The classification of land introduced in 1985 in the first report on Land Use Change in England included a “Residential” category that covered “Houses, flats and adjoining garages, gardens, estate roads and pathways, sheltered accommodation where residences have separate front entrances.”
This classification thus established the principle that gardens should not be separated from the curtilage when establishing for statistical purposes whether residential land has been redeveloped for other purposes.
The 1992 Planning Policy Guidance note (Housing) drew on the 1985 based classification. It states that
“recent information on land use changes in England shows that nearly half of the land developed for housing was either previously developed or was vacant land in built up areas”.
What counted as “previously developed” in this context was plainly based on the classifications which had been in use since 1985.