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Councils that fell short on the Government’s Housing Delivery Test cover less than 12% of England’s land but hold more than a quarter of its Green Belt. In 21 of them, a failing delivery score, majority Green Belt and above-average house prices all apply at once. For any business with land, a site or an expansion plan in those areas, the next round of planning decisions is likely to be argued harder than ever.
Last month, Business Partner Magazine reported that 93 English councils scored below 75% on the 2025 Housing Delivery Test. Under the new National Planning Policy Framework (NPPF), which took effect on 17 August, that score is now treated as evidence of unmet housing need for certain development outside settlement boundaries. The same evidence is relevant to the unmet need test in the grey belt policy.
The obvious follow-up question for anyone holding land is where that evidence meets the Green Belt. Chartered town planners at national consultancy Planning By Design have now answered it, matching every council’s 2025 Housing Delivery Test result against MHCLG’s latest local authority Green Belt statistics and the ONS house price to earnings ratio.
Two debates, one map
Of the 93 councils below 75%, 91 could be matched across all three datasets. Between them, they hold 418,440 hectares of Green Belt, 25.6% of England’s total, while covering just 11.8% of the country’s land.
Green Belt covers 27.1% of the land in those councils. Across England as a whole, it covers 12.5%. In other words, the areas furthest behind on housing have more than twice the national share of Green Belt.
Fifty-seven of the 91 contain some Green Belt. In 25, it covers at least half of the council’s land.
Aaron Basi, Chartered Town Planner and Head of Planning at Planning By Design, said:
Green Belt and housing delivery are usually treated as two separate debates. This data shows they sit on top of each other. In these areas a failing delivery score now counts as evidence of unmet need, much of the land around existing towns is Green Belt, and homes are well beyond what local earnings can reach. That is where applications, refusals and appeals under the new framework are most likely to concentrate.
The 21 Green Belt battlegrounds
Planning By Design defines a Green Belt battleground as a council where three conditions overlap: a Housing Delivery Test result below 75%, Green Belt covering at least half of its land, and a house price to earnings ratio above the England figure of 7.63.
Twenty-one councils meet all three. Together, they hold 272,200 hectares of Green Belt, a sixth of England’s total. Over the three years to March 2025, they delivered 21,827 homes against a requirement of 48,065. That is a combined delivery rate of 45% and a shortfall of 26,238 homes.
Nine of the 21 are in the East of England, eight in the South East, two in London and two in the West Midlands.
| Council | Region | HDT 2025 | Green Belt share of land | Price to earnings ratio |
|---|---|---|---|---|
| Castle Point | East of England | 11% | 55.9% | 9.81 |
| Basildon | East of England | 23% | 62.7% | 9.66 |
| Sevenoaks | South East | 25% | 92.9% | 13.43 |
| Hertsmere | East of England | 26% | 78.9% | 11.92 |
| Thurrock | East of England | 29% | 71.2% | 8.74 |
| Spelthorne | South East | 33% | 64.2% | 12.22 |
| Tandridge | South East | 38% | 93.9% | 13.23 |
| Havering | London | 40% | 54.0% | 10.96 |
| St Albans | East of England | 46% | 81.5% | 15.01 |
| Welwyn Hatfield | East of England | 46% | 76.6% | 9.18 |
| Three Rivers | East of England | 47% | 75.6% | 10.70 |
| Dacorum | East of England | 52% | 50.0% | 11.91 |
| Solihull | West Midlands | 53% | 66.6% | 7.75 |
| Bromsgrove | West Midlands | 58% | 88.9% | 9.99 |
| Elmbridge | South East | 59% | 58.2% | 15.74 |
| Gravesham | South East | 61% | 76.8% | 8.86 |
| Bromley | London | 62% | 51.0% | 12.08 |
| Tonbridge and Malling | South East | 63% | 71.0% | 12.03 |
| Epping Forest | East of England | 66% | 90.9% | 12.42 |
| Mole Valley | South East | 72% | 75.5% | 11.63 |
| Windsor and Maidenhead | South East | 74% | 81.9% | 13.28 |
Green Belt battleground councils, sorted by 2025 Housing Delivery Test result. Source: MHCLG; ONS; analysis by Planning By Design.
Where the pressure is sharpest
Sevenoaks delivered 523 of the 2,130 homes required of it, a result of 25%. It also has the largest Green Belt area of any council below 75%, at 34,390 hectares, covering 92.9% of the district. The typical home there costs 13.43 times typical local earnings.
Tandridge in Surrey has the highest Green Belt share of any council below 75%, at 93.9% of its land, alongside a delivery result of 38%. Sevenoaks (92.9%), Epping Forest (90.9%) and Bromsgrove (88.9%) are the only other battlegrounds where Green Belt covers more than 85% of the land.
Elmbridge (15.74) and St Albans (15.01) are the least affordable of the 21. Castle Point has the lowest delivery result, at 11%.
The affordability gap holds across the wider group too. The typical council below 75% has a house price to earnings ratio of 9.32, against 7.46 for councils that passed the test at 95% or above. Forty-three per cent of councils below 75% have a ratio of 10 or more, compared with 18% of those at 95% or above. Nationally, affordability has improved, with England’s 2025 ratio the lowest since 2015.
The Yorkshire exception
Not every large Green Belt council below 75% is expensive. Kirklees (65%) and Bradford (56%) hold the third and fourth largest Green Belt areas among the 91 councils, at 24,990 and 23,880 hectares respectively. Their price to earnings ratios, 6.25 and 5.17, sit below the England figure, so neither meets the battleground definition. The pressure there is failing delivery and extensive Green Belt without the price pressure found around London.
A battleground is not a building site
Planning By Design is warning businesses and landowners not to read the findings as a map of where the Green Belt will be built on.
A failing delivery score is not planning permission, and Green Belt designation is not an allocation for housing. Green Belt land keeps its own distinct policy framework, and the stronger general support for development elsewhere in the NPPF does not override it. Any proposal still has to meet every test that applies to its site, from design and highways to drainage, heritage, landscape and biodiversity.
Basi said:
None of this means the Green Belt in these areas is about to be built on. What changes is how hard the arguments will be fought, and how much depends on getting the evidence right from the start. In a battleground authority, a weak application is likely to be refused and a weak refusal is likely to be tested at appeal.
What to do now
- Check whether the council covering your site is one of the 21 battlegrounds, and whether the site itself sits inside the Green Belt. Those are two separate questions.
- If it is Green Belt, find out whether it could qualify as grey belt. That is a site-specific test, not something a council’s delivery score decides.
- Be cautious with any buyer, promoter or adviser who presents the new rules as a route to easy permission. A failing score is evidence for one policy test, not approval.
- If you are preparing an application, build the evidence early. Design, highways, drainage, heritage, landscape and biodiversity apply in full, and weak cases in these areas are more likely to end up at appeal.
- If you already have a live application or appeal, check that it addresses the August framework rather than the version it was submitted under.
Planning By Design’s full Green Belt battlegrounds analysis, including the data behind it, is available here.
Also read:
The planning rules changed in August. If your business owns land, this is the number to check.
Image source: elements.envato.com
