Grey Belt Land: Definition and Application

Jeremy Wright Excerpts

Tuesday 15th September 2026 Westminster Hall

[Sir Jeremy Wright (Kenilworth and Southam) (Con)]

I beg to move,

That this House has considered the definition and application of grey belt land.

It is a great pleasure to serve under your chairmanship, Dame Siobhain, and to have the opportunity to introduce this debate on the definition of grey-belt land. Shortly after their election, the Government introduced a new concept to planning and development: grey-belt land. This would be a subset of land currently designated as green belt that the Government considered less worthy of protection than the rest of the green belt, on which they wanted to make development easier. I asked for this debate because it is important that we understand the significance of this new concept. Specifically—I know the Minister will do his best to help with all these items—I am interested in understanding, first, how different grey-belt designation seems from what the Government originally said it would be; secondly, its likely impact on our countryside; and thirdly, how it combines with other changes the Government are making to the balance of development in rural and urban areas.

Let us start with the difference between what the Government originally suggested grey belt would be and their definition published in the “National Planning Policy Framework” document. In July 2024, the right hon. Member for Ashton-under-Lyne (Angela Rayner), in her first incarnation as Secretary of State for Housing, Communities and Local Government, told the House that the Government’s intention was to

“release lower-quality grey-belt sites, disused car parks and garages, and ugly wasteland”.—[Official Report, 19 July 2024; Vol. 752, c. 315.]

She also said:

“The land we are talking about—grey belt, which we define in the NPPF consultation—is not agricultural land; it is disused garages and things of that nature”.—[Official Report, 30 July 2024; Vol. 752, c. 1196.]

However, when the actual definition of grey-belt land appeared in the NPPF of December 2024, the concept was considerably wider. Grey belt is now defined as land in the green belt that does not strongly contribute to three of the five purposes of the green belt that were included in the previous definition of green-belt land. Those three purposes are to check the unrestricted sprawl of large built-up are, to prevent neighbouring towns merging into one another, and to preserve the setting and special character of historic towns. In other words, to remain as green belt and not be reclassified as grey belt, land must need protecting in order to prevent urban sprawl or to stop urban areas merging, or be near enough to a historic town to affect its setting or character. Even a moderate contribution to those objectives will not be enough; to save the land from grey-belt status, it must contribute “strongly”.

The remaining two purposes of green-belt designation are no longer considered important enough to preserve green belt from becoming grey belt. Namely, they are assisting in safeguarding the countryside from encroachment, or assisting urban regeneration, by encouraging the recycling of derelict and other urban land.

We can draw two conclusions from all this about what is actually green belt and what is grey belt. First, quite a lot of what is now green belt will probably end up redesignated as grey belt, because the Government have set the bar quite high to retain green-belt status. Only a strong contribution to the three remaining effective green belt purposes will do. I am not the only one who thinks that much of the green belt could end up as grey belt. Recent analysis from “Channel 4 News” suggested that 96% of the green belt around Guildford could be grey belt, along with 92% of the green belt around Stoke-on-Trent and 80% of the green belt around Solihull.

My second conclusion is that land that continues to qualify as green belt as opposed to grey belt will largely be on the edge of urban settlements. That is because the grey belt is, in effect, all green-belt land that does not strongly contribute to the three green belt purposes that only apply very near to urban settlements. It follows that land in open countryside currently in the green belt will be less able to meet one of those three purposes, and is therefore more likely to be redesignated as grey-belt land. Much of that is agricultural land, which the Secretary of State said the green belt would not be.

The Secretary of State also told the House in a written statement on 30 July 2024 that much of the green belt is:

“better described as ‘grey belt’: land on the edge of existing settlements or roads, and with little aesthetic or environmental value.”

Given the actual definition of grey belt that the Government have decided on, the opposite is surely true. By their definition, the land on the edge of existing settlements or roads is in fact more likely to be green belt, and land further from existing settlements is more likely to be grey belt.

Why does any of this matter? It matters because grey-belt designation is intended to facilitate more development—that is the point. The Government are trying to release more land that is currently called green belt for housing and other things, so it matters what land the Government are actually making it easier to develop with grey-belt designation. The reality is that the land that the Government are making it easier to develop is not disused car parks and garages or ugly wasteland; it is agricultural land and open countryside.

