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Development in unplanned built-up areas

📐 Article6 min read

What you will learn When an unplanned built-up area exists, which four features govern fitting in, why what physically exists is the measure, why the decision is bound, and what a de facto area category means.

A substantial share of all building projects in Germany is assessed under this provision. It applies wherever no qualified local plan exists but development is contiguous.

The legislator proceeds there from a presumption of developability. The measure, however, is not a plan but the existing surroundings, which makes assessment more demanding.

When the regime applies

The precondition is a contiguously built-up locality. Two features must coincide.

Feature Meaning
Contiguity of development the existing development, despite gaps, conveys an impression of closure
Locality the development carries a certain weight and expresses an organic settlement structure

Where either is absent, the outer zone applies, with considerably stricter requirements. The article on development in the outer zone covers the consequences.

Note too that § 34 also applies where a simple local plan exists. Its provisions govern so far as they reach, and fitting in must be assessed for everything else.

The four features of fitting in

A project is permissible where it fits into the character of the immediate surroundings. Four features govern that assessment.

Feature Subject
Type of development residential, commercial, mixed and others
Extent of development height, storeys, footprint, massing
Building form detached or attached
Developable plot area position of the building on the plot

Assured servicing is added as a further condition. It must be legally and factually guaranteed.

Two limits can render even a fitting project impermissible. The requirements for healthy living and working conditions must be preserved, and the townscape must not be impaired.

The measure is what physically exists

This is the core of the provision and the commonest source of misunderstanding. It concerns the yardstick against which fitting in is measured.

The measure is what physically exists in the immediate surroundings, not what would be desirable, not what the preparatory land use plan envisages, and not what previously stood on the plot itself.

Several practical consequences follow.

Consequence What follows
The frame is set by what exists a project moving within the range found in the surroundings fits in
Existing development can widen the frame where both detached and attached forms exist in the surroundings, either may be permissible
The assessment looks to outward appearance rather than to computational subtleties, such as whether an attic counts as a full storey

How far the immediate surroundings extend

The term is not defined by fixed distances. What governs is the area on which the project has effects and which in turn shapes the project's character.

The delimitation may differ for each of the four features. For the type of use the area is frequently drawn more widely than for the developable plot area.

In practice this means the delimitation must be justified. A preliminary application naming and documenting the area relied upon is considerably more robust than one leaving it to the authority.

The decision is bound

One point frequently surprises clients and strengthens their position. It concerns the authority's room for decision.

§ 34 confers no discretion on the authority. Where the project fits on all four features, servicing is assured and the two further limits are observed, consent must be granted.

The authority therefore cannot refuse a project because it considers it undesirable in urban design terms. It can only find that the project does not fit, and that finding is reviewable.

Conversely, a municipality wishing to prevent a particular development has planning available to it and not refusal in the individual case. It cannot withhold consent by pointing to its own planning intentions.

The de facto area category

A special rule concerns the case where the surroundings correspond to one of the area categories in the land use ordinance, having developed as though a plan existed. Such an area is called a de facto area category.

Permissibility as to type of use is then assessed under the land use ordinance, including the standard and exceptional uses it provides for. The assessment corresponds in that respect to one within a local plan.

This matters for changes of use. In a de facto general residential area, the permissibility of a commercial use follows the catalogue in the ordinance rather than a free assessment of the surroundings.

How to obtain certainty

Assessing whether a project fits involves judgements that cannot be anticipated with certainty before application. That is the essential difference from a qualified local plan.

The most effective instrument against this is a preliminary application followed by a preliminary ruling. It determines bindingly whether a project is permissible in principle, before substantial design costs arise.

For site decisions in unplanned built-up areas it is almost always economic. The article on consent procedures covers the instrument.

This article reflects the position of the rules and case law at the date of checking and serves professional orientation. It does not constitute legal advice and does not replace assessment of the individual case.

Frequently asked questions

Where a coherently built-up part of a settlement exists. The article describes the criteria.

The project must fit into its immediate surroundings under four criteria. The yardstick is what actually exists.

As far as project and surroundings shape one another. The boundary is drawn case by case.

No, the decision is bound. Where the conditions are met, there is an entitlement.

German building regulations: a guide to design and consent