Six Months On: Assessing the Impact of the NPPF’s Grey Belt Policy As the planning sector marks six months since the revised National Planning Policy Framework (NPPF) was published (December 2024), David Jones MRTPI, Head of Planning at Evans Jones, reflects on the transformative impact of the new "Grey Belt" designation on Green Belt development policy.
- Location:
- England
- Value:
- Not Disclosed
- Services:
- Planning Appeals Planning Consultant Planning Appraisals / Master Planning Planning Objections Local Plan Representations
The December 2024 revision introduced the concept of the ‘Grey Belt’ — a newly defined category within planning policy. It offers a potential pathway for residential and other forms of development on land currently designated Green Belt. This approach aims to strike a balance between preserving the Green Belt’s integrity and addressing growing development needs, particularly housing.
Understanding Grey Belt Criteria
Grey Belt land is defined within Annex 2 of the NPPF as either previously developed Green Belt land or land that does not significantly contribute to key Green Belt purposes — namely preventing urban sprawl, stopping the merging of towns, or safeguarding the countryside from encroachment. Crucially, this excludes land with environmental or heritage designations such as Sites of Special Scientific Interest (SSSI), National Parks, or flood-risk areas.
To be eligible for development, a Grey Belt site must meet four key tests:
- The proposal must not undermine the overall purpose of the Green Belt.
- There must be a clear unmet need — either for housing (demonstrated by a shortfall in the local authority’s five-year housing land supply) or other forms of development.
- The site must be in a sustainable location.
- For major housing developments, the proposal must comply with the so-called “Golden Rules.”
These “Golden Rules” require:
- Affordable housing delivery of at least 15% above the highest local requirement (up to a cap of 50%).
- Necessary improvements to local or national infrastructure.
- The creation or enhancement of publicly accessible green spaces.
Dispelling Misconceptions
A common misconception persists among developers and planning authorities: that Grey Belt land must be previously developed or brownfield. In reality, even undeveloped greenfield sites can qualify, provided they meet the criteria outlined in the NPPF and do not contribute strongly to the key Green Belt purposes.
Appeal Decisions Shaping Policy Interpretation
Recent appeal decisions provide valuable insight into how Planning Inspectors are interpreting Grey Belt policy in practice.
Kenley Aerodrome (APP/M3645/W/24/3354498)
An appeal for an 80-dwelling development with 50% affordable housing was approved, despite the site falling within a Conservation Area. With only a 1.92-year housing land supply locally, the Inspector found the scheme’s benefits outweighed minor heritage harms and concluded the site qualified as Grey Belt. It complied with all Golden Rules, and no strong grounds for refusal were found.
Daws Heath Road (APP/M1520/W/24/3351658)
This case involved 173 homes near the village of Daws Heath. The Inspector examined whether expanding a village could conflict with the Green Belt’s objective to prevent town merging. The Inspector concluded that ‘villages’ should not be treated as large urban areas, meaning that proposals within or adjoining villages is not necessarily in conflict Green Belt purposes. As a result, the proposal was deemed compliant with the Grey Belt definition.
This nuanced reading of the NPPF suggests that development adjacent to sustainable villages may be more favourably received than proposals between larger urban settlements. The published policy guidance open the door to further development on Grey Belt land surrounding villages.
What’s Next for Developers?
During this transitional period, many local planning authorities (LPAs) are reassessing schemes which are currently at appeal. In cases where proposals clearly meet the Grey Belt criteria and Golden Rules, LPAs are withdrawing objections or choosing not to defend appeals.
For developers and promoters, the critical starting point for site assessment (housing) will be demonstrating unmet need — primarily through shortfalls in housing supply or failed housing delivery test. For non-residential developments, more tailored evidence on local demand will be required.
As we look ahead, the evolving application of Grey Belt policy presents both opportunities and challenges. For those who understand its nuances, it may offer a valuable route to unlocking sites that were previously off-limits.