Month: March 2025

Village Legal

What is a village? As a result of the government’s latest green belt planning practice guidance (see my 2 March 2025 blog post Colouring In The Grey Belt: The PPG) the answer to that question has practical policy consequences. When judging whether land is grey belt:

  • in assessing the extent to which the site strongly contributes to green belt purpose (a), to check the unrestricted sprawl of large built up areas, the guidance states categorically: “Villages should not be considered large built up areas”.
  • in assessing the extent to which the site strongly contributes to green belt purpose (b), to prevent neighbouring towns merging into one another, the guidance states categorically: “This purpose relates to the merging of towns, not villages.”

So if you have land on the edge of a village, the role that the land plays in separating that village from another village, or from a town, or in preventing the settlements from merging with one another, is irrelevant for the purposes of determining whether it is grey belt. Of course any potential development would have to meet other criteria, such as whether the location is “in a location that is or can be made sustainable”, but the distinction between town and village is now profound, for the purposes of applying green belt policy, both at local plan making stage and in determining planning applications and appeals.

Guess what, there is no definition of “village” in the glossary to the NPPF or indeed in national planning practice guidance. The issue is not entirely new given that one of the exceptions to development in the green belt being inappropriate has for many years been “limited infilling in villages” (now NPPF paragraph 154 (e)) but that was a relatively narrow point.

Because I live an interesting life, I participated this week in some lively WhatsApp debate on the issue (yes I’m looking at you, you and you others at this point). Someone pointed to the House of Commons Library’s research briefing City & Town Classification of Constituencies & Local Authorities (21 June 2018). Whilst interesting, this just deepened the mystery. It explains that according to an adjusted version of a taxonomy developed by the Centre for Towns, its classification (which is for wider public policy statistical purposes) was as follows:

12 Core Cities: twelve major population and economic centres (e.g. London, Glasgow, Sheffield)

24 Other Cities: other settlements with a population of more than 175,000 (e.g. Leicester, Portsmouth, Aberdeen)

119 Large Towns: settlements with a population between 60,000 and 174,999 (e.g. Warrington, Hemel Hempstead, Farnborough)

270 Medium Towns: settlements with a population between 25,000 and 59,999 (e.g. Gravesend, Jarrow, Exmouth)

674 Small Towns: settlements with a population between 7,500 and 24,999 (e.g. Falmouth, New Romney, Holbeach)

6,116 Villages and small communities: settlements with a population of less than 7,500 (e.g. Chapel-en-le-Frith, Cottenham, Menai Bridge)

But then the paper goes on to explain:

“This classification isn’t intended to resolve long-standing disputes about which settlements deserve to be called ‘cities’, ‘towns’, or ‘villages’. In fact, it takes no account of the ceremonial definition of ‘city’, using the term only as a way to identify larger settlements. For instance, St Albans is identified as a ‘large town’ here because its population is 86,000 – even though it has city status. Luton, on the other hand, doesn’t have city status, but is classified here as an ‘Other City’ because its population is 225,000.

The precise division between ‘large’, ‘medium’ and ‘small’ towns is, to a large extent, subjective.”

Hmm. So that doesn’t help. By coincidence I then saw a blog post on Bluesky posted by the Urban History Group, What is a town? It starts: “What exactly is a town? The answer to this question has been debated for many decades by medieval historians.” Oh no, many decades is no good. The short piece refers to the definitional uncertainty as between small towns and large villages – resonating with the equivalent uncertainty that there is in our modern planning world. Most local plans will have a table settling out the area’s settlement hierarchy, eg

Tier 1 – city/large town

Tier 2 – town

Tier 3 – small town

Tier 4 – large village

Tier 5 – medium sized village

Tier 6 – green belt village

Tier 7 – green belt hamlet

The distinction between ”small town” and “large village” is going to come under additional scrutiny, but without any government guidance, that I am aware of, as to the criteria to be applied in drawing that distinction.

