Updates to the Planning Practice Guidance relating to the Green Belt

Earlier this year, we commented on the revised National Planning Policy Framework (NPPF) published on 12 December 2024 which introduced the concept of grey belt land and the Golden Rules for housing developments in the Green Belt. The Government has now published new planning practice guidance (PPG) on Green Belt land which outlines the steps to be taken by Local Planning Authorities (LPAs) in assessing Green Belt land to identify grey belt, assessing development proposals on grey belt land and the Golden Rules (specifically accessibility to green space).

In regard to plan making, the PPG outlines five (5) key steps to be undertaken by LPAs in assessing Green Belt to identify grey belt land and determine whether it should be released for development.

Step 1: Identifying the location and appropriate scale of the area to be assessed

The Government advises that in most cases LPAs will need to divide their Green Belt into separate assessment areas when identifying grey belt. Such assessment areas should be tailored to local conditions and circumstances. In particular, these areas should be significantly granular to enable the assessment of their variable contribution to the Green Belt purposes.

Step 2: Evaluation of the contribution of the identified assessment areas to the Green Belt purposes in (a), (b) and (d) of para 143 of the NPPF

For each of the relevant Green Belt purposes, the PPG lists ‘illustrative features’ that make a contribution to the purpose and suggests how that contribution could be ranked as “strong”, “moderate” or “weak”.  Although, the illustrative features lack detail this provides a useful starting point for LPAs and may help achieve more consistency across the country. The PPG confirms that the scale of settlement to which the relevant Green Belt purposes relate to are towns and not villages.

Step 3: Consideration of the policies at footnote 7 of the NPPF and whether these provide a strong reason for preventing development of the assessed area

When determining whether the policies in footnote 7 provide a strong reason for preventing development in the assessment area, LPAs should consider where grey belt would be covered by or affect other designations in footnote 7. The PPG notes that land may be provisionally identified as grey belt land ahead of more detailed proposals coming forward enabling the application of those policies to be considered.

Step 4: Identifying Grey Belt Land

After considering the conclusions from steps 2 and 3, an assessment area can be identified as grey belt land where: 

• it is considered that it does not strongly contribute to any one of purposes a, b, or d of paragraph 143 of the NPPF; and
• the application of the policies in footnote 7 (other than Green Belt) does not provide a strong reason for refusing or restricting development.

Step 5: Identifying if the release of such land would fundamentally undermine the five Green Belt Purpose (taken together) across the whole area of the plan  

The Green Belt assessment should consider whether the release of Green Belt land would fundamentally undermine all five (5) Green Belt purposes across the plan area. LPAs should consider whether the development would compromise the ability of the remaining Green Belt to effectively fulfil all five of its designated purposes.

Other updates to the PPG

Decision making

In respect of decision making, the PPG reiterates the position as detailed in the NPPF and highlights that the guidance provided in respect of steps 2, 3 and 5 (above) should be applied in the same manner in relation to the application site. 

Sustainable locations

The PPG emphasises that where grey belt land is not in a location that is or can be made sustainable, then development on such land is to be considered inappropriate. When determining whether locations are sustainable, LPAs should consider the local context and site or development specific considerations. 

Green Space and the Golden Rules

Major housing development on Green Belt land or land released from the Green Belt should contribute to accessible green space. The PPG provides further guidance as to the type of contributions required. For example: green spaces should be safe, visually stimulating and attractive, include safe active travel roues (where possible) and such contributions should be secured through the use of conditions or planning obligations. 

Viability

The NPPF states "the use of site-specific viability assessment for land within or released from the Green Belt should be subject to the approach set out in national planning practice guidance on viability." Currently, the PPG states that where development takes place on land situated in, or released from, the Green Belt and is subject to the ‘Golden Rules’ a site specific viability assessment should not be undertaken or taken into account for the purpose of reducing developer contributions, including affordable housing. However, the Government have advised that it intends to review this guidance before the end of the year and will be considering whether there are circumstances in which site-specific viability assessments may be taken into account.

Conclusion

Given the Court of Appeal decision in Mead Realisations Limited v Secretary of State [2025] EWCA Civ 32 which confirms that the PPG has the same legal status as the NPPF, the recent updates to the PPG are intended to achieve a more consistent approach to identifying grey belt land by LPAs and decision makers, including on appeal.