28/08/2024
Insights
It's a good start - but let's keep going!
Eddisons Planning Director, Kate Wood, pushes for a wider and more realistic definition of Grey Belt as part of the consultation process on changes to the National Planning Policy Framework which runs until 24th September.
Within days of becoming Chancellor of the Exchequer, Rachel Reeves announced a review of the Green Belt and that land newly termed as ‘Grey Belt’ should be released for development.
The purpose of Green Belts is to prevent urban sprawl and the merging of towns into each other by keeping this designated land permanently open. Operationally, planning applications in the Green Belt are considered on the basis of whether they keep land open and in rural character.
This, effectively, prevents most development. Exceptions are allowed, for instance cemeteries, motorway service areas and affordable housing.
Otherwise, it’s necessary to demonstrate ‘Very Special Circumstances’ (VSCs) to overcome the ‘harm’ to the Green Belt from a proposed development. Even dire housing need is sometimes deemed insufficient to demonstrate VSCs.
Green Belt designation is not about beautiful or special countryside, habitats or similar. Other designations cover those issues, such as National Landscapes. Green Belts are only for openness and the prevention of sprawl and merging.
Against this background, the idea of the ‘Grey Belt’ is being promoted to describe sites that are ‘ugly’ and, often, previously developed. Such sites can still be considered to have an open character, hence the need to define them specifically as exceptions to enable their development.
Grey Belt has been calculated by some professional bodies to be up to 3% of the Green Belt. It’s a palatable first step that can be understood and, generally, agreed by those wishing to protect the Green Belt for a variety of reasons - some of which don’t relate to the Green Belt’s primary purpose.
There is the potential to build a lot of houses on Grey Belt land. However, in being previously developed land, there may be site contamination or similar challenges that won’t necessarily be straightforward or, crucially, financially viable for developers to overcome.
There is a risk to affordable housing, this being often the first thing to be lost when the costs of development versus the potential profit don’t make the development worthwhile. Nobody is going to build a scheme for no profit - that’s simply business.
However, affordable housing is often needed most in areas within or surrounded by Green Belt because development has been stifled for so long that the area’s house prices are pushed up.
So, whilst Grey Belt is a start, nobody should consider this as the whole answer to the national housing shortage.
A review of Green Belt boundaries against the purposes of maintaining openness and preventing sprawl and merging would, I suggest, throw up a lot of such land that doesn’t fit genuine Green Belt or the new Grey Belt definitions.
A few years ago, I had a client with a small field in the Cambridge Green Belt that could have accommodated 30 houses. It was on the edge of a village, just outside the village limits drawn on the Local Plan map. Entirely enclosed by well-established thick belts of trees and vegetation, it was ‘open’ land but could not be considered to contribute to the openness of the Green Belt, nor would it result in sprawl from Cambridge (being a village within the Green Belt) or the merging of settlements.
However, as it was in the designated Green Belt, its development was unacceptable in principle, even though the nearby primary school was at risk of closure and was taking in pupils from out of catchment. It could only progress for development by the site’s allocation in the next Local Plan, which is the only way to change Green Belt boundaries and, therefore, results in significant delay and uncertainty.
The way Green Belts have been designated is to draw a line around the edge of the city/town, representing the inner boundary. Then a line several miles further out is drawn, representing an outer boundary, thereby creating a ‘doughnut’ ring.
Within that ring, villages have lines drawn around them as Village Development Limits, and everything outside these limits is ‘Green-washed’, literally with watercolour paint on the older maps. This is the process by which land has arrived in the Green Belt that, arguably, should not be there.
Just because land is outside Village Development Limits, it should not necessarily be designated as Green Belt without further consideration. This is where the definition of Grey Belt can be extended and refined. It would then be treated as just countryside with relevant policies applying.
My client’s field would have been Grey Belt and could then have benefitted from policies permitting development on the edges of villages, infill sites, etc.
Assessing land against the purpose of Green Belts rather than how it looks needs to be the focus of the Green Belt review, whereby a more appropriate definition of Grey Belt will result in a more genuine Green Belt that can be better protected in the long term.
This article is reproduced by kind permission of Business Weekly in which a version recently appeared as part of the publication’s monthly ‘Scaling up in association with Eddisons’ feature.
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