Recent Revisions to the National Planning Policy Framework

The new Labour government have been promising since their election in July to tackle the UK housing crisis by developing neglected spaces in the ‘Green Belts’ protection zones surrounding cities. The 14 Green Belts currently form 12.6% of the total UK landmass and, since the first being designated around London in 1935, they have stopped the urban areas of cities like Birmingham, Manchester and Nottingham from consuming their surrounding countryside.[1] As of December 2024, however, Labour’s latest revision of the National Planning Policy Framework (NPPF) has begun gently altering the scope of these protections to allow house building on what they now call the ‘grey belt’. [2] This implications this could have for the heritage sector and future archaeologists is complex and so requires clarification.

‘Grey belt’ land is now officially defined in the NPPF as ‘land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in paragraph 143.  It constitutes sites which do not contribute to the following purposes: controlling the ‘unrestricted sprawl’ of urban areas, the prevention of ‘neighboring towns merging into one another’ and to the preservation ‘of the setting and special character of historic towns’[3]. More specifically, ‘grey belt’ land would consist of sites already known in planning policy as ‘brownfield’ or ‘greyfield’ sites which are land parcels which have become abandoned, neglected or underutilised likely through economic decline or contamination. The example used to illustrate these types of sites by Chief Secretary to the Treasury Darren Jones was that of a ‘disused petrol station in Tottenham’, but also includes sites like old farmyards, carparks or industrial units located on the edge of greater urban areas.[4] According to analysis by Knight Frank, there are over 11,000 of these sites making up 1% of Green Belt land and which, if developed, could host up to 100,000-200,000 new properties.[5]

Labour have reprioritised their focus to the ‘grey belt’ land primarily for their potentially high economic and social benefits, but also in no small part because redeveloping ‘grey belt’ sites is considered less likely to have a significant environmental impact. Environmentally, developers have argued, ‘grey belt’ land is too ‘poor-quality’ for agricultural cultivation or ecological conservation, and therefore redeveloping it instead of the surrounding ‘greenfield’ (previously undeveloped land) land, which constitutes the remaining 76% of Green Belt land, would be more sustainable. [6] However, as with all developments there will always be a potential to create irreversible change and depending on the local topography, geology and previous ground intrusion, possibility of impacting in-situ remains cannot be circumvented, especially since ‘grey belt’ sites are usually adjacent to places and roads continuously occupied since prehistory.

It appears clear to me that ‘grey belt’ sites might be assumed to have a low archaeological potential due to modern impacts, the substantial evidence archaeologist now possess show that no site can be dismissed as entirely ‘free’ of archaeological remains. This was dramatically illustrated in 2012 with the recovery of King Richard III’s remains beneath Leicester City Council’s car park and is continuously reinforced to both the public and commercial sphere through regular announcement of new discoveries on developments across the UK.

The HS2 project has been particularly beneficial in this regard as multiple of its sites have shown a national audience that archaeological remains can often withstand multiple rounds of redevelopment. At HS2’s Curzon Street station in Birmingham, for example, the pristine foundations of an early 19th century roundhouse and engine turntable were uncovered in 2020, having survived repeated surmounting redevelopments since its demolition in 1870.[7] Similarly, in the same year, a collection of 300 Iron Age ‘potins’ named the ‘Hillingdon Hoard’ was discovered in the highly built up London borough just bordering the London Green Belt during redevelopments for HS2’s Hillingdon Station.[8]

Even beyond HS2, similar examples are regularly being published, with striking examples including the discovery of in-situ Iron Age roundhouse and enclosure only a few meters below ground-level during excavations for London’s Whitechapel underground station.[9] Found in 2019, these illusive ditches had managed to survive continuous redevelopment being positioned near Aldgate and the city walls since at least the 1st century CE and are a testament of the need for any brownfield or ‘grey belt’ sites, regardless of its position, to be properly historically assessed prior to the beginning of works.

Fortunately, it appears that the UK government, despite their promises to cut back the planning system, has no intentions of reducing heritage considerations with these ‘grey belt’ revisions. A joint 2024 report produced by Oxford Archaeology and the governmentally affiliated Forestry Commission to assess the impact of tree rooting on archaeology, supports the impression that they are commitment to ensuring heritage in forefront of all rural and semi-rural developments of which most ‘grey belt’ sites will consist of. Additionally, the lack of changes to ‘Chapter 16’ of the NPPF, the section which underpins the entire heritage planning industry, in the latest revisions, bodes well for the future of the sector in dealing with these new sites.

This shift in planning focus will present different opportunities to different archaeologists, as although it could be a source of new work, it could equally be the source of renewed conservation efforts. For budding commercial archaeologists, ‘grey belt’ development could mean starting their careers on many small developments radiating around cities like London, Birmingham and Manchester, in a similar way to how previous careers began on HS2 and Crossrail. For aspiring community archaeologists, this could be the spark to create new projects with the increasingly important mission of preserving through record our ‘green belts’ before they are redrawn.

Thankfully, the consideration of historic landscapes and the built heritage assets within them are already partially protected under the NPPF. Like buried remains, impacts to built heritage assets are also considered in the NPPF, with the added stipulation that all developments must consider how they will impact upon their ‘setting’. According to Historic England, ‘setting’ is the ‘surroundings in which the asset is experienced’ and can include any elements like views, spatial relationships or historical context which contribute to an assets significance, regardless of its immediate proximity or broader placement.[10] To illustrate to this, consider the brownfield developments on Piccadilly Street in York. Although not within the site, any development within this area will have to consider the setting of the scheduled monument Clifford’s Tower, which sits directly opposite of the River Foss. A developer will would have to ensure its design is sympathetic to the elements that make up its setting (i.e. views across the city, the historic building design, its relationship to the River Foss etc.), or else it could cause varying degrees of ‘substantial harm’ (NPPF) to its setting and could be rejected.

This definition is intentionally malleable as it allows individual assets to be considered within their own unique contexts, which in ‘grey belt’ cases will likely be rural or intentionally conserved. The Green Belts are also dotted with numerous Listed Buildings, Scheduled Monuments, Conservations Areas and Registered Parks & Gardens amongst which ‘grey belt’ sites may be nestled, and so it may be the next challenge to future archaeologists and heritage professionals to begin assessing and designing low-impact developments which will non-inhibit but will also simultaneously enhance their historic setting. This is also not mentioning the increased demand that may arise from retrofitting the surviving historic structures which may exist within ‘grey belt’ land, which may require renewed collaboration across the sector to ensure that these remains are properly conserved and adapted.  

Although ‘grey belt’ sites might be considered low quality ‘green space’ by NPPF standards, arguably they are precious because they will be irreversibly replaced by urban sprawl. Future archaeologists will seek to understand our lost landscapes, just as we seek to understand that of our immediate ancestors, whose underappreciated green spaces and hinterlands have been replaced by suburban and industrial developments. It now falls to us, the next generation of archaeologists, to assess and characterize these spaces before they too are absorbed, and to utilise our skills and resources to do so before it’s too late.