To help achieve their goal of delivering 1.5m new home over the next five years, Labour have announced plans to make it easier to build on poorer quality parts of the green belt – areas they’re calling “grey belt.”
To understand what grey belt means, we first need to understand the green belt.
Established in the 1950s, green belt is a planning designation given to areas of land surrounding our towns and cities that is expressly designed to stop their outward growth. The green belt has expanded significantly since it was first introduced. Today, it covers almost 13% of England – around twice the area that is actually developed.
It has been very successful in restricting development. The amount of building in green belt areas is 80% lower than it would otherwise have been. And that has an impact on house prices – they’re 20% higher as a result, with prices around 4% higher across England as a whole. The green belt therefore makes a key contribution to our housing crisis – something which Labour have recognised.
Although there is a popular image of the green belt as being beautiful, green countryside full of wildlife, much of it isn’t. The designation has nothing to do with landscape or ecological quality – it is just about limiting growth. In fact, much of the green belt is already developed – with petrol stations and car parks, storage yards and farm buildings, for example – or is underused wasteland.
The government plan to let homes be built on some of those poorer quality areas of land. In their words, “we don’t think it is right that wastelands and old car parks located on the green belt are given the same protections in national policy as rolling hills and nature spots in the green belt.”
Prior to the general election, Labour politicians described the grey belt as “poor-quality scrub land, mothballed on the outskirts of towns” and “poor-quality and ugly areas.” That might be helpful to explain the concept, but it is also a little vague.
Now in government, Labour have set out a more detailed definition in their proposed update to the National Planning Policy Framework. It tells us that the "grey belt" is:
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
What does that mean in practice?
"Previously Developed Land" is the planning jargon for what most of us refer to as brownfield land.
Although those sites can be redeveloped under current rules, that is subject to the green belt being no less “open” after the new development is completed. In practice, that means new buildings have to be of a similar size and in similar locations to those they replace - preventing sites being redeveloped to their maximum potential. For example, if a site is occupied by a small industrial unit surrounded by a large parking area, the new buildings could be no bigger than the building itself – the area used for parking would need to be left free of new buildings.
By including those sites in the definition of grey belt, existing brownfield sites in the green belt can be redeveloped more intensively.
In planning terms, however, not every site with buildings on it counts as brownfield – many uses are excluded. For example, agricultural buildings like barns and chicken sheds aren't brownfield. While a garden centre is considered to be brownfield, a plant nursery isn't. Including uses like these in the definition of grey belt would allow development on a greater number of sites, while meeting Labour’s objective of protecting the most attractive, highest quality parts of the green belt - but that isn't part of the proposals so far.
The supporting consultation document tells us that for a site to make a limited contribution to the green belt, it must meet the following criteria:
a) Not strongly perform against any Green Belt purpose; and
b) Have at least one of the following features:
i. Land containing substantial built development or which is fully enclosed by built form
ii. Land which makes no or very little contribution to preventing neighbouring towns from merging into one another
iii. Land which is dominated by urban land uses, including physical developments
iv. Land which contributes little to preserving the setting and special character of historic towns
National planning policy sets out five purposes that the green belt is supposed to achieve. They are:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
Whether a site does not "strongly perform" those purposes - the requirement to be classed as grey belt - is subjective. The best way of making that judgement is likely to be to look at the council's own Green Belt Assessment, carried out when local authorities prepare a new local development plan. The Green Belt Assessment will divide the whole of the green belt into separate parcels and then consider to what extent those parcels contribute to each of the five green belt objectives.
Grey belt sites will be delivered in two different ways.
The first is through the existing local plan process. Every council in England should have a local development plan that identifies, amongst other things, how many homes are to be built over the next 15 years, and where those homes should be located. Delivering enough new homes might not be possible without identifying some areas of the green belt for development and, in those cases, grey belt sites should be prioritised.
It will also be possible to secure planning permission for new homes on grey belt sites which are not already identified for development in a local plan - but only if the council are failing to deliver enough homes. That means that either they have delivered less than 75% of the new homes they should have over the previous three years (the "Housing Delivery Test"), or they don't have enough deliverable housing sites available to meet their needs for the next five years (known as a "five year housing land supply").
In both cases, there are a number of "golden rules" that developments will have to meet if planning permission is to be secured.
The requirements to improve infrastructure and new open spaces aren't really any different to what developments are currently expected to provide. However, the expectation that half of homes will be affordable is significant. Although it is important that affordable housing is provided on all new developments, those homes have to be sold at a large discount to their market value - and often for less than they cost to build. Developers treat that as a cost of development and reduce what they offer to pay to landowners for their sites as a result. If half the homes are to be affordable however, the impact on land values will be dramatic. In many places, development may not be commercially viable at all.
The new version of the National Planning Policy Framework is expected to come into force this autumn, following a consultation over the summer. While it is possible that some of the detail to the approach to grey belt could change as a result, but the government's overall intentions are clear.
Whatever that detail, Labour’s willingness to imaginatively re-consider green belt policy is welcomed. Their approach to grey belt has the potential to enable housing development on more sites, and to make an important contribution to increasing the supply of new homes as a result.
The Strategic Land Group has been working with landowners to deliver planning permissions on their land at our cost and risk for more than 15 years. Our fee is a share of the value of the site once it is sold, so if we don’t succeed, it doesn’t cost you anything. Over that time, we’ve seen a whole range of planning policies come and go. We’re used to quickly understanding new policy, and how it can help landowners secure planning permission. If you know of a site which might be suitable for development as “grey belt” land – or for any other reason – please don’t hesitate to get in touch for a free, no obligation consultation.
