The 2024 update to the National Planning Policy Framework (NPPF) has now been published by the government. This update has brought a significant shift in how development in the Green Belt will be handled. In the past, building on Green Belt land was generally considered inappropriate, with very few exceptions.
Now, however, certain types of development—particularly housing and commercial projects—will have a clearer path to gaining planning approval, as long as they meet specific criteria. Let’s take a closer look at these changes and what they mean for future developments in Greenbelt areas.
The Old Green Belt Policy: Challenges to Development
Historically, constructing new buildings in the Green Belt was often deemed inappropriate unless developers could demonstrate very special circumstances.
Greenfield sites—those that have never been built on—were especially hard to develop, requiring exceptional justification. Even for previously developed land, such as brownfield sites, planning permission was hard to secure unless the development didn't harm the openness of the Green Belt or, in the case of affordable housing, addressed specific local needs without significant negative impact.
The Old Green Belt Policy: A More Flexible Approach
As of today, the rules have changed. Housing, commercial, and other developments in the Green Belt are no longer automatically considered inappropriate. According to the revised guidelines, outlined in paragraph 155, development will be allowed in the Greenbelt if it meets the following conditions:
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.
There is a demonstrable unmet need for the type of development proposed.
The development would be in a sustainable location, with particular reference to paragraphs 110 and 115 of the NPPF 2024.
Where applicable the development proposed meets the ‘Golden Rules’ requirements set out in paragraphs 156-157 the NPPF 2024.
These changes mark a departure from previous policies, offering developers more clarity and flexibility when seeking approval for Green Belt projects.
1 - What Is 'Grey Belt' Land?
One of the most important changes is the introduction of the concept of "Grey Belt" land. Grey Belt refers to land that is either previously developed or doesn’t significantly contribute to the primary purposes of the Green Belt. These purposes include:
Preventing the unrestricted sprawl of large built-up areas
Preventing neighbouring towns from merging into each other
Preserving the setting and special character of historic towns
Land that doesn’t fulfill any of these functions—or falls under other policies outside the Green Belt—can now be classified as Grey Belt, potentially opening up more land for development.
Developers must still ensure their projects do not "fundamentally undermine" the essential purposes of the Green Belt. Although this condition has been slightly adjusted, it remains a high standard to meet, and proving that a development doesn't undermine these purposes could still be challenging.
2 - Meeting Unmet Needs
Developers will now need to show a clear, demonstrable need for the development they propose. For housing projects, this need is usually evidenced if the Local Planning Authority (LPA) cannot demonstrate a five-year housing land supply or if housing delivery tests show a shortfall. This is a change from earlier drafts, which included broader criteria for what constituted a “demonstrable need,” including regional or national needs.
3 - Sustainable Location
The new guidelines require that development be in a sustainable location. While the term “sustainable location” is not explicitly defined, the updated rules cross-reference key sections of the National Planning Policy Framework (NPPF), particularly paragraphs 110 and 115. This implies that a location could be deemed sustainable if it has the potential to become so, allowing more developments that demonstrate long-term sustainability through proper planning and infrastructure.
4 - The Golden Rules
The Golden Rules are key principles developers must follow when proposing a Green Belt development. These include:
Affordable housing: The project must include affordable housing, either in line with development plan policies or calculated according to paragraph 157 of the NPPF.
Infrastructure improvements: The development must include necessary improvements to local or national infrastructure.
Green spaces: New or improved green spaces must be accessible to the public.
These requirements aim to ensure that developments contribute positively to the local community, enhancing not only housing and commercial space but also infrastructure and green spaces.
Affordable Housing and Viability
Under the new rules, affordable housing provision will be calculated 15% higher than the highest affordable housing requirement that applies to the development, up to a cap of 50%. This means developers will need to provide more affordable housing than what current policies might require. This change is likely to stir up discussions around the financial viability of projects, as developers will need to prove that these increased requirements are feasible. The previously proposed benchmark land value—based on “existing use value plus a premium”—has been dropped, and viability assessments will now be based on the guidance set out in the Planning Practice Guidance (PPG).
Conclusion
These changes represent a major shift in the way Green Belt land is treated in planning. While some aspects—particularly the increased affordable housing requirements—could spark debate, developers now have a clearer path to securing planning permission for projects in areas that were previously off-limits.
This shift in policy represents an important moment for Green Belt development. As the planning community adapts to these changes, the coming years will be crucial in balancing the demand for new development with the need to protect and preserve Green Belt areas for future generations.