Large areas of Guildford Green Belt to be reclassified?

Guildford Borough Council are starting to publish documents that contribute to the Evidence Base that will be considered during the development of the new Local Plan in 2029.

The document that will produce the most comment is the Green Belt Assessment that shows most of the Green Belt in Guildford borough is now classed as "grey belt" or "potentially grey belt" under new government planning rules. Grey Belt designation lowers protection against development substantially compared to Green Belt.

Guildford Green Belt as at 7/2026

Guildford Modified Greenbelt as evaluated (including Footnote7)

Note there is an important caveat on this proposed map that is explained below.

Guildford Green Belt Assessment

The new rules on what counts as 'grey belt' as opposed to green belt are complicated. Grey Belt status is very important as it substantially reduces the protections afforded by Green Belt status, and as can be seen covers substantial areas not just the odd old car park/petrol station as implied in Government announcements. GBC have used an independent consultancy AECOM to assess what the rules mean for every part of Guildford's greenbelt - producing a report the report is attached to post below or can be accessed at GBC Website at Green Belt Assessment (GBA). 

It is important to note that a GBA has no Legal Status and thus doesn't change boundaries, which only change as part of the Local Planning process.  See paragrph on Legal Weight of Assessment Documents at foot of the post. The assessment is only evidence to justify boundary changes.

How the Assessment relates to the new Guildford Local Plan?

The GBA does make any decisions on what land will be allocated for development in the Local Plan. National policy states that Local Plans are expected to meet the identified need in full. This may include the consideration of Green Belt land if all other suitable opportunities for growth have been explored first - namely the redevelopment of previously developed land, optimisation of density on sites and the use of non-Green Belt land.

If there is still unmet need then the NPPF states that this can constitute the exceptional circumstances necessary to justify altering Green Belt boundaries. When altering Green Belt boundaries plans should give priority to previously developed land, then consider grey belt which is not previously developed, and then other Green Belt locations. However, this must be in the context of promoting a sustainable pattern of development. For this reason, it may in some instances be preferable to allocate non grey belt land over grey belt land.

What is Grey Belt?

Green Belt serves five purposes as set out in the current NPPF 2024 at Para 143.:

a) to check the unrestricted sprawl of large built-up areas;

b) to prevent neighbouring towns merging into one another;

c) to assist in safeguarding the countryside from encroachment;

d) to preserve the setting and special character of historic towns;

e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

Grey Belt is Green Belt land that does not strongly contribute to any of the following three Green Belt purposes as set out above, these are:

a) to check the unrestricted sprawl of large built-up areas;

b) to prevent neighbouring towns merging into one another

d) to preserve the setting and special character of historic towns.

NPPF Used for GBA

The GBA uses as its basis the NPPF published in 2024 (NPPF 2024) .  

GBA excludes land in certain areas where national planning policy related to Para 11 - The presumption in favour of sustainable development  (called NPPF ‘footnote 7’ constraints) provides a strong reason for refusing or restricting development.  This highlights constraints on the use of land relating too:

• habitats sites (and those sites listed in paragraph 189) and/or
• Designated as Sites of Special Scientific Interest;
• land designated as Green Belt,
• Local Green Space,
• a National Landscape,
• a National Park (or within the Broads Authority) or defined as Heritage Coast;
• irreplaceable habitats;
• designated heritage assets (and other heritage assets of archaeological interest referred to in footnote 75);
• areas at risk of flooding or coastal change.

 The GBA thus also assesses land against Footnote 7 that are applicable in the borough before determining whether land can be considered grey belt.

• habitats sites (Thames Basin Heaths Special Protection Area (SPA)) and/or designated as Sites of Special Scientific Interest;
• Local Green Space;
• Surrey Hills National Landscape;
• irreplaceable habitats (Ancient Woodland, lowland fen and ancient trees);
• designated heritage assets;
• areas at risk of flooding.

Map of Guildford Borough showing Constraints.

Once designated as grey belt' developers need to prove that that the proposed development meets three golden rules

1. Building 50% affordable housing
2. Increasing the amount of *publicly accessible* greenspace.
3. Being in a sustainable location (which can mean as little as having a regular bus service, or being a short driving distance from schools and shops)

Does the GBA determine planning applications?

