The Green Belt. What it is and why; what it isn't; and what it should be

‘I began to see what a sacred cow the Green Belt has become’.

Richard Crossman, Minister for Housing & Local Government, in 1964.

The need for change

The mere mention of the words Green Belt raise hackles. There are some who consider it’s present boundaries to be sacrosanct. According to recent Ipsos polling, six in ten people in England would retain it's current extent of Green Belt even if it restricts the country's ability to meet housing needs. There are some, including leader writers at The Economist, who would do away with it all together. Neither position is tenable, but there is a trend towards an entrenchment of these positions that makes sensible conversations about meeting housing needs almost impossible. The status quo is unsustainable, both literally and figuratively.

The past

In both planning and cultural terms, the notion of a ‘Green Belt’ goes back a long way. Long after Thomas More’s ‘Utopia’ and Elizabeth I’s ‘Cordon Sanitaire’ in 1580, the roots of the Green Belt can be found in Lord Meath’s ‘Green Girdle’ in 1889 and the London Society’s Development Plan for London in 1919.

David Niven suggested in 1920 a series of arterial roads to reduce congestion and potentially support an ‘outer park system, or continuous garden city right round London, [that] would be a healthful zone of pleasure, civic interest, and enlightenment’.

It is interesting to note that from the 1920s onwards there was an explicit link between stopping the outward spread of the city and the construction of new settlements elsewhere, but the third and final wave of new town designations were made between 1967 and 1970.

It is also interesting to note that at the turn of the 19th century, as Octavia Hill was founding the National Trust to preserve the countryside and to protect ancient and beautiful buildings, at the same time the Arts & Crafts movement was helping to romanticise the countryside. Although it evolved in the city, at its heart was nostalgia for rural traditions and 'the simple life'.

From these roots, the Greater London Regional Planning Committee proposed a Green Belt around London in 1935 and the Town & Country Planning Act 1947 allowed local authorities to include Green Belt proposals in their development plans, but the concept did not obtain statutory force until the first county development plans in the 1950s.

As Steve Middlehurst has noted, the wars further reinforced the notion that the countryside is fundamental to a national sense of identity:

‘In both the first and second World Wars images of the rural idyll were used as recruitment posters and reminders of “what we are fighting for”; inferring that it was not the industrial might of one of the World’s great economies or the largest empire ever seen, or the cities where most of the population lived that defined Britain as a nation; instead a shepherd and his flock walking across a stylised hill side in view of the English Channel was the essence of Britishness.’

The nationwide pattern of Green Belt that has emerged since is not the result of a strategic review. A Conservative government promoted the establishment of Green Belts in a 1955 Circular, which some county councils did and some county councils did not. 15 urban cores are now enclosed (at least in part) by Green Belt, including Blackpool, Burton, Morecombe and Stoke. Leicester, Hull, Southampton and Brighton are not.

The here and now

The Green Belt remains, as it had clearly become to Crossman in 1964, a sacred cow, but, worse than that, the very name has come to evoke strong, often misunderstood feelings, which are now entwined with attitudes towards both development and the countryside generally. As an influence on the commencement, progress and adoption of local plan reviews, Green Belt is arguably the greatest.

In November 2017 Sajid Javid wrote to 15 LPAs about local plan progress, 12 of which had Green Belt within their boundary.

As Lichfields reported in April 2022, ‘a slew of local plans have been withdrawn, ‘shelved’, stalled, or are not taking on the feedback of local plan inspectors in recent weeks and months’. Many of the delays, it was noted, particularity in the South East of England, are linked to the vexed issue of housing needs, which ultimately, in discussions about how and where to accommodate need, come back to Green Belt.

Indeed, as Lichfields also reported in May 2022, of the 70 LPAs who have not adopted a new local plan in the past ten years, 74% contain Green Belt.

Local plans are about much more than housing numbers, which means that the inability to grapple with housing needs, distribution and Green Belt has a negative impact on the other areas of policy that local plans should be tackling. Areas like, for example, employment land, transport and climate change reduction and mitigation.

Notwithstanding provision for National Development Management Policies (see below), there is the little in the Levelling Up & Regeneration Act that materially affects Green Belt and it’s influence on plan-making. An accompanying policy paper states that ‘existing Green Belt protections will remain and we will pursue options to make the Green Belt even greener’.

