In Focus: Grey belt land

The Labour party introduced the concept of grey belt land in 2024 as part of its plan to build 1.5m homes over the next five years. In essence, grey belt land is simply land that sits within the greenbelt and has either been previously developed or doesn’t necessarily contribute towards the core purposes of the greenbelt, and as such, could be built on. Grey belt land examples given by the government include sites such as land on the edge of existing settlements, or rurally located former petrol stations/ car parks etc.

As a reminder, the five key purposes of green belt designation are:

1. to prevent 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
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

All of which ultimately align with one key purpose: preventing urban sprawl. What this has meant in practice though, is that it has historically been very difficult to obtain planning permission within the green belt, even for necessary and sustainable development. Not least because planning within a green belt area can be a very contentious issue, and local planning authorities have generally erred on the side of caution, taking the stance that by allowing planning proposals within the green belt, they would be giving permission for development contrary to the purpose of the designation and therefore by extension, national planning policy.

As such, it was becoming increasingly obvious that something had to be done to reintroduce some common sense into the equation.

When the National Planning Policy Framework (NPPF) was last updated in December 2024, and larger housing targets were given to more than 200 local authorities, it was agreed that councils could (and should) review their greenbelt boundaries in order to help meet these new housing targets. As part of this green belt review, some new ‘golden rules’ for proposals within the green belt were introduced, all with a view to facilitating the increased targets for housebuilding , whilst still having regard to the green belt and the government’s anti-urban-sprawl stance.

The golden rules are for local authorities to enforce and police, but it is worthwhile for both landowners and developers to have knowledge and due regard to them as well. The golden rules for new developments within the greenbelt are:

• Brownfield sites should be developed first
• Grey belt sites can then be looked at in the absence of any developable brownfield sites – Local Planning Authority (LPA’s) should identify and prioritise lower quality grey belt land too
• Affordable homes (more social rented accommodation should be required within new developments)
• Boost public services and infrastructure (developers to provide any necessary ancillary infrastructure such as transport links alongside new housing developments)
• Improve genuine green spaces

With local planning authorities potentially reviewing their green belt areas (if they haven’t already done so) there may be scope for landowners within the green belt to speak with their land agent or preferred planning professional about possible opportunities – especially if they have some previously developed land, or land on the edge of a settlement that would be perfect for a small rural housing development. Even better if there is a demonstrable need for such development within the locality which has, as yet, remained unmet through previous calls for sites.

Currently, policy fails to consider that landowners may wish to build and manage their own affordable housing projects. Without changes to policy, small sites are not economical to deliver, unless by housing associations who prefer to focus on much larger sites. For this reason, the CLA has continued to lobby for a Rural Exception Site Planning Passport to help local authorities overcome some of the hurdles to delivering rural affordable housing. More information on the planning passport proposal can be found in our Programme for Government missions, available to read and download here.

Knight Frank research looked into how much land could be unlocked for development if all greenbelt land (around 12% of the land in England) were to be reviewed, and its work suggests that there are over 11,000 sites within the greenbelt that have been previously developed and could therefore be re-purposed to provide anywhere between 100,000 and 200,000 new homes (depending on development density). Given that this initial scoping focused solely on previously developed sites, and not potential new sites on the edge of settlements etc, it is obvious to see that the potential of the grey belt is even greater.

Of course, wherever there are opportunities, there are invariably challenges too, and grey belt development is no different. At present we do not know how consistent different planning authorities will be in understanding and utilising the new grey belt policies, there is scope for some authorities to see the opportunities and take them, whilst other authorities may remain staunchly protective of green belt areas, preferring instead to continue focussing on developing sites already identified within their Strategic Housing Land Availability Assessments (SHLAAs).

Moreover, there will still be all the usual planning hurdles (and costs) to overcome – highways, drainage, environmental assessments, surveys and mitigation will still be required. Objections from neighbours and local communities, overall site viability and economies of scale will still need to be carefully considered when planning any new small to medium sized developments and necessary (in some cases mandatory) consideration given to affordable/ social housing too.

It is also worth remembering that even in green belt areas, permitted development rights may apply (unless otherwise curtailed due to national landscape or conservation areas). Meaning, if you do have an agricultural barn, or old industrial unit on the edge of a settlement that is ripe for redevelopment, it might be worth looking at what is achievable via permitted development before you get carried away envisioning the site being cleared to make way for a new housing development.

Your regional CLA office is ready to help, either by helping you to understand if your site may fall within the new ‘grey belt’ definition, or by recommending professionals in your area to help you scope out the future potential of any sites you have in mind, so do reach out and give them a call.