5 golden rules: How the revised National Policy Planning Framework (NPPF) will unlock our green belt
Published: 29 January 2025
The Government has announced an overhaul of the planning system designed to accelerate housebuilding and deliver 1.5 million homes over this Parliament. It's critical to understand the real-world outcomes of the revised National Policy Planning Framework (NPPF) and how they will affect you, the economy, and our environment.
From introducing a new grey belt concept to initiatives on affordable homes and infrastructure projects, the Government has put changes in place through its consideration of five 'golden rules'.
- Brownfield first
- Grey belt second
- Affordable homes
- Boost public services and infrastructure
- Improve genuine green spaces
Rule 1: Brownfield first
What are the new plans?
The Government has proposed prioritising the development of new housing on brownfield sites, i.e. sites that have previously been built on and lapsed into a deteriorated state. These sites often include old industrial land, factories, mills, garages, and sites which may have significant pollution issues.
The ‘why’ is grounded in principles of sustainability, biodiversity, and availability of suitable connected land for development. The purported availability of brownfield sites helps to tackle the housing crisis, while protecting the green belt by limiting development and reducing the impact of urban sprawl.
The ‘how’ in practice is easy enough. The State of brownfield report 2022 by CPRE shows 1.2 million homes could be built on 23,000 sites covering more than 27,000 hectares of brownfield land across the UK. This would fill the UK’s entire housing quota for 3 years, almost meeting the 5-year target Labour have set themselves without touching virgin greenfield land.
- North West (167,461 potential homes)
- Yorkshire and The Humber (108,790 potential homes)
- West Midlands (99,600 potential homes)
Individual local authorities with the highest brownfield capacity in terms of housing plots include Birmingham City Council, Manchester City Council, and three London boroughs.
A 'brownfield passport' is set to be released in 2025, which will allow developers greater access to build on urban areas that have been designated as underused sites.
So, there is technically enough land to adopt this brownfield first policy, but it presents some challenges.
Developers have already expressed concerns about the plans and pointed to the issues that arose when targets prioritising brownfield were first implemented in the 1990s. The targets resulted in local authorities refusing to approve new developments on greenfield sites regardless of the local requirements. The Government hope to prevent a repeat of this by laying out a clear mandate and pushing their quotas for house building.
They have also approved £3 billion in guaranteed lending from UK banks for builders applying for funds intended to build new housing sites. This guarantee removes some risk for builders to take on housing development sites with lower potential margins.
The issue lies in the combination of two of the golden rules: brownfield first, and affordable homes. Developers have long maintained that developments should be planned and led by their expertise, allowing for more effective use of the greenfield sites available, but some balance needs to be struck for housing to be affordable.
Brownfield sites present some obvious challenges, and each has the potential to erode the developer's bottom line. The requirement for testing and remediation of brownfield land increases the overall cost of development, making the affordable housing quota harder to meet economically.
The newly summarised 'golden rules' provide some focus to help drive the housing agenda forward. As land quality experts, we have years of experience assessing brownfield sites and working with developers, local planning teams, regulators, and construction companies to tackle the challenges presented by potentially contaminated sites. This expertise naturally extends to grey belt sites, with the added sensitivity of working with sensitive environmental receptors.
By liaising with both policymakers and developers to establish an understanding of the new legislation and the challenges on the ground for developers, we hope to smooth the transition.
Rule 2: Grey belt second
What are the new plans?
The implementation of the grey belt designation is an interesting evolution to UK planning policy. The overall premise is that grey belt areas can be identified and used to help address the UK’s housing dilemma by building new homes while preserving the more valuable parts of the green belt. Grey belt land and its presence in new planning policy offers an auspicious solution to transforming once-neglected areas into productive and effective communities while balancing the need for housing with environmental sustainability.
The scale and availability of grey belt land is the subject of debate and the industry is working at pace to identify suitable sites. According to The Times, 3% of green belt land in England has the potential to be considered grey belt, which amounts to approximately 46,871 hectares. Some sources suggest this figure could be even higher.
At a national level, Labour are making policy that will help them hit their target of 1.5 million homes over the next five years. This new designation will free up space for housebuilding in areas previously blocked by red tape.
Labour are hoping to preserve the more valuable parts of the green belt – those areas of open countryside and rolling hills that you would associate with such a definition – while still meeting housing needs. The premise is that just over half of the green belt is agricultural land, with much of the rest in former industrial areas or land of poor environmental quality.
Labour are pledging more support to local authorities by providing additional funding and resources (including £100 million for planning officers), on top of bolstering local resources with increased planning fees to cover costs and an additional 300 planning officers, making sure they have the staff and capacity needed to approve homes for local people. This support is aimed at speeding up development decision-making and facilitating the identification and development of grey belt sites.