What Green Belt is

According to a 2021 House of Commons Library briefing, the Green Belt in England extended to 1,652,300 hectares in 1997. According to a 2023 DLUHC statistical release as of March 2023 it extended to 1,638,420 hectares or 12.6 of the land area.

Paragraph 142 of the NPPF states that the government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

Paragraph 143 states that it’s 5 purposes are:

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

Paragraph 145 states that there is no requirement for Green Belt boundaries to be reviewed or changed when plans are being prepared or updated.

Paragraph 146 states that before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development, which will take into account whether the strategy:

• makes as much use as possible of suitable brownfield sites and underutilised land;
• optimises the density of development, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and
• has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.

Paragraph 147 states that when drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account and that LPAs should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land.

Paragraph 150 states that once Green Belts have been defined, LPAs should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.

What Green Belt is not

‘May I say at once that the designation of the green belt is not a measure for the protection of the countryside.’

JR James, a senior civil servant in a talk to the CPRE, 1959.

According to the CPRE, 34% of England’s nature reserves, 34% of Community Forests and 22% of historic parks and gardens are in the Green Belt, but these sites would be subject to these protections regardless of a Green Belt designation.

The CPRE launched an "Our Green Belt” campaign in 2015 to show the Government how important it is us'. According to the CPRE:

It’s where we relax. It’s where we watch wildlife. It’s where we take part in our hobbies. It’s where we eat and drink. It’s where we feel inspired. It’s where we make memories.

'Come on, Kids. It's Sunday afternoon. Let's go to the Green Belt...' said no parent ever.

Land is not included in the Green Belt for environmental, ecological or recreational reasons. The Green Belt does not protect special parts of the countryside. Other planning designations such as Areas of Outstanding Natural Beauty, National Parks and Sites of Special Scientific Interest, among other designations, do that. Outside of Green Belt, a further 26.4% of land in England is designated as either a National Park, an Area of Outstanding Natural Beauty, or a Site of Special Scientific Interest. This means that 37.2% of land in England is designated as either Green Belt or one of these other designations.

Whilst 33% of England's Green Belt is, as the Adam Smith Institute point out, intensively farmed, land is also not included within the Green Belt for the purposes of food security.

Public opinion

According to a 2015 poll from Ipsos Mori (commissioned by the CPRE to mark 60 years of Green Belts), even though 70% of the public claim to know little or nothing about the Green Belt, 65% of people know that it should not be built on. Only 23% of people claimed to know a 'fair amount' about the Green Belt and a quarter of people had never even heard of it (62% for 15-24 year olds).

Another Ipsos Mori poll for campaign group ‘Housing the Powerhouse’ in 2017 found net support for Green Belt release across Greater Manchester where this would result in investment for infrastructure and services.

These messages were endorsed in polling for the Adam Smith Institute in 2021. Of all the ways of places to build homes the Green Belt was least popular, even when within walking distance of train stations. That said, a majority of respondents had an incorrect understanding of what the Green Belt actually is.

The topic remains incredibly controversial locally and is likely to have contributed to an increase in independent councillors. It was also striking that Rishi Sunak, whilst trailing Liz Truss in the Conservative Party Leadership race, saw a block on Green Belt development as a vote-winner amongst the party’s membership.

Public attitudes towards the Green Belt are though based on wildly over-estimated views on the extent to which the country is built on. According to the Ipsos polling referred to in the introduction to this piece, the mean guess (excluding don’t knows) for the percentage of land in England currently developed - defined as “land that has been built on and is occupied by a permanent structure such as a building or a road, a path or pavement, a railway line” - was 47.12%. This compares to the real figure of 8.7%.

The interchangeability in public discourse of Green Belt and greenfield and misconceptions about the recreational, ecological and landscape value of Green Belt, perhaps not helped by the term Green Belt itself, is evidence of the need to improve public knowledge and understanding of it.

The case for reform

Beyond the impact that the Green Belt is having on plan-making and public discourse on planning in the here and now, there are other compelling reasons for seeking reform.

Sustainable patterns of development

Development is “leapfrogging” the Green Belt. Rather than developing highly accessible sites on the edge of major cities that just happen to have been designated as Green Belt, homes are built instead around smaller towns on fields that to all intents and purposes are identical in amenity or agricultural value, but just happen to have a different planning designation.

As one example, courtesy of SLG, homes planned beyond the Green Belt required a new bus link to deliver people into the centre of the city. This increases vehicle miles to protect fields that were given a particular label solely to suit the preferred development pattern in 1950.

