To meet targets of building 1.5 million homes, the new government launched a consultation on the process for releasing Green Belt land. Proposals include creating a new designation of “Grey Belt” land. But given the contentious nature of Green Belts and the arguments made for and against development in these locations, the addition of this new designation may prove problematic. In this article, Professor Ian Mell explores the issues around the new proposals.

• Within pre-existing Green Belt designations, different interpretations can lead to conflict, delays to planning applications, and appeals.
• The creation of Grey Belts could lead to opposition and tensions between developers and communities.
• The proposed Grey Belt should be used to develop and fund a new programme of social housing – but it may not create sufficient space to meet the 1.5 million new homes proposed.

Assessing the value and purpose of land in the Green Belt

The new proposed Grey Belt designation is defined by the government as “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.”

My work on urban and rural green infrastructure identifies extensive debate regarding Green Belt areas. For some, all Green Belt designations are of high quality and require protection. Whilst other stakeholders view them as a bureaucratic constraint on development.

In reality, Green Belts are both. Each varies in its form and function, which influence the socio-economic and ecological value of these spaces.

Before policymakers identify “Grey Belt” sites, they should consider the functionality and potential development options across the entirety of Green Belt designations. However, this would potentially require a comprehensive re-think, as the UK has changed dramatically socially and ecologically since the 1947 Town and Country Planning Act was brought into force. It may therefore be appropriate to reflect on whether the core principles of Green Belt legislated in this act remain fit for purpose and if not how Green Belt legislation/guidance may be revised.

Can Grey Belt proposals contribute to delivering new homes across the country?

Delivering more homes requires more than the creation of Grey Belt zones. Unless Grey Belt are legislated to overrule Green Belt policy it is unclear how they will circumvent local planning policy objectives.

If Grey Belts are legislated to supersede Green Belt policy at a national and local level then it could be expected that development will occur, and potentially occur quickly because the threshold for acceptance/approval will change. However, if such a change was proposed it would almost inevitably be challenged by campaigning organisations who view the protection of Green Belt as being of paramount importance.

There is also a question of whether the proposals would unlock sufficient space to meet the 1.5 million new homes proposed. If Grey Belt were added to brownfield designations would that be adequate in terms of space to deliver 1.5 million? If not, it would have a minimal impact on the availability of land for development.

It also fails to account for existing problems of land banking (where developers buy a plot of land to develop or sell in the future) and failure to deliver on existing permissions to build homes from the development sector due to economic circumstances. Designating Grey Belt may therefore have a minimal impact cumulatively at a national scale and locally in delivering housing that meets the needs of local communities. It may also lead to piecemeal development in Green Belt that does not contribute to local housing needs or provide amenities for existing communities.

Local planning authorities, housing targets and the needs of local communities

The changes in legislation and policy guidance that would be needed to scaffold the application of Grey Belt would be significant. Ensuring that local planning authorities (LPAs) can effectively manage development in Grey Belts would require significant additional resources.

In practice it would also require LPAs with Green Belt (and those adjacent to Green Belt areas and working collaboratively with other LPAs) to reconsider their local plan and Green Belt policy within it. This could lead to legal challenges over decisions already made by LPAs on planning applications and would almost certainly require amendments to be made to local policy frameworks. This could delay development, lead to more appeals, and increase costs placed on LPAs to manage strategic development.

Specific consideration of how Grey Belts would be integrated into local plans and policies is needed. This would require government at national and local levels to take stock of local amenities and consider the impact of new development on these, i.e, rural transport, schools and hospitals. If Grey Belt proposals are taken forward, then the provision of local amenities should be factored in as essential infrastructure that needs to be developed – not as infrastructure that potentially gets delivered.

The proposed 50% affordable housing target included in the Grey Belt proposals is positive, but questions remain about how this is delivered. Affordability targets already exist in many places, especially in rural areas, but are malleable due to the nature of the development/building market. The addition of such a criteria within a Grey Belt designation although aimed at delivering homes for those in need may lead to limited uptake of development opportunities if the return on investment is deemed unacceptable to developers.

Policy pathways forward for Green Belt and Grey Belt

Proposals to introduce Grey Belts require further reflection – their introduction would potentially make a complex and adversarial planning debate more complicated and open to challenges from pro/anti Green Belt stakeholders. There is also a question of whether Grey Belt extends, or significantly differs from brownfield designations (except geographically). If not, then there is limited merit in working to introduce Grey Belt to policy as it would lead to greater confusion as to what can be done in these areas.

Compartmentalising the development process within Green Belt to move previously developed land into a different conversation may lead to more problems with delivery than it solves. It is recommended that government move away from a homogenous interpretation of Green Belt and commission a wholesale evaluation of the socio-cultural, economic and ecological benefits of Green Belt in the UK to understand what functions they deliver.

If Grey Belt policy is brought forward, then it should focus on development that is publicly funded by UK government and be used solely as council/social housing or sold as affordable housing. If government is proposing to develop and fund a new programme of social housing development on Grey Belt, then there is scope to deliver meaningful development.