In addition to increased funding, the Government has already established a national committee to lead the initiative of finding grey belt sites, the Built Environment Committee. This committee requested input from interested parties last year and it’s assumed they’ll help steer clearer definitions of the national policy in 2025.
At a developer level, there are already many digital land survey tools offering a predictive mapping of areas that could eventually be labelled as grey belt once assessed.
Assuming the key objective of increased housing supply is met, there are several other likely outcomes to the identification and development of grey belt land, such as more balanced development with high-value green spaces and environmentally significant areas being protected. It can also be hoped that the development of grey belt land can stimulate economic growth by creating jobs in construction and related industries, as well as by attracting new residents and businesses to an area.
Grey belt land will likely pose the exact same challenges as brownfield development when it comes to identifying and dealing with legacy contamination. Following established processes to assess potential historical contamination will be required in addition to the consideration of viable, cost-effective and time-efficient remediation techniques.
Rule 3: Affordable homes
What are the new plans?
The Government launched the latest Affordable Homes Programme in 2021, to run through to 2026. The programme offers grants to facilitate building homes under the affordable housing quota. The fund received a £500m top-up in the latest Budget to account for the Government’s increase on the quota.
On affordable homes, developments on green belt land require that at least 50% of the new homes built must be affordable. This ensures that a significant portion of the housing addresses the affordability crisis. In addition, for grey belt land, the requirement is to deliver 15% more affordable homes that the local housing policy mandates, up to a cap of 50%. This allows a certain degree of flexibility. Once local authorities have new plans in place, they will have the flexibility to set the affordability requirement for grey belt sites themselves, enabling councils to scale up or down requirements specific to the local needs and market conditions.
There are other changes to the Right to Buy scheme which will protect social housing stock and facilitate more economical housebuilding for investors to effectively meet their quotas.
The need for stronger policy around affordable housing is clear, with the relative price of housing compared to average salaries in the UK having doubled over the last 20 years.
Most recent numbers show that 1.2 million households are on waiting lists to rent affordable housing. However, this figure is outdated and doesn’t reflect the overall number of households in need of affordable housing.
The Government has already allocated significant funds for developers to access as investments for affordable housing, as well as funds to aid local authorities in pushing developments forward. The £500 million in additional funding for the Affordable Homes Programme is an example of this.
There is also a significant £3 billion in guaranteed loans available for builders to undertake new developments, backed by the Government with UK banks and lenders. This is intended to remove some of the risk for builders in taking on brownfield sites that offer lower potential profits.
Access to the Affordable Homes Programme funding is only available for registered investors (details on how to register can be found here). Once built, the housing is then often owned by a registered provider, most commonly housing associations or local authorities.
Though these organisations fund and eventually own the housing, any private developer must consider a certain quota of affordable housing in their plans.
Affordable housing policy in the UK is likely to have several outcomes, including the obvious increased housing supply, with a focus on measures to ensure that housing targets are met in areas with the greatest need. This can bring about improvements in overall quality of life, including better health outcomes and educational attainment.
By increasing construction activity, the policy is also likely to stimulate economic growth, creating jobs and creating local opportunities.
It's a given that, as targets and quotas increase and opportunities are realised through the identification of grey belt land in addition to existing brownfield sites, the requirement for thorough site assessment, navigation of planning conditions, and likely site remediation will increase. We provide expert advice to guide developments from inception to completion, navigating any complexities around legacy contamination.
Rule 4: Boost public services and infrastructure
What are the new plans?
Alongside the need for new housing is a need for infrastructure to support the households who will live there, which means more land to develop.
To build this new infrastructure, chancellor Rachel Reeves has unveiled new plans to mobilise the pension funds of local authorities as infrastructure investment by taking a leaf out of Australia’s book. The plan is to combine smaller local pensions to create large 'mega pensions'; funds with more buying power to take on high-risk, high-return investments.
Building business, service, and transport infrastructure is an essential requirement to support the new homes that will be built under the housing policy changes. These new services and infrastructure links are also crucial to the UK hitting its growth goals.
The chancellor's latest budget included a 10-year national infrastructure strategy, outlining plans for transport, energy, and social infrastructure alongside the new housing policy.
The Government recently announced ambitious plans to speed up new infrastructure development by reforming the planning process in their Planning and Infrastructure Bill. The bill is set to be released in early spring 2025.
The plans aim to target housebuilding around popular commuter train stations, remove red tape that has blocked developments starting, and allow the Government to step in on specific high-profile developments. These reforms will see developers applying for projects in key areas receive a default 'yes' response to their application.
Environmental impact assessments have been identified within these reforms as potential blockers that will be scaled back and simplified to prevent them stopping new project work taking place. It has been recommended that environmental outcome reports will replace the previous assessments, seeking to simplify the process and save time and money for developers.
