Published: 3rd March 2025
Area: Planning
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Grey belt decision tracker: the growing appeal of grey belt
Planning | Blog
Planning policy context
Grey belt was introduced in the revised National Planning Policy Framework (‘NPPF’) published on 12 December 2024, as part of a suite of measures by the Government to help build 1.5M new homes over the parliamentary period. On 27 February the National Planning Policy Guidance (‘NPPG’) was updated to provide further guidance on assessing and identifying grey belt.
Grey Belt, as defined in Annex 2 of the NPPF, is previously developed land (‘PDL’) or Green Belt land that does “not strongly” contribute to purposes A, B or D (relating to checking unrestricted sprawl, preventing merging of towns and preserving historic setting). Also, notably, the NPPF updated the definition of PDL to include hardstanding as well as permanent structures.
Impact on development & planning strategy
Following the introduction of grey belt, our analysis from March 2025 shows that 1 in 3 (36%) housing appeals on grey belt land have been approved and its usage has the potential to treble the number of ‘acceptable’ sites considered for local plans.
Reaching an agreement with a Local Planning Authority that a Green Belt site is PDL or grey belt can significantly help de-risk and speed up the planning process. Marrons has developed a straightforward assessment methodology in line with the NPPF and NPPG to clearly demonstrate that a site is PDL or grey belt so please get in touch if you would like a view on any sites.
Recent appeal decisions (and decisions at planning committees) demonstrate the positive impact grey belt is having on bringing forward sites. Significantly, our analysis of appeals shows that although the approach to assessing Green Belt land has become more objective every application is considered on a case-by-case basis.
Allowed Grey Belt Planning Appeals
| Case | Inspectors Comments |
|---|---|
| APP/H2265/W/24/3346228 – ALLOWED (21 February 2025) Land at former Court Lane Nurseries, Court Lane, Hadlow.Tonbridge and Malling. 57 dwellings with a children’s day nursery, access and open space. | Constitutes grey belt and complies with the Golden Rules. |
| APP/M3645/W/24/3343193 & APP/M3645/W/24/3343194 – ALLOWED Land east of Woodcock Hill, Felbridge. Tandridge. (Three dwellings) | Constitutes grey belt and no harm to green belt. |
| APP/M3645/W/24/3347815 – ALLOWED (19 February 2025) Field between 84 and 90 Rook Lane, Chaldon. Tandridge. (Infill 2-3 dwellings) | Constitutes grey belt, clear need for homes, no impact on openness. |
| APP/C3620/C/24/3347934 & APP/C3620/W/24/3346512 – ALLOWED (18 February 2025) Land adjacent to Cidermill Hatch, Partridge Lane, Newdigate, Dorking, Surrey. Mole Valley. (Stationing of caravans for residential use, widening of access and hardstanding) | Constitutes grey belt and does not harm green belt openness. |
| APP/V4630/W/24/3347424 – ALLOWED (14 February 2025) Land off Chapel Lane, Great Barr. Walsall. (Battery storage facility) | Classed as grey belt and need for energy capacity is demonstrated. |
| APP/H2265/W/24/3347410 – ALLOWED (13 February 2025) Land part of Wrotham Water Farm, off London Road, Wrotham. Tonbridge and Malling. (24 hour Truck Stop) | Classed as grey belt, demonstrates need for truck stop. |
| APP/E3715/W/24/3344241 – ALLOWED (21 February 2025) Land adjacent to Treetops. Shilton Lane, Shilton, Coventry. Rugby. (Traveller site) | Does not comprise grey belt and causes harm to green belt openness but Very Special Circumstances shown. |
| APP/T3725/W/24/3347315 & APP/Q4625/W/24/3347316 – ALLOWED (30 January 2025) Land to the south of Birmingham Road, Kenilworth. Warwick & Solihull. (Solar farm) | Deemed Grey Belt despite impact on openness, but shows Very Special Circumstances. |
| APP/M3645/W/23/3331609 – ALLOWED (29 January 2025) Land North of Effingham Road, Keepers Corner, Burstow, Tandridge (Gypsy caravan site and 6 day room chalets) | Deemed Grey Belt. Does not contribute to Green Belt purposes and complies with Local Plan. |
| APP/R3650/W/24/3352222 – ALLOWED (25 January 2025) Land adjoining Hydon Farm, Hambledon Road, Hydestile, Godalming (1 dwelling) | Village-edge house succeeds under grey belt policy. Minor proposal did not require application of the Golden Rules therefore not inappropriate development. |
