Unlocking grey belt potential through joined up planning expertise

The introduction of grey belt has seen the biggest shake-up in Green Belt policy since its inception, until the updated December 2024 NPPF this policy had hardly changed in decades. The opportunity for grey belt land is now vast and our teams understand how to unlock its potential. Our integrated advisory services combine planning, landscape, heritage, and strategic communications expertise to deliver sustainable, commercially viable, and well-articulated developments.

Since the concept of grey belt was introduced in 2024, we have completed over 60 appraisals for our clients. By integrating planning, landscape, heritage, and strategic communications expertise, we offer clients a co-ordinated and efficient route to bringing grey belt sites forward, strengthening evidence, reducing risk and helping unlock sustainable development where it is most needed.

We provide expert heritage, townscape and landscape analysis to inform conclusions on whether land comprises grey belt. Our appraisals assess whether land meets the definition of grey belt as set out in the December 2024 NPPF and the Planning Practice Guidance on Green Belt (February 2025). We evaluate the contribution a site makes to Green Belt purposes a), b) and d), drawing on our professional landscape and heritage judgment and a robust understanding of context and a site’s contribution to the function of the grey belt. We also assess whether any areas or assets of importance identified in Footnote 7^[1] of the NPPF, within or in proximity to the site, are likely to provide a strong reason for refusing or restricting development. This work is proportionate and pragmatic and is designed to clearly articulate risk, opportunity, and scope for landscape-led solutions at an early stage. For more information on our Heritage, Townscape and Landscape service please contact Joanna Ede and Kerrie Melrose.

[1]While the draft NPPF proposes omitting consideration of Footnote 7 from the identification of grey belt, relevant considerations, including landscape and heritage significance remain important material considerations in planning decisions. These matters will, therefore, continue to carry significant weight and should be addressed from the outset of any proposal. Our landscape and heritage team can provide informed early-stage feasibility advice to help identify and manage potential implications.

Key Contacts

Joanna Ede

Director, Head of Landscape

joanna.ede@turley.co.uk

+44 794 138 6544

Kerrie Melrose

Director, Heritage and Townscape

kerrie.melrose@turley.co.uk

+44 792 054 7592

Planning

The planning context for grey belt includes understanding the role and purposes of the relevant area of Green Belt including its original rationale and relevant history. We draw on published Green Belt Assessments and apply their findings in the context of current policy, guidance and case law on grey belt. This includes critiquing whether previous work correctly interprets the strategic purposes of Green Belt; assesses land at a suitably granular level to inform identification of grey belt; and whether relevant circumstances have changed since the assessment was undertaken.

In making the case for development of grey belt land we assess the nature of any unmet development needs. This includes undertaking reviews of likely future five-year housing land supply; Housing Delivery Test performance; and assembling evidence of needs for employment land and energy infrastructure. These inform whether a development can be regarded as “not inappropriate” within Green Belt and benefit from an additional presumption in favour of permission. For more information on our Planning service please contact Dave Trimingham.

Heritage, Townscape and Landscape

We provide expert heritage, townscape and landscape analysis to inform conclusions on whether land comprises grey belt. Our appraisals assess whether land meets the definition of grey belt as set out in the December 2024 NPPF and the Planning Practice Guidance on Green Belt (February 2025). We evaluate the contribution a site makes to Green Belt purposes a), b) and d), drawing on our professional landscape and heritage judgment and a robust understanding of context and a site’s contribution to the function of the grey belt. We also assess whether any areas or assets of importance identified in Footnote 7^[1] of the NPPF, within or in proximity to the site, are likely to provide a strong reason for refusing or restricting development. This work is proportionate and pragmatic and is designed to clearly articulate risk, opportunity, and scope for landscape-led solutions at an early stage. For more information on our Heritage, Townscape and Landscape service please contact Joanna Ede and Kerrie Melrose.

[1]While the draft NPPF proposes omitting consideration of Footnote 7 from the identification of grey belt, relevant considerations, including landscape and heritage significance remain important material considerations in planning decisions. These matters will, therefore, continue to carry significant weight and should be addressed from the outset of any proposal. Our landscape and heritage team can provide informed early-stage feasibility advice to help identify and manage potential implications.

Key Contacts

Joanna Ede

Director, Head of Landscape

joanna.ede@turley.co.uk

+44 794 138 6544

Kerrie Melrose

Director, Heritage and Townscape

kerrie.melrose@turley.co.uk

+44 792 054 7592

Strategic Communications

We assess and advise upon the local stakeholder landscape to help deliver positive planning outcomes for grey belt sites. Many local areas and planning authorities are subject to numerous grey belt applications. Understanding stakeholder responses to other grey belt applications can inform the best approach to new applications, including stakeholder targeting, and identifying preferred infrastructure provision and affordable housing to satisfy the “golden rules”. Our team then delivers the resulting strategy all the way through the pre-application, post submission, determination and (if necessary) Appeal stages. For more information on our Strategic Communications service please contact David Blackadder-Weinstein.