I did have a brief, far from comprehensive, look at planning appeal decisions. There was one dating from 2019 for instance (APP/B3438/W/18/3211000) which revolved around whether the proposal was “limited infilling in a village” or in fact just a hamlet. The inspector resorted to a dictionary:

“The main parties dispute whether Ridgeway is a village or a hamlet.  This has consequences in terms of whether the scheme accords with Framework paragraph 145 e).  The Oxford Dictionary defines a village as a group of houses and associated buildings, larger than a hamlet and smaller than a town, situated in a rural area.  It defines a hamlet as a small settlement, generally one smaller than a village, and strictly (in Britain) one without a Church.  While a church may have once existed in Ridgeway, there is no church there now as it has been replaced by a dwelling known as Chapel House.  There are also no other associated buildings in Ridgeway that would, in my judgement, mean that Ridgeway is anything more than a hamlet.  The proposal does not accord with the exception in Framework paragraph [(now) paragraph 154(e)].

I think we are going to need some more specific guidance than dictionaries can provide. One WhatsApp response proposes an “if it has a Greggs it isn’t a village” test. I suppose that is a start but I am sure you can do better?

Whilst I’m being an annoying pedant, I would also like separately to draw attention to an inaccuracy in the NPPF glossary’s definition of “major development”:

The definition of “major development” in Article 2 of the Town and Country Planning (Development Management Procedure) (England) Order 2015 is as follows:

“major development” means development which involves one or more of the following—

(a) the winning and working of minerals or the use of land for mineral-working deposits;

(b) waste development;

(c) the provision of dwellinghouses where—

(i) the number of dwellinghouses to be provided is 10 or more; or

(ii) the development is to be carried out on a site having an area of 0.5 hectares or more and it is not known whether the development falls within sub-paragraph (c)(i);

(d) the provision of a building or buildings where the floor space to be created by the development is 1,000 square metres or more; or

(e) development carried out on a site having an area of 1 hectare or more;

The definition of “major development” in the NPPF glossary is:

“For housing, development where 10 or more homes will be provided, or the site has an area of 0.5 hectares or more. For non-residential development it means additional floorspace of 1,000m2 or more, or a site of 1 hectare or more, or as otherwise provided in the Town and Country Planning (Development Management Procedure) (England) Order 2015.”

The green belt “golden rules” only apply to “major development”. What if you have a scheme of say nine units on a site of between 0.5 and 1 hectares? Under the Development Management Procedure Order that is not major development. But under the glossary, because it has imprecisely summarised the definition in the Order, it would seem to be. Error?

What a time to be a planning lawyer.

NB Back on the main theme of this blog post: shortly after we announced we were setting up our new law firm eight or so years ago, Peter Village KC called me to say that Village Legal would have been such a better name. Maybe so.

Simon Ricketts, 23 March 2025

Personal views, et cetera

PI Bill Guest Post – Some Early Thoughts On The Bill’s Nature Recovery Provisions

I’m away this week of all weeks but I thought I would share my Town Legal colleague Susannah Herbert’s early thoughts on Part 3 (development and nature recovery) of this week’s Planning and Infrastructure Bill. This is not intended as a full summary – there are plenty of those already.

Part 3 of the Bill sets out provisions to provide for the strategic approach to addressing environmental impacts along the lines set out in the Development and Nature Recovery Planning Reform Working Paper published in December 2024.  This relates to protected sites and protected species under the Habitats Regulations, the Wildlife and Countryside Act 1981 and the Protection of Badgers Act 1992 so it will not affect areas or species not covered by this legislation or other EIA requirements.  It applies to “development” as defined in section 55 of the TCPA 1990 and also development within the meaning of the Planning Act 2008 (section 32) and listed building consent under section 8 of the Planning (Listed Buildings and Conservation Areas) Act 1990.

The principle is that Natural England is to put in place Environmental Delivery Plans (“EDPs”) which set out “conservation measures” to address certain identified “environmental impacts” of development on “environmental features” within a specified area and developers within that area then pay a “nature restoration levy” to fund the implementation of the EDP instead of having to carry out appropriate assessment or obtain protected species licences on a site by site basis. 

The government believes that facilitating a more strategic approach to the discharge of environmental obligations will result in improved environmental outcomes being delivered more efficiently and reduce delays to development caused by lack of mitigation for example in respect of nutrient neutrality. 

Much of the detail about the payment of the levy is to be contained in “nature restoration levy regulations” which would set out details concerning liability, matters that Natural England must have regard to in setting the amount of the levy, appeals in respect of the levy, use of the levy, collection, enforcement and compensation (for loss resulting from enforcement action).   The government may also give guidance to Natural England about any matter connected with the levy.

