Green Belt is not a Grey Area: Grey Belt Policy in Epping Forest District

Members may have seen mention in the media of “grey belt” land. This is a concept introduced by the Government to enable residential building on protected Green Belt as part of its initiative to increase the number of dwellings in England.  However, the lack of detail on the likely extent of grey belt, combined with the government’s wider policy to further development at the expense of natural heritage, potentially poses a major threat to Green Belt around Epping Forest and Epping Forest itself. 

Green Belt and Grey Belt: A Brief History

Grey belt was first introduced in 2024 as a sub-category of “Green Belt.” The latter, terming rings of open, undeveloped landscape around urban areas as protected landscapes, was a major move of mid-20th Century planning policy, protecting recreational and amenity land around London from urban sprawl. As part of its initiative to increase the number of dwellings in England, the Government has declared that grey belt is an exception to the rule and terms Green Belt land available in principle to be built on.  Government guidance on this is contained in the National Planning Policy Guidance (1).  A site must “strongly contribute” to one or more of three Green Belt purposes, and, if it does not, it may be classified as grey belt:

• Purpose A – to check the unrestricted sprawl of large built-up areas;
• Purpose B – to prevent neighbouring towns merging into one another;
• Purpose D – to preserve the setting and special character of historic towns

The guidance is not detailed and much will depend on how local authorities, or their consultants, conduct “grey belt reviews” of the Green Belt land within their boundaries and how central Government reviews their recommendations. If land is designated as grey belt, subject to further tests (2), there will be an assumption of approval in principle to develop the sites.

Green Belt Map around Epping Forest. Source: Green Belt Interactive Map by CPRE 

Why does this matter for the Forest?

Of the local authorities covering the Forest, Epping Forest District Council (EFDC) is likely to be the one most affected.  EFDC, jointly with Harlow Council, has commissioned a Green/Grey Belt review by Arup using £140,000 funding provided by central Government. The Council indicated that there will be a consultation on the methodology to be used and on the sites selected. The review has a provisional completion date of the end of March 2026 when the final report should be released.

Owing to its conservation status, the Forest itself, at least the areas covered by the 1878 Act, should not be included in the grey belt review although the Complementary/Buffer Lands owned by the Corporation of London might be, as well as other Green Belt land around the Forest.  However, we do not know the size of the areas of land being considered or the location of the sites being reviewed.  Any significant reduction in the size of the Green Belt and increase in residential development has the possibility of increasing visitor footfall, and the damage and disturbance this can cause, alongside increasing the existing levels of air pollution damage from additional vehicle trips on roads in and around the Forest.

If the sites are close or adjacent to the Forest, there is also a risk of what are called “urban effects”, that is light pollution, escape of invasive plant species, predation by cats and soil changes from dog fouling. There is also the risk of the rural nature of areas and their landscape character being lost through unsympathetic housing design and density and a consequent impact on the Forest’s “natural aspect”.

Why is EFHT doing?

We view the creation of grey belt as of great concern, especially since the concept appears to be far greater in scale than the Government indicated at the time of the General Election.  We would be particularly concerned about any proposals which may lead to additional urban sprawl around Epping and Chingford and any which contribute to the possible gradual merger of areas such as Waltham Abbey and Sewardstone.     

Already, we have devoted a lot of effort over the past few months to objecting to planning applications for land both inside and outside of the Local Plan which the developers are claiming as grey belt and some of which have been agreed as being grey belt. These include sites adjacent to the Forest such as at West Essex Golf Club (refused by the planning officer, but whose report categorised the land as grey belt) and sites further away which still have the potential to affect the Forest including a large residential development proposed at North Weald Golf Club (refused without land re-categorised as grey belt), sites on the edge of Epping on which decisions are awaited and large solar farms, one near The Lower Forest and one on Land east of Tawney Common (refused with the site re-categorised as grey belt). There is clearly pressure from developers to exploit the lack of clarity on grey belt sites to justify Green Belt development, even when the land in our view still fulfils at least one of the three Green Belt purposes listed above.  

We are also concerned about the longer-term impacts. There may be pressure eventually to have piecemeal development of areas between the grey belt sites leading to a gradual urbanisation of large areas around the Forest.   

We are speaking with EFDC Councillors and will review proposals, when received, to establish how they might affect the Forest and decide what actions we will need to take. We recognise that the impact on the Forest of the Government’s grey belt proposals could be huge and we will provide updates as soon as possible. 

Notes:

1. National Planning Policy Guidance in relation to Green Belt: https://www.gov.uk/guidance/green-belt 
2. These further tests include sustainability, the provision of affordable homes, necessary infrastructure and greenspace and that the development of the site should not fundamentally undermine the Green Belt across the entire area of the Local Plan.  

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