Analysis of three official datasets finds that the councils failing the Government’s Housing Delivery Test hold a quarter of England’s Green Belt, despite covering under 12% of its land. In 21 of those councils, failing delivery, majority Green Belt and above-average house prices all apply at once.
The councils under most pressure from England’s new planning rules are also among those with the most Green Belt and the least affordable homes, according to analysis of official data by chartered town planners at national consultancy Planning By Design.
In August, Planning By Design found that 93 local planning authorities recorded a 2025 Housing Delivery Test result below 75%, and that more than half of them are in London and the South East.
That threshold now carries real weight. Under Policy S5 of the new National Planning Policy Framework (NPPF), a Housing Delivery Test result below 75% is 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 question is where that evidence meets the Green Belt.
Planning By Design has now matched every authority’s result against two further official datasets.
The data behind this analysis
- Housing Delivery Test: 2025 measurement, MHCLG. Homes delivered against homes required in each council, 2022/23 to 2024/25.
- Local authority Green Belt statistics for England: 2024 to 2025, MHCLG. Green Belt area in each council as at 31 March 2025.
- Ratio of house price to workplace-based earnings, ONS. Median house price divided by median full-time earnings, 2025.
The Green Belt is where the shortfall sits
Of the 93 authorities below 75%, 91 could be matched across all three datasets. Those 91 councils contain 418,470 hectares of Green Belt, 25.6% of England’s total, while covering 11.8% of England’s land.
Green Belt covers 27.1% of the land in the councils below 75%. Across England as a whole, Green Belt covers 12.5% of the land.
Put simply, Green Belt covers more than twice as much of the land in the areas furthest behind on housing as it does across the country.
Fifty-seven of the 91 councils contain some Green Belt. In 25 of them, Green Belt 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 things apply at once: 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 tests. The 21 battlegrounds hold 272,230 hectares of Green Belt, a sixth of England’s total.
Over the three years to March 2025, the 21 battleground councils 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 (ha) | Green Belt share of land | Price to earnings ratio |
|---|---|---|---|---|---|
| Castle Point | East of England | 11% | 2,500 | 55.9% | 9.81 |
| Basildon | East of England | 23% | 6,900 | 62.7% | 9.66 |
| Sevenoaks | South East | 25% | 34,390 | 92.9% | 13.43 |
| Hertsmere | East of England | 26% | 7,980 | 78.9% | 11.92 |
| Thurrock | East of England | 29% | 11,670 | 71.2% | 8.74 |
| Spelthorne | South East | 33% | 3,320 | 64.9% | 12.22 |
| Tandridge | South East | 38% | 23,300 | 93.9% | 13.23 |
| Havering | London | 40% | 6,070 | 54.0% | 10.96 |
| St Albans | East of England | 46% | 13,140 | 81.5% | 15.01 |
| Welwyn Hatfield | East of England | 46% | 9,930 | 76.7% | 9.18 |
| Three Rivers | East of England | 47% | 6,720 | 75.6% | 10.70 |
| Dacorum | East of England | 52% | 10,630 | 50.0% | 11.91 |
| Solihull | West Midlands | 53% | 11,870 | 66.6% | 7.75 |
| Bromsgrove | West Midlands | 58% | 19,290 | 88.9% | 9.99 |
| Elmbridge | South East | 59% | 5,610 | 58.2% | 15.74 |
| Gravesham | South East | 61% | 7,600 | 76.8% | 8.86 |
| Bromley | London | 62% | 7,660 | 51.0% | 12.08 |
| Tonbridge and Malling | South East | 63% | 17,050 | 71.0% | 12.03 |
| Epping Forest | East of England | 66% | 30,830 | 90.9% | 12.42 |
| Mole Valley | South East | 72% | 19,510 | 75.5% | 11.63 |
| Windsor and Maidenhead | South East | 74% | 16,260 | 81.9% | 13.28 |
Where the pressure is sharpest
Sevenoaks delivered 523 of the 2,130 homes required of it, a Housing Delivery Test result of 25%. Sevenoaks contains 34,390 hectares of Green Belt, the largest area of any council below 75%, covering 92.9% of the district. The typical home in Sevenoaks 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%. 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) have the least affordable homes of the 21 battlegrounds. Castle Point has the lowest delivery result, at 11%.
How affordable are the councils below 75%?
The typical council below 75% has a house price to earnings ratio of 9.32. For councils that passed the test at 95% or above, the typical ratio is 7.46.
Forty-three per cent of councils below 75% have a ratio of 10 or more, meaning the typical home costs at least ten years of full-time earnings. Among councils at 95% or above, the figure is 18%.
Nationally, affordability has improved: England’s 2025 ratio was the lowest since 2015.
What it does not mean
Planning By Design is warning that the findings should not be read as a map of where the Green Belt will be built on.
A failing Housing Delivery Test result is not planning permission, and Green Belt designation is not an allocation for housing. Green Belt land remains subject to 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.
What the data shows is where those tests are most likely to be argued.
Aaron Basi said:
“We have spent a year telling landowners that reform of the Green Belt is not the same thing as permission on their field. That is still true, and it is still the most expensive misunderstanding in this market.”
“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.”
The Yorkshire exception
Not every large Green Belt council below 75% is expensive. Kirklees (65%) and Bradford (56%) hold the third and fourth largest areas of Green Belt among the 91 councils below 75%, at 24,990 and 23,880 hectares, covering 61.2% and 65.2% of their land.
But the price to earnings ratios in Kirklees (6.25) and Bradford (5.17) are below the England figure, so neither council meets the battleground definition. The pressure there looks different: failing delivery and extensive Green Belt, without the price pressure found around London.
What happens next
MHCLG is due to publish updated Green Belt statistics in October 2026. Planning By Design will update this analysis when they are released.
Anyone with a live application or appeal can read Planning By Design’s full breakdown of what the new NPPF changes for planning applications from 17 August, or the explainer on how the grey belt rules work.
Is your site in a battleground area?
If you have land, a live application or an appeal in one of these areas, contact Planning By Design’s award-winning team for a free, no-obligation consultation.
Frequently Asked Questions
Which councils failed the 2025 Housing Delivery Test?
Ninety-three of England’s 301 local planning authorities recorded a 2025 Housing Delivery Test result below 75%, the point at which the new NPPF treats the result as evidence of unmet housing need. Fifty-two of those 93 are in London or the South East. The full regional breakdown is in Planning By Design’s August analysis.
How much of England is Green Belt?
England’s Green Belt covered 1,633,220 hectares as at 31 March 2025, about 12.5% of the country’s land area, according to MHCLG.
Which councils have the most Green Belt?
Among the councils that fell below 75% on the 2025 Housing Delivery Test, the largest Green Belt areas are in Sevenoaks (34,390 hectares), Epping Forest (30,830), Kirklees (24,990) and Bradford (23,880).
What is a Green Belt battleground?
It is a term used by Planning By Design for a council where three things apply at once: a Housing Delivery Test result below 75%, Green Belt covering at least half of its land, and homes less affordable than the England average. Twenty-one councils meet all three tests.
Does failing the Housing Delivery Test mean Green Belt land can be built on?
No. A result below 75% counts as evidence of unmet housing need for certain policies in the NPPF. Green Belt land remains subject to its own policy framework, and every proposal is still assessed on its own merits.
What is the Housing Delivery Test?
The Housing Delivery Test is an annual Government measure comparing the number of homes delivered in each local planning authority over three years with the number of homes required over the same period.