We can see an indication of that in the decisions of planning inspectors in cases where developers have argued for grey-belt status. The Campaign to Protect Rural England has examined cases in the year following the first definition of grey-belt land in the NPPF of December 2024. In that period, planning inspectors approved 13 developments of 10 or more houses on green-belt land, which they believed should be reclassified as grey belt in accordance with the Government’s definition. Of the 1,250 homes those schemes deliver, nearly 90% are in previously undeveloped countryside, not on wasteland or former car parks.

I appreciate that the Minister may say that grey-belt designation is not enough on its own to allow development; other criteria must also be met. That is so, but it is worth examining those other criteria. First, development on green-belt land must also meet an unmet need, but with many councils unable to demonstrate a five-year land supply—often, it has to be said, due to recent increases in Government housing targets, to which I may return—I suspect that, routinely, that unmet need will be easy to demonstrate.

Secondly, the development must be in a sustainable location, but sustainability is an elusive concept. If I am right that most grey-belt land will be in countryside away from urban settlements, then transport infrastructure, health and education provision and even mains gas and sewerage may well be less plentiful. Therefore, we have to ask if many of the grey-belt locations will really be sustainable. Presumably, the Government must believe so, or grey-belt designation is not going to move the needle on housing provision.

Perhaps the Minister expects to see considerable infrastructure upgrades to rural grey-belt locations, but that will be expensive and will affect the viability and deliverability of the housing developments that the Government may be relying on. Then housing developments in grey-belt locations must provide more social housing than elsewhere—perhaps 50% of the total. Whatever the merits or viability of that, social houses will have the same impact on the openness of the green belt and our countryside as any other kind.

Finally, the Minister may remind us that, according to the NPPF, a development on grey-belt land may only take place if it

“would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan”.

I accept that, theoretically at least. That brings back into consideration both the encroachment of the countryside and urban regeneration. Again, it is worth exploring how valuable and usable that safeguard is likely to be, and it seems it will be challenging to argue. The plan area for most of my constituency is south Warwickshire. It would be difficult to claim that building on a single grey-belt site would fundamentally undermine the green belt in half the county, unless the cumulative effect of many grey-belt developments could be considered in measuring the fundamental undermining of the green belt. Would the Minister clarify whether the cumulative impact of other sites, in conjunction with the sites subject to individual consideration, will be relevant in that exercise? If not, why not?

I turn to the broader impact of the grey belt on the countryside. As I said earlier, it appears to me that grey-belt land as the Government have defined it will increasingly be agricultural land and other land in the countryside, which will be easier as a result to turn into housing estates, warehouses or solar farms, for example. The protection for our countryside that green-belt status has thus far offered will be substantially eroded, and for constituencies with large amounts of green belt, that could be very significant.

My constituency is roughly 30% green belt, and others are substantially more. The residual green belt will be areas on the fringes of towns and cities but, to be clear, not around our villages, which are specifically excluded from the definition of an urban area in the NPPF. That might seem uncontroversial—logical even—but it has a practical effect in the context of the debate. That is because the difference between small towns and large villages is becoming increasingly academic. In my constituency, for example, the town of Southam had a population in 2024 of around 9,200, and the village of Wellesbourne had a population of around 7,600. Under the Government’s definition, small towns in the green belt can defend themselves from grey-belt designation, but large villages in the green belt cannot. Grey-belt designation means more pressure from development on villages and rural areas, more pressure on rural roads and schools, and more of our countryside lost to bricks and concrete on top of the huge housing developments already in and around villages in constituencies like mine.

It is hard to believe that that impact is accidental, because it has to be seen in the context of other changes the Government have made. Making it easier to build houses in the countryside goes hand in hand with revised housing targets from the Government that are higher in rural areas and lower in urban areas. My constituency, again, is a good example. Most of it falls within Warwick district and Stratford district, and just across the border is the city of Coventry. The Government have reduced Coventry’s housing target by 50%. The target for Warwick district, which is mostly green belt, has gone up by 65%. Stratford district’s new target is 99% higher. That is not accidental; it is a deliberate plan to transfer housing pressure from urban to rural areas.

