Outdoor Sport and Recreation in the Green Belt
GREEN BELT
Andrew Ransome
6/24/20266 min read
Within the National Planning Policy Framework (NPPF), outdoor sport and recreation have always occupied a recognised and valued place. Playing fields, golf courses, cricket grounds, allotments and cemeteries are, in their different ways, consistent with the essential openness of the Green Belt.
The NPPF reflects this by providing specific exceptions for buildings associated with these uses.
This article explains the exception for outdoor sport, outdoor recreation, cemeteries, burial grounds and allotments under paragraph 154(b) of the December 2024 NPPF.
It also considers what makes the openness test for these uses more demanding than for agricultural buildings.
Green Belt Policy: Paragraph 154(b)
Paragraph 154(b) of the NPPF provides that the construction of buildings for appropriate facilities for outdoor sport, outdoor recreation, cemeteries and burial grounds and allotments is not inappropriate development in the Green Belt.
This exception is provided the facilities preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
This exception is more tightly drawn than the agricultural buildings exception. Five conditions must all be satisfied for a proposed building to fall within it:
The facility must be a building — not an engineering operation, a surface or an area of hardstanding.
The building must be for one of the specified uses: outdoor sport, outdoor recreation, cemeteries and burial grounds, or allotments.
The building must be for appropriate facilities for that use — not any building that happens to be on land used for sport.
The facilities must be in connection with the existing use of the land or a proposed change of use — not a speculative building with no established or proposed sporting use.
The facilities must preserve the openness of the Green Belt and must not conflict with the purposes of including land within it.
All five conditions are cumulative.
A proposal that satisfies the first four but fails the openness test is not protected by paragraph 154(b) and becomes inappropriate development, requiring very special circumstances.
The Openness Test: A Strict Standard
Unlike the agricultural buildings exception, paragraph 154(b) expressly requires the proposed building to preserve the openness of the Green Belt.
This is a demanding standard, and the courts have consistently interpreted it strictly.
In R (Amanda Boot) v Elmbridge Borough Council [2017] EWHC 12 (Admin), the High Court held that even a limited or not significant adverse impact on openness means that openness is not preserved.
The test is either openness is preserved or it is not.
The strict test means that design and siting matter enormously for sport and recreation buildings in the Green Belt.
A small, well-sited and well-screened pavilion, golf facilities or equestrian stables may preserve openness; a larger, more prominent structure of the same type, may not — even if it serves an entirely appropriate sporting purpose.
The openness assessment must be made with care, and the degree of visual intrusion, built form and landscape impact are all directly relevant.
Appropriate Facilities
The word 'appropriate' in paragraph 154(b) means that not every building associated with an outdoor sporting use will qualify.
The facilities must be appropriate to and necessary for the use in question, rather than buildings of a scale or character that goes beyond what the use genuinely requires.
A modest changing room and toilet block serving a community rugby club on a Green Belt pitch is likely to be an appropriate facility.
A large two-storey clubhouse with a bar, a function room, a gym and permanent office space serving the same club may well not be — particularly if the scale of the building exceeds what the club genuinely needs.
In Connection with the Existing Use or a Change of Use
The requirement that the building must be in connection with the existing use of the land, or with a change of use, is a functional link requirement.
It means that the exception does not permit speculative buildings that are constructed in anticipation of a future sporting use that has not yet been established.
In practical terms, a proposed changing room block on land currently used as a playing field is in connection with an existing use and satisfies this requirement.
A proposed pavilion on agricultural land for which a change of use to a playing field is simultaneously applied for would also satisfy the condition.
A proposed sports building on agricultural land with no associated sporting use, either current or proposed, would not satisfy the condition.
Engineering Operations and Associated Works
Vehicular access tracks, car parking areas, earthwork bunds, drainage works and lighting columns are not buildings.
They fall outside paragraph 154(b) and are instead assessed as engineering operations under paragraph 154(h)(ii).
The same dual test applies: they must preserve the openness of the Green Belt and must not conflict with the purposes of including land within it.
All-weather sports surfaces require careful assessment, for example MUGA picthes, tennis courts, padel courts and ménage. An artificial pitch creates a large area of hard landscape material that is permanently visible and could be considered inconsistent with the open, rural character of the Green Belt.
