Grey Belt: Updated National Planning Practice Guidance

As Firstplan previously reported in December 2024, the latest iteration of the National Planning Policy Framework (‘NPPF’) (also published in December 2024) sets out a series of changes to Green Belt planning policy.  Whilst the Green Belt designation still stands as one of the strictest land use designations, the updated NPPF introduced the identification of ‘Grey Belt’ land, which may offer stakeholders further scope for developing sites in the Green Belt. The Government have given £70,000 to 133 local planning authorities to progress reviews of their Green Belt, chiefly to re-assess allocated land and interestingly to identify Grey Belt sites.

As a recap, ‘Grey Belt’ is defined in the NPPF as: ‘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 purposes (a), (b), or (d) (as set out in paragraph 143)’.   In short, these purposes seek (a) to check unrestricted sprawl, (b) to prevent the merging of towns and (d) to preserve the setting of historic towns.  Notably, land covered by key designations, such as national landscapes and SSSIs, is excluded from the Grey Belt.

Developing in the Green Belt is notoriously challenging and as such, the introduction of Grey Belt could offer meaningful avenues for rural sites to potentially be brought forward for development.  However, since its introduction, the application of Grey Belt in planning applications and appeals has not been consistent leading to varying local authority and appeal decisions.

At the end of last month, the Government updated the National Planning Practice Guidance (NPPG) in respect to the assessment and application of Grey Belt policy. The updated guidance can be considered to still leave considerable space for varying interpretation; however, a number of themes which can be identified are:

• Assessment of the ‘Specific Site’ – the updated NPPG now clarifies that assessment of how strong contributions to purposes (a), (b) or (d) (definition of Grey Belt test) is specifically relating to the application site, and not the wider parcel of land.

• Better Definition of ‘Sprawl’ – the updated NPPG states that sprawl is ‘ungainly, awkward or untidy’ – i.e. if developed, the site would result in an incongruous pattern of development. However, if the site has physical features (such as planting, topography, roads and rivers), then this could be seen to restrict and contain development (i.e. it could be seen as helpful in preventing unrestricted sprawl).

• Clarifying the role of ‘Villages’ – the updated NPPG now clarifies that villages should not be considered ‘large built-up areas’.  In addition, villages should not be considered the same as towns.  Therefore, when Green Belt policy refers to preventing neighbouring towns from merging into one another (purpose (b)) and preserving the setting of historic towns (purpose (d)), the NPPG clarifies that this should not be applied to villages.

• Better Definition of ‘Merging Towns’ – the updated NPPG now clarifies that if a site is just positioned between two towns, then it does not ‘strongly’ serve purpose (b). Moreover, to strongly contribute to purpose (b), a site must be considered to form a substantial part of the gap between towns, and even then, the key matter is visual separation, i.e. the perception of towns merging.

The above summary identifies some of the key updates to the NPPG in respect of Green Belt policy and the application of the Grey Belt assessment of land.  Whilst this guidance doesn’t open the floodgates for rural development, it nonetheless should provide some further direction to local authorities in assessing potential Grey Belt sites, as well as assisting applicants in navigating the complexities of development potential in the Green Belt. We hope this should lead to greater understanding of Grey Belt across the industry and more consistency in decision making and determination of whether a site is within the definition of Grey Belt land.

Should you wish to discuss any aspect of the developing in the Green Belt, then please feel free to reach out to one of the Firstplan team, and we’d be happy to advise further.

Article prepared by: Tom Roberts, Darcey Morse & Gerard Manley | Please contact the Firstplan team at info@firstplan.co.uk.