Grey Belt
The grey belt is a contentious and very worrying aspect of the National Planning Policy Framework (NPPF).
When the matter was first discussed in the summer of 2024 the clear indication from the Government was that it would refer to poor quality and largely pre-developed areas within the green belt, such as car parks or petrol stations, that probably should not have been in the Green Belt to start with.
However, what came to fruition in the December 2024 version of the NPPF was a lot different and far more damaging.
Planning Policy now states that a piece of Green Belt that does not contribute strongly to Green Belt purposes A, B or D can be considered grey belt.
Stepping back a little, there are five purposes of the Green Belt as set out below. Purpose purposes C and F are not used to determine grey belt.
(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.
This is a very subjective matter as there are no firm rules on how the Green Belt should be rated against the five purposes. This leaves it open to wide interpretation.
As an example, Basildon council’s highly controversial 2023 Green Belt study completely changed the purposes (negatively) compared to their previous 2017 Green Belt Review. The subsequent 2025 Green Belt Study changed the situation yet again (slightly more positively). And we have seen situations where developers have come up with their own ratings, which are different again, clearly to prove grey belt to their advantage. It’s a total minefield based on planning judgement and no firm guidelines.
But, and very frustratingly, grey belt is now part of planning legislation and Basildon council has to apply that legislation based on the most recent Green Belt Study from 2025.
When the matter was first discussed in the summer of 2024 the clear indication from the Government was that it would refer to poor quality and largely pre-developed areas within the green belt, such as car parks or petrol stations, that probably should not have been in the Green Belt to start with.
However, what came to fruition in the December 2024 version of the NPPF was a lot different and far more damaging.
Planning Policy now states that a piece of Green Belt that does not contribute strongly to Green Belt purposes A, B or D can be considered grey belt.
Stepping back a little, there are five purposes of the Green Belt as set out below. Purpose purposes C and F are not used to determine grey belt.
(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.
This is a very subjective matter as there are no firm rules on how the Green Belt should be rated against the five purposes. This leaves it open to wide interpretation.
As an example, Basildon council’s highly controversial 2023 Green Belt study completely changed the purposes (negatively) compared to their previous 2017 Green Belt Review. The subsequent 2025 Green Belt Study changed the situation yet again (slightly more positively). And we have seen situations where developers have come up with their own ratings, which are different again, clearly to prove grey belt to their advantage. It’s a total minefield based on planning judgement and no firm guidelines.
But, and very frustratingly, grey belt is now part of planning legislation and Basildon council has to apply that legislation based on the most recent Green Belt Study from 2025.
