Green Belt – Grey Area?
Havering’s Green Belt is one of the key features of the area, providing green aspects, open spaces and an important sense of connection with the natural world on our doorstep. The Upminster & Cranham Residents’ Association has always taken a strong line in seeking to protect the Green Belt from inappropriate development, and to ensure that a sound test is applied to any proposals that are brought forward. This normally means that very special circumstances have to be demonstrated.
However, due to the Government’s changes to Planning Policy, many locations within the Green Belt can now be considered previously developed – so called Grey Belt, and different, less onerous tests can be applied.
I know that local residents will be extremely disappointed in discovering that many sites, in our designated Green Belt, could now be up for grabs to developers wherever the broader Grey Belt tests are met. This is in direct conflict with the established London and Local Plans, which have been rendered outdated by the Government’s push to deliver Housing.
Havering is currently revising its Local Plan, and is reviewing the impact of the Grey Belt criteria, and this revision cannot come soon enough. It should provide some clarity and controls over which sites can be brought forward for Housing, and other development, under the revised National PPF, but the re-designation of some Green Belt land to Grey Belt is inevitable.
Councillor Oscar Ford (Upminster Ward)

I appreciate the article outlining the emerging concept of “Grey Belt” following recent Government changes to national planning policy, particularly the pressure to increase housing delivery. However, it is important to clarify how this policy shift is being interpreted and applied locally in Havering.
While much of the Government’s push relates to housing, there are already examples within Havering where infrastructure projects have been approved or seriously considered on land designated as Green Belt in the current Local Plan. This raises legitimate concerns about the validity and authority of the existing plan, if decisions are being made that appear to contradict it.
A clear example is the Battery Energy Storage System (BESS) approved at St Mary’s Lane. In this case, the only party to describe the site as “Grey Belt” was the applicant, Clearstone. This assertion was challenged by Havering residents during the planning process, yet it was ignored by the Case Officer and not addressed in the officer’s report. Despite the site being identified as Green Belt in the adopted Local Plan, the three HRA members of the Strategic Planning Committee voted in favour of the development.
As Havering moves towards a revised Local Plan, it is vital that the Council adopts a realistic, transparent, and defensible approach to Grey Belt designation. Any such land should clearly meet strict criteria, for example, low-quality land that is not in agricultural use and does not strongly serve Green Belt purposes, such as preventing urban sprawl or safeguarding openness.
Furthermore, Government guidance must be applied consistently. The House of Commons briefing paper on Battery Energy Storage Systems (23 June 2025) states that suitable sites should be identified within the Local Plan. Havering’s current plan identifies no sites for BESS, yet approval was granted on designated Green Belt land. This inevitably leads residents to ask: what is the point of a Local Plan if it is not upheld?
The forthcoming draft Local Plan must be subject to full public consultation, allowing residents to clearly see which sites are proposed for re-designation as Grey Belt and to engage meaningfully with the Council before adoption. Only through this process can residents properly understand the implications for their communities including loss of openness, impacts on mental wellbeing, potential effects on house prices, and ultimately whether they wish to continue living in Havering as these changes take shape.
Transparency, consistency, and public trust must be at the heart of the revised Local Plan if confidence in the planning system is to be restored.
Dear Alan, there is much in what you state that I concur with, but for clarity, the test applied by the Local Planning Authority in relation to the BESS application, whatever the applicants assertion, was that of ‘very special circumstances’, i.e., the Green Belt test. The LPA concluded that, on balance, the energy infrastructure imperative provided such circumstances, a view that was endorsed by the Strategic Planning Committee decision.
The current revision of the Local Plan is progressing and many elements are reviewed that will influence the designation of land. When the Plan was last updated, the provision or otherwise of wind power installations was reviewed and included but Battery Storage was not, and Grey Belt did not exist as a designation and so this was not a consideration.
The Government defines consultation requirements in relation to Local Plan development, this includes specific requirements for public consultation; there will be the opportunity for residents to have their say.