House prices

A 2014 paper by Hilber and Vermeulen estimated that house prices in the South East of England (where London’s green belt covers an area three times the size of Greater London) in 2008 would be 25% lower if the land supply was as flexible as that as the North East of England, which is still highly restrictive by international standards.

Brownfield land availability

There simply is not enough land within existing urban boundaries to meet future development needs.

A 2022 report from Lichfields analysed every local authority Brownfield Registers and concluded that, even if every identified site was built to its full capacity, the capacity of previously-developed land equates to 1,400,000 net dwellings, which is just under a third (31%) of the 4.5m homes that are needed over the next fifteen years. Even with significant government support, Lichfields concluded, brownfield land can only be part of the solution to the housing crisis. Further, brownfield land is not evenly distributed, and not well aligned to the demand for new homes in areas most in need.

According to recent research from Savills, 9% of the total residential pipeline coming forward in London in 2022 could become industrial as land values for this sector continue to rise. This would equate to the potential loss of 130,000 residential units, which is equivalent to over two-thirds of the new homes built in 2021 and speaks to the urgency of the issue.

In particular relation to London it is worth noting the following conclusions of the Inspector’s Report into the London Plan:

"Therefore from the evidence we heard the inescapable conclusion is that if London’s development needs are to be met in future then a review of the Green Belt should be undertaken to at least establish any potential for sustainable development"

Strategic priorities

Some form of Green Belt could contribute more to spatial planning priorities than the five tests currently included in the NPPF.

A 2016 report by the London Assembly’s Planning Committee concluded that:

If the Green Belt is to be retained, its functions should be redefined to fit the 21st Century. By performing a new range of strategic functions (such as contributing to climate change mitigation objectives) it may be easier to justify its retention in the face of housing demands. The new Mayor should revise Green Belt functions to reflect London’s 21st Century strategic priorities.

A 2016 RTPI policy paper stated that:

Planning policies such as green belts have enabled a managed approach to urban expansion, whilst avoiding urban sprawl around our major cities. The planning profession has championed this policy for over 60 years. However, it is important to revisit the purposes that green belts need to fulfil over the coming generation. The value of green belts is not simply about what is ugly and what is attractive, as some argue. We need to talk about what green belts are for, and about their social impact, along with their continued role in shaping and managing urban growth.

Green Belt reform

Reform 1a (short term) - Railway stations

In a paper for the Centre for Cities, Cheshire and Buyuklieva calculated that between 1.7 to 2.1 million new homes could be built on land within 800 metres of train stations within 45 minutes of the city centres of London, Manchester, Birmingham, Bristol, and Newcastle. This, it was stated, would increase England’s total housing stock by between 7% and 9% and use less than 1.8 per cent of the Green Belt.

According to the Adam Smith Paper highlighted above, 1 million new homes could be built on the 3.7% of the Green Belt within walking distance of a railway station.

Plan-led, coordinated development of this nature would result in manifestly better, more sustainable outcomes than non-plan, appeal-led development that an extension of the current local plan hiatus could foster.

The most recent NPPF states that there is no requirement for Green Belt boundaries to be reviewed or changed when plans are being prepared or updated. This change must be reversed. The preceding iteration stated that before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the LPA should have examined fully all other reasonable options for meeting its identified need for development (which includes brownfield maximisation, optimising density, and sharing need with neighbours).

That paragraph could be amended to confirm unequivocally that exceptional circumstances very much do exist if a LPA has gone through that process. It could then be made clear that that, when the thresholds for demonstrating exceptional circumstances have been met, land around new or proposed public transport nodes or land demonstrably shown by way of a Green Belt Assessment to be low-performing are likely to represent the most appropriate locations for new development.

Reform 1b (short term) - Grey Belt

The railway station proposition and a release of Green Belt on the objective basis of access to non-car travel had seemed to be gaining some traction as a policy solution, but appears to be less favourable presently than the concept of releasing Grey Belt, which Labour would reportedly introduce to "tackle the Tory "housing emergency" by allowing development on "ugly or poor quality Green Belt land" (the full press release can be found here).

Labour’s press release states that Grey Belt will be “a new class of land to ensure grey and poor-quality parts of the Green Belt are prioritised, and that any development benefits local communities”. It goes on to state that “poor-quality and ugly areas of the Green Belt should be clearly prioritised over nature-rich, environmentally valuable land. At present, beyond the existing brownfield category the system doesn’t differentiate between them. This category will be distinct to brownfield with a wider definition.”

