Green Belt, Brown Belt, Grey Belt – Why not the Whole Rainbow?
Is the Grey Belt enough? What the new NPPF means for environmentally-minded development.
British politics seems to have an intrinsic rhythm with regard to when major policy changes are made. Equivalent to some kind of parliamentary circadian rhythm, each election cycle sees a relatively predictable suite of updates in government policy and the executive - following the state opening of parliament, a new government is formed, the administration’s overall vision is laid out in the King’s speech, and (albeit belatedly this year) we receive our first budget.
It is no different with housing reform. The housing crisis, i.e. the sheer lack of high-quality or affordable housing across the UK, is a challenge that few administrations over the past few decades have been able to control. With this in mind, following every election cycle the new government always comes in strong with proposals for how to revolutionise the built environment sector and get us on a more favourable track, translating manifesto pledges into action.
How do they do this? By issuing an updated National Policy Planning Framework (NPPF), of course.
Early last year, as election campaigning was in full swing and each party was launching their respective manifestos, one major area where each sought to outflank the others was the guarantee of a new generation of British housing.
Now, with the Labour government firmly in power, having won a whopping 412 seats out of a possible 650, they are keen to prove that their promises relating to housing were more than another brick in the manifesto wall. We discussed Labour’s manifesto pledges on housing in a separate article.
Having released a draft updated NPPF in July of last year, it was shortly opened for public consultation. Consultees included various bodies, industry leaders and the general public.
After months of reviewing the consultation responses by the Ministry of Housing, Communities and Local Government (MHCLG), the final revisions were published on 12 December.
With the final version in mind, we at Love Design Studio decided to review what these proposed changes are and identify what this could mean for us as an environmental design agency and our industry at large.
True to the manifesto?
It seems the civil servants who drafted this latest NPPF wanted to make our lives a little easier this time around, seeing as they graciously decided to annotate the areas where changes have been made - formerly, it had only been through diligent cross-referencing with previous versions that we could deduce where it had been tweaked. You can find the tracked-changes version here.
From looking into the updated NPPF (NPPF24), we wanted to assess to what extent the changes made within it reflect manifesto pledges. And, as expected, we see a relatively mixed bag, with some pledges stuck to firmly, others ignored, and yet others kicked down the line.
First and foremost, it is encouraging to see that their headline announcement - that they would maintain the government’s target of 5-year housebuilding totaling 1.5 million units - remained untouched. This is unsurprising as, with Labour campaigning on a platform of housebuilding to not only meet the supply-side demands the country faces but to act as a necessary stimulus for the economy, a more tepid pledge would not have gone down well with the public. This is underscored by their previous condemnation of former governments’ lack of impetus in the planning arena; having described planning reform as a “graveyard of economic ambition”, Chancellor Rachel Reeves’ credentials would otherwise have been immediately weakened.
One key area in which they have stuck to their guns is in facilitating easier acquisition of land on which to develop. The current dearth of available land for development has, in recent years, severely limited our capacity to build new housing, leading to both a housing shortage and skyrocketing housing and rental prices. True to their promises, NPPF24 details how the government will free up poor-quality land in the bounds of the green belt - referred to as ‘grey belt’ land - to allow for its development. Whilst the government recognises the importance of the green belt in conservation and tackling urban sprawl, the targeted release of certain portions will provide much-needed supply.
They have also proposed adjustments to laws surrounding compulsory purchase orders (CPOs) whereby, if, in the public interest, the land could be acquired without factoring for hope value, overcoming the hurdle of prohibitively high land prices.
There are a number of other proposals beyond these, yet there are a handful that relate specifically to our work at Love Design Studio. Let’s dig into these.
Breaking new ground - digging into the grey belt
Our analysis of the alterations to the NPPF highlighted three key updates that will impact the built environment and sustainability consultancies at large.
The first of these lies in the grey belt. The term itself seemingly originated as Keir Starmer was laying out his vision for the country earlier in the year, leading to no small amount of confusion on what would constitute ‘low-quality green belt’.
This was, to a certain extent, cleared up in NPPF24. Looking into the glossary of terms, we find the following definitions:
“Grey belt: For the purposes of plan-making and decision-making, ‘grey belt’ is defined as land in the green belt comprising Previously Developed Land and any other parcels and/or areas of Green Belt land that make a limited contribution to the five Green Belt purposes.”
Alongside a few other footnotes and references, this starts to paint a clearer picture of the land that will and will not be freed up for development. The only challenge, however, is that some ambiguity necessarily persists. For example, there is concern about what defines a ‘limited contribution’ to the green belt. Land is often de-prioritised ecologically in terms of its value by the types of ecosystems that it supports - brackish, weedy plots of land are likely to be dismissed. However, with more and more ecological evidence emerging that thriving ecosystems are contingent upon a mixture of habitats, removing the protections of one could have further-reaching consequences than previously considered.
