- Decision
- allowed, 19 August 2026
- Decided by
- Planning Inspector: D Wilson
- Authority
- Shropshire (West Midlands)
- Appeal reference
- 6006151
- Application reference
- 25/04158/FUL
- Procedure
- written representations
- Development
- Siting of an agricultural worker's mobile home for 3 years (retrospective)
- Homes
- 1
- Site context
- open countryside
- Green Belt
- No
- Framework applied
- August 2026 NPPF
- Determinative policies
- HO11(1)(a)
- Development plan policies
- Shropshire Core Strategy 2011 CS5, CS6, SAMDev Plan 2015 MD7a, Type and Affordability of Housing SPD 2012
- Main issues
- essential functional need for rural worker; highway safety
Summary
Temporary (3-year) mobile home for a worker at a new 32,000-hen free-range egg unit, already sited. Allowed. The inspector found an essential and functional need for someone to live on site given 24-hour supervision and short response times, and that off-site accommodation at a moderate distance would not do. The decision rests entirely on local plan policy and the SPD; no Framework policy is named.
Issues and findings
- Transition. "as any policies in the Framework that are material to this decision have not fundamentally changed, I am satisfied that this has not prejudiced any party and I have had regard to the latest version" (DL ¶4). Decided two days after publication, without consultation.
- Essential functional need — local CS5 / MD7a (equivalent to HO11(1)(a)): PASS. "there are short windows of time to deal with problems before there is panic and distress with the birds and the potential for mortality. As such, there is an essential and functional need for someone to be present on site for the majority of the time" (DL ¶8). "accommodation a moderate distance away from the appeal site would unlikely be suitable for the 24-hour presence that is required" (DL ¶10).
- Alternatives. Council said alternatives weren't properly explored (MD7a); rejected because the family home is listed and at moderate distance and rentals are unspecified and too far away (DL ¶9, ¶14).
- Highway safety: PASS via tracking plan and a condition (DL ¶12–13).
Planning balance
No balance run; full compliance with the development plan (DL ¶11, ¶13, ¶16). Temporary and occupancy conditions justified because the home is "in a location where residential development would not normally be permitted" (DL ¶15).
What made the difference
A rural enterprise appraisal quantifying the stock size, automation risk and response times, together with a site visit confirming the unit was now operating. The Council's alternative-accommodation objection failed because the alternatives were at "moderate distance" and response had to be immediate. Had the unit not been operating, or had the appraisal not shown 24-hour needs, the case would have been weaker.
Transferable points
- For intensive livestock, short response windows to bird panic and mortality can establish an essential need for an on-site presence (DL ¶¶8, 10); this aligns with HO11(1)(a).
- Accommodation at "moderate distance", including a family home, is not a suitable alternative where problems must be "spotted or heard within a short amount of time" (DL ¶¶10, 14).
- Some inspectors apply the 2026 Framework to rural-worker cases without citing any Framework policy, treating the material policies as "not fundamentally changed" (DL ¶4).
Policy findings
Policy codes are those of the National Planning Policy Framework (August 2026) unless a development plan is named.
| Policy | Finding | Weight | Note |
|---|---|---|---|
| HO11(1)(a) | pass | not cited; the letter names no Framework policy. Essential and functional need for 24-hour on-site presence at a 32,000-hen automated unit (DL 8-11) | |
| Shropshire CS5, SAMDev MD7a, SPD | accord | functional need shown; alternatives (family listed home, rentals) at moderate distance unsuitable for short response times (DL 9-11, 14) | |
| Shropshire CS6 | accord | HGVs can still turn and park per tracking plan; condition keeps area clear (DL 12-13) |
Key facts
- 32,000 hens in two areas, automated systems, two full-time workers
- Rural enterprise dwelling appraisal showing 24-hour supervision needed; short windows before panic and mortality
- Nearby accommodation and the listed family home at "moderate distance" judged unsuitable
- Mobile home already on site; temporary 3-year permission with agricultural occupancy condition
- 2026 Framework applied without consultation, material policies said to have "not fundamentally changed"
Sources
This note is one of the decisions behind the NPPF 2026 Navigator, which shows how each Framework test has been applied across all the decisions in the database. Also available as Markdown.