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By Paula Moss
Vice-chair of Effingham Parish Council and founder of “Rural Roar”, a campaign seeking reform of grey belt policy.
A new planning policy is putting Surrey villages at risk—and one local parish council is fighting back.
Effingham Parish Council has become the founding voice of ‘Rural Roar’ (ruralroar.org.uk), a campaign seeking reform of the grey belt test that classifies most of Guildford’s green belt land as low-value, grey belt land, making it easier for developers to build on it.
The latest evidence confirms that this updated grey belt policy poses an
existential threat to villages across Surrey and beyond.
Guildford’s own green belt assessment, carried out independently by AECOM, was recently released. It finds that 551 of the borough’s 575 assessment areas — almost 96 per cent — qualify as grey belt.
In Effingham, all seven assessment areas are now classified as grey belt, including land AECOM itself records as making a strong overall contribution to green belt purposes. It’s labelled grey belt regardless, because the test excludes villages from its assessments — entirely.
Similar assessments across the southern greenbelt mirror Guildford’s report. Guildford (96 per cent), Sevenoaks (95.8 per cent), Tonbridge & Malling (98.6 per cent and North Somerset (95.7 per cent).
All point to the same issue. The latest iteration of the NPPF (National Planning Policy Framework) has stripped land around villages of all its “footnote 7” protections, specifically its contribution to heritage and the environment.
Regardless of its role in meeting the purposes of the green belt, most land around villages now falls by default into grey belt. Developers can effectively build all over the green belt between village settlements, carte blanche.
And it’s happening now in Surrey – before new authorities and local councils even get a chance to determine their own spatial strategy.
The impact in Buckinghamshire highlights how stark the issue is. They have gone from 13.7 per cent of greenbelt land designated as grey belt to 83 per cent overnight as a result of the rule change in the NPPF. The land hasn’t changed – the rules have.
The grey belt test is scoped for towns and cities: preventing urban sprawl, preventing towns merging, protecting the character and setting of historic towns. Villages get no credit under any of the test elements.
This is not a marginal gap in the methodology. It means greenbelt sites in rural settlements across Surrey are structurally predetermined for approval as grey belt, whatever the strength of the local evidence for protecting them.
Of course, there are other factors weighed in the balance. However, the evidence now suggests that designation as grey belt appears to win out in the end.
Grey belt status secures development status 80 per cent of the time A large-scale review by GapSense of 710 substantive appeal decisions found 79 per cent succeeded where grey belt status was the deciding factor.
The Government’s own Budget cited this evidence directly. HM Treasury’s Budget 2025 states: “Since the updated NPPF was introduced in December 2024, an unprecedented 80 per cent of major residential appeals located on grey belt land have been approved, homes that likely wouldn’t have been built under previous policy.”
Separate case-by-case research by CPRE (campaign for the Protection of Rural England) and “Good Plan Consulting” examined the underlying appeal decisions.
They found that 10 of 13 approved major grey-belt housing sites — 77 per cent — were greenfield, not previously developed land. Those greenfield sites accounted for 1,098 of the 1,250 homes approved: 88 per cent of the total, against just 12 per cent on genuinely previously developed land — the kind of land that the grey belt test was supposed to identify.
For example: in February 2025, an inspector approved 57 homes on Grade 1 agricultural land at Hadlow, Kent – land the government’s own definition was meant to exclude.
Evidence from both sides of this debate converges on the same conclusion: this is not the derelict, previously-developed land the policy was sold on. It is high-quality green belt land strongly serving the purposes of the green belt.
The threat is real, the damage is being done already and the urgency cannot be overstated.
Guildford’s planning team has confirmed it will not assess whether individual developments or clusters of development would fundamentally undermine the remaining green belt until it has settled its preferred spatial strategy and candidate Local Plan allocations — work that could take years.
In the meantime, applications asserting grey belt status can be submitted by developers and determined now, long before any safeguard exists. Villages are being asked to absorb development against a test with an obvious flaw.
Grey belt policy needs to be reformed, and it needs to be challenged immediately.
Effingham Parish Council recently passed a resolution to support the reform ambitions of Ruralroar.org.uk. It is calling for an immediate suspension of the application of the grey belt test to sites around villages until the test can be reformed to adequately and appropriately assess these sites in the same way that sites around towns and cities are assessed.
That doesn’t mean no development – it means sites will be assessed by the NPPF and Local Plan requirements – but developers should not be able to put forward and rely upon flawed grey belt designations.
If this greybelt rule goes unchallenged, the green space between our ancient villages will be filled with large-scale housing developments, and the character and heritage of rural Surrey will be lost forever.
Rural Roar is now leading a coordinated campaign with local and parish councils, adding to the roar. The decision to strategically enlarge a village or a town should rest with the appropriate local authority via an evidence-based Local Plan.
It should not be led by developers on a site-by-site basis. We are urging residents to contact their MPs, highlight this issue and demand reform of grey belt tests applied to villages.
The case for suspension of the NPPF is strong, and the threat applies now, across every village in Surrey. A policy that labels 96 per cent of Surrey’s assessed green belt as grey belt cannot be deemed fit for purpose. It must be challenged.
Full evidence and the campaign’s proposed reforms are at: ruralroar.org.uk.
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