The Latest on Grey Belt Housing Policy
Nearly a year after introducing the term, the Labour party in mid 2024 finally did come up with a definition of a grey belt area. Despite a plan in mind, the grey belt policy has been marred with questions with regards to its viability. In this article, we will attempt to clarify and simplify key updates and policies concerning grey belt areas.
Lately there has been some noise concerning the identification of grey belt areas. The gravity is such that there has been a regular overhaul of the National Planning Policy Framework (NPPF), the first being July 2024, which was followed by another update in December of the same year, and the recent one in February 2025.
The reason for such regular modifications has been the government’s imminent goal of fulfilling its grand plan of constructing 1.5 million homes in the coming 5 years. To achieve this humongous task, the government has planned to utilise grey belt areas to consider them for housing development. While the ambition to address the housing crisis is outlined, the challenge of viability remains.
What is a Grey Belt Area?
A ‘grey belt’ area or land refers to the land within the ‘green belt’ that does not or negligibly contributes to the purpose of a commissioned green belt area.
According to the National Planning Policy Framework (NPPF), a grey belt land is defined as a previously developed land that does not serve the following five purposes of the green belt.
1. Relating to Contribution to the land
A grey belt is an already developed land that…
- Is exposed to unrestricted growth in urban areas.
- Is vulnerable to any encroachment of the countryside.
- Does not contribute to merging towns within each other in the sense that it preserves the geographical sanctity and boundary between settlements.
- Does not contribute to preserving the special character and historical pedigree of towns.
- Does not contribute towards the regeneration of a worn-out land or a land in very poor condition.
2. Relating to Protected Areas
Unlike green belt areas, a grey belt land…
- Is not a designated land.
- Is not a national landscape.
- Are not irreplaceable habitats.
- Are not categorised as heritage assets of any archaeological interest.
3. Relating to Development of the Land
Development of the grey belt is considered appropriate if…
- The development is taking place in a sustainable location abiding to para 110 & 115 of the NPPF.
- There is a lacuna in the targeted five-year supply of housing sites planned to be delivered.
- The development would make full use of the grey belt area without disregarding the inherent purpose of the green belt land.
- Ensuring that the development meets the affordable housing criteria and investments in infrastructure and towards green spaces.
Considerations to Identify Grey Belt Land
The following considerations may be necessary to identify a grey belt land and allocate the same for development –
- Performing a review of the green belt boundaries to mark areas of grey belt as grey belt areas, which form a good part of the green belt land.
- If not all, most green belt assessments should be taken up by local authorities.
- Spatial development strategies should be considered for green belt assessments to drive strategic policies for the development and use of land.
- Considering used sites or previously developed lands that are now demolished with scope for redevelopment.
- Considering areas under green belt that do not contribute or make a negligible contribution to fulfil the green belt’s designated purpose.
How Are Green Belt Assessments Done?
In order to assess green belt areas, both local and strategic considerations need to be outlined –
- Identifying the location and scale of the area to be assessed.
- Evaluating the contribution of each assessment area towards the green belt purpose.
- Evaluating whether the development of the assessed green belt area will compromise any of the above-mentioned green belt purposes.
Arising Contentions
- There is uncertainty about the actual number of homes, the grey belt areas can accommodate.
- The House of Lords Built Environment Committee had cast doubts on the impact of labour’s grey belt housing. The committee had questioned the labour’s grey belt plan in view of its grand announcement of delivering 1.5 million homes over the next five years.
- Similar questions were also raised by the University of Manchester, which had warned that pre-existing green belt areas may be marred with conflicts such as delay in planning approvals and surge in the number of contentions and appeals.
The Ground Reality
Contrary to the contentions that the grey belt policy is incoherent and will not have any significant impact with regards to development, the ground reality in fact paints a different picture. Below are a few examples of the status of construction developments in grey belt areas –
- A grey belt land in North-west Harpenden has been approved for the construction of approximately 550 homes (420 affordable & 130 retirement homes) by the planning committee at St. Albans city & district council.
- The Basildon planning committee has approved a 250-home scheme on a land classified as grey belt in Billericay off Laindon Road. What’s interesting is, the same committee had previously rejected a series of applications in the last two years, citing green belt area.
- The largest cloud & AI data centre facility has been approved in Hertfordshire by the Hertsmere planning committee after having concluded that the area is a grey belt land.
- A mixed-use commercial, recycling and residential scheme in a grey belt land in Elmbridge, Surrey. Although the proposal was rejected for concerns over traffic congestion, and environmental impact, much cognisance was given to other factors.
- Another proposal in Beaconsfield, Buckinghamshire was rejected, though the site contributed to prevent urban sprawl, and the plan was to develop a 120-home scheme. The issue here was the degree of harm that would be inflicted on the green belt land.
- A battery storage facility has been approved in a grey belt site outside Leighton Buzzard. However, it is still in contention as there isn’t much provision to build sufficient affordable housing.
There are Barriers…
Although the aforementioned projects signify development, but they are not guaranteed planning permission. Every proposal is meticulously assessed by local planning authorities and is determined for approval based on the following factors –
- Does the development address the overall goal of the housing crisis and is in line with residential development?
- If the grey belt land is in use for industrial development, does it provide sufficient employment?
- If the grey belt land is proposed for community development, can it also accommodate educational institutions, healthcare facilities or other public services?
- If it is a mixed-use development, does the grey belt land encompass residential, employment, and community living?
- If it is a housing development, does the land has access to schools, public transport, healthcare, and other immediate necessities?
- Are the developments in question happening in a sustainable location?
- If it is an industrial development, does the land have facilities for employ transport for workplace connectivity, shipping access, etc?
- Does the proposal in question ensure the preservation of the local character and heritage assets?
- Is the area for development in question immune from natural calamities, floods, poor air quality or any other ecological adversities?
- Is the area proposed for development able to sustain and mitigate urban chaos and sprawl?
Conclusion
If you knew, about 12% of England’s land constitutes the green belt, and 3% of it is the grey belt area. Close to 80% of the green belt land in England is either unused barns, or is non-functional, so the opportunity is more to consider these for housing development.
Local authorities should consider releasing some part of the green belt for housing development. The identification process should be meticulous and rigorously done with careful considerations.
At Extension Architecture, we have extensively spread our wings to offer expert guidance and support on all critical aspects of building and construction, including assessing such key areas to help enable favourable outcomes.
You can visit our office at Roehampton Lane, London, or you can simply call us if you wish to seek more information on this topic. Contact us Now!