Identifying land as grey belt does not grant planning permission. The GBA is an evidence base and will be a starting point only for decision taking regarding sites that may be grey belt. The decision maker (planning officers, planning committee or a planning inspector) will still need to consider the site-specific circumstances and make their own assessment regarding whether the site is grey belt or not.

The full report has been published online on the council website together with accompaning detailed maps has been published on the GBC Web Site See this Link.  The report and a useful FAQ paper produced by the council are also appended below.

Revised Methodology due in Autumn 2026

The Assessment will be re-issued in the autumn (Source GBC FAQ’s on the GBA See Document at Foot of Post) to reflect the changes arising from the new NPPF2026 - See dreaft at this link - due to be made operational in the Autumn.  Footnote 7 Considerations will no longer be relevant. The policies that appear relevant is the Draft Version is adopted appear to be GB2 and Appendix E. 

GBC believe this will the revision of the map to reflect the the removal of the ‘provisionally Grey Belt’ category.  This gives a map as below which is still of concern.

Map showing Borough without Footnote 7 applied.

The draft NPPF2026 has Policy S1 Positive Plan Making that makes reference to applying policies within the NPPF 2026 to plan making that are at Footnote 23 these relate to: habitats sites and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, a National Landscape, a National Park (or within the Broads Authority) or defined as Heritage Coast; irreplaceable habitats; designated heritage assets; and areas at risk of flooding or coastal change.

The NPPF2026 is still a draft and the final version with amendments after the January 2026 consultation will be made operational in the Autumn  - THERE COULD STILL BE SURPRISESTO COME.

The Society is very concerned how the GBA will evolve.

• We await updated guidance from MHCLG that will replace the current guidance note that relates to NPPF 2024 See Link 
• The overlap of protected areas e.g. the Surrey Hills National Land Landscape has carried almost no weight in the assessment to date, it is hoped that this is rectified by the new NPPF 2026.
• We need to check the assessments on the various Assessment Areas to see that they are correct. 

Impact on Guildford.

The findings of the assessment are very concerning. Guildford is at risk as it must deliver more housing (circa 1100 per annum double the previous delivery rate) to meet a central government edict.  The Green Belt Assessment creates an open season for developers over a wide swathe of land in the borough as, although it doesn't legally, change boundaries it provides rationale for developers to ask to individual areas to be redeveloped.  Guildford won’t have an updated local plan until q1 2029 and we are in danger of a developer free-for-all that results in piecemeal developments being built lacking a sense of place, infrastructure and social facilities.

Legal weight given to Assessment documents

Evidence Base Studies (non-statutory) - These are produced to develop the evidence base from which Local Plans are developed, but do not create polices these are part of the Local Plan.

Examples:

• Green Belt assessments
• Housing and Economic Needs Assessments (HEDNA)
• Settlement hierarchy studies
• Landscape sensitivity assessments
• Transport modelling
• Infrastructure capacity studies

Legal status:

• Not legally binding
• Not policy
• Material only insofar as they justify the Local Plan
• Can be challenged at examination if flawed, inconsistent, or disproportionate.

2. Statutory Assessments (legally required) - These have procedural legal status but still do not create policy:

• Sustainability Appraisal (SA) / Strategic Environmental Assessment (SEA)
  • Required under the Environmental Assessment of Plans and Programmes Regulations 2004
  • Must accompany the plan at each stage
  • Legal requirement: failure can quash a plan
• Habitats Regulations Assessment (HRA)
  • Required under the Conservation of Habitats and Species Regulations 2017
  • Must demonstrate no adverse effect on integrity of protected sites

Legal status:

• Legally required
• Must be “adequate”
• Can be grounds for legal challenge
• Still not policy and do not bind planning decisions directly.

Planning inspectors don’t ask if an assessment has legal status but will ask if the evidence in the assessment is

• Is the evidence proportionate?
• Is it methodologically sound?
• Does it justify the policy choices?
• Has it been properly consulted on?
• Is it consistent with national policy?

If the evidence is weak, the inspector may:

• Require review and modifications
• Reject sites
• Find the plan unsound
• Recommend withdrawal

But they do not give the evidence itself legal force.