We know then that Grey Belt is more than previously-developed land (PDL), which it needed to be because the redevelopment of such sites in the Green Belt is already supported by the NPPF and there is just not enough of it. According to Knight Frank, 11,000 pieces of PDL within the Green Belt could accommodate a maximum of only 200,000 homes. Rather though than expand the definition of PDL, which presently excludes, for example, agricultural or forestry buildings and land used for mineral extraction, there is specific reference to a new class. How then might what is also referred to as “poor-quality scrub land, mothballed on the outskirts of towns” be adequately defined for planning purposes and in such a way as to be distinct from PDL.

Such a definition make take in:

• Land that is or has been occupied by a permanent structure that is not captured by the current definition of PDL (so, for example, agricultural and forestry buildings);
• Land on the edge of urban areas that is or has been used for recreation (golf courses), but that excludes playing fields; and
• Land that has been significantly influenced or defined by the urbanising effects of development, transport infrastructure or non-agricultural human activity (pony paddocks or ‘rounding off’ a settlement inside a road or railway).

Defining Grey Belt in this way would go some way towards preventing the ‘gaming of the system’, which was a concern raised by some in response to subjective terms like ‘poor-quality’ and ‘ugly’ because of the need to prevent temptation amongst the owners of land that it is not poor-quality and ugly to allow it to become such.

In practical terms, were an incoming Labour administration to reverse the most recent changes to the NPPF and explicitly state that there is a requirement for Green Belt boundaries to be reviewed through the local plan process in order to meet housing need then a Green Belt Assessment would continue to identify the most appropriate site to do so, be they PDL, Grey Belt or green field.

Out with a local plan, which many LPAs will still be for some time, the next NPPF could offer the same explicit support to the development of Grey Belt sites as the existing one does for PDL.

Practicalities like the biodiversity value of such Grey Belt sites, and the stated ambition for 50% affordable housing, which may both render some Grey Belt sites unviable, will have to work themselves out in the wash, but arguably the most important element of the Labour announcement was recognition that “we cannot build the homes Britain needs without also releasing some land currently classed as Green Belt.”

Short Term Reform

Whether linked to public transport nodes or Grey Belt or both, the capturing of land value from these releases in order to provide compensatory improvements, which the NPPF already makes provision for, could support the release of sensible sites in the short-term and, in the absence of any other plans, add some flesh to skeletal proposal for ‘making the Green Belt greener’. Guidance could perhaps be strengthened in this area to make clear that for every hectare of Green Belt that is allocated for development at least of hectare of retained Green Belt will be improved by way of either environmental quality and accessibility.

Further, and whilst perhaps not a source of very many new homes, the NPPF could be amended such that a proposed neighbourhood plan allocation provides the exceptional circumstances required to amend Green Belt boundaries. At present a neighbourhood plan has to align with higher tier strategic policies, but if that strategic policy framework is not progressing, the community that would like to make, and benefit from, an allocation is not able to do so.

In the short-term also, the inclusion of Green Belt policies within National Development Management Policies could also provide an opportunity to standardise the approach to Green Belt Review / Assessment, which both the integrity and operation of current planning system would benefit from.

Of course, the Green Belt is very much a greater-than-local designation and, as the issues with planning in the here and now show, individual LPAs can struggle making the case unilaterally for amending the boundaries of elements within a particular administration area. The Green Belt is strategic policy that is best dealt with a strategic tier of plan-making.

Reform 2 (medium term) - repurposing & reappraisal

Despite statements to the contrary, the Green Belt is not ‘to provide fresh air and open spaces for 30 million people’. Nor are they ‘places to exercise, take part in hobbies, relax and appreciate nature’.

That being said, the NPPF does states that ‘once Green Belts have been defined, LPAs should plan positively to enhance their beneficial use.

This apparent contradiction, that opportunities for outdoor sport and recreation and the retention and enhancement of landscapes, visual amenity and biodiversity, can be a function of Green Belt once defined, but not one of it’s five principal features, is likely to add to the public confusion over what Green Belt is and what it is for.

Since then landscape and recreational amenity are legitimate factors to be taken into account in the planning of good places, and in the public’s mind are what the Green Belt is for already, there would be merit in factoring them into the reasons why Green Belt is designated. This too would also foster better, more sustainable outcomes.