The implications of these provisions are potentially extremely significant for both developers/ landowners and for nature recovery and whether the impact will be positive or negative will depend very much on the implementation and scope of the EDPs.  The win-win scenario of improved environmental outcomes with lower cost and delay for developers may be achieved if strategic mitigation is effectively identified and implemented and the levy charged to developers is more cost effective than it would be to provide the mitigation on-site.  However, it is also possible that the levy will need to be set at an unviable level, that the conservation measures are not effectively implemented at the same time as removing protections from protected species and habitats and that the loss of flexibility for developers has unintended consequences for viability and deliverability.

The Explanatory Notes include an example of how the proposals are intended to work based on nutrient pollution from residential development in a river catchment affecting a protected water course.  Part of an EDP may be the imposition of a condition on a planning permission which in the example could be that all houses include septic tanks.  The EDP would then provide for conservation measures such as the building of a wetland to be funded by the tariff.  The impact would be monitored and an extension to the wetland may be delivered if the main measures are not sufficient.  The payment of the levy would remove the requirement for an appropriate assessment to be carried out for the specific development.

However, many questions and potential issues remain. 

Cl. 61(4) allows for EDPs to be mandatory in a specified area (although this has to be justified).  This would remove the choice from developers to provide on-site mitigation even if this were preferable in nature recovery terms and more viable for the particular site. 

The charging schedule for the levy will be set for each EDP and for each kind of development to which the EDP applies.  Natural England must have regard, to the extent and in the manner specified by nature restoration levy regulations, to the actual and expected costs of the conservation measures proposed; matters specified in the regulations relating to the economic viability of development; and other actual or expected sources of funding for those conservation measures.  The regulations may permit charging schedules to operate by reference to descriptions of purposes of development; any measurement of the amount or nature of development; the nature or existing use of the site; inflation; by reference to values used for other statutory purposes ; or may allow for differential rates including provision for supplementary charges, a nil rate, increased rates or reductions. 

None of these matters are directly linked to the actual impacts of a particular development.  This may be appropriate where the relevant impact can be sufficiently and fairly estimated on the basis of e.g. the quantum and type of development taking into account the existing use of the land such as the example of residential nutrient pollution given.  However, in other cases such as in respect of protected species, the result may be that a development has to pay the levy to mitigate an impact on a species which was not present on the site in the first place or which would not be impacted by the development because of the design of the development.  It may be that the intention is that surveys are carried out as part of bringing forward the EDP to establish which parcels of land it should apply to but this would potentially result in unnecessary work if surveys have to be carried out over a whole area compared to surveying only those sites where development is proposed.  It is also not clear if the surveys would be kept up to date.  The Secretary of State may make further regulations regarding requirements for Natural England when preparing an EDP which may address some of these questions.

The strategic nature of the mitigation proposed to be provided begs another set of questions.  If a certain number of developments are required to contribute to fund the strategic mitigation, how will the sequencing work?  Will the impacts of the first developments remain unmitigated until sufficient development comes forward to fund the strategic mitigation (in which case how much damage will be done to protected species or habitats in the meantime)? or will the conservation measures be funded by the Government in anticipation of development (which may not materialise and therefore may end up being an unnecessary cost to the public finances)?  Both of these approaches are possible under cl. 66(4)  which allows for expenditure already incurred to be reimbursed and for money to be reserved for future expenditure.

The regulations may also make provision about payment in forms other than money (such as making land available, carrying out works or providing services) (cl 67(6)) which may allow part of the cost of the levy to be offset by on-site mitigation or potentially providing additional mitigation and somehow receiving credit for this although there is no clear mechanism for this to operate.

It should also be noted that Natural England would be given the power to compulsorily acquire land for purposes connected with the taking of a conservation measure (cl. 72).

Public authorities would be required to co-operate with Natural England in connection with the preparation or implementation of an EDP (cl. 75).  Natural England must publish a report for each financial year on the exercise of its functions in respect of these provisions (cl. 73) and the Secretary of State may also designate another person to exercise the functions of Natural England (cl. 74).

The Bill (cl 53- 60) sets out the process for preparation of an EDP, statutory consultation, making of the EDP by the Secretary of State based on an “overall improvement test”, publication, reporting, amendment, revocation and challenge.  There would therefore be opportunities for developers to make representations concerning a proposed plan possibly arguing that a particular allocated site should be excluded if on-site mitigation is proposed or presenting evidence as to viability in respect of the proposed levy.  There is also the potential to challenge a plan by way of judicial review which could potentially introduce a whole new set of delays to development.