It is no surprise, then, that the Government do not want the green-belt purposes of safeguarding the countryside from encroachment and assisting urban regeneration to stand in the way of grey-belt designation and easier development. However, my constituents and those of other Members present have seen considerable housing development around them already, and now they face even more, while predominantly Labour councils, it has to be said, in urban areas are not asked to find housing land within their own borders—land that would largely be brownfield sites. That is not just bad news for our countryside; it is bad news for our cities, too, as they will not get the new housing, particularly for first-time buyers and young families, that would help to revitalise the economy of places like Coventry.

It seems to me that the Government have described the green belt as one thing and then defined it as something else. It seems to me that there will be much more grey belt and much less green belt as the Government ask local authorities to review their green belt and as they or the Planning Inspectorate accede to developers’ arguments that the green belt they want to build on is actually grey. All of that will have a significant and irreversible impact on our green-belt countryside.

The Minister is of course entitled to disagree with my analysis or to tell me that I do not need to worry, but I would like him to address in particular the following points. First, does he accept that grey belt is likely predominantly to be open countryside and greenfield sites, contrary to what the Government originally suggested? If so, does he accept that the impact on our countryside in green-belt areas will be significant and destructive? Finally, is that likely impact deliberate or accidental? If accidental, will he look again at what grey-belt designation will likely deliver in practice? Will he be prepared to continue the conversation that I hope we will have this afternoon and seek to minimise the impact of this change on our rural communities, about which many of us are extremely concerned?

--- Later in debate ---

[Matthew Pennycook]

I will say two things in respect to that, and I will come on to detail how the approach works in relation to decision making very shortly. In general terms, developers can make whatever claims they like about any particular site across the country; it is for the local authority to assess whether, in its view, that site constitutes grey belt, if that is part of the application that is submitted. Where there is disagreement and it goes to appeal, I have set out exactly how planning inspectors need to determine such applications.

It is crucial to note that where grey belt is identified, it does not automatically follow that it should be allocated for development or released from the green belt, or that development proposals be approved in all circumstances. Other considerations in decision making are relevant, as I will expand upon shortly. I also want to stress that any alterations to green belt boundaries must promote sustainable patterns of development by ensuring that any alterations, taken together, do not fundamentally undermine the five green belt purposes of the remaining green belt when considered across the plan area. Considerations also include giving priority to the release of previously developed land in the green belt, then considering low-quality grey-belt land, which will include disused petrol stations and other previously developed land of that kind, although not necessarily be limited to it, and only then exploring other green belt locations.

To respond to the right hon. and learned Member for Kenilworth and Southam on whether allocating grey-belt land for development will necessarily lead to the cumulative erosion of the green belt over time, I would point out two things. First, as I have already mentioned, development proposals on grey-belt land must respond to a demonstrable unmet need—I will come to his points about the standard method shortly. Secondly, it is precisely to avoid the situation that we inherited—which was a haphazard and piecemeal approach to green belt land designation and release—that this Government have implemented the approach that we have. Its effective working is predicated on ensuring that designation and release take place in a strategic manner over time through local plans with a 10-year horizon, and in due course—because they are just as important—through spatial development strategies with a 20-year horizon. We want the approach to be plan-led.

[Sir Jeremy Wright]

I know that the Minister recognises the point that the hon. Member for Taunton and Wellington (Gideon Amos) was making to him is that, although we all want this to be a plan-led process, the NPPF still allows for grey belt designation to be achieved through an individual application, and that is what the Conservatives are also concerned about. I wanted to test him on this question of cumulative impact. He may come on to this later, in which case I apologise, but I put to him in my speech that if we look at an individual application or site, it may be difficult to make a credible argument that building there would undermine the purposes of the green belt across the plan area. On the other hand, if we look at a series of grey belt applications and their cumulative impact on the green belt across the plan area, it might be easier to demonstrate. Can he clarify which of the two the Government believe it should be?

