Land categorisation is a big driver of how UK councils create housing strategies and approve planning applications in their local area.
This page explains what the key terms mean and how things will change once Labour’s NPPF update takes effect later this year.
What is a Brownfield Site?
A brownfield site is a parcel of land that’s previously been developed upon. Some common examples include derelict housing or long-closed factories that are past the point of repair.
As you may have guessed, brownfield land is undesirable for local residents. It gives the impression that an area is “run-down” and unattractive, which pushes down the prices of local housing, and, according to the broken windows theory, can encourage anti-social behaviour and crime. They’re also associated with several environmental hazards, like asbestos, heavy metals, and fly tipping.
The majority of brownfield land in the UK is concentrated in urban areas, particularly in post-industrial cities. Since 2017, planning authorities have been required to keep and publish a brownfield land register for their local area. This includes a list of brownfield sites appropriate for housing, as well as sites granted permission in principle.
Building on Brownfield Land
A lot of work needs to be done on a brownfield site before it can be reused (such as clearing existing structures or ground pollution), meaning they’re more expensive to develop than your typical greenfield site. This means the rules for building on brownfield are a bit looser to make it a more attractive investment opportunity for developers.
Now, Labour is signalling that they want to make brownfield development even easier, with a fast-track “brownfield passport” scheme touted in recent days. Their proposed NPPF also retains the clause that brownfield sites won’t need as much of an affordable housing contribution, in a bid to encourage development at all costs.
What is Green Belt Land?
The opposite of a brownfield site is a greenfield site, land which has not been previously developed, like an untouched meadow or forest. However, this is slightly different to the Green Belt, which is a special category of protected land designated by law.
In short, not all greenfield land is protected by the Green Belt. And, as we’ll explore later, not every piece of land in the Green Belt can genuinely be considered a greenfield site!
Building on Green Belt Land: What’s So Special About it?
According to the National Planning Policy Framework, the Green Belt purpose is to::
- heck the unrestricted sprawl of large built-up areas
- Prevent neighbouring towns merging into one another
- Assist in safeguarding the countryside from encroachment
- Preserve the setting and special character of historic towns
- Assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
Once land has been designated as Green Belt, there is a presumption against development except in “exceptional circumstances”. This could include critical infrastructure projects or, in limited cases, small-scale developments with minimal environmental impact.
The key point is that development must fulfil an essential need that cannot be accommodated elsewhere — and planning authorities will expect a much more rigorous application that argues its case.
Why Has The Green Belt Grown So Much?
The passage of the Town and Country Planning Act 1947 saw the concept of Green Belt land written into law, with local authorities now being allowed to include Green Belt proposals in their development plans. In the decades since, the Green Belt has steadily grown in size, reaching 12.6% of England’s total land area by 2023.
Labour’s draft NPPF has retained the requirement for local planning authorities to “consider whether it is appropriate to establish Green Belt around or adjoining new developments of significant size”.
This is especially interesting given the creation of a New Towns Taskforce back in July, which will identify suitable locations for the biggest raft of planned towns in the UK since the 1970s. As such, it’s likely that we’ll see new areas pop up on the Green Belt map in the not-so-distant future.
What is Grey Belt Land?
Grey Belt land is a much newer term in our glossary of land classification. It was coined by Labour politicians in April 2024 to refer to “poor quality and ugly areas” that have somehow ended up being protected by the Green Belt designation despite not being green space.
This could mean things like quarries or car parks that were once given Green Belt planning permission, only to later fall out of use (i.e. brownfield land). It could also refer to land which isn’t being managed sustainably and only makes a “limited contribution” to those five Green Belt purposes we mentioned earlier.
So, why have Labour introduced this new category of land in their NPPF?
It’s simple. The reintroduction of mandatory housing targets (see: 5 key takeaways from the NPPF) means many councils will be tasked to allocate more suitable land for development than ever before. The government fears that some planning authorities will struggle to find enough sites to reach their housing targets, which inevitably means looking in new places, like the Green Belt.
Building on Grey Belt Land under Labour’s New Planning Reform Laws
As crucial as building on the Grey Belt may be, these planning reforms do not indicate a gung-ho approach. Rather, the proposed NPPF advocates a sequential test when allocating land as Grey Belt. This means councils should try to exhaust all options from the first category before moving onto the next.
The three tiers of Grey Belt site are as follows:
- Brownfield sites (previously-developed land) located in the Green Belt.
- Any other parcels and/or areas of Green Belt that make a limited contribution to the five Green Belt purposes. For instance, land that is dominated or fully enclosed by built form, and which is in a sustainable location (close to existing public services).
- Higher performing Green Belt sites that could be made more sustainable if developed upon.
No matter the type of Grey Belt land that is released for development, it will be subject to a stricter set of ‘golden rules’ than a standard brownfield site. These include the provision of at least 50% affordable housing, necessary improvements to local infrastructure, and making local green spaces more accessible to the public. Councils themselves are also instructed to set out ways in which Grey Belt designation can be offset through compensatory improvements to remaining Green Belt boundaries and land.
The Grey Belt and Local Planning
The introduction of the Grey Belt represents a substantial shake-up of the land use system in England — one that will be visible in spatial planning strategies for years to come.
While the underlying function of the Green Belt remains the same, planning authorities can now release land for much less than the “exceptional circumstances” test that we’ve been familiar with for decades. And, if a council is struggling to meet their new housing targets, the government will expect them to make full use of this policy to find suitable sites.
In terms of next steps, councils should immediately assess their existing Local Plan against the newly-allocated house building targets. If a council cannot demonstrate a 5-year housing land supply or is delivering less than 75% against the Housing Delivery Test, then it opens up the possibility of Grey Belt development. They might also expect to see new kinds of Green Belt proposals from developers, and should give due consideration to the commercial and industrial needs they aim to meet.
As for citizens, it means you might get to engage in more public consultations than usual if you live close to Green Belt land. Councils will want to hear what you think about new development, and how the Green Belt could be made more accessible and enjoyable for your everyday use.
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