Speaking to our resident experts here at Love Design Studio, we asked if they had any comment to contribute on this development. Andy Love, our director, had the following to say on the issue of the grey belt:
“We worry that the newly defined ‘grey belt’, whilst trying to give more nuance to how we allocate land for development, might not go far enough. What could be envisioned is a more ‘rainbow belt’ approach, where the unique characteristics and value, whether that be social or environmental, of each plot of land is defined more stringently. Further, this approach would consider the value of different plots within the context of those around it - after all, you need many colours to make a rainbow!”
What we as a team consider a more appropriate approach would be to define the value of a plot of land in a more socially and environmentally apt manner, often referred to as taking an ‘intersectional environmentalist’ approach. Take, for example, an imaginary basketball court in suburban London. Whilst the environmental and financial value of this piece of land might be relatively low, the social value of this as a community spot should be factored in when making an assessment of its potential for development. Going deeper, consider that there were brackish shrubs growing at the margins of the plot, serving as a link between the neighbouring grassland at one end and woodland at the other. Seeing as this would constitute a wildlife ‘corridor’, its ecosystem value should be determined in relation to its proximity to other habitats, a key consideration in any biodiversity net gain (BNG) calculations for developers.
This would overcome the severely limited definition of grey belt. As opposed to the current bland spectrum of land allocation value, government regulations should reflect something more nuanced.
Figure: The spectrum of land allocation should be more reflective of its differential value to individual stakeholders, as well as its environmental value in the context of a wider ecosystem.
Finally, the last piece of encouraging additions we find within the updated NPPF are further provisions for what can be done with Green Belt land upon release. Clearly harking back to manifesto pledges surrounding getting low-income families into suitable housing, paragraph 155 onwards states that said new developments on “released land” must provide 50% affordable housing as a minimum. On top of this, developers must either increase connectivity to, or provide a greater number of, green spaces within local neighbourhoods. This is to ensure residents have ample access to green spaces, and that parks and recreation areas are within a short walking distance for end users.
Whilst this is evidently good news, particularly with multiple studies over the past few years demonstrating a strong positive relationship between access to nature and improvements in mental health, we at Love Design Studio are concerned that measures do not go far enough.
We worry specifically about the use of the term affordable housing. Sure, affordable homes are more closely aligned with the spending power of the average UK household, with property values and rents reflecting 80% or lower of local market rates. However, with housing prices rising due to inflationary pressures, this might not be enough to provide suitable housing as price points shoot further and further beyond household incomes. If the NPPF were to attempt to more accurately reflect the housing needs of the nation, greater focus would have been placed on the provision of social housing.
Whilst social housing was referenced within paragraph 155, it simply states that an “appropriate portion” must be allocated to social housing, without specifying a figure. This might give developers much-needed flexibility with regard to local housing needs, yet does little to address the overall housing challenges faced by the country.
In order to address challenges around homelessness and housing provision, we could have alternatively envisioned a mandate for all housing developers to work with local planning authorities to determine the appropriate levels of social and affordable housing. As an example, we could consider a Grey Belt region on the outskirts of London in a borough with high levels of deprivation with huge unmet housing needs. To free up this portion of what is essentially the Green Belt, the developers could be obliged to work with local authorities to undertake an audit of the local housing needs and, if their social and affordable housing pledges make headways in improving local circumstances, this would operate in the developers’ favour in terms of planning approval.
Win-win. Beleaguered local authorities could make progress in alleviating their housing problems, with developers rewarded with planning permission on previously inaccessible land.
How presumptive of them?
The second area of interest came in the NPPF24’s update to the presumption.
The presumption in favour of sustainable development is a clause included within the NPPF that promotes plans with sustainable patterns of development, meaning those that seek to improve the environment, mitigate climate change, enact climate adaptation, and generally meet the development needs of the area. Part of the new government’s appeal with regards to their housing plans derived from historic promises to “reform and strengthen” the presumption, further prioritising sustainable practice within the development pecking order.
And it seems that some moves have been made in this direction, yet only marginally. Specifically, the language used within one explanatory paragraph has been modified, suggesting the presumption has become somewhat stronger in cases where “policies for the supply of land are ‘out of date’”.
The prior iteration of the NPPF stated that the presumption becomes triggered in cases where “no relevant development plan policies” are in place, or those policies “which are most important for determining the application are out of date”. Now, the updates included state that these “most important” policies, which had previously been the subject of extensive debate, relate specifically to the supply of land. Essentially, the update provides greater clarity for when the presumption is triggered.
Overall, the effects of this change are uncertain, yet we can guess at a few. Primarily, we hope to see an expedited approval process for housing where it is needed most, allowing authorities to meet their local housing demands. There is, however, the concern that this could lead to overdevelopment, whereby individual development projects might themselves be sustainable, but the rate and degree of development within a given area would be too high for the local environment to tolerate.
