Appeal 6001848

The appeal is dismissed.

On 16 December 2025, the Government published a consultation on proposed reforms to the National Planning Policy Framework (the Framework). Whilst broad changes to the structure of the Framework are proposed as part of this consultation, these proposals could be subject to further change and can only be given very limited weight at this stage. It has therefore not been necessary to consult the parties on the changes, and in reaching my decision, I have had regard to the Framework published in December 2024.

The main issues are: • whether the proposal would be inappropriate development in the Green Belt for the purposes of the National Planning Policy Framework (the ‘Framework’) and development plan policy; • the effect of the proposal on the openness of the Green Belt; • the effect of the proposal on the character and appearance of the appeal site and surrounding area; and • if the development would be inappropriate, whether the harm to the Green Belt by way of inappropriateness, and any other harm, would be clearly outweighed by other considerations so as to amount to the very special circumstances necessary to justify it.

The appeal site comprises a detached bungalow within a large plot in the Green Belt. The plot contains a number of ancillary buildings, including a timber snooker room, a garage and other domestic outbuildings.

Policy PMD6 of the [name] and Policies for the Management of Development (2015) (the ‘Local Plan’) states that the extension of a building must not result in disproportionate additions over and above the size of the original building. In the case of residential extensions this means no larger than two reasonably sized rooms or any equivalent amount. The Council contends that the cumulative effect of existing and proposed extensions would result in disproportionate additions over and above the size of the original dwelling.

The Framework states that the construction of new buildings in the Green Belt is inappropriate development unless it falls within one of the listed exceptions. Exception (c) of Paragraph 154 allows the extension or alteration of a building, provided that it does not result in disproportionate additions over and above the size of the original building. Although the most straightforward application of this exception is to additions physically attached to an existing building, it is recognised that, in some circumstances, a detached structure can be treated as an “extension” in policy terms where it functions as a normal domestic adjunct to the host dwelling and is sufficiently closely related to it.

Whether a detached building can properly be treated as an extension for the purposes of paragraph 154(c) is a matter of planning judgment informed by the purpose of the policy. The exception is intended to allow limited enlargement of existing buildings without undermining Green Belt openness through disproportionate increases in built form. It is not intended to permit the creation of additional, sizeable buildings within the curtilage simply because they would serve a domestic function.

In this case, the proposed building would not constitute a small-scale domestic adjunct closely related to the host dwelling. It would be a substantial structure providing a combined garage and snooker/games accommodation with ancillary facilities. Its scale and internal arrangement indicate a building capable of hosting activity independent of the main dwelling rather than a modest ancillary addition.

The proposal would also be physically and visually separate from the host dwelling. It would be sited to the front of the plot, such that it would be read as an additional freestanding building rather than as part of the dwelling’s built envelope. Given its width, footprint and prominence within the frontage, it would have a dominant presence in views into and across the site and would not be read as clearly subordinate to the host dwelling. It would materially increase the amount of built form across the front of the plot and would not appear as a modest addition to the site. For these reasons, the proposal would not fall within the scope of paragraph 154(c) of the Framework.

Under exception (d), the replacement of a building would not be inappropriate development, provided the new building is in the same use and not materially larger than the one it replaces. The appellant argues that the proposal would replace both an existing garage and snooker room such that the overall floorspace would be broadly comparable. However, the evidence indicates only the existing snooker room would be demolished as part of the scheme. The existing garage would remain and benefits from planning permission to be converted to a self-contained annexe. Accordingly, the proposal would in practice replace only the existing snooker room.

The proposed building would be substantially larger than that building in footprint and bulk and would introduce additional uses within a single, consolidated structure. It would therefore be materially larger than the building it would replace and would not accord with the exception outlined at paragraph 154(d) of the Framework.

On this basis, the proposal would represent inappropriate development in the Green Belt and would not accord with the exemptions outlined at Paragraph 154 of the Framework. It would also conflict with Policy PMD6 of the adopted Thurrock Local Development Framework Core Strategy and Policies for the Management of Development 2015 insofar as it seeks to ensure that the Green Belt is preserved from inappropriate development.

The site is characterised by a spacious layout and extensive open garden areas with the dwelling set back from the road. The existing snooker room is a modest, single-storey structure located to the rear of the plot and reads as a lightweight, subordinate feature.

Openness is identified in the Framework as one of the Green Belt’s essential characteristics. It has been identified as being formed of both spatial and visual aspects. The proposal would introduce a long and substantial building within the open front garden of the site. The construction of a large new building and the introduction of built form within what is an undeveloped part of the site would result in a reduction in spatial openness.

The width, footprint and prominent siting of the proposed building would materially increase the amount of built form within the open frontage and would be readily perceived from the road. This would reduce the sense of openness within the site and would result in encroachment into garden land that presently contributes to the openness of the Green Belt.

For these reasons, the proposed development would result in an adverse impact on both the spatial and visual openness of the Green Belt resulting in moderate harm to the Green Belt.

The character of the appeal site and its surroundings is defined by dispersed residential development within large, verdant plots. The built form along [address] is also intermittently separated by paddock fields and wooded verges which contribute to an open, semi-rural setting. The frontage of the appeal site has a spacious and open character due to the main dwelling being substantially set back from the road. Existing ancillary buildings on the site are modest in scale and arranged so as not to dominate the frontage.

The proposed building would be of considerable width and would occupy a prominent position to the front of the plot along the western boundary, forward of the principal elevation of the dwelling. This would disrupt the established hierarchy of built form on the site, diminishing the visual primacy of the main dwelling. It would also increase the built presence across the frontage. What’s more, the associated hardstanding and new access would further increase the amount of development at the front of the plot, adding to the urbanising effect in a location which currently reads as verdant and open garden land.

The appellant contends that the proposed building would be screened by existing vegetation and would therefore not appear visually intrusive. Whilst there is mature vegetation along the western boundary of the site, this screening is not continuous or year-round and would not reliably or consistently obscure the proposed building from views along the lane or across the site frontage. The frontage fencing would partially obscure views of the proposed building, however, its roof would still be visible from the road. In any event, screening would not address the change in the pattern of development that would result from introducing a substantial new building within the front garden.

By reason of its scale, siting and massing, the building would remain perceptible in the street scene and would materially alter the character of the site from one with a loose, verdant and spacious frontage to one with a more built-up appearance. The proposal would therefore appear as a bulky and visually intrusive feature that would fail to integrate with the character and appearance of the appeal site and its surroundings.

Given this, the proposal would harm the character and appearance of the appeal site and surrounding area. It would therefore conflict with Policies CSTP22, CSTP23, and PMD2 of the Local Plan insofar as they seek to ensure proposals are well-designed and contribute positively to surrounding context and character.

The Framework highlights that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances, with substantial weight given to any harm to the Green Belt. 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.

The appellant refers to other developments in the wider area. However, there is insufficient information about their scale, siting or planning status to draw meaningful comparisons, and in any event each appeal must be determined on its own planning merits. I have attached very limited to this consideration.

The installation of solar panels on the proposed building would be a positive feature, and some limited weight has been afforded to this consideration.

The proposal would cause harm to the Green Belt by way of inappropriateness, as well as moderate harm to openness, and substantial weight must be given cumulatively to this harm. I have also found that the proposal would harm the character and appearance of the appeal site and surrounding area. The other considerations advanced in this case do not clearly outweigh the substantial harm that I have identified. Consequently, the very special circumstances necessary to justify the development do not exist.

The proposal conflicts with the development plan and the material considerations do not indicate that the appeal should be decided other than in accordance with it.

For the reasons given above the appeal should be dismissed.