| APP/V1505/C/24/3344638-3344653 – ALLOWED (23 January 2025) Land North West of Hillview, Southend Arterial Road, Nevendon, Wickford (Enforcement – stationing of caravans for residential uses) | Increased area of gypsy/traveller caravan site. Not Grey Belt although limited harm to Green Belt and VSC apply. |
| APP/R4408/C/24/3344454 – ALLOWED (22 January 2025) Jimboy Stables off Mackey Lane, Brierley, Barnsley (Siting of caravan, laying of aggregate, and the material change of use of land for residential use and associated storage of vehicles, a timber hut and other domestic items) | Deemed Grey Belt as does not contribute to any Green Belt purposes. No harm to character of area, appropriate for residential use and no amenity impact. |
| APP/M3645/W/24/3339699 – ALLOWED (22 January 2025) Beacon Platt, High Street, Dormansland, Surrey, Tandridge (4 dwellings) | Within Green Belt but deemed Grey Belt as surrounded by development and on garden land. Does not contribute to Green Belt purposes. No 5YHLS. |
| APP/H1515/W/24/3341474 – ALLOWED (16 January 2025) Horseman Side, Navestock, Brentwood (6 appeals relating to extending Gypsy/Traveller site) | Site is grey belt. Consideration LPA Green Belt review, and comments that “looking at parcels is helpful in a strategic sense to inform plan making and future development growth. However, for decision making, it seems more relevant to look at a site specific level for determining grey belt land, otherwise the scale could be too large and skewed by land some distance from the actual site.” The review further states that, “the NPPF does not define the extent of grey belt land in any given case other than it must lie within the Green Belt.” |
| APP/V4630/W/24/3347424 – ALLOWED (13 January 2025) Chapel Lane, Great Barr, Walsall (49.35MW battery storage facility) | Site is grey belt land because it does not strongly contribute to purposes A and B. Purpose D was agreed to be discounted. |
| APP/M3645/W/24/3347328 – ALLOWED (10 January 2025) Woodside House, Copthorne, Tandridge (2 dwellings) | Site agreed to be grey belt land in respect of revised NPPF. It does not strongly contribute towards purposes A, B and D. Golden rules do not apply because it is not major development. |
| APP/V1505/C/23/3314641 – ALLOWED (19 November 2024) Canford Avenue, Wickford, Essex | Reference to Written Ministerial Statement of 30 July 2024 and draft NPPF which includes “grey belt”, noting grey belt sites have little ecological value, are inaccessible to the public, are located at settlement edges with little aesthetic or environmental value. The site is grey belt. |
Dismissed Grey Belt Planning Appeals
| Case | Inspectors Comments |
|---|---|
| APP/T0355/W/24/3345911 – DISMISSED (26 February 2025) Broom Lodge, Stanwell Road, Horton. Windsor and Maidenhead. (Conversion of dwelling to five flats and ten new dwellings) | Does not meet criteria for grey belt and would be inappropriate to Green Belt. |
| APP/B1930/W/24/3349580 – DISMISSED (18 February 2025) 162 Radlett Road, Colney Street, St Albans. (Four detached dwellings) | Considered to be grey belt but negatively impacts on openness and not sustainable. |
| APP/H4505/W/24/3350113 – DISMISSED (11 February 2025) Thornley Bank Boarding Kennels and Cattery, Hollinhill Lane, Rowlands Gill. Gateshead. (4-5 dwellings) | Considered grey belt but not in a sustainable location |
| APP/Y3615/W/24/3352713 – DISMISSED (11 February 2025) The Tyrrell Building, Long Reach, Ockham, Surrey. Guildford. (Three dwellings, extension to commercial building and access.) | Classed as grey belt but considered to harm the oppenness of the green belt. |
| APP/K2230/C/23/3328720 – DISMISSED (11 February 2025) White Post Farm White Post Lane, Sole Street, Cobham. Gravesham. (Residential use of caravans, construction of dayroom.) | Not grey belt, strong contribution to purpose of Green Belt. |
| APP/M3645/C/22/3304211 – DISMISSED (5 February 2025) Land lying to the south west side of Coldharbour Farm, Lingfield Common. Tandridge. (Building, fence, gates and hard surfacing) | Grey belt but no unmet need for this development. |
| APP/J1535/W/24/3346957 – DISMISSED (31 January 2025) Land south of Spains Hall Road, Ongar. Epping Forest. (Butchery on farm) | Potential for consideration of grey belt but loss of openness and no Very Special Circumstances justify refusal. |
