaks were made to Green Belt policy, and there have been relatively few, they tended to tilt in favour of maintaining the Green Belt. In the 2023 version of NPPF this explicitly applied even where it meant development needs would go unmet.

This Government has clearly signalled a different approach. In support of its ambitions for higher economic growth and 1.5 million homes this Parliament, it is purposefully tilting the balance back towards development.

How is policy proposing to do this?

Where previously the real purpose of Green Belt had become obfuscated with imagery of bucolic countryside and rich landscapes, the new approach is evidence based. The 2024 changes introduced requirements to assess the different characteristics and purpose of Green Belt.

The new approach is predicated on the fact that not all Green Belt performs equally in relation to Green Belt purposes. The intention is to identify parts of it that could most readily accommodate sustainable development. The 2024 NPPF identifies purposes a) “Check the unrestricted sprawl of large built-up areas”; b) “Prevent the merging of neighbouring towns”; and d) “Preserve the setting and special character of historic towns” as being the most influential in identifying what some have termed "low quality" Green Belt – or grey belt.

The proposed changes take this evidence-based approach a step further. One of the tasks of new Spatial Development Strategies (SDS) will be to set out a positive vision for the growth of an area. Draft NPPF proposes that this be "informed by an assessment of the strategic role of Green Belt land within the strategy area" (GB2.1). This strategic assessment will consider all five Green Belt purposes from a strategic perspective. This will mean considering the original rationale for the designation of Green Belt and the extent to which it remains. It is a welcome acknowledgement that the strategic purpose(s) of the Green Belt differ across the country.

For example, where the Green Belt around a conurbation was necessary to encourage urban regeneration, we need to consider to what extent remaining urban land can meet future development need. If Green Belt was to prevent separate towns from merging, we need to be clear on the towns (and not villages) to which this applies and identify the land that is most important to that purpose. Where Green Belt was to protect the countryside, we need to identify ways to meet development needs while maintaining the benefits of, and access to, genuine countryside.

Green Belt Assessments to support an SDS can be expected to be very different from those that support local plans. They will take a helicopter view of Green Belt across much larger spatial areas.

SDS are to use the findings of these strategic Green Belt assessments to "help develop their spatial strategy" (GB2.2). This is a more positive approach to Green Belt than one which regards its coverage as a reason to constrain growth or divert it elsewhere.

SDS spatial strategy will identify where Green Belt boundaries "require further consideration through the local plan process". So Green Belt assessments to support local plans will have a clear strategic steer on broad locations where Green Belt boundary changes will be needed. Importantly this will be undertaken in the context of the SDS positive vision and spatial strategy for an area which will include the relevant apportionment of development needs and strategic environmental protections.

Assessment at local plan level will include the identification of grey belt. At plan-making stage this will be focussed within the broad locations that can most effectively support and enable strategic growth objectives. NPPF incorporates advice on Green Belt assessment (Annex E) which helpfully includes policy on undertaking assessments at a suitably granular scale to identify all grey belt land. This further emphasises the positive intent of the new approach.

The cumulative effect of the recent and proposed changes is to restore Green Belt to the status of important spatial planning consideration and reduce the risk of "protection" being seen as an end in itself.

What about in practice?

In a plan-led world where an up-to-date SDS presents a shared, compelling vision for investment and growth, and local plans translate these into place-specific proposals and policies, the proposed approach seems eminently logical and achievable.

We are, however, some way from a plan-led world. While there has been a noticeable up-tick in plan-making activity over the past couple of years, adopted coverage remains at around only one third. Past Green Belt policy effectively trumped development needs. Grey belt signalled a significant change and the draft NPPF takes this further.

The introduction of grey belt opened a route, particularly for housing, but for other development in the Green Belt for which there is an unmet need, to the additional presumption in favour of sustainable development (the so called "tilted balance"). Draft NPPF proposes to extend this presumption, in the case of land around well-served train stations in the Green Belt, without the requirement to demonstrate an unmet need (GB7.1h).

This, along with "brownfield passports" was a well-trailed further tilt of the balance towards development. It is confirmation, if it was needed, that the new planning system is firmly intended to be plan-led but that much needed growth and investment should not be held up by the absence of an up-to-date plan.

There is now, enshrined in national policy, both a clear incentive for local planning authorities to expedite positive and up to date plans that meet their identified development needs; and to the development industry to make its full contribution to delivering economic growth and boost to housebuilding.

What else has changed in respect of Green Belt?

Close analysis shows that, beyond the significant changes above, the draft NPPF incorporates most of the contents of current Green Belt policy (albeit in different order and wording). For completeness it is worth noting a few exceptions:

1. The definition of grey belt is proposed to exclude reference to the so called “footnote 7” list of most protected sites. As the consultation document makes clear this is a clarification of intent rather than policy change. Likely in response to differing application of current policy, it clarifies that protections are not relevant to whether or not land is grey belt but will remain important considerations in whether development of that grey belt should be approved.
2. Consistent with the dropping of the Duty to Co-operate there is no longer an explicit requirement for a plan-maker to discuss with its neighbours the potential to meet needs in non-Green Belt areas (currently NPPF paragraph 147c). It is hard to see this making much difference in practice.
3. There is a helpful and explicit caution against seeking to use Green Belt to achieve what other policies should address – for example to protect the character of an existing village (GB41c). 
4. Reinstating the requirement (which was paragraph 147 from NPPF 2023) when releasing land from the Green Belt to consider compensatory improvements to the environmental quality and accessibility of the remaining Green Belt. This seemed an odd omission at the time and its reinstatement reflects what has generally become good practice.
5. Making explicit that plans should set out how Green Belt can contribute to the priorities of relevant Local Nature Recovery Strategies (GB5.1.6) and extending the "Golden Rules" policy in relation to green space for housing development to show that such green space will make a positive landscape contribution and support nature recovery.
6. Addition of "electricity network and water infrastructure" among the categories potentially "not appropriate" development in the Green Belt (GB7.1f iii). This is helpful confirmation and supportive of the need for investment in renewable and low carbon electricity and the increasing desperate need for enhanced water treatment and storage facilities.
7. Removal of the requirement that appropriate facilities for outdoor sport and recreation "preserve” the openness of the Green Belt (which is currently in NPPF 154b). This had proved a confusing test in practice and its omission is helpful.
8. Making explicit the limited circumstances in which the viability of Green Belt development can be reconsidered. These are previously developed land; multi-phase strategic sites; and types of development not tested in a plan level viability assessment. This is the corollary of proposed policy GB4.1e which requires that sites being released for housing through Green Belt boundary change should demonstrate that they can meet the Golden Rules. 

Concluding thoughts

The proposed changes build on the Government’s revised approach to Green Belt. It could be said that whereas, in the recent past at least, the presence of Green Belt could constrain growth, it is now to be seen as a spatial tool to guide growth to the most suitable locations. This is a welcome return to some of the original intent of Green Belts.

Critics will argue it is an attack on countryside and disincentive to re-use brownfield sites. Perhaps anticipating this, the drafting is careful to strengthen the presumption of approval on brownfield sites and provide clear incentives for up-to-date local plans that meet development needs. Grey belt, in particular, is a targeted way to ensure that the mere presence of a Green Belt boundary that may have been drawn many decades in the past, does not determine the ability of this and future generations to meet their need for new homes, new workspaces and better infrastructure. An authority with a positive plan to meet its development needs will have no reason to fear “speculative” applications on grey belt.

For our part, we welcome the proposed modernising of Green Belt policy and look forward to engaging in strategic reviews to support SDS and local scale identification of grey belt opportunities.

For more information on grey belt, please contact Dave Trimingham.

9 January 2026