Grey Belt and the Revised NPPF: What Landowners Need to Show

The revised National Planning Policy Framework published in August 2026 has changed how grey belt land is identified and how Green Belt is assessed. For landowners and promoters it has opened up more opportunities, but it has not removed the need for evidence. Whether a site is grey belt, and whether development on it is acceptable, still turns on how the land functions as part of the Green Belt, and much of that is a question of landscape and views.

This article summarises what has changed and explains where landscape and visual evidence makes the difference. It is a general guide, not legal advice, and the Framework and its Annex should always be read in full for a specific site.

What has changed in the 2026 Framework

The Green Belt policies are now set out as a series of numbered policies, GB1 to GB8, covering plan-making and decision-taking, with a national method for assessing Green Belt in Annex E. Three changes are particularly relevant to landowners:

• The grey belt definition is narrower in its tests. Grey belt is land that is previously developed, or land that does not strongly contribute to Green Belt purposes (a), (b) or (d): checking the unrestricted sprawl of large built-up areas, preventing neighbouring towns merging, and preserving the setting and special character of historic towns.
• The footnote 7 exclusion has gone. Under the December 2024 Framework, land could not be grey belt where other protective policies, such as those for designated landscapes or heritage assets, provided a strong reason for refusal. That exclusion has been removed from the definition. Those policies still apply, but they now bear on whether development is acceptable rather than on whether the land is grey belt.
• Assessment guidance has moved into the Framework. Annex E sets out illustrative features relevant to rating a parcel's contribution to purposes (a), (b) and (d), giving councils and applicants a common starting point.

Development on grey belt land can be "not inappropriate" in the Green Belt, but only where the Framework's further tests are met. These include that it would not fundamentally undermine the purposes of the remaining Green Belt taken together, considerations of need and a sustainable location, and, for major housing, the Golden Rules on affordable housing, infrastructure and green space.

Classification and acceptability are separate questions

Because the footnote 7 exclusion has been removed, more land can now meet the grey belt definition, including land in the setting of a National Landscape or a listed building. That does not mean development there will be acceptable. A site may be grey belt and still be refused because of its landscape or heritage effects. Landowners therefore need two kinds of evidence: evidence on the site's contribution to the Green Belt purposes, and evidence on the effects of the proposed development itself.

Why visual evidence matters

Openness is the essential characteristic of the Green Belt. The courts, including the Court of Appeal in Turner (2016) and the Supreme Court in Samuel Smith Old Brewery (2020), have confirmed that openness has a spatial dimension and a visual dimension, and that how a site is seen is a legitimate consideration.

The spatial dimension is largely a matter of measurement: the volume, footprint and extent of built form before and after development. The visual dimension is where judgement and evidence are needed, and it is often decisive. It asks:

• How visible is the site, and from where? Is it seen as part of an open, continuous countryside, or is it already contained by the settlement edge, roads, woodland or existing development?
• Does the site read as part of the town, as part of the countryside, or as a transition between the two?
• Would development on it be perceived as sprawl, or as a logical rounding-off of the built edge?
• Would it reduce the perceived gap between settlements, from the routes and places where people actually experience that gap?
• Does the site contribute to views of, or the setting of, a historic town?

Each of these questions links directly to purposes (a), (b) and (d), and each is answered through landscape and visual analysis: site survey, viewpoint photography, analysis of visual containment and boundaries, and, where helpful, Zones of Theoretical Visibility and wirelines.

What a landowner needs to show

A well-prepared landscape case for a grey belt site usually sets out:

• The site's relationship with the settlement edge, including physical and visual containment by roads, hedgerows, woodland, topography and existing development.
• Its contribution to each relevant Green Belt purpose, engaging with the council's own Green Belt assessment and the Annex E features, and explaining clearly where a parcel-level judgement does not reflect conditions on the ground.
• Visual openness, through a structured set of viewpoints showing how the site is perceived from public routes, neighbouring settlements and the wider countryside.
• The effect on the remaining Green Belt, showing that release or development would not compromise the purposes of the wider Green Belt.
• Landscape-led design principles: where development should and should not go, how a robust new Green Belt boundary could be formed, and what planting or open space would integrate the scheme.

Timing

Landscape evidence is most effective when it is prepared early: before land is acquired or optioned, in response to a call for sites, or before a planning application is designed. Early analysis can identify the parts of a site that perform weakly against the Green Belt purposes and steer development towards them, strengthening both the grey belt case and the eventual application.

In summary

The 2026 Framework has made grey belt easier to identify, but it has also made the quality of the evidence more important. The spatial effect of development can be calculated. The visual and landscape case, how the site is seen and what role it plays between town and countryside, needs to be demonstrated. That is where a focused landscape appraisal earns its place.