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Class Q appeal fails where steel frame needs rebuilding

An Inspector rejects four homes under Class Q after finding a bare agricultural steel frame would need rebuilding rather than conversion.

A Class Q appeal for four homes at an agricultural site near Doncaster has been dismissed after an Inspector found that a largely bare steel frame would need so much new building fabric that the scheme amounted to rebuilding, rather than conversion. The decision was issued on 6 November 2026.

The case concerns land beside Willow Bridge Farm at Braithwaite, where City of Doncaster Council had refused prior approval under reference 26/00766/PRIOR. Inspector E Heron visited on 27 October and examined whether the works proposed under Schedule 2, Part 3, Class Q of the General Permitted Development Order could qualify.

The critical problem was not simply that new cladding or roofing would be installed. The existing structure had little remaining enclosure, a claimed concrete floor was not visible on site and no structural survey had been provided. This Class Q appeal turns on proving that there is a building capable of conversion in the first place.

Why the Class Q appeal failed on building operations

The proposed development was to convert an agricultural building into four C3 dwellinghouses. On inspection, the structure consisted principally of a steel portal frame. It was open along all its sides and across the roof, save for a small area of corrugated sheets. The floor surface appeared to be soft organic material rather than a finished hard floor.

The applicant argued that the steel frame would be retained as the primary structural element, with rafters treated as beams for a new roof and ceiling. The planning statement referred to a structural survey, but no such survey was before the Inspector. The Council had made the same observation in its delegated report.

Without that evidence, the Inspector could not be satisfied that the existing frame could be retained and used as the principal support for the converted building. The proposed new walls would occupy all elevations and a completely new roof would be required. Taken together, those works went beyond the installation or replacement of fabric reasonably necessary for conversion.

The Inspector said the scheme would be more akin to a new or fresh build rather than a conversion. Retaining a few steel members did not resolve the underlying problem, even though the proposal involved no enlargement. The Class Q appeal was dismissed because the building operations were outside the permitted-development right.

Another difficulty was the mismatch between drawings and the building seen during the site visit. The elevation plans showed an additional lean-to steel frame that did not match the observed structure. The planning statement described a solid sealed concrete slab, but the Inspector saw a soft surface. This inconsistency increased doubts about the building fabric available for retention.

Hibbitt still matters under the current Class Q rules

In reaching the decision, the Inspector referred to Planning Practice Guidance paragraph 105 and the High Court decision in Hibbitt & Anor v Secretary of State [2016] EWHC 2853 (Admin). The governing distinction is between conversion of a suitable existing structure and construction that is, in substance, a replacement building.

The case did not depend on every new component being unlawful. Class Q expressly contemplates installing or replacing certain doors, windows, roofs, walls and services, subject to its limitations. But the right is not an invitation to construct an almost entirely new building around a retained skeletal frame. What must be assessed is the overall work actually required.

Our current Class Q barn conversion guide explains the permitted work, qualification conditions and prior-approval process. The 2024 changes expanded aspects of the right, including numerical limits and defined extensions, but did not create an unrestricted demolition-and-rebuild route. The current statutory wording must be applied rather than an outdated rule of thumb.

This Class Q appeal is a useful test of the limits of relying on the word ‘conversion’ in an application. A structural report should identify what exists, its condition and the extent of works needed. An applicant must also explain how the final design retains the substance of the agricultural building, not merely one or two pieces of its frame.

Flood risk and highways were never reached

Doncaster Council had also disputed the proposal’s acceptability on flood risk and highway grounds. Those are potentially important prior-approval matters under Class Q2, but they did not decide this appeal. Inspector Heron had already found that the scheme did not meet the basic permitted-development limits, so assessing the later approval matters could not rescue it.

This is the procedural sequence many applicants miss. First, identify a building and a proposal that fall within all the relevant Class Q limitations. Only then can the authority determine whether prior approval should be granted on the matters specified by the Order. Prior approval is not a general power to waive a failure in the underlying permitted-development right.

The appellant referred to other decisions and planning statements said to support similar schemes. However, details had not been supplied to the Inspector, so the Inspector could not establish whether those situations were comparable. Even where examples exist, their usefulness depends on the original structure, proposed operations, drawings and evidence being genuinely alike.

Various benefits of the proposal were also cited, but the Inspector found they fell outside the matters that could be considered under the relevant paragraph of the GPDO. This was not a full application for housing in the countryside where the Inspector could undertake an unrestricted planning balance. It was a request for prior approval of development that had first to qualify under the relevant national permitted-development right.

What farmers and designers should check before applying

A successful Class Q submission begins with evidence of the actual agricultural building. Accurate survey drawings, dated photographs, a measured record of the frame, roof, foundations and floor, and a suitably qualified structural appraisal should be consistent with one another. If key components have already disappeared, the applicant needs a credible explanation of what can lawfully be retained.

Applicants should compare every external wall, roof plane and structural element proposed for removal or replacement with the specific work permitted by the GPDO. Describing the scheme as a change of use is not enough when the proposed building operations would create something substantially new. That distinction is at the heart of this Class Q appeal.

The decision does not establish that every open-sided steel-frame barn is ineligible for Class Q. It addresses the particular combination of missing fabric, extent of new construction and absent structural evidence before this Inspector. A different building with credible engineering evidence and genuinely limited works may be assessed differently.

There is a further commercial point for purchasers. A vendor’s assertion that a farm shed has conversion potential should not be taken as a substitute for planning and structural due diligence. If the structure is too incomplete, acquiring the land on the assumption of four residential units may leave a buyer needing a full planning application instead.

The Doncaster Class Q appeal was decided by Inspector E Heron on 6 November 2026, appeal 6013489, against application 26/00766/PRIOR. The appeal decision is also available on AppealBase.

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