Save our Green Belt – our campaign for amendment of ‘grey belt’ definition

CPRE Hertfordshire is campaigning for an urgent change in the revised National Planning Policy Framework (NPPF) published in December 2024. We are calling on the Government to amend the definition of so-called ‘grey belt’ land in the Green Belt.

The specific definition of ‘grey belt’ – as per the revised NPPF – is hugely damaging to the continued existence of the Green Belt in England.

The establishment of the Green Belt, initially to control the unrestricted urban sprawl of London and subsequently applied to other conurbations, is widely regarded as the most successful planning policy since the introduction of the present statutory planning system in 1948. It has had the effect of maintaining open countryside with a host of benefits for both rural and urban communities and for nature and the environment.

But there is an inconsistency between the NPPF paragraphs on the Green Belt and the NPPF glossary definition of ‘grey belt’. This inconsistency could result in the loss of our Green Belt countryside forever as well as habitat loss for wildlife. We want the NPPF ‘grey belt’ definition to be amended so this inconsistency is removed, and Green Belt protections remain in place.

We have written to all Hertfordshire MPs requesting their support for our campaign. We are also calling on all candidates from all political parties in the upcoming Local Elections on 1^st May to sign up to our campaign.

Read our letter to MPs

We also urge all of our supporters to contact your local Councillor and gain their support for this urgent change in the definition of ‘grey belt’.

What does the NPPF say about Green Belt?

NPPF Chapter 13 ‘Protecting Green Belt land’ makes clear the Government’s continued intention that Green Belt land is permanent and that development should be restricted within the Green Belt. NPPF paragraph 142 could not be clearer about this.

NPPF paragraph 143 then lists the five specific purposes of the Green Belt. These are

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.

But then the NPPF goes on to introduce the concept of ‘grey belt’ land, in the Green Belt, and this is where the fundamental inconsistency arises.

What does the NPPF say about ‘grey belt’?

Taking a step back, ‘grey belt’ was initially described as poor-quality Green Belt land like disused car parks. But the actual ‘grey belt’ definition in the recently revised NPPF is so broad that it could include almost any Green Belt land.

This has the effect of allowing developers to submit speculative planning applications on Green Belt sites anywhere, and argue they are ‘grey belt’. How is this possible?

This is because the NPPF Glossary defines ‘grey belt’ in such a way as to undermine two of the five Green Belt purposes:  c) safeguarding the countryside from encroachment, and e) assisting in urban regeneration by encouraging the recycling of derelict and other urban land.

Specifically, and this gets technical, the concept of ‘grey belt’ is introduced in NPPF paragraph 155, as follows:

“The development of homes, commercial and other development in the Green belt should also not be regarded as inappropriate where all of the following apply:

a) The development would utilise grey belt land and would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan;

b) There is a demonstrable unmet need for the type of development proposed;

c) The development would be in a sustainable location, with particular reference to paragraphs 110 and 115 of this Framework; and

d) Where applicable the development proposed meets the ‘Golden Rules’ requirements set out in paragraphs 156-157 below”

And then the NPPF Glossary gives the precise definition of ‘grey belt’ as

“Grey belt: For the purposes of plan-making and decision-making, ‘grey belt’ is defined as land in the Green Belt comprising previously developed 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.”

Note that two of the five Green Belt purposes – c) safeguarding the countryside from encroachment, and e) assisting in urban regeneration by encouraging the recycling of derelict and other urban land – are not mentioned. And it is these two Green Belt purposes that are often cited by Local Planning Authorities (Councils) and the Planning Inspectorate in decisions that refuse permission for development in the Green Belt.

The omission of two of the five Green Belt purposes in the definition of ‘grey belt’ is clearly inconsistent with the NPPF provisions regarding Green Belt. It is also perverse at a time when the Government has repeatedly and publicly stated it wants to see a ‘brownfield first’ approach to development.

In Hertfordshire alone there is space for at least 29,580 new homes on brownfield land. And there are 4,213 long term empty homes across the county that could be brought back into occupancy. That’s more than 33,000 new homes that are possible before having to build on any greenfield sites in the countryside.

What can be done about this?

We are urging the Government to restore Green Belt protections by ensuring that ‘grey belt’ proposals are judged against all five Green Belt purposes, and that this is consistent throughout the NPPF. This will ensure that development needs are appropriately balanced against the many benefits of conservation.

Proposed new wording of the NPPF glossary definition of ‘grey belt’:

Grey belt:  For the purposes of plan-making and decision-making, ‘grey belt’ is defined as previously development land and/or any other land that does not strongly contribute to the purposes of the Green Belt in paragraph 143.  ‘Grey belt’ excludes land where the application of the policies relating to the areas of assets in footnote 7 (other than Green Belt) would provide a strong reason for refusing or restricting development.

What’s at stake with all of this?

Since the publication of the revised NPPF in December, every major planning application for Green Belt land in Hertfordshire has asserted that the proposed development site is ‘grey belt’ and that this should justify granting permission. Our photo gallery below shows just a few of these sites. We think it’s both tragic and unnecessary that these and other highly valued landscapes are at imminent risk of being lost to development, forever.