| APP/P0240/W/24/3348840 – DISMISSED (24 January 2025) Sear Farm, Harlington Road, Upper Sundon, Luton (9 dwellings) | Deemed Grey Belt but does not meet Golden Rules to include affordable housing. Harmful to Green Belt. |
| APP/W1525/W/24/3342809 – DISMISSED (24 January 2025) Fairlawn Workshop, Woodham Road, Rettendon, Essex (4 dwellings) | Deemed Grey Belt, not inappropriate in the Green Belt. Dismissed on highways safety grounds. |
| APP/M2270/C/24/3339249 – DISMISSED (23 January 2025) Land at North Eastern Plot, The Ranch UK, Redwings Lane, Pembury, Tunbridge Wells (Enforcement – siting of caravans and equestrian use) | Not Grey Belt as sited in High Weald National Landscape. No VSC and balanced judgement deemed harmful to Green Belt. |
| APP/W3005/W/24/3347049 – DISMISSED (20 January 2025) Land Between 124 and 142, Church Lane, Selston, Ashfield District (8 dwellings) | The site is deemed to be Grey Belt however the proposals do not achieve the Golden Rules due to no affordable housing and no provision of accessible green space. |
| APP/G2245/W/24/3351517 – DISMISSED (21 January 2025) Land East Of Chirnside House, London Road, West Kingsdown, Sevenoaks (3 self-build dwellings) | The site is classified as Grey Belt, and not inappropriate development. However, there was no mechanism agreed to secure provision as self-build housing. |
| APP/E1855/W/22/3310099 – DISMISSED (16 January 2025) Lea Castle Farm, Kidderminster, Worcestershire (Sand and gravel quarry) | Site not grey belt because it strongly contributes to purpose A. VSC do not exist. |
| APP/J1915/W/24/3339916 – DISMISSED (16 January 2025) The Stables, Bishop’s Stortford, East Herts (New build office) | Site is PDL but not grey belt due to the PDL strongly contributing to purpose A and NPPF Footnote 7 (Local Green Space). VSC do not exist. |
| APP/P0240/W/24/3347529 – DISMISSED (24 December 2024) Leighton Road, Stanbridge, Central Bedfordshire Council (Against enforcement notice for 1 dwelling and associated development) | Site agreed to be grey belt land however golden rules not achieved including provision of affordable housing. VSC do not exist. |
| APP/M1595/W/23/3336013 – DISMISSED (29 October 2024) Gammon Staples Farmhouse, Orsett, Thurrock | Not grey belt as proposed changes to national policy are still being assessed. Inspector comments that regardless of whether the site is PDL or not, the proposals would have a greater impact on openness. |
| APP/X4725/W/24/3347440 – DISMISSED (11 October 2024) Darrington Service Station, Wakefield (Detached food to-go building) | Not grey belt as limited weight given to proposed changes to NPPF, in spite of agreement that the site is previously developed land. Proposals include 300% increase in volume of built development. |
| APP/B1930/W/23/3325998 – DISMISSED (23 September 2024) Bucknells Drive, St Albans City and District (12 bungalows) | Not grey belt. Undeveloped land, edge of settlement with built form on two edges, enclosed by and including some woodland. Not considered to be infill. 41% affordable housing carries significant weight. |
| APP/R0660/W/24/3339806 – DISMISSED (23 September 2024) Brooklyn and Broomfield, Cheshire East (2 dwellings) | Not grey belt as inspector considers the site makes a significant contribution to one of the five green belt purposes. Notably the site is small. Inspector states that grey belt is previously developed land or land which makes a limited contributions towards green belt purposes. |
| APP/N0410/W/23/3335048 – DISMISSED (13 August 2024) Grenville Lodge, Buckinghamshire (2 dwellings) | Not grey belt as site lies within 500m buffer of Special Area of Conservation. |
To stay up to date with all new grey belt decisions, click your chosen dates below.
Get in touch today!
Please do get in touch with Roland and our team, as we are working on many Green Belt sites, including potential grey belt sites, across the country where we are pulling together planning applications and making representations to Local Plans. We would be delighted to help you formulate and update your strategy in response to future changes to national policy to help achieve your development aspirations.
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