Planning for Renewable Energy in the Green Belt
Renewable energy development in the Green Belt often requires Very Special Circumstances. Learn how solar farms, battery storage and NPPF policy apply.
GREEN BELT
Andrew Ransome
6/25/20263 min read
As the national drive towards net zero carbon accelerates, landowners and developers are increasingly exploring whether solar farms, wind turbines, battery storage facilities and other energy infrastructure can be accommodated in the Green Belt.
The policy position under the December 2024 NPPF is clear: most renewable energy development in the Green Belt is inappropriate, requiring a demonstration of very special circumstances.
However, the NPPF explicitly recognises that the environmental benefits of renewable energy generation can, in the right case, constitute those circumstances.
The Policy Position: Inappropriate by Default
Paragraph 160 of the December 2024 NPPF states:
When located in the Green Belt, elements of many renewable energy projects will comprise inappropriate development. In such cases developers will need to demonstrate very special circumstances if projects are to proceed. Such very special circumstances may include the wider environmental benefits associated with increased production of energy from renewable sources.
This is a meaningful acknowledgement: the NPPF expressly contemplates that renewable energy benefits can in principle constitute very special circumstances.
This represents a more permissive approach than the position under earlier iterations, and reflects the increasing weight the planning system attaches to climate change mitigation as a material consideration.
Is All Renewable Energy Development Inappropriate?
Not necessarily. The starting point is paragraph 154, which sets out the closed list of exceptions.
Certain elements of renewable energy schemes may fall within those exceptions.
Engineering operations under paragraph 154(h)(ii) — certain groundworks, cable trenching, site preparation — may not be inappropriate if they preserve openness and do not conflict with Green Belt purposes.
A material change of use under paragraph 154(h)(v) involving no new buildings may also satisfy the test.
However, the principal components of most renewable energy schemes — solar panel arrays, wind turbines, battery storage buildings, substation buildings — are likely to be treated as new buildings or inappropriate engineering works.
Very Special Circumstances for Renewable Energy
Where renewable energy development is inappropriate, the applicant must demonstrate that other considerations clearly outweigh the totality of Green Belt harm and any other harm.
The NPPF's explicit reference to wider environmental benefits provides a material starting point. In practice, the following factors have supported VSC arguments:
Demonstrable carbon reduction benefits, with evidence of generation capacity and carbon savings over the scheme's lifetime.
Reversibility: solar farms are sometimes granted for a fixed period (commonly 25–40 years) with a decommissioning condition. The temporary nature of the harm is relevant to the balance.
Limited harm to openness: where the site is well-screened, panels are low-profile and there are limited public views, the degree of openness harm may be assessed as moderate.
Weak contribution to Green Belt purposes: where the site makes limited contribution to checking sprawl, preventing settlement merger or preserving a historic setting, the purposes harm may be limited.
Agrivoltaic arrangements combining solar generation with grazing or crop production, maintaining an agricultural character.
Flood Risk and Solar Farms
Annex 3 of the December 2024 NPPF classifies solar farms as essential infrastructure for flood risk vulnerability purposes.
This does not remove the Green Belt constraint — Green Belt policy applies regardless of flood risk — but it has implications for sites in flood zones where other uses might otherwise be prevented.
Renewable Energy in the Green Belt: Summary
Renewable energy development in the Green Belt is in most cases inappropriate, requiring Very Special Circumstances.
Paragraph 160 provides a firmer policy footing than existed under earlier versions by expressly acknowledging that wider environmental benefits of renewable energy may constitute Very Special Circumstances.
The strength of the case depends on demonstrable carbon reduction, reversibility, the degree of openness harm, and contribution to Green Belt purposes.
Early pre-application engagement with the local planning authority is advisable.
Planning Application Advice
If you own land or a building in the Green Belt and want to understand your development options, I can advise on planning strategy and manage your application from initial assessment through to decision. Contact me to discuss your site.
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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Get in touch for planning advice: Email: andrew@andrewransome.co.uk
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