One improvement to the NPPF24 that we would have recommended would involve taking a cumulative sustainability perspective on the development. This would mean that both the housing needs of the local authority and the impact of the development on the environment would be strictly tied to the level of pre-existing development in the area. This could subsequently be updated further to cover the environmental impacts of more macroscale infrastructural projects, such as roads and car parks.
Building for Net Zero
Key to the proposals in the new NPPF driving sustainable developments will be in encouraging a reduction in the carbon emissions and energy demands of developments over the course of their lifecycles - that is, across construction, use, and end of-life. This is alongside driving an increase in the UK’s renewable energy capacity.
In the NPPF24, the government lays out amendments that, it is hoped, will “increase support for renewable energy schemes, tackle climate change and safeguard environmental resources.” These changes supposedly underpin a large majority of the other government policies laid out, supporting high-skilled jobs, bringing down energy bills, and facilitating Britain’s green energy transition.
Largely, these measures are at the macroscale and have wide-reaching consequences for the UK’s energy infrastructure, and less so at the level of individual housing developments.
We are seeing new measures that will allow decision-makers to give more significant weight to the benefits associated with renewable and low-carbon energy generation. Local planning authorities (LPAs) are now mandated to support all forms of renewable energy projects, irrelevant of local benefit; whereas previously, the wording implied that only projects of high impact in reducing emissions would be prioritised, now all carbon-cutting projects, no matter the size of the impact, must be considered. Furthermore, these same LPAs are now obligated to identify suitable areas for renewable and low-carbon sources.
As with most of this updated NPPF, it is in the minutiae of wording where we find the real value; taking this example, simply by stripping out the word ‘consider’ from this paragraph of the framework, the greater onus is immediately placed on local authorities to actively find low-carbon solutions to their energy needs by identifying suitable areas for renewable energy development.
Analysts, however, are sceptical. Including these provisions within the wording of the NPPF has its value, of course, yet it does nothing to alleviate the development burden of already overstretched local authorities. In fact, with LPAs already overburdened and under-resourced, with urban LPAs in particular struggling to find suitable land for development, it only stretches them further. Despite Reeves’ recent autumn budget including some provisions to support LPA recruitment and training, it is unknown to what extent this will make a dent. Sure, this is not the remit of the updated NPPF, yet a government wanting to ameliorate these challenges would have provided complementary measures in local government settlements.
Whilst these updates are encouraging, few consider them sufficient to meet the scale of the challenge. In particular, we have seen little by way of ensuring that developments enshrine low-carbon principles in their construction or in terms of their overall design; energy production and energy consumption are two sides of the same coin, so if we can ensure renewables principles are embodied at both junctures, we can minimise the consumption of high-carbon energy throughout the lifecycle of property.
Key provisions we would like to have seen included:
New Low-Carbon Construction Principles: Strengthen portions of the NPPF24 that give greater incentives for the construction of properties through low-carbon means, including low-carbon concrete and steel, the use of more sustainable materials, and prefabrication. This would minimise emissions at the early stages of a property’s lifecycle.
Passive Cooling & Insulation: Give greater weight to proposals that minimise energy consumption over their use, including through integrating the principles of passive cooling (less energy use due to AC) and insulation (lower energy demands due to heating). Developments that have built-in energy sources, namely solar panels, could also be either further prioritised or mandated in appropriate areas.
Retrofitting Incentives: Addressing the lifecycle energy demands of new developments does nothing to alleviate that of existing properties across the UK. In a similar vein to Biodiversity Net Gain (BNG), we could envision a process whereby developers that commit to retrofitting either nearby properties or the local neighbourhood infrastructure to minimise energy consumption would be prioritised over other projects, possibly through the easier provision of land or planning permission.
We would have wanted to see amendments that prioritise the use of sustainable materials, embodying climate-resilient measures in housing design, and retrofitting existing buildings. The previous NPPF contained similar measures, but no amendments here included seem to bring us closer toward this goal.
The updated NPPF has indicated that some of its measures will promote a transition to more sustainable development across the UK, which is entirely welcomed by organisations such as our own.
Yet the overarching issue that we see within NPPF24 relates to its wording, or, more specifically, that tweaks to the wording are what the updates primarily focus on; with the housing crisis across the country only having grown over the past decade, a new NPPF with more teeth would have been more welcome.
This would have provided more mandatory measures, speeding up not only the development of new housing and infrastructure across the country, but ensuring that their specifications meet a new era where principles of sustainability take centre stage.
Starmer has historically been perceived as a ‘safe pair of hands’ and less of a radical than his Labour predecessor, so it was always unlikely that he would shake things up too much. Hopefully, a future NPPF will hold the answers we’re looking for.