The green belt is not a new concept. The principles underpinning it have been constructed over centuries, becoming more clearly defined when the Greater London Regional Planning Committee first proposed the green belt in 1935.
With a general election looming, the Labour Party has raised the issue of revising green belt policy – a bold and divisive topic to raise at this stage. But it does feel like now is the time to dust off the policy book and ask the question: on balance, is there sufficient benefit in redefining the green belt to attempt to mitigate the housing crisis which outweighs the harm this may do to the ability of the green belt to meet its objectives? Industry has certainly been having this discussion for some time.
Recap: what is the green belt?
The green belt comprises defined areas of land clustered around 15 urban cores, protected from development through designation in local plans. Local planning authorities should only alter green belt boundaries in “exceptional circumstances”. If you want to build in the green belt, you will usually need to meet the “very special circumstances” test, which is no mean feat. The idea is entrenched: don’t build in the green belt.
The National Planning Policy Framework provides that the fundamental aim of the green belt is to prevent urban sprawl by keeping land permanently open; it stops towns and cities merging into each other. The green belt serves defined purposes centred on the spatial management of urban areas, with an aside for preserving the setting and special character of historic towns.
While often conflated with “green” planning policies, the green belt is not concerned with ecological merit – it is concerned only with space. It so happens that the green belt “space” may have ecological merit. You could be forgiven for thinking the green belt exists for environmental protection or prioritising amenity space; indeed, this was historically an objective of the green belt brought sharply back into focus during the pandemic.
The issue is that the green belt is not small; it accounts for 12.6% of the land area of England, according to the Department for Levelling Up, Housing and Communities, much of which is land that could otherwise be built on.
The green belt’s potential
Releasing a proportion of the green belt for development may go some way to alleviating the housing crisis – but should we? In 2015, the Adam Smith Institute argued that redrawing green belt boundaries to release land within a 10-minute walk of a railway station would allow for the development of up to one million new homes. Subsequently, in 2019 the Centre for Cities argued that release of green belt land within 800m of train stations which service major cities within 45 minutes would provide land sufficient to raise the housing stock by between 7% and 9%.
In either eventuality, one questions at this moment in time, which housebuilders would aim to deliver such volume? For context, the most recent 300,000 homes-a-year target has never been met. Despite such studies into the green belt’s potential, the government stated in November 2023 that it “has no plans for a national review of the green belt”.
Housing is just the tip of the iceberg. As the need for data centres increases seemingly exponentially, this government is investing £960m into a connections action plan to improve the National Grid to ensure that the UK is not left behind. Data centres need space, the more the better. Next stop: logistics. Knight Frank estimates that, over the next five years, the UK requires 112m sq ft of new industrial and logistics space. The logistics industry needs space, the more the better.
Any argument for review of the green belt based solely on the need for housing is reductionist; there are many competing demands for space. Many will be hoping that these competing demands will rise up the political agenda.
Labour’s grey belt
In its April 2024 press statement, Labour set out its golden rules for housebuilding, introducing the term “grey belt”. Labour refers to the grey belt as “neglected areas such as poor-quality wastelands and disused car parks that are in the green belt”, “poor-quality and ugly areas of the green belt” and “distinct to brownfield with a wider definition”. Labour’s rules would create a hierarchy of brownfield first (familiar), grey belt second, with a target of 50% affordable housing. This hierarchy aims to support targets to deliver 1.5m homes within the first five years of a Labour government.
Without doubt, sincere pledges to deliver housing will be well received, and this policy, if followed through, appears to have a legitimate prospect of facilitating increased housing delivery. It may at least assist local planning authorities that have faced issues with local plan processes owing to the quantum of green belt land within their ward. However, these golden rules relate to a policy based on a green objective, which the NPPF does not recognise. To square the circle, Labour will have to revisit the objectives that prop up the whole concept of green belt.
There are also some internal inconsistencies in what is proposed: much of what it gives as examples of grey belt would amount to “previously developed land” in current national policy, where the “very special circumstances” test already does not apply if there is no impact on openness. And are Labour’s concepts aimed at the local plan-making process, or to be applied in the determination of planning applications? If the latter, what would be the transitional arrangements?
Black and white
Of course, the green belt is just one of the issues hampering housing delivery. Releasing green belt land for development is not a silver bullet. Other variables include market appetite for delivery, stalled pipelines, costs of development finance, mortgage costs, workforce availability, planning authority resources, skills, consumer confidence and so on. These are real barriers which developers, potential home-buyers and planning authorities grapple with on a daily basis. “Grey belt” is a snappy headline; let’s see what it means in black and white.
Matt Speed is an associate at Town Legal LLP
