Comment

Towards a new London Plan: Changes afoot for Metropolitan Open Land and Green Belt

The recently published consultation document, ‘Towards a new London Plan’ explores the release of parts of London’s Green Belt for development and suggests the current link between Metropolitan Open Land (MOL) and Green Belt could be severed. What are the implications of these potential changes and what opportunities might they bring?

Historically, MOL in London has been closely aligned to Green Belt in the requirement to be considered under the same national policy tests. However, the new consultation document ‘Towards a new London Plan’^[1] suggests this link could be removed, recognising the potentially greater importance of MOL to Londoners. Presently, Policy G3 of the London Plan links to national Green Belt policy, meaning MOL could potentially be considered against the new tests for identification as ‘grey belt’. The consultation document suggests removing that link.

A reasoned approach

This is a logical approach given the differences in the designations and the potential difficulties in matching and applying the grey belt criteria. Land is subject to additional criteria to qualify as MOL - including, the provision of open air facilities; features or landscapes (historic, recreational, biodiverse) of national or metropolitan value; or a strategic corridor, node or link in the network of green infrastructure - all of which are not Green Belt purposes as set out at paragraph 143 of the NPPF. Notably, MOL often provides a valuable open space resource for Londoners, whereas Research by Greenscape Information for Greater London^[2] found that only 5.5% of the Green Belt has a primary land use for park or formal garden and only 16% is commons, country parks, woodland or nature reserves. The Green Belt also primarily lies to the edges of London (and extends significantly beyond into neighbouring authorities), whereas MOL punctuates throughout the city itself, with the exception of the City of London and Havering. The same research found that Inner London is 14% MOL and 0% Green Belt, whereas Outer London is 9% MOL and 27% Green Belt.

The case for a London-wide review

In our experience, there are, however, instances where both designations cover land that isn’t serving the intended purpose. A London-wide review of both designations could therefore be important to understand where land could be put to use for development, whilst at the same time maintaining important areas of green space for recreation and ecological use. Golf courses have been floated as land within both designations which have limited use to the wider public and could be considered for release for housing. The potential for more industrial uses in the Green Belt has also been suggested.

From the consultation document, it’s clear that access to green space and biodiversity value will be key drivers in determining which landscapes to protect.

The move to review London’s Green Belt, as it has been nationally, marks a significant change in approach for the new London Plan and is likely to identify potential for development in land that has previously been discounted. The new London-wide Green Belt Assessment will need to assess land against the new definition for ‘grey belt’^[3]. With Green Belt purpose (a) focussed on preventing the outward sprawl of London, the extent of the Green Belt between London and surrounding large built-up areas suggests that much land does not meet the criteria as making a strong contribution for this purpose. However, access to transport infrastructure may limit the opportunities for appropriate development. We can also expect that the GLA will look to make Green Belt / grey belt development sites work very hard when it comes to meeting the ‘Golden Rules’^[4], particularly when it comes to expectations for affordable housing delivery.

We will be closely monitoring updates to the London Plan. In the meantime, if you’d like to discuss the implications of these potential changes or opportunities associated with Green Belt and MOL sites, please get in touch with Isabel Jones from our Heritage, Townscape and Landscape team or Freya Turtle from the London planning team.

22 May 2025

[1] Towards a new London Plan - consultation
[2] Mapping London's Green Belt and Metropolitan Open Land - GIGL
[3] NPPF Annex 2: Glossary - Grey belt: For the purposes of plan-making and decision-making, ‘grey belt’ is defined 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. ‘Grey belt’ excludes land where the application of the policies relating to the areas or assets in footnote 7 (other than Green Belt) would provide a strong reason for refusing or restricting development.
[4] NPPF paragraph 156