Confused by Green Belt Rules?

Many consider the Green Belt to be the greatest and most successful planning reform since the end of WW2.
With a new National Planning Policy Framework to digest, are we on the verge of losing what's left of our green space, or is this fake news?
We try to dissect the latest policy and ask, can we come up with a sustainable solution in time?

Established in 1938 to prevent uncontrolled urban sprawl, the capital’s Green Belt has grown to cover an area three times larger than London itself and represents 31% of England’s total Green Belt area. The government attaches great importance to Green Belts and as landscape architects, if your project sits within such a landscape designation, understanding the policy framework within which the Green Belt sits is crucial. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open.

The Green Belt serves five purposes:
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;
e) To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

Exceptions to the Rule

The UK government promises to protect the Green Belt and the National Policy Planning Framework (NPPF) states that the boundaries of this zone should only be challenged ‘where exceptional circumstances are fully evidenced and justified.’ The phrase exceptional circumstances can feel very vague and so it is understandable that developers and environmentalists alike can feel nervous when new frameworks are put in place.

Of course, altering the boundaries can also mean expanding the protection zone! In 2022-2023 10 local authorities increased the Belt by 870 hectares (0.1% increase). Ten hectares were lost however due to a rise in the high-water mark.

It is important to remember that exceptions to development on the Green Belt are not new. The previous NPPF (2023) and the 2024 edition agree in part on the list of exceptions (see table below), and that previously developed land should be the primary focus for approved Green Belt development which includes brownfield sites.

Source: www.gov.uk

Source: adapted by R-LA from NPPF 2023/2024

1.5 Million New Homes
Labour has pledged to build 1.5 million homes over the next five years which is around 300,000 new homes a year. As a guide, data in March 2023 recorded 234,397 houses built within the previous tax year. With such ambitious targets, a degree of planning reform can hardly be a surprise. The Conservatives had set equally high projections and both NPPF 2023 and NPPF 2024 agree that if a council is failing to meet affordable housing targets, this too is an acceptable exception to the Green Belt rules.

However, the 2024 Framework has introduced a colour hierarchy (green, brown, grey) to Green Belt land and it delves into the affordable housing caveat more than the previous policy which is perhaps the biggest change that people are concerned about.

“Where it is necessary to release Green Belt land for development, plans should give priority to previously developed land, then consider grey belt which is not previously developed, and then other Green Belt locations.”

According to the NPPF 2024, brownfield sites come under the previously developed land banner (see glossary below). In 2024, Knight Frank released a report which identified 11,205 brownfield sites within the existing Green Belt. The report predicted that within these 13,500 hectares approximately 200,000 new homes could be built but that is not nearly enough to reach targets. A BBC report has demonstrated the challenging targets that have been set by Labour on local councils and it makes for interesting reading.

The current government defines ‘grey’ as land in the Green Belt comprising previously developed land and/or any other land that does not strongly contribute to the unrestricted sprawl of large built up areas, nor prevent neighbouring towns from merging or that doesn't preserve the setting and special character of historic towns.

Source: BBC 9th January 2025

The New Golden Rules

The latest NPPF has introduced three final conditions to allow development on the existing Green Belt and these are called the Golden Rules (see table) . If the housing proposal complies with the golden rules then it ‘should be given significant weight in favour of the grant of permission.’

Note, the percentage of affordable housing includes small print that states that the cap is 50% unless this would make the development of these sites unviable. This would suggest that ultimately the amount of affordable housing is at the discretion of the planning officer in charge at the local level.

Source: adapted by R-LA from NPPF 2024

Grey Belt

At a council meeting on 12th February 2025, the councillors from Erewash Borough Council approved plans for Bloor Homes to build 259 houses on the Derby Green Belt despite more than 550 people opposing the plans. The proposal had previously been dubbed inappropriate and is now considered to fall under the 'grey belt' policy, providing a degree of affordable housing and a 15m buffer zone from nearby ancient woodland. The council's head of planning stated that the proposal was self contained and would not lead to the merging of towns.

James Beverley, on behalf of Bloor Homes, said the development would provide 10 per cent affordable housing on the site (26 houses) along with giving the council £5.5 million to build further homes elsewhere in the borough; more than £1 million for highway improvements; £1.6 million for school places; £258,000 for healthcare facilities and £47,000 for bus stops.

Councillors approved the plans by a vote of seven in favour to five against.

Source: Bloor Homes propose 259 homes on the Derby Green Belt

Notes: The National Planning Policy Framework (NPPF) was first published on 27 March 2012 and updated on 24 July 2018, 19 February 2019, 20 July 2021, 5 September 2023, 19 December 2023 and 12 December 2024. This sets out the government’s planning policies for England and how these are expected to be applied.

GLOSSARY ACCORDING TO NPPF 2024:

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/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in paragraph 143. ‘Grey belt’ excludes land where the application of the policies relating to the areas or assets in footnote 7 (other than Green Belt) would provide a strong reason for refusing or restricting development.
Brownfield land: See Previously developed land.
Previously developed land: Land which has been lawfully developed and is or was occupied by a permanent structure and any fixed surface infrastructure associated with it, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed). It also includes land comprising large areas of fixed surface infrastructure such as large areas of hardstanding which have been lawfully developed. Previously developed land excludes: land that is or was last occupied by agricultural or forestry buildings; land that has been developed for minerals extraction or waste disposal by landfill, where provision for restoration has been made through development management procedures; land in built-up areas such as residential gardens, parks, recreation grounds and allotments; and land that was previously developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape.

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