Previously Developed Land in the Green Belt
Learn what counts as previously developed land (PDL) in the Green Belt, key exclusions, case law and redevelopment opportunities.
GREEN BELT
Andrew Ransome
6/30/20264 min read
Previously developed land (PDL) — brownfield land — occupies a distinctive position in Green Belt policy. It benefits from specific treatment under paragraph 154(g) of the December 2024 NPPF, is given priority in the sequential approach to Green Belt release, and is one of the two components of the grey belt definition.
Understanding precisely what the Previously developed land definition includes and excludes is therefore essential to any assessment of development potential on Green Belt sites.
The NPPF's Previously Developed Land Definition
Annex 2 to the December 2024 NPPF defines previously developed land as land which has been lawfully developed and is or was occupied by a permanent structure and any fixed surface infrastructure associated with it, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed).
It also includes land comprising large areas of fixed surface infrastructure such as large areas of hardstanding which have been lawfully developed.
The definition explicitly excludes:
Land that is or was last occupied by agricultural or forestry buildings.
Land developed for minerals extraction or waste disposal by landfill, where provision for restoration has been made through development management procedures.
Land in built-up areas such as residential gardens, parks, recreation grounds and allotments.
Land that was previously developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape.
The Agricultural and Forestry Exclusion
The agricultural and forestry exclusion is the most frequently encountered issue in practice.
The exclusion applies to land that is or was 'last occupied' by agricultural or forestry buildings. Crucially:
A farm building currently in agricultural use — is not previously developed land.
A former farm building last used for agriculture, now vacant — is not previously developed land (the 'was last occupied' wording applies).
A former farm building that has changed use from agriculture to another use (commercial storage, workshops, etc.) — is is not previously developed land as it is no longer last occupied by an agricultural building.
R (Lee Valley Regional Park Authority) v Broxbourne Borough Council [2015] confirmed that land is not previously developed where the permanent structure upon it is lawfully and solely an agricultural or forestry building.
Residential Gardens in the Countryside
The previously developed land definition excludes residential gardens only in built-up areas.
Gardens of properties in the open countryside are therefore not automatically excluded.
The Court of Appeal in Dartford Borough Council v Secretary of State for Communities and Local Government [2017] confirmed that residential gardens which are not in built-up areas are not excluded from the general PDL definition.
However, the decision-maker must form a view about whether the land is within a 'built-up area' — a term not itself defined in the NPPF — and must then assess whether the land otherwise satisfies the general PDL definition.
The Previously Developed Land Exception: Paragraph 154(g)
Paragraph 154(g) of the December 2024 NPPF provides that limited infilling or the partial or complete redevelopment of previously developed land (including a material change of use to residential or mixed use including residential), whether redundant or in continuing use (excluding temporary buildings), is not inappropriate development, provided the development would not cause substantial harm to the openness of the Green Belt.
This is a significant simplification from the previous policy, which contained two alternative openness tests.
The December 2024 NPPF applies a single test: no substantial harm to openness.
This is a more permissive standard than the previous 'no greater impact' test, and is a material improvement for applicants proposing redevelopment of PDL sites in the Green Belt.
The December 2024 wording allows for some degree of impact, provided it does not reach substantial harm — a lower and more achievable threshold for many sites.
Residential and Mixed-Use PDL Redevelopment
The December 2024 NPPF expressly includes material changes of use to residential or mixed use including residential within the paragraph 154(g) exception.
This confirms that converting or redeveloping previously developed land to housing — not merely retaining its existing use or changing to a non-residential use — is capable of being not inappropriate, provided the openness test is met.
This is a significant opening for redundant commercial or institutional previously developed land sites in the Green Belt where residential development is proposed.
Can a Redundant Farm Building Site Be Redeveloped?
This is one of the most commonly asked questions. The answer depends entirely on the history and current status of the buildings.
If they are still in agricultural use or were last used for agriculture, the land is not PDL and paragraph 154(g) cannot apply.
If they have been in a different use — storage, workshops, community — the land may be PDL and paragraph 154(g) may provide a route.
Even where a farm building site is not PDL, alternative routes may exist:
re-use under paragraph 154(h)(iv);
Class Q permitted development for residential conversion; or,
if the site makes a limited contribution to purposes (a), (b) and (d) and is free from Footnote 7 constraints, the grey belt route under paragraph 155.
Each route carries different requirements and risks.
Previously Developed Land in the Green Belt - Summary
Previously developed land in the Green Belt is a defined category with important exclusions:
agricultural and forestry land last so occupied,
residential gardens in built-up areas, and
structures that have blended into the landscape.
The Dartford [2017] and Lee Valley [2015] decisions clarify the key borderline cases.
Under paragraph 154(g) of the December 2024 NPPF, PDL redevelopment including residential is not inappropriate provided it does not cause substantial harm to openness — a more permissive test than before December 2024.
For redundant agricultural sites, PDL status, re-use and grey belt qualification must each be assessed carefully before a strategy is determined.
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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