Thanks for that Susie. This is now me again in this paragraph. Plenty more to cover both on this subject and the PI Bill itself. Aside from not having read the whole Bill itself yet (I know I know), I also haven’t read the Life of Pi by Yann Martel. I’m told by google that “its main message is that life can and will be difficult. However, people must persevere by any means necessary. Being adaptive and having faith in yourself and a higher power can help a person achieve any obstacle in their path.” How true. As in life so in planning and infrastructure.

Simon Ricketts, 13 March 2025

Personal views, et cetera

Cons & Pros

A list of the 25 or so current statutory consultees in relation to relevant planning applications is set out in table 2 of the government’s guidance, here.

The previous government appointed Sam Richards in December 2023 to carry out an independent review of the role of statutory consultees in the planning system, since when that, er, consultation disappeared into a large hole. Would the new government take up the cudgels? Sam Stafford’s 6 November 2024 blog post On Stat Cons is good on the subject, referring back to previous concerns raised by the RTPI and a series of suggestions that had been made by the Competition and Markets Authority. On 26 January 2025, the Deputy Prime Minister and the Chancellor announced a moratorium on the creation of new statutory consultees and committed to reviewing the existing arrangements.

Anecdotally, the statutory consultees where issues most frequently arise are surely National Highways, the Environment Agency and Natural England. True, the issues within their domain are often technically, and sometimes legally, complex, but how often does the local planning authority or applicant receive a relatively standard holding response or objection and then have to engage in lengthy chasing process to resolve the issue?

We now have action, but is it in the right direction? A press statement emerged from MHCLG overnight, Bureaucratic burden lifted to speed up building in growth agenda – GOV.UK (10 March 2025), followed by a written ministerial statement.

The headlines from the press statement:

  • “Review of statutory consultee system to promote growth and unblock building
  • Consultation on limiting the scope of statutory consultees and removing a limited number of them, including Sport England, Theatres Trust and The Gardens Trust in planning decisions, while ensuring necessary community facilities and needs continue to be met
  • Will also establish a new performance framework with greater ministerial oversight
  • Reforms will reduce delays and uncertainty on planning proposals, demonstrating the government’s Plan for Change in action”

The government will be:

  • Consulting on reducing the number of organisations, including the impact of removing Sport England, the Theatres Trust and The Gardens Trust.
  • Reviewing the scope of all statutory consultees, to reduce the type and number of applications on which they must be consulted – and making much better use of standing guidance in place of case-by-case responses.
  • Clarifying that local authorities should only be consulting statutory consultees where necessary to do so, and decisions should not be delayed beyond the 21 day statutory deadline unless a decision cannot otherwise be reached or advice may enable an approval rather than a refusal. 
  • Instituting a new performance framework, in which the Chief Executives of key statutory consultees report on their performance directly to Treasury and MHCLG Ministers.”

Sport England has responded as follows:

“The purpose of our statutory planning remit is to protect playing fields and community spaces for sport and physical activity.

“Britain’s childhood obesity crisis is rising and low physical activity levels cost our economy £7.4billion a year, making it vital we protect the places that local communities can be active.

“We support growth and exercise our powers carefully and quickly, ensuring local neighbourhoods are designed to help people live healthy, happy and active lives.

“We look forward to taking part in the Government’s consultation exercise and arguing the importance of protecting playing fields and places where local people can keep active.“


 It perhaps has a reason to feel sore. The government’s press statement picks out a particular incident where “In Bradford, a development to create 140 new homes next to a cricket club was significantly delayed because the application was thought to have not adequately considered the speed of cricket balls.” I decided to look into this one. It was in fact widely publicised, for instance in a 12 November 2024 piece Speed of cricket balls could stump housing scheme. Sport England had queried the applicant’s consultant’s conclusions as to risk, based on the consultant’s assumptions as to the speed at which the balls might travel. Was this so wrong in principle or was the problem one of the slowness or over-rigidity of Sport England’s reaction? It is not clear. 

I am a past trustee of the Theatres Trust and I was disappointed to see that the Trust is being considered for removal from the list. It is difficult to see how the Trust can effectively fulfil its statutory role under the Theatres Act 1976 of protecting theatres (widely defined) without being consulted on any planning application involving land on which there is a theatre or which will have an impact on theatre use. The Trust responded to 289 applications last year and, from my now admittedly historic knowledge of how the Trust operates, I would be surprised if any of those responses were late or unhelpful. 