[Matthew Pennycook]

I am more than happy to do so; it is a fair question. In terms of the sequential approach that local authorities need to take with grey belt assessment and green belt release through local plans, the test of fundamentally undermining is at a plan level. Local authorities look at all the sites they have assessed through a review to constitute what is grey belt and then select those that they might need to bring forward to meet assessed housing need. I cannot go into detail, but the joint local plan for south Warwickshire, which includes the right hon. and learned Gentleman’s constituency, is instructive in that regard. It has gone through its regulation 19 consultation and the authority is looking towards submitting that emerging local plan. That will release land equating to 1.54% of Stratford-upon-Avon and 6.99% of Warwick. That is a plan-led approach to green belt release that will meet need in that area. I will come on to speak about decision making, but that is the test, in terms of fundamentally undermining the five purposes in the remaining green-belt area. I will briefly speak about what the guidance says in that respect as well.

There have been several questions about decision making. It goes without saying that we want local planning authorities to get up-to-date plans in place. I repeat that ad nauseum; we inherited a dreadful situation, where less than a third of plan coverage was up to date. We cannot have a plan-led system with such low levels of coverage; we are doing lots as a Government to ensure that we are driving towards universal coverage, including intervening where necessary. However, when development proposals come forward outside of a local plan, the NPPF also provides a limited route for development proposals of grey-belt land in the green belt in certain circumstances.

When considering development proposals, decisions should be informed by green belt assessments, as I have previously referenced. Where grey-belt sites are not identified in existing plans or green-belt assessments, authorities should consider evidence, informed by our guidance, on whether the site strongly contributes to the relevant green belt purposes.

It is important to note that where a site is judged to be grey belt, development proposals on grey-belt land must also respond to demonstrable unmet need for the type of development proposed. If that does not exist, that is grounds for the local authority to refuse. It must also be sustainably located and meet our golden rules, which, as hon. Members are aware, require additional benefits to be provided to local communities— including higher levels of affordable housing, new or improved green spaces and improved local infrastructure where the green belt is developed—in recognition, and rightly so, of the value placed on that type of land.

As previously mentioned, the contribution that a specific plot of green-belt land makes to the relevant green belt purposes is only one consideration involved in the decision on whether to develop there. Decisions should also be informed by an overall application of the relevant policies in the NPPF. That includes policies in the natural environment chapter, which safeguard areas of importance for the landscape, geodiversity or biodiversity value, including protected landscapes and designated sites for nature.

To assist local planning authorities and other decision makers in both plan making and decision making, and to support a consistent approach to determine whether land is grey belt, my Department published updated planning practice guidance on 27 February last year. That PPG sets out a range of considerations to help to determine whether land is grey belt and how to consider proposals on potential grey-belt land. When considering how any given land performs against the relevant green belt purposes, the guidance also sets out illustrative features to help to inform judgments.

The PPG does not—we have been challenged on this point, so I want to address it head on—provide an exhaustive or overly prescriptive list that accounts for all possible scenarios. It is ultimately for the decision maker to consider those factors in accordance with national policy and guidance. It is right that they exercise their judgment in doing so, given that local context and development-specific considerations will vary markedly across the country. We want that flexibility to allow expert local judgment to be applied. The more prescriptive we get in national policy, the more edge cases and difficulties we will create. Our system is discretionary in nature; it is for local authorities and decision makers to make that judgment in the round.

To the point made by the hon. Member for Woking, in instances where a given application goes to appeal, and the relevant inspector is asked to determine whether a site is classified as grey belt, they will consider relevant legislation and national planning policy, including the NPPF and PPG, and any relevant local development plan policies and material considerations.

I want to briefly address the standard method and the urban-rural balance. This issue is put to me frequently in debates and I attempt to set the record straight, but it appears in the next debate none the less. The targets we have introduced are ambitious—they entail uplifts in many areas, and we expect rural areas to play their part in providing the homes the country needs—but the formula does direct housing growth to larger urban areas. It does not, though—this is the significant change we made—direct it by applying an arbitrary 35% urban uplift to the 20 largest cities and urban centres. That was the previous Government’s approach; we think it was arbitrary.

Instead, the standard method that we have introduced increases targets by 20% across city regions. It also better directs housing growth to a range of urban areas, including smaller cities and other areas of growth, as well as to the larger cities. We think that is a fairer approach. It is not the case that we have uniformly dropped housing targets across metro areas.

