FAQ: Understanding the Grey Belt Study

This blog summarises findings and implications of the Grey Belt Study, providing essential guidance for parish councillors and local residents.

1. What is a Grey Belt Study and what do they reveal?

An ONH Grey Belt Study, usually commissioned by a Parish Council, identifies areas within the Green Belt that may be suitable for residential development in principle if strict national policy criteria are met. These areas are known as Grey Belt. This is because of national policy changes and is not subject to a choice. Areas either meet or do not meet the definition of Grey Belt. The principle of residential development may therefore be supported by national policy on such sites where they have not been before. Proposals remain subject to assessment against all other relevant development plan policies and other material considerations. It simply means objections raised regarding the principle of development are likely to be easily dismissed.  

2. What are the strict national policy criteria?

Listed in NPPF §155, the rules specify that development may be permitted if it uses Grey Belt land that does not undermine all of the purposes (taken together) of the Green Belt to deliver a scheme in a sustainable location when there is a demonstrable need for homes (no five year housing land supply or housing delivery drops below 75% of the housing requirement over the previous three years). The Grey Belt Study has demonstrated that there is Grey Belt areas and that there are sustainable locations in the parish. Major development (10 or more homes or a site > 0.5 hectares) will also need to meet some additional ‘Golden Rules’.

3. What are the 'Golden Rules' for development in the Grey Belt?

Outlined in NPPF §156, the rules specify that major development may be permitted if it delivers affordable housing, supports necessary infrastructure improvements, ensure access to good quality green space. Improvements to green spaces should also support nature recovery and landscape setting objectives. These rules do not need to be met by minor development (9 or fewer or a site < 0.5 hectares).

4. Why are some areas only identified as 'Provisional Grey Belt'?

These are areas that may meet the definition of Grey Belt. However, this cannot be fully established until a planning application has been prepared and the details of the development has been laid out. For example,  it can’t be judged whether a site will cause substantial harm to the Conservation Area or its setting, without seeing what the application for development on the site is in detail.    

5. Is the scale of growth still a key consideration?

Yes. Even in suitable locations, scale must align with infrastructure capacity and local character. Large-scale development could still be inappropriate. This can either be made clear within a development plan document or through representations to planning applications and/or any emerging Local Plan.

6. Has national policy on Green Belt development changed?

Yes. The 2024 NPPF clarifies that Grey Belt land can be considered for development where contribution to specific Green Belt purposes is limited. The supporting Planning Practice Guidance (PPG) has also made it clear that there are Green Belt purposes which only apply to towns, specifically excluding villages in their entirety. What these NPPF and PPG changes have done is lower the planning risk in areas where this risk has always historically been high and therefore deterred investment into seeking to realise development opportunities. 

7. How likely is development to occur on Grey Belt land?

Development is not guaranteed. Ultimately it remains down to the landowner to assess the planning risk of submitting a planning application. Even if land has been identified as Grey Belt, proposals remain subject to assessment against all other relevant development plan policies and other material considerations.

8. What can the Parish Council do with this information?

The Council can use the findings to focus resources and shape responses to any potential future planning applications which may come forward in these areas; respond to any emerging Local Plan seeking to grapple with the Grey Belt issue; and finally to inform the content of a Neighbourhood Plan. The Neighbourhood Plan could include policies to ensure existing design guidance is adequate to guide the design of potential future schemes; to guide specific potential Grey Belt development areas including establishing an appropriate scale of Grey Belt development. The Parish Council can also make sure that any strategies it may have on infrastructure improvements, in particular on green spaces, continue to be kept up to date.

Interested in a Grey Belt study for your area? Please contact us for more details.