Daniel Slade: Is the introduction of the ‘grey belt’ a good thing?

Dr Daniel Slade is Head of Practice and Research at the RTPI

The green belt looms large over planning in England - it is hard to think of another policy concept that is so misunderstood while being so emotionally and politically charged. This makes it striking that the government, even with its huge majority, has grappled with the issue in its just-closed consultation on national planning policy.

Most notably, it has introduced the concept of the ‘grey belt’. Understanding its significance requires both a careful reading of the consultation details and wider political dynamics. Doing so reveals that the grey belt is, at its core, two things: First, a significant and perhaps necessary political ‘move’, and second, a process for releasing green belt land.

It also reveals that the government’s grey and green belt policies’ success depends on another, intrinsically linked, area of planning policy: strategic planning.

The grey belt as the thin end of a political wedge

The RTPI has long argued that the green belt has performed its core role – urban containment – relatively well for a long time. But the only way for the green belts across England to do this in a way that meets communities’ needs is for them to be dynamic. Despite this, recent changes to national policy have attempted to ‘freeze’ them in response to political pressure, and the first step to addressing this must be to open the political space that provides the wiggle room for policy change. The idea of a ‘grey’ belt very vividly implies that not all green belt land is equal, and that sometimes there may be a case for altering it.

While many RTPI members may have liked a fulsome national debate about the nature and role of the nation’s green belts, the government’s introduction of ‘grey belt’ does do this. Indeed, it’s clear that this is the concept’s primary role.

The grey belt as a process

Given this job, government announcements after the general election and before this consultation suggested that the ‘grey belt’ would comprise ‘low-quality’ green belt land that was unattractive and had poor amenity value – think photographs of petrol stations, razor wire fences and shopping trolleys in hedgerows.

But this is not the case. Instead, the consultation provides a definition of grey belt land that largely hinges on whether land makes a ‘limited contribution’ to the five long-established purposes of the green belt. These are:

a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns from merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

What’s crucial here is that each of these principles relates to the green belt’s fundamental role as urban containment policy. They do not relate to those characteristics that the public often thinks green belts are about – environmental quality, recreation, attractiveness, etc.

This is a positive move, going some way to ensure that the concept of grey belt does not obscure the core role of green belt as urban containment policy. Other policy designations can effectively enhance or protect those other attributes – and there is a strong case for a much broader discussion about green belt land’s role in climate change mitigation and adaptation, for example – but that should be brought about through other policy tools.

Another important aspect of this definition is that it is relative. In other words, whether green belt land is actually ‘grey’ depends on its relationship over time to other land uses and the rest of the ‘belt’ within which it lies. Assessing these relationships will be ongoing and essentially procedural. Indeed, the consultation lays out the sequential process by which LPAs should release land when struggling to meet their housing needs. This all adds to the sense that the grey belt is more of a process than a ‘thing’.

Three issues with the government’s proposed green belt policy

So, if the grey belt is a political move wrapped around a land release process, what is the RTPI’s view on it in terms of policy?

Most foundationally, we agree with the consultation that LPAs should have to review their green belt land where they cannot meet their housing need. This is a simple but important point, and one which previous revisions to the NPPF frustrated.

Beyond this, we have three big concerns about the proposals…

First, the new NPPF should do more to ensure that those sites that are deemed ‘grey belt’ are in sustainable locations. The consultation document broadly refers to the sequential release of sustainable sites, but given the potential for many that make a ‘limited contribution’ to the five purposes to be isolated and car-dependent, this is not enough.

Second, the government proposes to introduce a series of ‘golden rules’ to ‘ensure that major development on land released from the green belt benefits both communities and nature’. This includes a rule that housing schemes on land released from the green belt should provide ‘at least 50% affordable housing, with an appropriate proportion being Social Rent, subject to viability. This is a fine ambition, but across large swathes of green belt land, a 50% target will not be viable, and will open up the process to costly and time consuming viability negotiations. Continuing to set affordable housing requirements via local plans but with this buttressed by strong national policy backing for maximising delivery, and/or potentially for a national percentage uplift in the number of affordable homes required, would address these issues.

Third, taking into account the consultation proposals as a whole (but particularly thinking about the impacts of the New Standard Method), many local authorities are likely to face housing targets that they are simply unable to meet. There could be be serious knock-on effects to this, for community support, plan making, speculative development and development on green belt land.

To work, the government’s emerging green belt policy will depend on strategic planning

The key thing that will alleviate this pressure will be the allocation of housing targets from the strategic (i.e. combined authority or county) level, according to local constraints and opportunities, with green belt reviews being run alongside.

The government is aware of this, and we’re extremely pleased that by all accounts it wants to introduce genuine strategic planning as soon as possible. The real question therefore is what happens in the interim, before these new strategic arrangements come into place. Indeed, this is one of the key questions for government across the whole of this consultation.

The sector, and particularly those local authorities that will struggle to meet their targets, or working to get a new plan in place, need to have a clear route map for the introduction of strategic planning, both nationally and as it relates to their area.

So, is the grey belt a good thing? It isn’t black and white, but depends to a great extent on how effectively the government manages the transition to strategic planning.