The announcements have been met with enthusiasm by major developers, who see the plans as a great indicator of this Government following through with their mandate to take charge of the UK’s housing issues.
More developments are still being discussed in a working paper, as the Government seeks input from the market and local authorities before releasing their finalised plans. Within the proposals are plans to place a moratorium on the statutory consultee system, which had been identified as a bottleneck slowing down new projects.
One of the major driving forces behind the new proposed system will be the Government itself. Since 2011, previous governments have made decisions on 130 major infrastructure projects; Labour have committed to 150 over five years in their new plans.
Between this self-set target and their ongoing hedge-trimmer approach to any red tape they find, it’s clear the Government is highly motivated in hitting their target of 1.5 million new homes – and the infrastructure growth required to support them.
Removing bottlenecks and blockers is intended to allow stalled developments to go ahead and speed up the approval of new project applications.
The moratorium placed on new statutory consultees, a default 'yes' for new projects in commuter hubs, and the environmental outcome report are examples of suggested changes to achieve this supercharging of growth in the UK.
Another major new policy to benefit developers is the announcement of the Nature Restoration Fund. Under previous rules, any new development was required to include a mitigation or compensation strategy for offsetting environmental harm caused by the project. These environmental obligations were often an unnecessary expense and ultimately ineffective. The new rules aim to create a less siloed and bureaucratic system for a better structure and more strategic plan. Developers will now be able to pay into a pooled fund that will be available for environmental expert bodies like Natural England to use in taking a strategic, national approach to species and habitat management.
Within the latest Budget, £70m was allocated to ensure new infrastructure developments considered and allowed for appropriate environmental protections.
Rule 5: Improve genuine green spaces
What are the new plans?
No policy changes are clear yet on defining how this initiative will be implemented, but it is likely to be an expansion of the Local Green Space designation.
The previous designation was created in the 2012 planning policy framework. According to the CPRE, a total of 6,515 locally valued green spaces have been protected under the Local Green Space designation since its introduction.
The legislation has been key for councils in preserving some green spaces without another protection, e.g. area of outstanding natural beauty (AONB) or green belt land. However, findings show the areas that are most in need of green spaces are the same ones where the designation has been used the least.
Green spaces are key to people’s mental wellbeing and the UK's biodiversity, but these spaces need to be of sufficiently high quality to benefit our wildlife. Areas of poor aesthetic and ecological quality offer little for us or our environment.
The underuse of previous legislation may indicate the powers weren't sufficient, incentives to use the legislation weren’t strong enough, or the benefits hadn't been properly communicated to local authorities.
The requirement to expand the policy and ensure the new housing policy includes genuine green spaces is explained in full in the CPRE’s Local Green Spaces 2023 report.
Designating Local Green Spaces is part of the process of planning new neighbourhoods, so any new developments under the new planning policy framework will account for required green spaces.
The Local Green Space designation can only be used where the green space is:
- in reasonably close proximity to the community it serves,
- demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity, or richness of its wildlife; and
- local in character and is not an extensive tract of land.
So, we know how the green spaces will be designated and protected, but not yet how the Government intends to build upon previous policy. It could be that the genuine green spaces policy removes protection from low-quality Local Green Spaces, much like the grey belt policy will remove green belt protected status from low-quality green belt land.
The Open Spaces Society has expressed some concerns that the new planning policy framework doesn’t do enough to protect Local Green Spaces as a policy and that more can be done to improve genuine green spaces.
Some of the proposed changes to the policy include enclosing some green spaces as town or village greens or granting local people recreation rights over the space permanently.
The CPRE has also provided a list of recommendations based on its own reports. They suggest standardising the definitions being used to designate Local Green Spaces and placing greater importance on their approval during the planning process.
The outcome of any changes to Local Green Spaces legislation are most likely to affect the planning stages of a new development, and potentially free up more space for development in areas that lose the designation if they’re low quality.
Developers planning new projects will have to place greater emphasis on ensuring they factor in higher-quality green spaces with better ecological value. This will mean a more considered approach to how areas of nature are included in the planning of new neighbourhoods and towns.
The challenges that lay ahead for meeting development demands within the UK, and the associated changes to planning policy, need to be met by an adaptable and forward-thinking industry. The requirement for a well-resourced and skilled construction sector will be paramount in ensuring planned developments reach the point of completion.
The introduction of the grey belt provides a sensible change to the restrictions placed on existing development and will provide a remit to develop within areas previously blocked by restrictions.
The realisation of development schemes on land that may have been subject to a more contaminative past has consistently required the application of a phased approach to assessment and remediation. The release of sites where a certain amount of red tape has been lifted, but where development may not be as straightforward, adds further demand for proactive and risk-based solutions. We have the necessary skills and experience within our land quality team to meet these challenges.
Please contact our experts to find out more about how you can leverage the revised legislation to create opportunities for you.
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