The draft National Planning Policy Framework continued – amendments to Green Belt and Grey Belt

Following our article published on 23 January 2026 The draft National Planning Policy Framework, a new direction and a new balance, we consider below some of the proposed changes to the green/grey belt policies in the draft National Planning Policy Framework published in December 2025 (“the draft NPPF”).

Plan making

The most consequential changes sit within the plan-making framework of the draft NPPF which signals a more permissive approach for local authorities when considering whether to release Green Belt land via the local plan process.

Policy GB1: establishing new Green Belts

Policy GB1 retains the current test, that new Green Belts should only be established in exceptional circumstances. The key change being Policy GB1(1c) which requires proposals to demonstrate compatibility with long term growth ambitions, rather than merely assessing their consequences for sustainable development. The change clarifies that new Green Belts should not constrain long-term sustainable growth ambitions for the area.

Policy GB2: Grey Belt given policy status

Policy GB2 largely reflects existing PPG on assessing Green Belt land but crucially formalises this approach within national policy. It requires spatial development strategies to assess the strategic function of the Green Belt against the five established purposes and to identify broad locations for consideration.

The policy further mandates that local plans must be informed by an assessment undertaken in the accordance with Annex E. This assessment includes the identification of Grey Belt land and underpins any Green Belt boundary alterations consistent with Policy GB3. Although Annex E closely mirrors existing PPG, its incorporation into the draft NPPF elevates its status from guidance to policy.

In effect, Policy GB2 embeds Green Belt assessment and the identification of Grey Belt land, as a mandatory and systematic component of plan making, firmly positioning Grey Belt land within the policy framework.

Policy GB3: altering Green Belt boundaries made easier

Arguably one of the largest changes to policy relates to the ability for Green Belt boundaries to be altered through the Local Plan where this would ‘enable the development of land around stations’. This is a substantial addition as it widens the scope of Green Belt land to be released for development, potentially providing substantial new development opportunities. We discussed this major change during our Places & Spaces – Mind the Gap podcast.

Notably, Policy GB3 removes the requirement for local planning authorities to engage with neighbouring authorities to determine whether identified development needs could be accommodated elsewhere before releasing Green Belt land. This represents a significant procedural shift. Previously, authorities were expected to demonstrate that all reasonable alternatives, including redistribution of need through cross boundary co-operation, had been exhausted prior to altering Green Belt boundaries. The removal of this step may therefore be interpreted as a relaxation of the cascade approach to Green Belt release, potentially lowering the evidential threshold required to justify boundary amendments.

Policy GB5: beneficial uses

Policy GB5 places an explicit requirement on the Green Belt to provide beneficial uses for communities and nature. To this end, development plans should set out, amongst other objectives, how the Green Belt can contribute to the priorities for nature recovery within the relevant Local Nature Recovery Strategies and how the impact of any proposals to remove land from the Green Belt (by altering its boundaries) can be offset through compensatory improvements to the environmental quality and accessibility of the remaining Green Belt. This policy reiterates a clear emphasis on Green Belt land having a functional value rather than it being land that is simply to be protected, reflecting natural capital thinking which values land as an environmental asset which contributes to the economy and human well-being.

Decision making

Grey Belt definition removes reference to Footnote 7 – hurrah!

What does this mean? It reduces interpretative uncertainty in respect of identifying Grey Belt land thereby potentially widening the pool of land capable of being considered Grey Belt. Existing considerations which should be followed when making judgements as to whether land is Grey Belt have been promoted from the PPG to Annex E of the draft NPPF, so will carry more weight. Ultimately, this should all make it easier to identify Grey Belt land with greater certainty.

Policy GB7: what’s new to the list of Not Inappropriate Development in the Green Belt?

Policy GB7(1a) replaces the word ‘buildings’ with ‘development’ in respect of agricultural development to also allow non-building agricultural developments.

Policy GB7 (1h): the default yes!

Although discussed in our previous article we must mention the default ‘Yes’. Policy GB7 (1h) now includes certain housing and mixed-use development near well-connected stations as not inappropriate development, thereby circumventing the ‘very special circumstances’ test and widening opportunities for development.

Policy GB8: the golden rules

Now includes three limited exceptions where the use of site specific viability assessment may be justified to enable development in the Green Belt. Exceptions include: 1. development proposals on previously developed land or multi-phase, 2. strategic sites or 3. a development model which is wholly different to that assumed in the viability assessment that informed the development plan. Thereby, supporting major development in the Green Belt. It is worth noting that these three exceptions are contingent on other proposed reforms including an affordable housing floor, benchmark land values and forthcoming changes to viability PPG.

Final thoughts

In our view, the draft NPPF maintains the overarching principle of Green Belt protection, but it recalibrates how such land is assessed, allocated and justified within the planning system. The emphasis has shifted from a uniform approach of restraint to a more criteria driven and evidential approach, particularly in the context of meeting development needs.

Given the scale and significance of the proposed changes, a substantial volume of consultation responses is inevitable. The government has been explicit that this is a working draft and has invited constructive input to refine the provisions. However, as with all policy reform, the ultimate measure of success will lie not in the wording alone, but in how this revised framework is interpreted, applied in practice and tested at appeal.

What’s next?

Responses to consultation of the draft NPPF must be submitted before 10 March 2026. We will continue to closely monitor progress and provide updates accordingly.