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 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 protects afforded be 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 Green Belt Assessmnt (GBA). 

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?

Grey Belt is Green Belt land that does not strongly contribute to any of the following three Green Belt purposes as set out in NPPF paragraph 143.

These are:

1. to check the unrestricted sprawl of large built-up areas;
2. to prevent neighbouring towns merging into one another; and
3.  to preserve the setting and special character of historic towns.

It also excludes land in certain areas where national planning policy (called NPPF ‘footnote 7’ constraints) provides a strong reason for refusing or restricting development.  GBC use from Footnote 7 the following constraints 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.

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.

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 a it is open season for developers over a wide swathe of land in the borough.  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.