Considerate design is required, for exmpel, where the surface is sunken, well-screened and/or modest in scale, it may preserve openness.
Where it involves significant lighting columns, perimeter fencing, hardstanding car parks and associated ancillary buildings, the cumulative impact on openness may be significant and the openness test may not be satisfied.
Floodlighting for outdoor sport is a particularly sensitive issue in the Green Belt.
Even where the physical structures are relatively modest, the light spill and visual impact at night can be a material consideration in the openness assessment.
Cemeteries, Burial Grounds and Allotments
Cemeteries, burial grounds and allotments are specifically listed in paragraph 154(b) alongside outdoor sport and recreation.
In all three cases, the exception applies to buildings for appropriate facilities in connection with those uses — not to the land use itself, which typically requires a material change of use application.
A cemetery chapel, a maintenance building for a burial ground, an allotment tool store or a communal allotment shed may all qualify as not inappropriate buildings under this exception, provided the openness and purposes tests are satisfied.
The land use change must be assessed separately as a material change of use. This falls under paragraph 154(h)(v), which provides that material changes of use including for outdoor sport or recreation, or for cemeteries and burial grounds, can be not inappropriate provided they preserve openness and do not conflict with Green Belt purposes.
Paragraph 154(h): Other Forms of Development
The December 2024 NPPF consolidated what was previously a separate paragraph 155 of the NPPF into paragraph 154 as sub-paragraph (h).
This brought together a range of further categories of development that are not inappropriate in the Green Belt, all subject to the same dual test of preserving openness and not conflicting with Green Belt purposes.
The paragraph 154(h) categories are:
Mineral extraction.
Engineering operations.
Local transport infrastructure which can demonstrate a requirement for a Green Belt location.
The re-use of buildings, provided they are of permanent and substantial construction.
Material changes in the use of land, such as changes of use for outdoor sport or recreation, or for cemeteries and burial grounds.
Development, including buildings, brought forward under a Community Right to Build Order or Neighbourhood Development Order.
The courts confirmed in Fordent Holdings Ltd v Secretary of State for Communities and Local Government and Cheshire West and Chester Council [2013] that this is a closed list.
A proposal that does not fall within one of the specified categories is inappropriate development, regardless of how closely it resembles a listed category. Decision-makers cannot extend the list by analogy.
The Relationship Between Paragraph 154(b) and Paragraph 154(h)
There is an important structural relationship between these two categories.
Paragraph 154(b) covers buildings for appropriate facilities for outdoor sport and recreation — it is the route for new buildings.
Paragraph 154(h)(v) covers material changes of use of land for outdoor sport and recreation — it is the route for changes of use without new buildings, or where the primary issue is the use of the land rather than the construction of a building.
Where a proposal involves both a change of use and a new building — for example, converting agricultural land to a playing field and erecting a pavilion — both paragraphs are engaged.
The change of use must satisfy paragraph 154(h)(v); the building must satisfy paragraph 154(b). Both must independently preserve openness and not conflict with Green Belt purposes.
Outdoor Sport and Recreation in the Green Belt - Summary
Outdoor sport, recreation, cemeteries, burial grounds and allotments have a well-established place in the Green Belt.
Buildings to support those uses are not inappropriate development under paragraph 154(b) provided the five-part test is satisfied: a building, for an appropriate facility, for a specified use, in connection with an existing or proposed use, that preserves openness and does not conflict with Green Belt purposes.
The openness test is a strict standard any adverse impact means openness is not preserved.
Engineering operations including all-weather surfaces and lighting are assessed separately under paragraph 154(h)(ii).
The other forms of development in paragraph 154(h) are a closed list and all carry the same dual test of openness and purposes.
Changes of use for outdoor sport and recreation are assessed under paragraph 154(h)(v), separately from any associated buildings assessed under paragraph 154(b).
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Andrew Ransome MRTPI - Email: andrew@andrewransome.co.uk
About me
Andrew Ransome is a Planning Director and a Chartered Member of the Royal Town Planning Institute (RTPI), with more than two decades of experience in town planning.
He specialises in delivering strategic planning solutions for complex developments across both rural and urban environments, helping clients navigate planning challenges and unlock development opportunities. Connect with Andrew on Linkedin.
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