Before I conclude, I want to touch briefly on villages—

[Sir Jeremy Wright]

Before the Minister does that, I understand his point earlier about guidance, and I am certainly not asking him to comment on an individual application, but the purpose of the point that I made to him earlier was to suggest that the reality of grey-belt designation is that grey-belt sites are likely to be further away from urban settlements rather than closer to them, because those closer are more likely to remain as green belt. As the Minister says, there are three purposes—A, B and D—that would enable a site to remain as green belt rather than be designated grey belt. Can he see circumstances in which a field in my constituency that is not on the outskirts of an urban settlement could possibly satisfy the test of those three requirements and remain as green belt rather than be redesignated as grey belt?

[Matthew Pennycook]

I will address the right hon. and learned Gentleman’s specific question in due course. Before I do so, I want to put on the record the policy in relation to villages. He can rest assured that I will address the point; if he is unsatisfied, he is more than welcome to intervene again.

A number of hon. Members mentioned villages. The PPG that I have referenced throughout my remarks makes it clear that, in assessments of contribution to the relevant purposes, large built-up areas and towns do not include villages. However, neither the NPPF nor the PPG includes a definition of a large built-up area, town, historic town or village. Considering whether any particular settlement constitutes a village is, again, a matter for the given local planning authority to judge, and it may be informed by the adopted local settlement hierarchy in that area. Where authorities may wish to restrict development in villages for other reasons, a range of tools are available, such as conservation areas or normal development management policies.

On the right hon. and learned Gentleman’s specific point, I say to him directly that I do not recognise his assertion that grey-belt land, in every part of the country, is likely to be predominantly in open countryside. The guidance that I have referenced is clear that land that is likely to be assessed as grey belt is more likely to include “existing development” or “other urbanising influences”, with land that is free from development more likely to make a strong contribution to the three relevant green belt purposes listed in policy GB2.

A point that needs to be made generally is that this issue is incredibly place-specific across the country. It will vary widely, given the significant variation in how green-belt land is constituted in different geographies throughout the country, so it is very hard to apply a blanket or generalised approach, as the right hon. and learned Gentleman has, to say, “In all circumstances, such will apply.” It varies across the country and, as I have said, our policy as a whole ensures that development is directed towards sustainable locations, which will act to prevent development from coming forward in isolated or unsustainable locations. That hopefully clears up the right hon. and learned Gentleman’s point about open countryside—one of three.

[Sir Jeremy Wright]

Will the Minister give way?

[Matthew Pennycook]

I will give way to the right hon. and learned Gentleman one last time, but I am more than happy to set out the full policy in writing.

[Sir Jeremy Wright]

That may be very helpful, and I am genuinely grateful to the Minister, because I know he is doing his best to provide clarity. I know he would accept that the starting point for all these decisions will be the NPPF definition. I accept his point about guidance and the other qualifying criteria; we have spoken a little about the limitations that there might be on those qualifying criteria.

The substantial point remains, does it not, that the definition in the NPPF of grey-belt land overwhelmingly—perhaps not in every instance, but overwhelmingly—will be met by fields, farms and greenfield sites that are not near to urban settlements. A, B and D in the list clearly each relate to the fringes of urban settlements, and the Minister knows that the green belt encompasses more than just such sites. It is inevitable, is it not, that the starting point will be that grey-belt land will be those sites that are not on the fringes of urban settlements, which is of course the direct antithesis of how the Government originally described the concept.

[Matthew Pennycook]

I understand the point that the right hon. and learned Gentleman is making. I am afraid I do not agree with his characterisation of the policy, which is, again, in essence that grey-belt land in every part of the country is more likely to be found predominantly in open countryside.

All I can do is to repeat again our approach: land that is likely not to make a strong contribution to the relevant green belt purposes is likely to contain existing development or other urbanising influences. But I say again that it is for individual local planning authorities to make green belt assessments and to make judgments about sites that might constitute grey-belt land. If some of those sites—in most cases not all of them, but some of them—are required to meet demonstrable unmet need, it is for the authority to select the most appropriate and sustainable sites from that list. I refer the right hon. and learned Gentleman to his local plan, which is hopefully on the verge of submission—a small percentage of green belt will be released over the plan period to meet demonstrable unmet need.

[Sir Jeremy Wright]

Will the Minister give way again on that specific point?

