A hay store at an established equestrian site in Central Bedfordshire has been allowed on appeal after the Inspector found that it fell within the Green Belt exception for appropriate facilities connected with outdoor sport and recreation.
The retrospective building at 2 Park Farm, Westoning, served existing stables, paddocks and a ménage. Central Bedfordshire Council had treated it as inappropriate development in the Green Belt. Inspector MG Garrard disagreed.
The decision is useful because the Inspector expressly rejected the idea that a facility stops qualifying for the exception simply because it takes the form of a building.
Why the hay store was challenged
The appeal concerned a small hay store which had already been erected on land used for equestrian purposes. The wider site contained stables, paddocks, a ménage and associated hardstanding.
The council considered the building to be inappropriate Green Belt development. That meant it approached the proposal on the basis that Green Belt harm had to be weighed in the usual way against any very special circumstances.
The Inspector instead started with the wording of the August 2026 Green Belt policies.
The Green Belt exception expressly includes buildings
Policy GB7(1)(f)(iv) of the August 2026 NPPF says that the provision of appropriate facilities, including buildings, for outdoor sport and outdoor recreation is not inappropriate development where the impact on openness is minimised and there would not be a significant conflict with Green Belt purposes.
The Inspector found that the keeping and exercising of horses on the site was an outdoor recreational activity. The hay store was used to support that established equestrian use and was therefore capable of being an appropriate facility connected with it.
That matters. The council’s case had treated the building form itself as a reason why the exception did not apply. The Inspector noted that the national policy expressly contemplates buildings.
This does not mean every stable, hay barn or other equestrian building is automatically acceptable in the Green Belt. The facility still has to be appropriate to the use and the separate tests concerning openness and Green Belt purposes still have to be satisfied.
A small building in the context of an established equestrian site
Scale and context were important. The hay store was described as modest and occupied only a limited part of a paddock. It sat in the context of the existing residential and equestrian development rather than appearing as a substantial new incursion into otherwise open land.
The Inspector found that its visual and spatial effect on Green Belt openness was minimal. There was also no significant conflict with the five Green Belt purposes.
On those facts the building fell within the NPPF exception and was not inappropriate development. The appeal therefore did not depend on demonstrating very special circumstances.
Anyone looking at a similar site still needs to assess the proposal on its own facts. Planning Geek’s Agriculture & Equestrian section and guide to deciding whether land is in agricultural or equestrian use explain some of the distinctions which can matter before the Green Belt analysis even begins.
Retrospective did not mean automatic refusal
The store had already been built, so the Inspector also considered national policy on intentional unauthorised development.
Policy DM8(2) says that where retrospective permission is being considered, substantial weight should be given to the fact that unauthorised development was intentional where that conclusion is supported by evidence.
The appellant explained that the store had been moved because the former location had become muddy. The Inspector found no substantive evidence that it had deliberately been erected without permission in an attempt to evade planning control.
As a result, only limited weight was given to the retrospective nature of the development.
That should not be read as a general amnesty for retrospective development. Planning Geek’s guide to retrospective planning permission explains why a council still has to determine the planning merits, while intentional unauthorised development can weigh heavily against a proposal where the evidence supports that conclusion.
The practical lesson for equestrian development
The useful principle from appeal 6007202 is fairly focused. Equestrian development can fall within the Green Belt exception for appropriate facilities connected with outdoor sport and recreation, and the fact that the facility is a building does not prevent that exception applying.
But three questions still need to be answered carefully:
- Is the building genuinely an appropriate facility for the outdoor sport or recreational use
- Has its impact on Green Belt openness been minimised
- Would it avoid significant conflict with the Green Belt purposes
A modest hay store beside established stables and paddocks may answer those questions very differently from a large building whose scale, siting or use has a much greater effect on the Green Belt.
Read the appeal decision
The appeal is 6007202, concerning 2 Park Farm, Park Road, Westoning, Central Bedfordshire. The Planning Inspectorate decision was issued on 4th September 2026.
Planning Geek hosts the appeal decision 6007202 in our own library. You can also view the appeal on the Planning Inspectorate service.
Created: 6th September 2026
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