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
8/25/20265 min read
Previously developed land (PDL) — brownfield land — occupies a distinctive position in Green Belt policy. It benefits from specific treatment under policy GB7(1)(e) of the August 2026 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 B to the August 2026 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: Policy GB7(1)(e)
Policy GB7(1)(e) of the August 2026 NPPF provides that the redevelopment of previously developed land (including a material change of use to residential or mixed use including residential) is not inappropriate development, provided the development would not cause substantial harm to the openness of the Green Belt.
This carries forward, unchanged in substance, the single-test approach introduced in December 2024, which replaced an earlier two-part openness test.
The threshold remains no substantial harm to openness — a materially more permissive standard than the tests applying elsewhere in Green Belt policy.
This is worth setting in context against the wider August 2026 changes.
Several other GB7 categories that previously required development to "preserve" openness now instead require only that its impact be "minimised" (policy GB7(1)(f)) — itself a more permissive standard than the old preservation test.
The August 2026 wording allows for some degree of impact, provided it does not reach substantial harm — a lower and more achievable threshold for many sites, and one that has not been tightened by the wider restructuring.
Residential and Mixed-Use PDL Redevelopment
Policy GB7(1)(e) expressly includes material changes of use to residential or mixed use including residential within the 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.
Previously Developed Land and Grey Belt
Previously developed land is one of the two routes into the grey belt definition, but qualifying as PDL does not automatically make a site grey belt.
The Annex B glossary defines grey belt as land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b) or (d) in policy GB2 — checking unrestricted sprawl, preventing towns merging, and preserving the setting of historic towns.
The words "in either case" are important. The purposes test applies equally to PDL and to land that has never been developed. A PDL site still has to be assessed against those three purposes before it can be treated as grey belt.
In practice, PDL sites will often make only a weak contribution to these purposes, since the presence of existing built form frequently weakens their function in checking sprawl or preserving separation between settlements — but this has to be demonstrated through the Annex E assessment process, not assumed from PDL status alone.
Purpose (c), safeguarding the countryside from encroachment, and purpose (e), assisting urban regeneration, are excluded from the grey belt test altogether, so a strong existing contribution to either of those purposes does not prevent a PDL site from being grey belt.
The practical significance of grey belt status is that it opens up policy GB7(1)(g) as an additional, and often more flexible, route to a not-inappropriate finding — requiring an evidenced unmet need and a sustainable location, rather than the substantial-harm-to-openness test under GB7(1)(e) discussed above.
Where a PDL site does not clearly satisfy the openness test at GB7(1)(e), it is worth checking whether it independently qualifies as grey belt and can instead be considered under GB7(1)(g).
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 policy GB7(1)(e) cannot apply.
If they have been in a different use — storage, workshops, community — the land may be PDL and policy GB7(1)(e) may provide a route.
Even where a farm building site is not PDL, alternative routes may exist:
reuse, alteration or replacement of the existing building under policy GB7(1)(b);
Class Q permitted development for residential conversion; or,
if the site makes a limited contribution to purposes (a), (b) and (d) in policy GB2, the grey belt route under policy GB7(1)(g), subject to the wider Annex E assessment process and the other conditions in that policy.
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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