What Types of Development Are “Not Inappropriate” in the Green Belt?
Understand which types of development are not inappropriate in the Green Belt under NPPF paragraphs 154 and 155, including key exceptions, Grey Belt reforms, openness, and planning strategy.
GREEN BELT
Andrew Ransome
6/19/20265 min read
Green Belt policy starts from a position of restraint. The National Planning Policy Framework (NPPF) provides that development in the Green Belt is inappropriate unless one of the specified exceptions applies.
Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. This is the starting point for assessing almost every proposal in the Green Belt.
Importantly, however, the NPPF does not impose a blanket prohibition on development.
Instead, it sets out a defined series of exceptions where development will not be regarded as inappropriate.
For landowners, developers and planning professionals alike, the first question should therefore be whether a proposal falls within one of those exceptions. If it does, there is no need to demonstrate very special circumstances.
The Structure of the Exceptions: A Closed List
The NPPF sets out an exhaustive list of circumstances in which development in the Green Belt will not be regarded as inappropriate.
Their legal significance is well established. In R (Lee Valley Regional Park Authority) v Epping Forest District Council [2016], the Court of Appeal confirmed that national Green Belt policy contains a closed list of exceptions.
Decision-makers cannot create additional categories: if a proposal does not fall within one of the specified exceptions, it is inappropriate development and must be justified by very special circumstances.
The Supreme Court subsequently confirmed in R (Samuel Smith Old Brewery (Tadcaster)) v North Yorkshire County Council [2020] that concepts such as “inappropriate development”, “very special circumstances” and “openness” are matters of planning judgment to be applied sensibly in their policy context, rather than rigid legal tests.
While the application of the exceptions requires planning judgment, the categories themselves remain fixed and exhaustive.
Paragraph 154: The Principal Exceptions
Paragraph 154 contains the principal exceptions to inappropriate development in the Green Belt.
Some relate to the construction, extension or replacement of buildings, while others apply to different forms of development.
Buildings and Redevelopment
The following types of development are not inappropriate under paragraph 154, subject to the relevant policy criteria:
Buildings for agriculture and forestry.
Appropriate facilities, including buildings, for outdoor sport, outdoor recreation, cemeteries, burial grounds and allotments, where they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
Extensions or alterations that do not result in disproportionate additions over and above the size of the original building.
Replacement buildings that remain in the same use and are not materially larger than those they replace.
Limited infilling in villages.
Limited affordable housing for local community needs under development plan policies, including rural exception sites.
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), provided it would not cause substantial harm to the openness of the Green Belt.
Each of these categories has generated substantial planning practice and case law. Concepts such as “original building”, “materially larger”, “limited infilling” and “substantial harm to openness” require careful assessment in the context of the individual proposal.
Other Forms of Development
Paragraph 154 also provides that certain other forms of development are not inappropriate, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
These include:
Mineral extraction.
Engineering operations.
Local transport infrastructure that 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 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.
Although these categories are distinct from the building-related exceptions above, they remain part of the same closed list in paragraph 154 and are subject to the important requirements relating to openness and Green Belt purposes.
Paragraph 155: The Grey Belt Exception
Paragraph 155 introduces an additional route by which development may be regarded as not inappropriate in the Green Belt.
It applies to the development of homes, commercial development and other development on Grey Belt land, but only where all of the specified criteria are met.
In summary, the proposal must:
utilise Grey Belt land;
not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan;
respond to a demonstrable unmet need for the type of development proposed;
be located in a sustainable location; and
where applicable, satisfy the “Golden Rules” requirements set out elsewhere in the NPPF.
The Grey Belt provisions represent a distinct policy pathway rather than simply another item within the traditional list of Green Belt exceptions and should be analysed separately when assessing development potential.
The Importance of Openness
The concept of openness remains central to Green Belt policy.
In Samuel Smith, the Supreme Court confirmed that assessing openness is a matter of planning judgment and that both spatial and visual impacts may be relevant.
In practice, this means a proposal's effect on the character of open land, its bulk and massing, and its visibility in the landscape may all be relevant considerations.
A relatively modest building may therefore fail the openness test if its siting or appearance significantly erodes the open character of the Green Belt.
Why the Exceptions Matter for Planning Strategy
The existence of these exceptions has important practical consequences.
Before considering whether very special circumstances might exist, applicants should first assess whether their proposal falls within one of the recognised categories in paragraph 154 or qualifies under the Grey Belt provisions in paragraph 155.
If it does, the proposal is not inappropriate development and does not need to be justified by very special circumstances.
If it does not, the applicant faces the considerably more demanding task of demonstrating that very special circumstances clearly outweigh the harm to the Green Belt and any other harm arising from the proposal.
Even where development is not inappropriate, planning permission is not automatic. The proposal must still be assessed against the wider development plan and other material considerations, including design, heritage, highways, landscape and residential amenity.
Green Belt Exceptions Summary
The current NPPF does not prohibit all development in the Green Belt. Instead, it establishes a closed set of exceptions.
Paragraph 154 contains the principal categories of development that are not inappropriate, covering both specified building-related proposals and other forms of development such as engineering operations, mineral extraction, changes of use and the re-use of buildings.
Paragraph 155 provides a separate route for qualifying development on Grey Belt land where its detailed criteria are met.
For anyone considering development in the Green Belt, determining whether a proposal falls within one of these policy exceptions should be the starting point for any planning strategy.
If no exception applies, the proposal will ordinarily require the demonstration of very special circumstances.
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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