[Matthew Pennycook]

I think I am testing the Chair’s patience. I will give way one more time.

[Sir Jeremy Wright]

I am sure the Chair will remind the Minister that we have plenty of time left in this debate.

On the specifics of the local plan, the Minister is right, of course, to point me to the specific statistics in relation to my local plan area. But he will recognise that, as was said earlier, there is a difference between decisions that a local authority makes about what to seek to extract from the green belt, and subsequent decisions about whether part of the green belt is in fact grey belt. The Minister has referred me to statistics relating to the former, not the latter.

[Matthew Pennycook]

This is where I come back to the importance of having up-to-date local plans. If a local planning authority has in place an up-to-date local plan, it may or may not include grey-belt sites, as the policy feeds through the system. At the point that an authority has a plan in place that meets demonstrable unmet need, it has robust safeguards against grey-belt applications that come through the decision-making route. That is why we are encouraging local areas to get local plans in place.

We have inherited a situation in which we have extremely low up-to-date local plan coverage. That has exposed communities to speculative development, and it is happening all over the country. We have to put in place policies that, through the decision-making route, allow homes still to be brought forward in that interregnum, but then we have to push heavily to drive towards universal plan coverage. At that point, the protections are in place. Over the 10-year plan period and, as we roll out spatial development strategies on a sub-regional level, over a 20-year horizon, that will ensure that there is a strategic plan for green-belt land designation and release.

To come back to the point I made earlier, it is not as if no green-belt land was released before 2024. I know the Conservative party likes to give the impression that it did not, but it oversaw plenty of green belt release, in a completely haphazard and unplanned way. We are taking a strategic approach, which we think is right.

I have addressed the right hon. and learned Gentleman’s point about what is likely to constitute grey-belt land. Let me directly address his other two specific points. Is this a significant policy? Absolutely, and it has been judged as much by the Office for Budget Responsibility and other external commentators. Is it deliberate? Absolutely. We want, as the right hon. and learned Gentleman asserted, to release more land into the system. This is where I take a principled different view from the CPRE and other commentators that say we can simply meet housing need through existing brownfield land. There is not enough land on existing brownfield land registers to meet the volume of homes that our country needs, let alone enough that is viable and in the right location. Where it is necessary, we want to see green-belt land released to meet demonstrable unmet need. It is right that when we look to release green-belt land, we focus on the lower-quality grey-belt land that does not make a strong contribution to those purposes.

To conclude, I again thank the right hon. and learned Member for Kenilworth and Southam for securing the debate, and other Members for their contributions. I hope that, while I may not necessarily have been able to convince Members in my response, I have been able to provide some valuable clarity on the national policy with respect to grey-belt land, and particularly the different approaches to plan making and decision making.

As set out in the Government response to the consultation on the new NPPF that was published last month, we have already recognised that further guidance may be helpful to support spatial development strategy-led strategic reviews of the green belt, and we will consider producing guidance on the considerations that should inform that process. As we update PPG to fully reflect the changes made in the new NPPF—and we absolutely must do that—we will of course consider whether any further clarity might be helpful to inform decision makers. To that end, I will reflect on a number of the points made in the debate.

[Sir Jeremy Wright]

I thank everyone who participated in the debate, from the Back Benches and the Front Benches. I particularly thank the Minister, who—there will be general agreement on this—is an excellent Minister. He tried to engage properly with the issues in the debate and to give us the clarity that we asked for. He is a perceptive man, and he is right when he says that he has not quite persuaded all of us of everything, but I am grateful to him for what he said last, which is that he will reflect on what has been said here and consider whether further clarity needs to be provided.

Ultimately, the evidence as to which of us is right about what the grey belt turns out to be will become apparent over the years during which the policy is used. If I can ask the Minister to reflect on one other thing, it would be that the Government keep under review—as I am sure they will—what the impact of the policy change ends up being. If we see a great deal of new development in open countryside within green-belt areas, rather than in the type of land that he and his Secretary of State have previously described as wanting the grey belt to be, I hope the Government will reconsider the policy and look again at whether it is doing the damage to the countryside that many of us fear it will.

Question put and agreed to.

Resolved,

That this House has considered the definition and application of grey belt land.