Development" is defined in s.3(1) of the 2000 Act as "the carrying out of any works on, in, over or under land or the making of any material change in the use of any structures or other land".
The terms "works", "land", "use", "structure" and "alterations" are defined in s.2(1) of the 2000 Act. These definitions are significant with regard to the interpretation of the term "development" as used in the Act and the 2001 Regulations.
"Works" is defined as "any act or operation of construction, excavation, demolition, extension, alteration, repair or renewal". In relation to a protected structure or a proposed protected structure it includes "any act or operation involving the application or removal of plaster, paint, wallpaper, tiles or other material to or from the surfaces of the interior or exterior of a structure". (see Chap. 7)
"Land" is stated to include "any structure and any land covered with water (whether inland or coastal)".
"Use" in relation to land is defined as "not including the use of the land by the carrying out of any works thereon".
"Structure" is stated to mean: "any building, structure, excavation, or other thing constructed or made on, in or under any land, or any part of a structure so defined and:
(a) where the context so admits, includes the land on, in or under which the structure is situate and
(b) in relation to a protected structure or proposed protected structure, includes:
(i) the interior of the structure;
(ii) the land within the curtilage of the structure;
(iii) any other structures within that curtilage and their interiors;
(iv) all fixtures and features which form part of the interior or exterior of any structure or structures referred in subparagraph (i) or (ii)" of the "protected structure" or any other structure within its curtilage;
So the simple answer to your question is YES.