Introducing landscape and recreational amenity as a purpose of Green Belt is not a major step on from encouraging LPAs to ‘plan positively’, but it would resolve at a stroke the toing and froing that goes on in the process of preparing a local plan about whether they should be. This toing and froing builds only mistrust, confusion and resentment and, either directly or indirectly, elongates the entire planning process.

Land that is intensively farmed, for example, with no landscape or recreational value would score proportionately lower in Green Belt value terms if new tests were introduced because, whilst they might be ranked, for example, moderate/high under five tests, they could be ranked moderate/low under, perhaps, seven tests by scoring nothing more in the new ones. Any parcels that do have landscape or recreational amenity value would score proportionately higher in value terms in any new test, notwithstanding that they might be covered by another restrictive designation anyway.

Beyond the short impact of recognising the potential role for land around railway stations, a further test of sustainability would formalise into the assessment process access to public transport.

A further benefit of a review of the purposes of Green Belt would be to put the appraisal / assessment process on a standard footing because the approaches that, for example, consultancies undertaken Green Belt Reviews and / or Green Belt Assessments can differ markedly. Reform of the EIA process also affords an opportunity to better link Green Belt Review/Assessment with the current Sustainability Appraisal process.

A review along these lines would protect sites worthy of protection, release for development sites that should be developed and, by doing so in a way that factored in more than the current five tests, do so in a more sustainable and equitable way.

Reform 3 (long term) - generational change

The CPRE has published a report calling on the Government to consult on and publish a national land use strategy that provides an integrated framework for local policy and decision-making on both planning and farming.

Going further than land use strategy, as the UK 2070 Commission identified, England does not have a spatial plan to provide a long-term framework for major infrastructure investment and development, which is something that most planners and built environment professionals would be supportive of.

Alongside such a plan could be a complete re-imagining of the role of Green Belt linked to a parallel plan for the growth of cities over a long period of time. A multi-generational boundary change could identify both high quality green space (to be brought under public control if not already) and developable areas (from which value could be captured over the very long term to fund intra and inter-city transport) in the places that need both. A ‘Royal Commission on the future Green Belt’ (or a review similar to that conducted by Bridget Rosewell into planning inquiries) could consider, example:

• realistic options for how the social and economic development needs arising in towns and cities be met, taking into account best practice in comparable advanced nations;
• the optimum spatial level of governance for designation and managing change in Green Belt;
• a clearer policy framework for designation, appraisal and management of change in current Green Belt; and
• how to enhance the landscape, ecological and recreational value of Green Belt land.

Such a review might even conclude that the next century’s Green Belt should be called something different.

As Create Streets concluded in 2018, most countries that have urban containment policies with teeth would appear either to have processes for adjusting them (or have already adjusted them) or to permit more of a ‘green wedges’ or ‘green fingers’ approach. This was found to be the case in Denmark, Australia, Holland, New Zealand and South Korea. It is a shift in thinking of this order of magnitude that is required in the long term.

Summary

‘If the Government and the county councils succeed in preserving the Green Belt around our large cities over the next ten years without having taken strong and effective action to guide jobs and people together to many more now and expanded towns they will have worked the biggest confidence trick since the South Sea Bubble’.

Wyndham Thomas, TCPA.

“Government leadership was necessary then, as now, to balance the competing requirements for land.”

Jonathan Manns, London Society Paper.

The Green Belt continues to loom large as a public policy behemoth, but at best it is having a polarising impact on local planning and at worst it is becoming electorally toxic to even tackle. This is to the detriment of everybody involved in the planning system and what it is they are seeking to achieve. The Green Belt presently could be said to be doing more public harm than public good.

Every attempt should be made by planners and politicians over the short, medium and long-term to remove rancour from and reframe current debates about Green Belt. There is a need in the short and medium term to identify sensible, public transport-based allocations so that LPAs can get local plans adopted. There is a need in the long term for a Green Belt or Green Wedge or Green Finger policy that is fit for the 21st century and the sooner a Royal Commission (or similar) is instructed to set to work on that the better.




N.B. It is intended that this piece be a living document that evolves over time. If you are interested in this topic and would like to suggest any improvement to the essential pitch, which is the case for a Royal Commission, please feel free to get in touch with me via samstafford@hotmail.com.