What Are Very Special Circumstances in the Green Belt?
Learn what 'very special circumstances' mean in Green Belt planning, how the planning balance is applied, and which factors can justify inappropriate development.
GREEN BELT
Andrew Ransome
7/6/20265 min read
When development in the Green Belt does not fall within any of the exceptions to inappropriate development in paragraph 154 of the December 2024 NPPF, it can only be approved if the applicant demonstrates very special circumstances.
This is the highest planning policy test in the English system.
Very special circumstances is frequently cited, but regularly misunderstood.
This article explains the test in full: what it means, what types of factors have been accepted and rejected, and how planners carry out the balancing exercise.
The NPPF's Very Special Circumstances Policy Test
Paragraph 153 of the December 2024 NPPF states that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.
Very special circumstances will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.
Substantial weight is given to any harm to the Green Belt, including harm to its openness.
Three things to note:
the test is one of 'clearly outweigh' — it is not sufficient for other considerations to merely outweigh the harm.
The harm to be weighed is the totality: inappropriateness, openness harm, and any other non-Green Belt harm. And
the NPPF requires substantial weight to be given to that totality — it cannot be minimised.
The Planning Decision Framework
Very special circumstances is often assessed as a sequence:
Is the development inappropriate?
Would there be any harm to the Green Belt?
Are there other considerations in favour of the proposal?
Do they clearly outweigh the harm?
If so, do very special circumstances exist?
Have relevant development plan policies and the NPPF been addressed?
This structure ensures that the very special circumstances conclusion is reached as a consequence of the balance, not stated as a premise.
Very special circumstances is the conclusion reached when the other considerations do clearly outweigh the harm.
What Is 'Very Special' About Very Special Circumstances?
The Court of Appeal in Wychavon District Council v Secretary of State for Communities and Local Government and Butler [2008] clarified that 'very special' does not mean rare or uncommon.
The word 'special' connotes a qualitative judgement about the weight to be given to the factor — not a quantitative test about statistical rarity.
Factors that are in one sense commonplace (the need for accommodation, health circumstances) may still be 'very special' if they carry sufficient weight in the specific circumstances of the case.
Basildon Borough Council v Secretary of State for the Environment [2000] confirmed that circumstances do not have to be unique.
Other Considerations: What Can Constitute Very Special Circumstances?
Housing Need
Ministers have said housing need on its own will not normally be sufficient to show very special circumstances. But general unmet housing need has been accepted as an 'other consideration' in many Green Belt cases, when considered alongside other factors.
The argument is strengthened where: the authority cannot demonstrate a five-year housing land supply; the site would contribute to a specific identified need such as care home, affordable housing or custom/self-build; or there are no suitable alternative sites outside the Green Belt.
Under the December 2024 NPPF, where a grey belt route is available, the Very Special Circumstances argument may be less necessary — the paragraph 155 conditions should be tested first.
Personal Circumstances
Medical need, family care requirements and disability accommodation can in principle constitute other considerations.
The standard remains high: a general desire for a larger or more convenient home does not suffice.
The need must be genuine, demonstrated, and specifically linked to the proposed development.
Economic Benefits
Sustaining or expanding an existing business, creating or retaining jobs, enabling a rural enterprise to function, or delivering investment in an area can all be material.
The weight depends on the scale and specificity of the benefit and where it cannot be located elsewhere— a detailed business case demonstrating identified jobs will carry more weight than a speculative general claim.
Environmental and Design Benefits
Remediation of contaminated land, removal of unsightly structures, improvements to biodiversity or landscape, and buildings of exceptional architectural quality can carry weight.
Enhancement of the beneficial use of the Green Belt — improving public access, providing outdoor sport and recreation — can all be a relevant considerations.
Enabling Development
Where inappropriate development generates resources necessary to secure the restoration of a listed building or delivery of community infrastructure, enabling development arguments have been accepted.
Key requirements: demonstrable need for the enabling proceeds; a clear and enforceable link between the development and the public benefit; and a finding that the benefit could not be achieved by other means.
Fallback Positions
A fallback position — development that could lawfully be carried out on the same site without the permission now sought — is a well-established category of other consideration in the Green Belt balance.
Where there is a realistic prospect that the fallback would be implemented, it is a material consideration that decision-makers must weigh.
The Court of Appeal in Mansell v Tonbridge and Malling Borough Council [2017] confirmed that permitted development rights can legitimately constitute a fallback, and that failure to take a realistic fallback into account is an error of law.
The value of a fallback as an other consideration depends on two things: the degree to which the fallback would itself harm the Green Belt if implemented, and the extent to which the proposed scheme represents a better outcome.
Where an applicant can demonstrate that an existing consent could be implemented and would cause comparable or greater harm to openness than the proposed scheme, the net benefit of granting permission for the proposed scheme over and above the fallback can be weighed as an other consideration.
The stronger and more clearly evidenced the fallback, the greater the weight it can carry in the balance.
How Is the Balance Struck?
The Very Special Circumstances assessment is a single exercise of planning judgement. There is no requirement to attach separate substantial weight to each element of harm identified.
The decision-maker must have real regard to the importance of the Green Belt and the seriousness of any harm.
Any other harm in the Very Special Circumstances test encompasses all harms, not only Green Belt harms — including impacts on character, heritage, amenity and ecology. These must be identified and included in the overall balance.
What Does Not Constitute Other Considerations
The absence of harm is not an other consideration.
The absence of severe harm cannot reduce the harm by reason of inappropriateness or the harm to openness.
A neutral factor — for example, that the proposal would not harm the character and appearance of the area — does not add positive weight to the balance.
Very Special Circumstances - Summary
Very special circumstances is the test that applies to all inappropriate development in the Green Belt that cannot find a route through the paragraph 154 exceptions.
The test requires the totality of harm to be clearly outweighed by other considerations.
Very special means qualitatively weighty considerations to satisfy the test. The balancing exercise is a single holistic judgement. A well-structured, evidence-based case is essential.
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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