The written ministerial statement gives this further detail as to the government’s intentions:

“…we will review the range and type of planning applications on which statutory consultees are required to be consulted and consider whether some types of application could be removed, or addressed by alternative means of engagement and provision of expert advice. In some cases, this could be done through undertaking more effective strategic engagement at the local and strategic plan level, reducing the need for comments on individual planning applications, and increasing the role of standing advice. We will consult on these changes in the Spring alongside the impact of removal of the organisations identified above, before taking forward any resulting changes in secondary legislation later this year.”

There is also the advice in the WMS that: “local planning authorities should limit consultation of statutory consultees to only those instances where it is necessary to do so. Local planning authorities must still consult with statutory consultees where there is a legislative requirement to do so, noting that if there is relevant and up to date standing advice published with respect to that category of development, then consultation is not required. Applications may need to be referred to particular statutory consultees outside of the statutory requirements where their expertise is required, given the nature of the development, but should not be referred where standing advice is sufficient.”. “Decisions should not be delayed in order to secure advice from a statutory consultee beyond the 21 (or 18) day statutory deadlines unless there is insufficient information to make the decision or more detailed advice may enable an approval rather than refusal.” “In those limited circumstances where the statutory consultee is expected to provide advice on significant issues and it is necessary (for example, on safety critical issues), appropriate extensions to the 21 day deadline should be granted so that sufficient and timely information is available to inform the decision.“

“To support timely and effective engagement with the planning system, we will also institute a new performance framework. As part of this framework, an HM Treasury and MHCLG Minister will meet annually with Chief Executive Officers of key statutory consultees in order to review their performance.” “Finally, the Government recognises that statutory consultees need to be resourced adequately, and on a sustainable basis to enable them to support the government’s growth objectives in full.”

Much of this is surely to be welcomed but I think we need to focus on ensuring that the main statutory consultees respond positively, effectively and quickly rather than simply cutting out those which look a little niche (they are – and when your proposals are in that niche that’s where their specialist input is so important). 

Simon Ricketts, 10 March 2025

Personal views, et cetera

Colouring In The Grey Belt: The PPG

Now that the Government’s Planning Practice Guidance has been confirmed by the Court of Appeal as having the same policy making status as the National Planning Policy Framework (see Mead Realisations Limited v Secretary of State (Court of Appeal, 30 January 2025), changes to the PPG might be seen as the MHCLG policy making equivalent of US Presidential executive orders in terms of immediacy. Last week’s PPG advice on grey belt might not have renamed the Gulf of Mexico but it does set some new firm boundary lines, effective from 27 February 2025.

In my 8 February 2025 blog post It Was The “Rushed And Incoherent” Jibe That Got Me I referred to the impact which the December 2024 NPPF has made by way of the introduction of the “grey belt” test, particularly in relation to decision making on planning applications and appeals. The flow of appeal decisions has continued and I refer to a couple of them later in this post, but since all of this (and indeed those decisions) we now have the government’s promised amendments to the PPG advice on the role of green belt in the planning system (27 February 2025) which will in my view serve to increase the number of proposals coming forward (given that its overall effect is to set the definitional boundary lines more clearly, largely to the benefit of promoters) whilst (to the extent that the advice is now more specific as to the way in which the grey belt tests should be applied) hopefully reducing the number of proposals that do actually have to go to appeal.

You will already have read Zack Simons’ 27 February 2025 blog post The “Grey Belt” has arrived but here is my brief take on some of the main points to note from the new guidance:

  • The Government expects all local planning authorities reviewing green belt boundaries to identify where land is grey belt, dividing their green belt into separate assessment areas for the purpose of identifying grey belt. The same will apply in due course for strategic authorities carrying out spatial development strategies. To state the obvious, these assessments are going to be hugely important to landowners.
  • Given that the core principle in relation to identifying green belt land as grey belt is an assessment as to the extent to which the land strongly contributes to green belt purposes (a), (b) and (d), there is helpful guidance as to the considerations to be applied in considering each of those judgements, setting out illustrative features in each case which might point to the contribution being strong, moderate or weak.“
  • In relation to Purpose A – to check the unrestricted sprawl of large built up areas – ignore villages, which are not to be considered to be “large built up areas”. An example of a strong contribution would be where, if developed, it would “result in an incongruous pattern of development (such as an extended “finger” of development into the Green Belt)”.
  • In relation to Purpose B – to prevent neighbouring towns merging into one another – a moderate (not strong) contribution would be “being able to be developed without the loss of visual separation between towns. This could be (but is not limited to) due to the presence or the close proximity of structures, natural landscape elements or topography that preserve visual separation”. A weak contribution: areas that “form part of a gap between towns, but only a very small part of this gap, without making a contribution to visual separation.”
  • In relation to Purpose D – to preserve the setting and special character of historic towns – this relates to historic towns, not historic villages. Only moderate contribution if the areas “form part of the setting and/or contribute to the special character of a historic town but include one or more features that weaken their contribution to this purpose, such as (but not limited to):
    • being separated to some extent from historic aspects of the town by existing development or topography
    • containing existing development
    • not having an important visual, physical, or experiential relationship to historic aspects of the town”
  • Even if the area makes no strong contribution to purposes (a), (b) and (d), it needs to be shown that the application of the policies relating to the areas or assets in footnote 7 to the NPPF (other than green belt) would not provide a strong reason for refusing or restricting development. The PPG makes it clear that it may still be possible for authorities to provisionally identify land as grey belt in advance of more detailed specific proposals.
  • Even if the area makes no strong contribution to purposes (a), (b) and (d) and even if footnote 7 is not a bar, its release or development must not “fundamentally undermine the purposes (taken together) of the remaining Green Belt across the plan area as whole.” This apparently means that “authorities should consider whether, or the extent to which, the release or development of Green Belt Land would affect the ability of all the remaining Green Belt across the area of the plan from serving all five of the Green Belt purposes in a meaningful way.”
  • The final steps of determining whether the development would not be inappropriate development, even if it meets the above criteria, are considering:
    • whether a development is sustainably located
    • whether it would meet the ‘Golden Rules’ contributions (where applicable), and
    • whether there is a demonstrable unmet need for the type of development proposed

For the purposes of the inter-relationship between the affordable housing provision “golden rule” and the application of viability testing, we of course still await the updated viability PPG.

I’m running out of time this morning, but briefly now to turn to the decision letters I mentioned.

First of all, the Carrington decision letter dated 17 February 2025 . This followed a written representations appeal against Trafford Council’s refusal of planning permission for a 35MW battery storage facility at Wild Fowl Farm, Carrington. The inspector works through the grey belt tests methodically and concisely and finds that they are all passed.

Secondly, the Beaconsfield decision letter dated 24 February 2025 mentioned in Zack’s blog post. This followed an inquiry in relation to Buckinghamshire Council’s refusal of planning permission for up to 120 dwellings at Broad Lane, Holtspur, Beaconsfield. Again, the inspector works through the various tests, but here finds in his planning judgment that the appeal site strongly contributes to purposes (a) and (b). Accordingly this was inappropriate development so the “very special circumstances test” was to be applied and despite a housing land supply position that was agreed to be “dismal”, the appeal was dismissed (the grounds including findings as to substantial harm to the character and appearance of the area as well as substantial harm to biodiversity).

I agree with Zack that the inspector’s conclusions in relation to purposes (a) and (b) in the Beaconsfield appeal decision are potentially inconsistent with the new advice in the PPG. The PPG is definitely going to move the dial further in favour of release of sites and approval of development proposals.

Let’s take a step back. None of this is theoretical. The whole point of this “grey belt” branding is to secure more development in the green belt, sooner rather than later, on those sites which are least sensitive from the perspective of the traditional purposes for designation of green belt in the first place. I don’t find the tests, particularly in the light of the PPG, particularly challenging to navigate (although, as with so much in relation to planning, ultimately decisions will depend upon the application of human judgement, albeit within the tramlines of the policy guidelines). That is not to say that I don’t have any sympathy for opposite views: for instance this cri de coeur from my Strategic Planning Group compatriot (NB report from our group anticipated this Spring, watch this space) Andrew Wood in his 27 February 2025 blog post Grey Belt: Anti-strategic and wildly over-complicated. But, mindful of that need for development on appropriate sites, sooner rather than later, I don’t agree, and in my experience decision-making in relation to release and development of green belt sites was more of a “black box” process before the introduction of the grey belt.

Simon Ricketts, 2 March 2025

Personal views, et cetera