16 August 2011

Green Belt Planning Policy – PPG2 Explained in Plain English

Architects, landowners and developers are often wary of Green Belt sites as they think it cannot be built on. In fact, keys parts of local and national planning policies actually encourage development of Green Belt sites, so long as it is the right kind of building, supporting the right kind of use. 

This article looks at how the key planning policies promote Green Belt development and how you can use them to guide your scheme towards gaining planning permission.

Making sense of ‘Planning Policy Guidance 2: Green Belts’*

The touchstone for all Green Belt policy is the document ‘Planning Policy Guidance 2: Green Belts’, also known as PPG2. Planning policy in England and Wales consists of national, regional and local policies, which describe the general and the specific of how all planning applications should be decided. Where Green Belts are concerned, you should always check local and regional plans for site specific policies, but many local authorities simply refer back to central government’s guidance contained in PPG2.

PPG2 is summed up in two key paragraphs, one of which you may find very helpful as an architect or developer and one which you will most likely find frustrating. Paragraph 1.5 is the difficult one and explains the criteria for designating land as Green Belt. This process is carried out by the local planning authority and is beyond your control. Five reasons are given, but they all basically add up to keeping the landscape open or free from ‘encroachment’. The positive outcome of this paragraph is to push development (buildings, jobs, homes) back into urban areas. However, the local consequence is that every square inch of Green belt is all too often treated as sacrosanct, the last line of defence against an unending barrage of change.

The next point, however, is overwhelmingly positive. The reason for creating Green Belts is not to create a forbidding choke-hold around our cities. It is to provide access to open spaces within reach of crowded cities. Paragraph 1.6 describes what activities or land uses are ‘appropriate’ for Green Belt land. If you can argue that your development will open up your Green Belt site to the public and encourage people to appreciate its value as a landscape (not a townscape), then you can argue that PPG2 supports your scheme. To quote paragraph 1.6 ‘the use of land in them (Green Belt developments) has a positive role to play in fulfilling the following objectives;

- to provide opportunities for access to the open countryside for the urban population;
- to provide opportunities for outdoor sport and recreation near urban areas;
- to retain attractive landscapes, and enhance landscapes, near to where people live;
- to improve damaged and derelict land around towns;
- to secure nature conservation interest; and
- to retain land in agricultural, forestry and related uses’

I have highlighted the words that I feel encourage development of the Green Belt and a strengthening of ties between town and fringe.

The most frustrating thing about PPG2 is the way that it is often misinterpreted by local planning authorities as a way of blocking development. The Green Belt is seen as a defence against the city for rural residents, whereas in fact it is meant to be an extension to, and integral part of the town that it surrounds.

So, what can you build?

The answer to that is everything and nothing.

PPG2 is very non-specific about what can and cannot be built on Green Belt land.  Only developments judged ‘appropriate’ in terms of maintaining openness and fulfilling the objectives such as creating opportunities for outdoor sport should be approved but there is little guidance on what counts as ‘appropriate’ and even 'inappropriate' developments can be approved under 'very special circumstances'.

There are no specific references to planning use classes like D2 Assembly and Leisure or C3 Dwellinghouses. Instead, guidance on what is 'appropriate' is given in a fit of double negatives in paragraph 3.4;

‘The construction of new buildings inside a Green Belt is inappropriate unless it is for the following purposes:

- agriculture and forestry (unless permitted development rights have been withdrawn – see paragraph D2 of Annex D);
- essential facilities for outdoor sport and outdoor recreation, for cemeteries, and for other uses of land which preserve the openness of the Green Belt and which do not conflict with the purposes of including land in it (see paragraph 3.5 below);
- limited extension, alteration or replacement of existing dwellings (subject to paragraph 3.6 below);
- limited infilling in existing villages (under the circumstances described in the box following paragraph 2.11), and limited affordable housing for local community needs under development plan policies according with PPG3 (see Annex E, and the box following paragraph 2.11); or
- limited infilling or redevelopment of major existing developed sites identified in adopted local plans, which meets the criteria in paragraph C3 or C4 of Annex C1'

There is little official guidance on 'very special circumstances', but these can include economic factors, the need for job-specific workers' accommodation or a proven local shortage of affordable housing.


Herein lies the inherent contradiction within Green Belt policy.

Any new building or development will by definition represent a form of ‘encroachment’, in that it will encourage people from both sides of the belt to use the space in between. But that is exactly what other parts of the policy encourage as opportunities for ‘access to the open countryside . . . outdoor sport and outdoor recreation’. Paragraph 1.7 says that the openness argument should always take precedence over the (useful) land use objectives. But with no clarity provided on ‘openness’, ‘encroachment’, ‘sprawl’ or ‘essential facilities’, these terms are all up for grabs and open to interpretation. If you can show that your new building will have an acceptable effect on ‘openness’ whilst enabling an open-air use of the site, then you can argue that your scheme is appropriate.

Who decides?

Ultimately, local planning officers and local councillors will be the arbiters of what is 'appropriate' and how much building is tolerable before 'encroachment' becomes an issue. They will also decide what counts as 'very special circumstances' and you may find that councillors will forget that such circumstances are only needed when the use is inappropriate.

You may also find that the local planning officer interprets ‘essential facilities’ to mean the bare minimum requirements. This effectively threatens a hiatus on any new leisure activities on our urban fringes or at the very least puts the onus onto the applicant to prove the minimal nature of their scheme, even if it is not in fact the 'minimum'. Consider, for instance, changing rooms for sports pitches. A local sports team might want separate changing rooms and showers for each team, plus the referees and a small shelter for spectators (or parents). This would be quite modest but way above the bare minimum, whereby everyone must arrive by car already in their kit and leave the site unwashed. This minimum does not need a building at all but falls far short most teams' idea of 'essential'.

Unfortunately, I’m not (yet) aware of any precedents that can challenge the restrictive, minimum interpretation of 'essential facilities'.

In practice I have found that relying on an 'appropriate' use is not enough when it comes to convincing local planning officers or committee members. You generally have to justify every square inch of footprint as 'essential', minimal and 'very special' to get any traction.

Green Belt 'appropriate' photos of zorbing, sports pitches and car boot sales courtesy of;
* Since this article was originally published PPG2 has been superseded by the NPPF. Many of the clauses quoted above have been edited or removed from the current policy and we suggest you refer to the current policy document for the avoidance of any doubt.